Effective Date: November 6, 2023.
Circufiber Privacy Policy
Welcome! You have arrived at www.circufiber.com (the “Site”), which is owned and operated by Circufiber, Inc. (“Circufiber”). Throughout this Privacy Policy the words “we”, “us” and “our” refer to Circufiber, and the words “you” and “your” refer to the user visiting the Site. This Privacy Policy applies to information that we collect at the Site. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of the Site (unless otherwise stated below).
By accessing and using our Site, you consent to our Privacy Policy, our Terms of Use and Terms of Purchase and our collection, use and sharing of your information and data, and other activities, as described below.
1. What Information Does the Site Collect?
(a) Information You Provide to Us
Personal Information. We may ask you to provide us with, or you might submit via the Site, personally identifiable information, which is information that identifies an individual personally, such as one’s first and last name, telephone number, e-mail address, shipping address, billing address and geolocation data (“Personal Information”). We may collect this Personal Information through various forms and in various places on the Site, including account registration forms, “contact us forms” at the Site.
(b) Information Collected or Stored As You Access and Use the Site
In addition to any Personal Information or other information that you choose to submit to us via the Site, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain other information whenever you visit or interact with the Site (“Usage Information”) for purposes of this Privacy Policy. This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. To the extent we associate Usage Information with Personal Information or that the Usage Information contains Personal Information, we collect directly from you on the Site, we will treat it as Personal Information.
Without limiting the generality of the foregoing, this Usage Information may include:
· your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Site, and our computers identify your Device by its Device Identifier;
· your Device functionality (including browser, operating system, hardware, mobile network information);
· the URL that referred you to our Site;
· details of transactions you carry out through the Site and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the Site;
· the areas within our Site that you visit and your activities there, including remembering you and your preferences;
· your Device location;
· your Device characteristics; and
· certain other Device data, including the time of day, among other information.
You may also provide information for publication or display posted in public areas of the Site (collectively, “User Contributions”). Your User Contributions are posted and transmitted to others at your own risk. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Tracking Technologies. We may use various other methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):
Cookies.
A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.
We use the following cookies to optimize your experience on our Site and to provide our services.
Cookies Necessary for the Functioning of the Store
|
Name |
Function |
|
_ab |
Used in connection with access to admin. |
|
_secure_session_id |
Used in connection with navigation through a storefront. |
|
cart |
Used in connection with shopping cart. |
|
cart_sig |
Used in connection with checkout. |
|
cart_ts |
Used in connection with checkout. |
|
checkout_token |
Used in connection with checkout. |
|
secret |
Used in connection with checkout. |
|
secure_customer_sig |
Used in connection with customer login. |
|
storefront_digest |
Used in connection with customer login. |
|
_shopify_u |
Used to facilitate updating customer account information. |
Reporting and Analytics
|
Name |
Function |
|
_tracking_consent |
Tracking preferences. |
|
_landing_page |
Track landing pages |
|
_orig_referrer |
Track landing pages |
|
_s |
Shopify analytics. |
|
_shopify_fs |
Shopify analytics. |
|
_shopify_s |
Shopify analytics. |
|
_shopify_sa_p |
Shopify analytics relating to marketing & referrals. |
|
_shopify_sa_t |
Shopify analytics relating to marketing & referrals. |
|
_shopify_y |
Shopify analytics. |
|
_y |
Shopify analytics. |
The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.
You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.
Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.
Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioral Advertising” section below.
When you visit our website, log in, register or open an email, cookies, ad beacons, and similar technologies may be used by our online data partners or vendors to associate these activities with information they or others have about you, including your email address. We (or service providers on our behalf) may then send communications and marketing to these email addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Site’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with theSite, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third-party service provider, is active only while you are connected to theSite, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
ETag, or Entity Tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices in the same user).
Tracking Technologies Usage. We may use Tracking Technologies for a variety of purposes, including:
Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access ourSite, including cookies required to prevent fraudulent activity and improve security.
Performance‑Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of theSite, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site.
Functionality‑Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing theSite, including identifying you when you sign‑in to ourSiteor keeping track of our specified preferences, including in terms of the presentation of content on ourSite.
Targeting‑Related. We may use Tracking Technologies to deliver content relevant to your interests on ourSite and third‑party sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you.
Tracking Technologies Choices and Consent.
If you do not want us to collect this information, do not use theSite.
We obtain your consent to our information storage or collection Tracking Technologies by providing you with transparent information in our Privacy Policy and providing you with the opportunity to make a choice to disable cookies as set forth above. Please note that we are not required to obtain your consent to the information collection Tracking Technologies identified above that are strictly necessary.
We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed.
Third Party Tracking and “Do Not Track.”
There may be other Tracking Technologies now and later devised and used by us in connection with theSite. Further, third parties may use Tracking Technologies in connection with ourSite, which may include the collection of information about your online activities over time and across third-party websites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third-party Tracking Technologies in connection with use of ourSiteand accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties. Also, various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.
(c) Information Third Parties Provide About You
We may, from time to time, supplement the information we collect directly from you on the Site with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. To the extent we combine information we receive from those sources with your Personal Information we collect on the Site, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties, even if they have used our technology to collect it and share it with us.
(d) Interactions with Third-Party Services
The Site may include functionality that allows certain kinds of interactions between the Site and a third-party website or application. For example, you might be able to link the Site with, or import/share information about you from, third-party websites. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, when you register with the Site, you may have an option to use your Facebook, Google or other account provided by a third-party site or application to facilitate the registration and log-in or transaction process on the Site, or otherwise link accounts. If we offer and you choose to use this functionality to access or use our Site, the third-party site or application may send Personal Information about you to us. If so, we will then treat it as Personal Information under this Privacy Policy, since we are collecting it as a result of your accessing of and interaction on our Site. In addition, we may provide third-party sites’ interfaces or links on the Site to facilitate your sending a communication from the Site. For example, we may use third parties to facilitate emails, tweets or Facebook postings. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. Circufiber may not control or have access to your communications through these third parties. Further, when you use third-party websites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on our Site.
2. How Do We Use the Information Collected?
Generally. We use your Personal Information to fulfill your order. We may also use this information to provide customer service to you, to communicate with you, to respond to your questions, and to contact you. We also may use your Personal Information, User Contributions or Usage Information that you submit or that we collect about you: (1) to provide you with information or services or to process transactions that you have requested or agreed to receive, including for job opportunity consideration as a result of an online employment application or for providing general information about Circufiber’s products in response to a request submitted online; (2) to provide you with information via email about product or service offerings from Circufiber or Circufiber’s partners on an ongoing basis, unless you opt out of receiving such emails; (3) to enable you to participate in a variety of the Site’s features; (4) to send promotional or marketing emails to you on behalf of the other businesses or organizations; (5) to process your account inquiry, including verifying your information is active and valid; (6) to improve the Site, to create new service offerings, to customize your experience on the Site, or to serve you specific content that is most relevant to you; (7) to contact you with regard to your use of any of the Site and, in our discretion, changes to the Site and/or any of the Site’s policies; (8) for internal business purposes; and (9) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.
Contact Us. Please note that information submitted to the Site via a “contact us” or other similar customer inquiry function may not receive a response.
3. How and When Do We Share Information with Third Parties?
We will not share Personal Information with third parties for their direct marketing purposes. If you affirmatively opt-in to receive marketing communications from third parties, we may, from time to time, share personal information you provide to us with selected third-party marketing partners that we believe offer products or services that may be of interest to you. If you would like us to stop providing your information to our third-party marketing partners, you may opt-out bycontact us by e-mail using our contact form. Otherwise, we will not share Personal Information with third parties for their direct marketing purposes. We may, however, share non-Personal Information, such as aggregated user statistics and browsing behavior information, with third parties. We may share the information we have collected, including Personal Information, as disclosed at the time you provide the information and as described below or otherwise in this Privacy Policy. Circufiber may also disclose Personal Information as follows:
(a) When You Request Information From or Provide Information to Third Parties. You may be presented with an option on our Site to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties.
(b) Third Parties Providing Services on Our Behalf. We may use third-party vendors (for example, Shopify) to perform certain services on behalf of us, such as hosting the Site, designing and/or operating the Site’s features, tracking the Site’s activities and analytics, and enabling us to send you special offers or perform other administrative services. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to Personal Information. We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here:https://policies.google.com/privacy?hl=en. You can also opt-out of Google Analytics here:https://tools.google.com/dlpage/gaoptout.
We are not responsible for those third-party technologies or activities arising out of them, nor are we responsible for the effectiveness of or compliance with any third party’s opt-out options.
(c) Advertising Partners. We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location). For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
FACEBOOK - https://www.facebook.com/settings/?tab=ads
GOOGLE - https://www.google.com/settings/ads/anonymous
BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
(d) Third-Party Software Data Collection. The Site includes an application programming interface provided by a company that does business as Circufiber that collects information about visitors that is used, either in isolation or in combination with or through reference to information from third-party data sources, determines your email address. Circufiber then uses your email address to reach out to you about your experiences at the Site, about Circufiber product offerings, or about third party product or service offerings. Circufiber’s website and privacy policy can be found at: www.Circufiber/. Again,we are not responsible for those third-party technologies or activities arising out of them, nor are we responsible for the effectiveness of or compliance with any third party’s opt-out options.
(e) To Protect the Rights of Circufiber and Others. To the fullest extent permitted by applicable law, we may also disclose Personal Information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Circufiber or third parties (including through the enforcement of this Privacy Policy, our Terms of Use and Terms of Purchase or other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders). To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.
(f) Affiliates and Business Transfer. We may share Personal Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.
4. Basis for Use of Personal Information.
Certain laws, including the EU General Data Protection Regulation ("GDPR"), require that we inform applicable individuals of the legal bases for our use and other processing of personal information. We do not at present sell or ship our products to Europe and do not have GDPR compliance obligations, but nevertheless note that we process personal information for the following legal bases:
· Performance of contract: as necessary to enter into or carry out the performance of our contract with you.
· Compliance with laws: for compliance with legal obligations and/or defense against legal claims, including those in the area of labor and employment law, social security, and data protection, tax, and corporate compliance laws.
· Our legitimate interests: in furtherance of our legitimate business interests including:
o Performance of contracts with franchisees and other parties
o Implementation and operation of global support (e.g., IT) services for our business operations
o Customer relationship management and improving our Services, including marketing and analytics
o Fraud prevention, including misuse of company IT systems or money laundering
o Physical, IT, and network perimeter security
o Internal investigations
o Mergers, acquisitions, and reorganization, and other business transactions
With your consent: where we have your consent (the GDPR (to the extent that it applies)) and other applicable laws give you the right to withdraw your consent, which you can do this at any time by contacting us using the details at the end of this privacy notice. In some jurisdictions, your use of the Site may be taken as implied consent to the collection and processing of personal information as outlined in this privacy notice.
In addition, we may process your personal information where necessary to protect the vital interests of any individual.
5. Does Third-Party Content or Links To Third-Party Services Appear on the Site?
The Site contains content that is supplied by third parties, and those third parties may collect Usage Information and your Device Identifier when pages from the Site are served to you. In addition, when you are on the Site you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off the Site onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you or others, including Personal Information, and may or may not have their own published privacy policies. We encourage you to note when you leave ourSite and to review the third-party privacy policies of all third-party websites and exercise caution in connection with them.
6. How Do I Change My Information and Communications Preferences?
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The Site may allow you to review, correct or update Personal Information you have provided through the Site’s registration forms or otherwise, and you may provide registration updates and changes by contacting us. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information or change your preferences on the Site, information that you remove may persist internally for Circufiber’s administrative purposes. You may cancel or modify our e-mail marketing communications you receive from us by following the instructions contained within our promotional e-mails or in some cases by logging into your Site account and changing your communication preferences. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of e-mails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our Site, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications. If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways: Postal Mail: Attention: Privacy Officer, Circufiber, Inc., 759 Chief Justice Cushing Hwy, Suite 326, Cohasset, Massachusetts 02025;Bycontact us by e-mail using our contact form.
7. What About Transfer of Information to the United States?
If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. If you are located, for example, in European Economic Area or Switzerland, your personal information will be transferred to the United States and possibly to other jurisdictions, which may not provide the same level of protection under your local data protection laws. In such cases, we rely on suitable personal information transfer safeguards. By using theSite or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.
8. What Should Parents Know About Children?
We understand the importance of protecting children’s privacy in the interactive world. The Services are not intended or directed to children under the age of 16, and we do not knowingly collect any personal information, or knowingly track the use of our Services, from children. If we have actual knowledge that personal information about a child under 16 years old has been collected, then we will take appropriate steps to try and delete such personal information.
9. California Resident Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit our California Residents Privacy Notice.
10. European Economic Area/European Union/United Kingdom Resident Privacy Rights
The GDPR (where applicable), gives data subjects the following rights regarding their personal information:
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for:
· compliance with a legal obligation; or
· the establishment, exercise or defense of legal claims.
We can continue to use your personal information following a request for restriction, where:
· we have your consent; or
· to establish, exercise or defend legal claims; or
· to protect the rights of another natural or legal person.
11. What About Security?
We endeavor to incorporate commercially reasonable safeguards to help protect and secure Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use ourSite and provide us with your information at your own risk.
12. What About Changes to the Privacy Policy?
We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of ourSite indicates your consent to the privacy policy posted at the time of use. However,we will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
California Residents Privacy Notice
Effective Date: November 6, 2023
Last Updated on: November 6, 2023
This WebsitePrivacy Policy for California Residents supplements the information contained in Circufiber, Inc.’s Privacy Policy[PC1] and applies solely to all Services (as defined in the Privacy Policy) visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.
Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B personal information") from some its requirements.
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:
Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|
Category |
Examples |
Collected |
|
A. Identifiers. |
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. |
YES |
|
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. |
YES |
|
C. Protected classification characteristics under California or federal law. |
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
|
NO |
|
D. Commercial information. |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
NO |
|
E. Biometric information. |
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
NO |
|
F. Internet or other similar network activity. |
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. |
YES |
|
G. Geolocation data. |
Physical location or movements. |
YES |
|
H. Sensory data. |
Audio, electronic, visual, thermal, olfactory, or similar information. |
NO |
|
I. Professional or employment-related information. |
Current or past job history or performance evaluations. |
NO |
|
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). |
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. |
NO |
|
K. Inferences drawn from other personal information. |
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
NO |
We obtain the categories of personal information listed above from the following categories of sources:
Directly from you.
Indirectly from you. For example, from observing your actions on our Services and the associated app.
From third parties.
We may use, share or otherwise disclose the personal information we collect for one or more of the following purposes:
To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To provide, support, personalize, and develop our Services, including the app, products, and services.
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your Services experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Services, third-party sites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of our Services, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Services, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, we have not disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.
We may also share your personal information by selling it to third parties, subject to your right to opt-out of those sales. Our personal information sales do not include information about individuals we know are under age 16. In the preceding twelve (12) months, we have not sold the following categories of personal information to the categories of third parties indicated in the chart below. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.
|
Personal Information Category |
Category of Third-Party Recipients |
|
|
Business Purpose Disclosures |
Sales |
|
|
A: Identifiers. |
Yes |
Yes |
|
B: California Customer Records personal information categories. |
Yes |
Yes |
|
C: Protected classification characteristics under California or federal law. |
None |
None |
|
D: Commercial information. |
None. |
None. |
|
E: Biometric information. |
None. |
None. |
|
F: Internet or other similar network activity. |
Yes |
Yes |
|
G: Geolocation data. |
Yes |
Yes |
|
H: Sensory data. |
None |
None |
|
I: Professional or employment-related information. |
None |
None |
|
J: Non-public education information. |
None |
None |
|
K: Inferences drawn from other personal information. |
Yes |
Yes |
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
The specific pieces of personal information we collected about you (also called a data portability request).
We do not provide a right to know or data portability disclosure for B2B personal information.
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
We do not provide these deletion rights for B2B personal information.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by accessing your Services account and [clicking on “Manage My Preferences”].
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You may also make a request to know or delete on behalf of your child by using our contact form..
You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include logging into your Services account using your user name and password to make the request;
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in the request to verify the requestor's identity or authority to make it.
For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us by e-mail using our contact form.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:
[link]
Alternatively, you may contact us by e-mail using our contact form. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by contact us by e-mail using our contact form.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our platform and app following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this notice, the ways in which Circufiber collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: 978-955-2783
Website: www.circufiber.com
Email: Please contact us by e-mail using our contact form.
Postal Address:
Attn: Privacy Officer
Circufiber, Inc.
P.O. Box 462 Mooresville, NC 28115
If you need to access this Policy in an alternative format due to having a disability, please contact us by e-mail using our contact form.
