| Effective Date: December 22, 2005
This privacy policy applies to the following
websites:
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www.circles.com
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www.circlesmembers.com
Circles is a licensee of the TRUSTe Privacy Program. TRUSTe is
an independent, non-profit organization whose mission is to build users' trust
and confidence in the Internet by promoting the use of fair information
practices. Because this web site wants to demonstrate its commitment to your
privacy, it has agreed to disclose its information practices and have its
privacy practices reviewed for compliance by TRUSTe. By displaying the TRUSTe
trustmark, this web site has agreed to notify you of:
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What personally identifiable information of yours or third party personally
identifiable information that is collected from you through the web site
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The organization collecting the information
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How the information is used
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With whom the information may be shared
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What choices are available to you regarding collection, use and distribution of
the information
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The kind of security procedures that are in place to protect the loss, misuse
or alteration of information under Circles' control
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How you can correct any inaccuracies in the information.
Circles is passionately committed to the privacy and security
of its members. We see ourselves as the stewards of our members' personal
information, not the owners. Circles believes that our members should always
have ultimate control over the collection and use of their personal
information. For this reason, we are making every effort to ensure that our
members feel that their privacy is always respected and their security is never
compromised.
If you do not receive acknowledgment of your inquiry or your
inquiry has not been satisfactorily addressed, you should then
contact TRUSTe. TRUSTe will then serve as a liaison with the Web site
to resolve your concerns.
Contact information
Through our referral and consulting forms, we gather contact information so
that parties can submit their interest in learning more about Circles services.
Once these requests for information are received, Circles contacts the
interested parties with our company information.
Personal Information
When corporations sign up for Circles' services, individual members are asked
to complete a membership form. The membership form provides Circles with
contact information so our Service Professionals (SP's) can communicate with
members regarding their requests for personal services. Beyond the basic
contact information (e.g. name, email, address, phone number), members also
have the option of providing additional information such as home and mobile
contact information and credit card number. By providing this information,
Circles is able to communicate more effectively and efficiently with members
regarding their requests. Circles uses billing information to purchase goods or
services on members' behalf. Members are not asked to provide any unique
identifiers (e.g. social security number) or other personally identifiable
information.
Service Requests
When making a request, members are asked to complete an order form that
describes in detail the service desired and any additional information the SP
needs to complete the member's task. Personally identifiable information is not
collected through the order forms.
Disclosure
Circles does not sell, share or rent individual information on members to any
third parties. Circles may, however, need to disclose personal information when
required by law wherein we have a good-faith belief that such action is
necessary to comply with an appropriate law enforcement investigation, judicial
proceeding, court order or legal process served on our Web site. We may also
share aggregate information with our partners in order to enhance the member's
experience on our site as well as our partners' sites. This is not linked to
any personal information that can identify any individual person.
Cookies & Log Files
A cookie is a piece of data stored on the member's hard drive containing
information about the member. No personally identifiable information is stored
in a cookie on our site. Once the member closes their browser, the cookie
simply terminates. Circles uses cookies to save the member's user name and
password so this information does not have to be re-entered each time the site
is visited. During the registration process, members are given the option not
to use the cookies, in which case the member has to retype the user name and
password each time the site is visited. Members are not limited from using any
part of the site if they choose to reject the cookie.
Cookies are also used to track and target the interests of our
members in order to provide them with a more personalized experience on our
site. There is no advertising on our site, so third parties cannot track
members through cookies on our site.
We use IP addresses to analyze trends, administer the site,
track members' movement, and gather broad demographic information for aggregate
use. IP addresses are not linked to personally identifiable information.
Our Partners
Circles is not responsible for the privacy practices of our partners and this privacy statement does not apply to co-branded sites
operated by Circles business partners. However, we are taking an active role in
working with each of our partners to ensure they adhere to the highest
standards of integrity in regards to our members' privacy and security. Circles
will not partner with any organization that sells or rents personally
identifiable information to third parties. Circles and its partners do reserve
the right to collect and share aggregate data (e.g. demographic and usage
trends), however that data will in no way be linked to any personally
identifiable information. To learn more about the privacy and security policies
of our partners, please visit our "Partner Criteria" page.
Security
Circles takes every precaution to protect our members' information. When
members submit sensitive information via the web site, the information is
protected both online and off-line. When our registration form asks members to
enter sensitive information (such as credit card number), that information is
encrypted and is protected with the best encryption software in the industry -
SSL. While on a secure page, such as our registration form, the lock icon on
the bottom of Web browsers such as Netscape Navigator and Microsoft Internet
Explorer becomes locked, as opposed to un-locked, or open, when you are just
'surfing'. To learn more about SSL, follow this link
http://www.ssl.com.
While we use SSL encryption to protect sensitive information
online, we also do everything in our power to protect member information
off-line. All of our members' information, not just the sensitive information
mentioned above, is restricted in our offices. Only employees who need the
information to complete the member's request are granted access to personally
identifiable information. Communications around credit card numbers and other
sensitive information are done strictly by phone, not by email. Our employees
must use password-protected screen-savers when they leave their desk. When they
return, they must re-enter their password to re-gain access to your
information. Furthermore, ALL employees are kept up-to-date on our security and
privacy practices through extensive training and company updates. Several times
a year, as well as any time new policies are added, our employees are notified
and/or reminded about the importance we place on privacy, and what they can do
to ensure our members' information is protected. Finally, the servers that we
store personally identifiable information on are kept in a secure and locked
environment.
If you have any questions about the security at our web site,
you can send an email to privacy@circles.com.
Supplementation of Information
In order for this web site to enhance its ability to tailor the site to an
individual's preference, we combine information about the purchasing habits of
members to create a personalized member profile. When a member makes a purchase
from any of our partners, the companies collect and share that purchase
information with us so we can tailor the site to our members' preferences.
Special Offers
We send all new members a welcoming email once they have completed the
membership form on the web site. Members will occasionally receive emails to
let them know of special promotions (e.g. Valentine's Day and Mother's Day).
Site and Service Updates
We also send the member site and service announcement updates which contain
important information about the service. We communicate with the member to
provide requested services and in regards to issues relating to their account
via email or phone.
Correction/Updating Personal Information
Members' personal information is verified each time they make a service
request. If a member's personally identifiable information changes (such as zip
code), members can correct or update their personal information by clicking on
"Edit Your Profile." Members can also update or edit their personal
profile by contacting a Circles Service Professional.
Choice/Opt-out
Our members are given the opportunity to 'opt-out' of having their passwords
stored on our site. Please see our choice and opt-out on the registration page.
Members who no longer wish to receive promotional materials
from our partners may opt-out of receiving these communications by clicking on
the opt-out policy (when available) or replying to emails with unsubscribe in
the subject line.
Notification of Changes
If we decide to change our privacy policy, we will post those changes on this
page so our members are always aware of what information we collect, how we use
it, and under circumstances, if any, we disclose it. If at any point we decide
to use personally identifiable information in a manner different from that
stated at the time it was collected, we will notify members by way of an email.
Members will have a choice as to whether or not we use their information in
this different manner. We will use information in accordance with the privacy
policy under which the information was collected.
How To Contact Us
If you have questions or concerns regarding this statement, you may contact us
at:
- Email: privacy@circles.com
- Telephone: (617) 622-6200
- Postal Mail: 300 A Street, Boston, MA 02210
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