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# Circles Privacy Policy 

## Introduction 

*Circles Coop eG*. is committed to ensuring the privacy of all our users. We are committed for the right to privacy and against government surveillance and intrusion. This policy represents our commitment as an organisation to your right to privacy, giving you a clear explanation about how we use your information and your rights over that information.

*Circles Coop eG*. built the Circles app as an Open Source app. This SERVICE is provided by *Circles Coop eG*. at no cost and is intended for use as is. This page is used to inform visitors regarding our policies with the collection, use, and disclosure of Personal Information if anyone decided to use our Service. If you choose to use our Service, then you agree to the collection and use of information in relation to this policy. The Personal Information that we collect is used for providing and improving the Service. We will not use or share your information with anyone except as described in this Privacy Policy. The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which is accessible at Circles unless otherwise defined in this Privacy Policy.

This policy applies to all online systems offered by *Circles Coop eG*. to the public, through our website [joincircles.net](https://joincircles.net/) and other websites we operate.

References to ‘we’,‘us’ and ‘our’ are to *Circles Coop eG.*, the main operating company of the Circles UBI registered as a cooperative by guarantee in Germany (Berlin, ℅ SUPERMARKT, Mehringplatz 9, 10969.) 

This policy was last updated on January 2021.


## What types of information do we collect and how?

For a better experience, while using our Service, we may require you to provide us with certain personally identifiable information, including but not limited to Email address, IP Address, Photograph, Date/Time of requests, The page being requested, Status code of the webserver, Browser / Operating system of the requester, Referrer, Safe address, Payment note, Transactions, Trust connections, Added/Removed Devices.  Donation amount, Donation frequency, Currency, Name of donor, Message of Donor, Channel of Donation, Expiring date of your Regular Donation. The information that we request will be retained by us and used as described in this privacy policy. The app does use third party services that may collect information used to identify you.


### We collect personal information in the following ways: 



*   When you register to Cicles Application
*   When you sign up for newsletter
*   When you make a donation to us
*   Engaging with our social media and digital advertising
*   When you sign up for our events
*   When you participate in other online campaigns or activities 
*   When you apply for a job or volunteering opportunity with us
*   When you visit our website
*   When you contact our team

To comply with German data protection rules *Circles Coop eG*. will always ensure we have legal justification for collecting and using your personal information.

The legal basis that we rely on will depend upon the circumstances in which we collect and use your personal information. In almost all cases, our processing of your personal information will fall into one of the following categories:

Where you have provided your consent to allow us to use your data in a certain way.

Where it is necessary for us to process your data in order to comply with a legal obligation.

Where it is in our legitimate interests to contact you in order to provide you service and raise funds. Where we rely on a legitimate interest to use your information, we will always ensure that this is done in a way so as not to be intrusive or cause distress, and that respects your rights.

Where it is necessary for us to process your data in order to carry out the performance of a contract with you.


### How we collect your data 

*Circles Coop eG*. obtains personal information from you when you register to the Application, engage with our social media and digital advertising, you join our events or make a donation.

We may occasionally supplement your data with other publicly and commercially available information where it meets GDPR standards. This may include information such as your parliamentary constituency or the characteristics of your local area to inform campaigning and requests for support, or on rare occasions, information such as company directorships, estimations of your wealth or potential interest in legacy giving, to ensure our communications are relevant. We may store relevant information about you that you voluntarily share with us.

We will only collect sensitive personal data where absolutely necessary and with your explicit consent.


### How we use your data 

*Circles Coop eG*.   uses our users’ and supporters’ personal data in a variety of ways which include the following:

*   Providing you with information or products that you have requested from us.
*   Providing you with information that is relevant to your interests.
*   Processing donations and joining fees received from you.
*   Making enquiries or informing you about your interactions with us (e.g. resolving issues with Direct Debits, or informing you of changes to events).
*   Responding to any complaints from you.
*   Offering you ways to fund our work.
*   Inviting you to work with us.
*   Keeping you updated on our work.
*   Informing you of volunteering and job opportunities.
*   Mentoring you.
*   Inviting you to participate in surveys or research.
*   Reviewing records such as for financial audits.
*   Analysing and refining our advertising, campaigning and other operations to increase our effectiveness.
*   To improve our websites
*   To fulfil any legal obligations


### Personalised Communication and Profiling 

In order to ensure our communication with you is relevant, timely and will ultimately provide a better experience for you, we may build up a profile of you based on the interactions you have had with the Circles. 

This profiling may include details of your past engagement with the Circles together with information gathered from sources detailed elsewhere in this Privacy Policy and may be carried out either by *Circles Coop eG*. or by a trusted partner. This does not affect any of your rights or limit you in how you can get involved with us and our work. You may opt out of profiling at any time by contacting us using the details at the bottom of this policy.


### Job Applicants (new)

If you apply for a job on our careers site your personal data will be collected.

We will collect a range of information about you, including:



*   Your name, address and contact details, including email address and telephone number.
*   Details of your qualifications, skills, experience and employment history

We initially rely on your consent to process your information as a job candidate. 

Your information will not be used for any purpose other than processing and managing your job application. Only people involved in the recruitment process for the role you apply for will have access to your personal data.

Personal information about unsuccessful candidates will be held for one year after the recruitment exercise has been completed and will then be destroyed.  


### Cookies  

Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device's internal memory. This Service does not use these “cookies” explicitly. However, the app may use third party code and libraries that use “cookies” to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of this Service.


### Log Data 

We want to inform you that whenever you use our Service, in a case of an error in the app we collect data and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics.


## How your data is kept secure


### What *Circles Coop eG*. does to keep your data secure

We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.


### Security measures

We have implemented appropriate technical and organisational measures to secure personal data against loss or against any form of unlawful processing. Our donation pages are secured using Secure Sockets Layer (SSL), a security protocol that provides communications privacy over the Internet in a way that is designed to prevent eavesdropping, tampering, or message forgery.

Only employees who require to access information about supporters and website visitors to perform their work are granted access to your personal data.


### Who has access to your data

#### Within *Circles Coop eG*.

Within Basic Income GmbH, only those authorised to process your data can access your data. We work hard to ensure our staff and volunteers can only see the data they need to perform their tasks. All our staff are trained to understand data protection and what they need to do to keep your data secure. We review our data awareness training regularly to ensure it is up to date. We ensure volunteers are given appropriate data awareness and protection training where they are responsible for handling data, for example, if they are collecting petition signatures at an event.

#### Working with Third Parties

We will never sell or swap your details with other organisations

We do use trusted companies like fundraising agencies, fulfilment houses and software platform providers to administer some activities, in which case they will use your details only for that purpose – for example, applying your name and address to a mailing of Connect magazine.


## Service Providers 

We will never sell or swap your details with other organisations.

We may employ third-party companies and individuals due to the following reasons:



*   To facilitate our Service;
*   To provide the Service on our behalf;
*   To perform Service-related services; or
*   To assist us in analyzing how our Service is used.

We want to inform users of this Service that these third parties have access to your Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.

Services we use are MailChimp, Stripe, Paypal, DonorBox, Google. 


## Data Retention 

Data collected by *Circles Coop eG*.  will be retained only for an appropriate length of time. In some cases, the retention periods are governed by law, while in others we are guided by best practice and our operational needs.

When we no longer need to retain your personal information we will ensure it is securely disposed of.

You have the right to ask us to delete personal information we hold about you in some circumstances, for example, if we are processing the data on the basis of consent and you wish to withdraw that consent.


## Links to Other Sites 

This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.


## How we will communicate with you

For any communications about our work, fundraising or volunteering we will only contact you via email and phone if we have your consent to do so.

We may send you materials by mail or via phone if we have your consent or we believe you would be interested in our work unless you have expressed a preference not to receive such content. 

To respond to your queries we will contact you either via the medium you used to contact us or by a medium you have indicated you would like us to respond with. If we need to contact you for any administrative purposes then we will usually email you or call you depending on what contact details we have available for you.


## Children’s Privacy 

These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.


## Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. This policy is effective as of 2020-09-25


## Contact Us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at hello@joincircles.net. 

This privacy policy page was originally created at privacypolicytemplate.net and modified/generated by App Privacy Policy Generator and revised at January 2021.

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