Data Privacy

Privacy policies and processing of personal data of the User of the circularx.com Site

1. Acceptance and management of cookies

Cookies are text files used for statistical purposes or for the operation of certain identification modules, for example.

The Site only uses identification, authentication, and audience measurement analysis cookies.

A banner informs the User about the use of cookies, the purposes of this use, and requests explicit consent made by a clear affirmative action.

The User has the option to manage the cookies used on the site by configuring their browser.

The deposit or reading of certain cookies does not require the prior collection of your consent, either because they do not process any data, or because they are strictly necessary for the provision of the service.

Strictly necessary cookies: these cookies allow you to navigate the Site and are essential for the proper functioning of the Site. Disabling them will result in difficulties in using the Site and will prevent access to certain features.

Functional cookies: these cookies allow you to remember your preferences, your choices in order to personalize your experience on the Site.

Performance and statistical cookies: these cookies collect information about how Users use the Site (the number of visits, the number of pages viewed, the activity of visitors) via the Google Analytics analysis tool. These cookies also allow us to identify and resolve problems with the operation of the Site and to improve it. 

The Google Analytics service enables us to count Users and identify how they use the Site. These cookies are deposited and read on the User’s terminal equipment as soon as the User accesses a website using the “Google Analytics” service.

Data may therefore be processed in a country outside the European Union.

Google Inc. is a Safe Harbor member and therefore ensures an adequate level of protection for personal data as required by Article 45 of the Regulation of April 27, 2016 (Decision 2000/520/EC of 7/26/2000).

The User can obtain more information about the Google Analytics service by visiting http://www.google.com/analytics/learn/privacy.html.

If you give your consent to cookies being read, CircularX will place cookies enabling it to collect the information strictly necessary for the purposes described above.

Users can also manage the cookies used on the site by configuring their browser, as detailed below.

While most browsers are set to accept cookies by default, the User may choose to accept all cookies, or to reject them systematically, or to choose which cookies the User accepts, depending on the issuer. The User may also set his/her browser to accept or reject cookies on a case-by-case basis, prior to their installation. The User may also regularly delete cookies from his terminal via his browser. The User must configure all browsers on his various terminals (tablets, smartphones, computers, etc.).

Each browser is configured differently to manage cookies and User choices. This is described in the browser’s help menu, which will tell you how to modify your cookie preferences.

For example:

However, by setting the browser to refuse cookies, certain functionalities, pages and areas of the Site will not be accessible, for which CircularX cannot be held responsible.

CircularX also draws the User’s attention to the fact that, when the User objects to the installation or use of a cookie, a refusal cookie is installed on his/her terminal equipment. If the User deletes this refusal cookie, it will no longer be possible to identify him/herself as having refused the use of cookies. Similarly, when the User consents to the installation of cookies, a consent cookie is installed. Consent or refusal cookies must remain on the User’s terminal equipment.

Click here to modify your cookie preferences.

2. Personal Data

2.1. What data is collected ?

The Data collected via the Site and later processed by CircularX, are those that Internet users transmit voluntarily, in particular via the downloading of a resource (white paper, guide, use case…), or a request via a contact form or email or telephone exchanges.

These are also Data collected indirectly through cookies.

CircularX may collect the following Data:

  • Data relating to the User’s identity: title, surname, first name, email address and telephone number entered when filling in the download or contact form;
  • Data relating to browsing: this concerns Data relating to the way in which the User uses the Site, including: IP address (address of the Internet user’s connection), browser used, browsing time, search history, operating system used, language and pages viewed, collected for the management of the User’s computer system and for the analysis of site use;
  • Data concerning visits to the Site, including traffic data, log files and other data or communication resources used when accessing the Site.

2.2. Why this data is collected and on what legal basis?

The data collected is intended for use by the Site. It is necessary for the processing and management of customer requests and for commercial relations. They are also used to provide customers with personalized services and to improve the relevance of the information offered to them.

Data relating to the User’s identity, email address and telephone number are collected so that the User can receive the white paper or contact the company via a contact request.

Data relating to browsing and visits to the Site are collected in order to improve the User’s experience on the Site:

  • Adaptation of the site layout to the device used,
  • Recognition of the User in order to maintain an active connection,
  • Analysis of traffic and browsing data to improve Site performance.

Regarding IP address data, CircularX reserves the right to use the Internet user’s IP address in cooperation with his or her Internet service provider, in order to identify the Internet user if it deems it necessary to enforce its GCU or to protect its services, its customers or at the request of legal authorities.

Circular Experience a simplified joint stock company (SAS) registered with the Créteil Trade and Companies Register under SIREN number 903 092 401 with a capital of 50,000 euros, whose registered office is located at 54 avenue Lenine, 94250 Gentilly, France,  is responsible for processing the data collected.

The processing of User Data is justified on different grounds (legal basis) depending on the use CircularX makes of it.

Among the applicable legal bases :

  • The execution of a contract concluded with the User, in the context of subscribing to services offered by CircularX, for example.
  • Legitimate interest: CircularX has an interest in processing data that is justified, balanced and does not infringe on the User’s privacy (downloading a white paper, subscribing to a newsletter, depositing technical cookies to ensure the security of the website, etc.).
  • Consent: the User accepts the processing of his/her personal data through express consent (checkbox, click…): for “not strictly necessary” cookies, for example.

2.3. Who processes the collected data?

The Data collected is processed by the CircularX employees in charge of:

  • Site management,
  • Support management,
  • Commercial and marketing management,
  • Legal management.

2.4. What is the data protection policy and what are my rights?

The data protection policy applies to:

  • browsing on the Site,
  • the communication of data to access documents downloaded from the Site and the contact form,
  • emails exchanged between CircularX and the User,
  • newsletter subscription.

The User may choose how Data is transmitted and used on the Site. The User may browse the Site without providing any Data. The User may refuse to provide the information requested for access to documents to be downloaded, in which case he will not have access to these documents.

In accordance with Articles 16, 17, 18, 20 and 21 of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 and Article 34 of the French Data Protection Act, CircularX guarantees the User a right of opposition, access, deletion, data portability and rectification of Personal Data concerning him or her.

The right of access: is the right for any person to obtain communication of all information concerning him or her held by the Data Controller.

The right of rectification: is the right of any person to obtain the rectification of inaccurate personal data concerning him or her, as well as the right to obtain that incomplete personal data be completed, including by providing a supplementary declaration.

The right to object: is the right of the data subject to object at any time (either at the time of data collection, or later, by contacting the data controller), for reasons relating to his or her particular situation based on the public interest or the legitimate interest of the data controller. With regard to commercial canvassing, any person may object at any time to his or her data being circulated, transmitted or stored. This right can be exercised without having to justify a legitimate reason.

The right to define directives relating to the fate of personal data after the death of the data subject: in the absence of directives or of mention to the contrary in said directives, the heirs of the data subject may after his or her death exercise the rights over the deceased’s personal data.

The right to restrict processing: is the right of the data subject to obtain from the controller the restriction of processing where:

  • the accuracy of the personal data is contested for a period of time allowing the data controller to verify the accuracy of the personal data,
  • the data processing is illicit and the person involved objects to the erasure of the personal data, demanding instead that their use be restricted,
  • the data controller no longer needs the personal data for the purposes of processing, but it is still necessary for the data subject to establish, exercise or defend legal claims,
  • the data subject has objected to the processing during the verification as to whether the legitimate grounds pursued by the data controller prevail over those of the data subject.

The right to portability: the individual has the right to have his or her personal data transmitted in a structured, commonly used and machine-readable format and have the right to transmit such data to another controller without the controller to whom the personal data has been communicated hindering this, where:

  • Processing is based on consent or contract, and
  • Processing is carried out using automated processes.

The right to lodge a complaint with a supervisory authority: For further information concerning the exercise of his rights, the data subject may go to the following web address: https://www.cnil.fr/fr/comprendre-vos-droits

2.5. What are the terms for exercising my rights?

You can exercise the aforementioned rights by writing to CircularX – Personal Data Protection Service – 54 Avenue Lénine – 94250 Gentilly – France or by email: donneespersonnelles@recommerce.com

A response will then be sent to you within 1 month following receipt of the request.

You must be able to prove your identity by any means. In case of reasonable doubt, an identity document may be requested.

An identity document is not required for the exercise of your right to object to receiving commercial offers or advertising.

For legal or contractual reasons, certain information cannot be altered or deleted from databases.

2.6. What is the retention period for personal data?

The Data collected is kept for a period of three years, starting from the date of collection or last contact, in order to meet the purpose for which it was collected.

Data collected by means of cookies or tracers will be kept for up to 13 months.

Beyond the above-mentioned retention periods, the Data collected will be anonymized and retained exclusively for statistical purposes.

3. Deletion of Personal Data

In accordance with the European GDPR regulation, I request the deletion of my personal data from your information system via this form. I provide my name and email address for you to locate and remove them from your information system.

I would like my personal data to be deleted.