CIRCUS 25’S APPROACH TO DATA PRIVACY

www.trade.circus25.com is operated by Circus 25 Ltd (we, us, our). We are committed to protecting and respecting our customer’s (you, your) privacy. This Privacy Policy (together with our Terms and Conditions Policy and Cookie Policy) explains how and why we collect, use, store, share, protect and delete the information associated with you (personal information) within the scope of the GDPR.

WHO DO WE KEEP DATA ON?

We collect and use information about you to provide you with our products and related services. You provide us with this information directly when you sign up for a trade account with us, by communicating with one of our sales people or when you sign up to our newsletter via our website.

We also gather data when you browse our website via cookies (please see our Cookie Policy) this is to provide you with the best customer experience and present the most relevant content to you. For example, your IP address and information about your device may be used to know your location – this is so we can see if you are accessing our services from inside or outside the UK.

We also gather data during the process of staff recruitment. We will only collect personal information if it is either knowingly, voluntarily or specifically provided by you or collected with your consent. If you send us an employment application, including CVs or cover letters, all of this information may be used for any purposes ordinarily related to processing an employment application.

We strive to keep all this information accurate and current to the best of our ability. You can always contact us to check if the information is correct, and if there are any inaccuracies we will immediately correct these.

WHAT DATA DO WE HOLD AND WHY?

At a minimum we hold the following data about a person (we call this “Default Information”)

• Full name
• Company name
• Company email address
• Company address

Default Information is necessary for us to provide you with our products and related services.

In addition, we may store the following data, if a person or their company chooses to share it with us (we call this “Additional Information”).

• Job Title and Department: Helps us identify the best contact person within a company.
• Personal Phone Number: May be provided to us in cases where a person does not have a company issued phone or if they do not have access to it (for example, when travelling).
• Personal Email Address: may be provided under circumstances where a company email address is not working.

BEST PRIVACY PRACTICES

We process personal data according to below principles:

• The information we hold on our Retail Clients is used to complete transactions, and is gathered and held under the lawful basis of “Contract.”
• The information we hold on our confirmed Trade Clients is used to complete transactions, and is gathered and held under the lawful basis of “Contract.”
• The information we hold on potential clients enquiring about our products and/or business is gathered and held under the lawful basis of “Legitimate Interest.”
• The information we hold about potential clients when they sign up or opt-in to receive information from us is gathered under the lawful basis of “Consent.”
• We apply appropriate security measures to protect the personal data we hold on you, including vetting the relevant systems “Data Processors” we use and training our staff “Data Controllers” on how to handle data.
• Retention: We keep the amount of data we hold to a minimum and only hold this data for as long as necessary. For example, we may retain and use information to comply with legal obligations, prevent abuse, resolve disputes and enforce our agreements.

RIGHTS TO PERSONAL DATA

All the data we hold on you is yours, which means that at any time you may request to see this and also apply your right to be forgotten.

• Right to Access — you may request to see the data we hold on you any time by contacting us directly.
• Right to Amend — you may request to amend the data we hold on you at any time by contacting us directly.
• Right to Op-Out — you may opt-out of receiving marketing communication from us at any time, simply click the “unsubscribe” from our mailing list or send us an email directly.
• Right to be Forgotten — you may request to have your data erased from our systems by contacting us directly.

WHO HAS ACCESS?

Our office staff including Sales, Marketing, Production and Logistics has access to “Default Information” and any “Additional Information” you supply us with to be able to fulfill any orders and services.

Circus 25 works with a number of third parties “Data Processors” to help us fulfill any orders and services successfully. We only share information with trusted third parties under clear instruction. We require all third parties interacting with this information to undergo a security assessment to ensure information is kept safe through appropriate security measures.

We do not share your information with any third parties who might wish to promote their own products and services to you unless you provide your consent.

CHANGES TO THIS POLICY

From time to time we may update this Privacy Policy. It is therefore important that you visit and review this policy regularly. When we make changes to this privacy policy in a substantial way, we will update the “last modified” date at the top of this Privacy Policy. Changes to this privacy policy become effective as soon as they are posted on this page.

NOTICE TO YOU

If we need to provide you with important information (related to legal, marketing or other business related purposes) we will identify and select the best way to contact you. We usually contact you through email or by placing a notification on our site.