Introduction

Your privacy and trust are important to us and this Privacy Policy (“Policy”) provides important information about how Circle 2 Success Limited, CRN: 08562155 (“the Company” “we” or “us”) handle personal information. This Policy applies to personal information which we process in the course of doing business including information processed through the Company’s website and the services we provide (collectively, our “Services”).

Please read this Policy carefully and contact us if you have any questions about our privacy practices or your personal information choices.

It is important that you check back often for updates to this Policy. If we make changes we consider to be important, we will let you know by placing a notice on our website and/or contacting you using other methods such as email.

It is also important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

This Policy was last updated on 31/01/2019.

Purpose of the processing

We may process personal information about you in different ways depending on our relationship with you. Please click on the link below which most closely identifies your relationship with us:

You are a member or an employee of a member of our business networking and collaboration services.
You are a supplier or an employee of a supplier to us.
You are a third party with whom we are in contact during the delivery of services to our members or the possible delivery of services to prospective members.
You are a prospective member or an employee of a prospective member. You are a prospective supplier or an employee of a prospective supplier.
You are an employee or related to an employee.
You are a prospective employee or a referee of a prospective employee.
We have received your information from a third party.
Your relationship with us is not covered by any of the above.

1. Members and employees of members of our business networking and leadership services

We will collect and store personal information including name, contact, workplace, transaction and financial details of our members and those employees of the members who are involved in instructing us so that we can provide our Services in accordance with our contract with you. We will also retain that information and any information relating to the contract between us in accordance with our retention policy following completion of the contract(s) between us and after you cease to be a member so that we can review our performance if any complaints or issues arise after completion of the contract. The length of time that we keep member files will depend on the nature of the Services provided. Where we are providing our members with business networking and collaborative services we would usually retain that member’s file for 3 years after cessation of their membership with us.

We may also collect and store personal information about employees of the members for whom we are providing Services for example where we are organising seminars, conferences, networking events or any other meetings. This information may include names, contact details and/or details relating to your employment. We are processing this information on behalf of your employer (our member) in order to provide them with the Services. You should therefore contact your employer for further information about how we process your information on their behalf.

We may share your contact details with other members in order to introduce our members to each other where we consider that there may be a mutual business opportunity between our members. It is in our legitimate interests to do this to provide benefits to our members and we believe that you would reasonably expect us to make introductions in this way.

Unless you request us not to do so, we may also contact you and those employees of the member about similar services which we offer or events which are being organised, for example in relation to a category of membership which does not apply to you or a geographical region outside of your geographical region. This contact may be made by telephone, e-mail or post. We will only do this where we have a legitimate interest to market to you and if we believe that you would reasonably expect us to contact you in this way. We will not send you general marketing information as part of a group e-mailing campaign unless you have consented to be contacted in this way.

2. You are a supplier or an employee of a supplier to us.

We will collect and store personal information including name, contact, workplace and transaction details of our suppliers and those employees of the supplier who are involved in the delivery of the contract so that we can receive your goods or services in accordance with our contract with you. We will also retain that information and any information relating to the contract between us for a period of up to 6 years following completion of the contract(s) between us so that we can review your performance if any complaints or issues arise after completion of the contract.

We may also contact you about new business opportunities for us to work together with you and to keep you informed of our activities. We will only do this if we believe that you would reasonably expect us to contact you in this way and that such processing does not have an impact on you in a way that would make this processing unfair.

We will not send you general marketing information as part of a group e-mailing campaign unless you have consented to being contacted in this way.

3. You are a third party with whom we are in contact during the delivery of services to our members or the possible delivery of services to prospective members.

We will collect and store personal information including contact details of third parties with whom we are in contact during the delivery of Services to our members or discussions relating to Services to prospective members. We process that information because it is in our legitimate interests to do so in order for us to be able to perform our contracts for our members or pitch for membership applications from prospective members. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not an impact on you in a way that would make this processing unfair. Where your personal information is kept as part of a file relating to the performance of a contract with one of our members, we will also retain that information and any information relating to that contract in accordance with our file retention policy following cessation of that member’s membership with us. This is so we can review the file if any complaints or issues arise after cessation of the relevant member’s membership with us. The length of time that we keep member files will depend on the nature of the Services provided. Where we are providing our members with business networking and collaborative services we would usually retain that member’s file for 3 years after cessation of their membership with us..

Where your information is stored in our contacts database but is not kept in a member or supplier file, we carry out a review of our contacts database every 2 years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it safely.

We may also contact you about new business opportunities for us to work together with you and to keep you informed of our activities. We will only do this where we have a legitimate interest to market to you and if we believe that you would reasonably expect us to contact you in this way and that such processing does not an impact on you in a way that would make this processing unfair.

We will not send you general marketing information as part of a group mailing, e-mailing or telephone campaign unless you have consented to be contacted in this way.

4. You are a prospective member or an employee of a prospective member. You are a prospective supplier or an employee of a prospective supplier.

We will collect and store personal information including name, contact and workplace details of people who we might do business with as a supplier or a member. We may collect this information from you, when you contact us (including through this website) or from a mutual contact. We will only collect contact information from your website or another third party website if we have identified you specifically as someone who may be interested in receiving a Service from us or delivering goods or services to us.

Where we have a legitimate interest to market to you, we may contact you about new business opportunities for us to work together with you and to keep you informed of our activities. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not an impact on you in a way that would make this processing unfair. Where your information is stored in our contacts database but is not kept in a member or supplier file, we carry out a review of our contacts database every 2 years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it safely.

We will not send you general marketing information as part of a group mailing, e-mailing or telephone campaign unless you have consented to be contacted in this way.

5. You are an employee or related to an employee

Employees should refer to the Employee Privacy Notice for further information about our privacy policy in respect of employees.

Where an employee has provided us with personal information about a spouse, civil partner or other family member/friend (perhaps in relation to sharing a Company car, private medical insurance or other benefits or as an emergency contact), it is the employee’s responsibility to inform that person that the employee has provided us with their details and that we will be processing it in connection with the relevant benefit and/or policy in accordance with this privacy policy.

6. You are a prospective employee or a referee of a prospective employee

If we have received your details in response to a recruitment initiative, we will store the personal information that either you, your recruitment agent or another third party has provided us with. We process that information because it is in our legitimate interests to do so in order for us to be able to make an informed decision about whether to interview you and, ultimately, recruit you. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not an impact on you in a way that would make this processing unfair. Where your personal information is kept as part of a file relating to prospective employees of the Company, we will retain that information and any information relating to that matter. This is so that we can review the file if any complaints or issues arise after the recruitment process. The length of time that we keep prospective employee files is usually [6] months after conclusion of the relevant recruitment process.

Unless you request us not to do so, we may also contact those individuals who are referred to in any information you provide us with, for example referees, this contact may be made by telephone, e-mail or post. We will only do this if we have your express permission to contact them in this way.

Where you have provided us with personal information about a referee or a previous employer, it is your responsibility to inform that person that you have provided us with their details and that we will be processing it in connection with your employment application. You should also give them our contact details (below) should they wish to discuss this with us.

7. We have received your information from a third party

If we have received your personal information from a third party, for example your employer or service provider, that third party will normally be the controller in relation to that personal information and we will be processing it on their behalf. You should therefore contact that third party to review their privacy policy.

8. Your relationship with us is not covered by any of the above

We may hold your name, contact and workplace details as a result of an interaction between you and one of our employees or prospective employees. This interaction could be as a result of a mutual business interest or a potential business opportunity for one of our members. We believe that we have a legitimate interest to process your information for the potential benefit of our members and ourselves and that you would reasonably expect us to process your personal information in this way and that such processing does not an impact on you in a way that would make this processing unfair. We carry out a review of our contacts database every 2 years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it safely.

Where you provide us with personal information about another person

If you give us personal information about another person, you must ensure that:

(a) you are legally entitled to give us that information;

(b) the disclosure is in accordance with any applicable data protection or privacy laws; and

Personal information we hold

We will store contact information and the contents of any correspondence between us. We may also record or take notes during telephone calls and meetings which we will store on any applicable file.

We may be required to use and retain personal information for other legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud.

When someone visits our website we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed by us in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it. The Company and our third-party providers set and use cookies and similar technologies to store and manage user preferences, enable content and gather analytic and usage data. For further information on our use of cookies, please see our Cookie Policy.

When we share personal information

The Company shares or discloses personal information when necessary to provide Services or conduct our business operations as described below. When we share personal information, we do so in accordance with data privacy and security requirements. We do not sell any personal information to third parties. We may occasionally share non-personal, anonymised, and statistical data with third parties. Below are the parties with whom we may share personal information and why.

Within the Company: Our business is supported by a variety of people who are part of the Company’s teams and functions. Personal information will be made available to them if necessary for the provision of Services, account administration, sales and marketing, customer and technical support, and business and product development, for instance. All of our employees and any contractors are required to follow our data privacy and security policies when handling personal information.
Between our members: Our business comprises a network of businesses, a professional and commercial community with a focus on building relationships, establishing connections, maximising growth, collaboration and best practice. This means that there will often be opportunities to make valuable introductions and from time to time we will share your personal information including name, contact details and place of work with other members to encourage the development of effective business relationships.
Our business partners: We occasionally partner with other organisations to deliver Services, provide content, or to host events, conferences, and seminars. As part of these arrangements, you may be both a member of the Company and a client of our partners, and we and our partners may collect and share information about you. The Company will handle personal information in accordance with this Policy, and we encourage you to review the privacy policies of our partners to learn more about how they collect, use, and share personal information.
Our third-party service providers: We partner with and are supported by service providers around the UK. Personal information will be made available to these parties only when necessary to fulfil the services they provide to us, including (without limitation) software, system, and platform support; direct marketing services; cloud hosting services; advertising and data analytics. Our third-party service providers are not permitted to share or use personal information we make available to them for any other purpose than to provide services to us.
Third parties for legal reasons: We will share personal information when we believe it is required, such as:

◦ to comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities;

◦ in the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings);

◦ to protect our rights, users, systems, and Services.

Where we store and process personal information

We take steps to ensure that the information we collect is processed according to this Policy and the requirements of applicable law wherever the data is located.

We store information in hard copy files, which are stored in our offices and/or in archived storage space in the UK. We also store information in electronic files using cloud hosting servers on servers in the UK through Office 365, Xero and Maximiser CRM. We collaborate with third parties such as cloud hosting services, suppliers, and technology support to serve the needs of our business, workforce, and members. We take appropriate steps to ensure that personal information is processed, secured, and transferred according to applicable law. In some cases, we may need to disclose or transfer your personal information within the Company or to third parties in areas outside of your home country, but we will not transfer your data outside of the European Economic Area.

How we secure personal information

The Company takes data security seriously, and we use appropriate technologies and procedures to protect personal information. Our information security policies and procedures are closely aligned with widely accepted international standards and are reviewed regularly and updated as necessary to meet our business needs, changes in technology, and regulatory requirements.

How long we keep personal information

We retain personal information for as long as we reasonably require it for business or regulatory purposes. In determining data retention periods, the Company takes into consideration local laws, contractual obligations, and the expectations and requirements of our members and suppliers. When we no longer need personal information or when you request us to delete your information, where this is legal, we will securely delete or destroy it. The length of time that we keep member and supplier files will depend on the nature of the goods and services received or provided. Where we are providing our members with business networking and collaborative services we would usually retain that member’s file for 3 years after cessation of their membership with us..

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your name, contact and workplace data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or have joined as member or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Company for marketing purposes.

Your legal rights

We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or safely delete your personal information.

Access to personal information: You have the right to request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If you request access to your personal information, we will gladly comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data.
Object to processing: of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request erasure: of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see above), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Request restriction of processing: of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer: of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Correction of yore data: You have the right to request that we correct your personal information if it is inaccurate or requires updating or complete your personal information if the information we hold is incomplete.
Withdrawal of consent: If we are processing your personal information on the basis that you have given your consent to us processing that personal information, you have a right to withdraw your consent at any time by using the “Contact Us” option on our website or let us know in writing, by email or by telephone.
Marketing preferences: To opt out of email marketing, you can use the unsubscribe link found in the email communication you receive from us or you can use the “Contact Us” option on our website or let us know in writing, by email or by telephone.
Filing a complaint: If you are not satisfied with how the Company manages your personal data, you have the right to make a complaint to the Information Commissioner’s Office (https://ico.org.uk).

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please let us know by using the “Contact Us” option on our website or let us know in writing, by email or by telephone.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Third-party links

This website has links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Children’s privacy

Our Services are not directed to children under 13. We will not knowingly send any marketing information to children under 13. If you learn that a child under 13 has provided us with personal information without consent, please let us know by using the “Contact Us” option on our website or let us know in writing, by email or by telephone.

How to contact us

Please contact us with any requests related to your personal information.

We understand that you may have questions or concerns about this Policy or our privacy practices or may wish to file a complaint. Please feel free to contact us in one of the following ways:

Email:

info@circle2success.co.uk

Address:

Attn: Circle 2 Success

Unit 22A, 21 Bamfurlong Industrial Estate, Staverton, Cheltenham, GL51 6SX

Telephone:

03300 536 186