Effective Date: 02/05/2023
Thirty-One Circles Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
IMPORTANT INFORMATION AND WHO WE ARE PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how we collect and processes your personal data such as advertising, website analytics and when you contact us about working on your behalf or applying to join the team. For Thirty-One Circles Subscription holders please also consult the Membership Terms of Service and DPA to understand how we act as a data processor on your behalf.
This website is not intended for children and we do not knowingly collect personal information from or about any person under the age of 13. If you are under 13 years old and wish to ask a question or use this site in any way which requires you to submit your personal information, please get your parent or guardian to do so on your behalf.
It is 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.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data may include first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data may include invoicing address, email address and telephone numbers.
- Financial Data may include bank account and payment card details.
- Transaction Data may include details about payments to and from you and other details of services you have purchased from us.
- Technical Data may include your user-id, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data may include your purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data may include information about how you use our services and website, including Alexa and computer network
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data when engaging our services, filling in forms or by corresponding with us by post, phone, email, and telephone or otherwise. This includes personal data you provide when you:
- Third parties or publicly available sources. We may receive personal data about you from various third parties.
- Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
- Contact, Financial and Transaction Data from providers of technical and payment services.
- Contact details and other personal information from publicly available sources.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Personal Data Involved and Sub-Processors
Membership Details, Use and Logs related to Membership
Amazon Web Services
Name, Address, Contact Details, User ID
Fulfillment of Contract
Payment Details For Memberships
Amazon Web Services
Subscription Information Including Profile ID, Customer ID Number, Transaction Numbers, IP Address, last 4 digits and expiration date of user's Credit Card
The buyer's first and last name, The buyer's WordPress email address, Address, Full Credit Card Info - Number, CVC, Expiration Date, The buyer's IP address
Fulfillment of Contract
Contact For Marketing Purposes
Name, Email, Audience Segment
Contact For Terms of Service / Policy or Platform Updates
Fulfillment of Contract
Thirty-One Circles Website Analytics and Audience Segmentation
Google Cloud and Google Analytics
Amazon Web Services
Email, User ID
Contact Via Contact Us Forms
Amazon Web Services, Microsoft 365
As provided by the user
Fulfillment of the user's request
Amazon Web Services, Microsoft 365
Contacts Details and CV Details
Fulfillment of the user's request
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile 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 purchased services from us and in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Company for marketing purposes.
You can ask us or third parties to stop sending you marketing messages by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
WHAT ARE COOKIES?
We may use information obtained from cookies or similar technology. Cookies are text files containing small amounts of information which we download onto your computer or device when you visit our website. Therefore, when we refer to “you” in this section we mean your computer. We can recognise these cookies on subsequent visits and they allow us to remember you.
Cookies come in many forms. We have set out below the main types and categories of cookies that are used. This section refers to all types and categories of cookies and not just those we use on our website.
First and third-party cookies – whether a cookie is first-party or third-party refers to the domain placing the cookie. First-party cookies are those set by a website that is being visited by the user, the website displayed in the URL window e.g. thirtyonecircles.com Third-Party cookies are cookies that are set by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets a cookie through that website this would be a third-party cookie.
Persistent cookies – these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.
Session cookie – these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.
Strictly Necessary Cookies
- Cookie Consent Management
- WordPress Logged In User tracking
- Gravatar - Social Media Integration
- Google Analytics - Analytics web tracking and Audience Segmentation
- Jetpack - Site speed Analytics
To opt out of Google Tracking please go to
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 contact us.
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.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties in order to achieve the purpose it was collected for with regard to this we may share your information with:
Specific third parties listed in the table in tables above for the purposes listed.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts or frameworks approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to only employees who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Retention lengths of data provided under a membership "Client Customer Data" is held for the duration of the subscription. All Customer Data will expire after 60 days of an inactive subscription and will be erased within a further 60 days. The Customer can request for the data to be erased before this point over email.
Data Retention length's do not include time data is stored as backups, once deleted from live use the backup will be retained for the length of the backup period as described in the backup policy. This will in no case exceed 6 months from the data the live data was deleted.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
- If you wish to exercise any of the rights set out above, please contact us.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
HOW TO OBTAIN A COPY OF YOUR INFORMATION
You are entitled to ask for a copy of the information we hold about you (for which we may charge a small fee to allow us adequate time to collect this for you) and to have any inaccuracies in your information corrected. Please contact us if you wish to exercise this right.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.