Privacy Policy

Thank you for visiting Circle Locker. Circle Locker is owned and operated by Circle Locker, LLC. We respect your privacy and are committed to protecting it through this Privacy Policy. As explained below, we collect information from you ( "you" "your" "consumer" or "visitor") in various ways when you interact with the Circle Locker application, website, and our other online services (collectively "Circle Locker").

By utilizing Circle Locker, you agree to the terms set forth below in this policy. If you do not wish to agree to this Privacy Policy, you must refrain from using Circle Locker. This policy may change from time to time. Your continued use of Circle Locker after changes are made to this Privacy Policy is deemed to be an acceptance of those changes. We will notify you, as the consumer, anytime changes or updates are made to the Privacy Policy.

1. Summary

As a consumer, you are free to explore Circle Locker without providing any personal Information, as defined below, about yourself. However, this may limit your ability to receive certain information from Circle Locker and may limit your access to Circle Locker. To access certain features of Circle Locker, you must first complete member registration where we may ask for certain personal information, as defined below:

When signing up for a Circle Locker account you will be asked first to submit personal Information such as location, age, and gender. Circle Locker may also request, at your election, further information, including but without limitation, product photos, a profile picture, app usage reports, purchase history and return history.

2. What Types of Information Does Circle Locker Collect

Personal Information refers to any information that you voluntarily submit to Circle Locker that directly or indirectly relates to, identifies, could reasonably be linked to, or describes a particular individual. Personal Information includes, but is not limited to; name, e-mail address, physical address, phone number, birth date, etc. Circle Locker collects Personal Information when you sign up for an account, send us an email, or engage in a transaction through Circle Locker, as well as information to which may also be contained on server logs, such as your Internet protocol ( "IP") address.

Personal Information can also include information about any transactions that you enter into with Circle Locker, and information about you that is available on the Internet, such as from Facebook, LinkedIn, Twitter, and Google, or publicly available information that we acquire from service providers.

Circle Locker may also collect Non-Personally Identifiable Information when you use Circle Locker. Non-Personally Identifiable Information is information which, by itself, cannot be used to identify or contact you. Non-Personally identifiable information which we store may include, without limitation, website pages viewed, sites visited before coming to the Circle Locker website, browser type, operating system, device type (mobile, tablet or desktop), organization name, articles, presentations and videos viewed, time spent viewing Circle Locker website or using certain features of the website, demographic data such as server locations clickstream data, cookies existing on your computer, search criteria used and results, date and time of access or visits to the Website, frequency of visits to the Website, connection speed, and other information through automated tracking technologies, some of which are discussed below, and Circle Locker may combine this automatically collected information with other information Circle Locker collects about you. Circle Locker does this to improve the services it offers and to improve Circle Locker services.

Information collected automatically through Circle Locker can directly or indirectly identify an individual. Navigational information refers to information about your computer and your visits to Circle Locker such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed.

Circle Locker may at times collect information and/or personal information from a third-party company that you have ordered from and are returning to. We may at times transfer information we have collected about and from you to third parties.

3. How Circle Locker Collects Information

Circle Locker collects information about you, as a consumer, when you voluntarily provide it through the App and Website, or in the manner such as those described below:

Web Beacons. Some pages of the Circle Locker may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages of Circle Locker and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Cookies (or browser cookies). A cookie is a small text file placed on the hard drive of your computer. You may refuse to accept cookies by activating the appropriate "Do Not Track" setting on your browser or delete or "flush" all cookies stored on your device. However, if you select this setting or delete all cookies you may be unable to access certain parts of Circle Locker or certain features of Circle Locker will be disabled. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to Circle Locker. Cookies placed on your computer by Circle Locker are called "first-party" cookies, and those placed by third parties would be "third-party" cookies. Circle Locker uses cookies for authentication, session management and personalization of your experience.

4. How Circle Locker Uses Information

Circle Locker may process personal information relating to you if one of the following applies:

You have given your consent to Circle Locker for one or more specific purposes. Under some legislations, Circle Locker may be allowed to process Personal Information until you object to such processing ( "opt-out"), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Information is subject to European data protection law, where you must explicitly agree to the processing of your Personal Information.
Provision of Personal Information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
Processing is necessary for compliance with a legal obligation to which Circle Locker is subject;
Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in Circle Locker;
Processing is necessary for the purposes of the legitimate interests pursued by Circle Locker or by a third-party.

In any case, Circle Locker will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

5. Purpose of Processing personal information

Personal information concerning you is collected in order to allow Circle Locker to provide its services, as well as for the following purposes: contacting you, analytics, managing contacts and sending messages, and processing and fulfilling your order(s).

Analytics. The services contained in this section enable Circle Locker to monitor and analyze web traffic and can be used to keep track of visitor behavior.
Contacting You. Circle Locker may use your information for notification and reminders such as:
Mailing Lists or Newsletters. By subscribing to the mailing list or for the newsletter, your email address will be added to the contact list of those who may receive email messages containing information of a commercial or promotional nature concerning Circle Locker. Your email address might also be added to this list as a result of signing up for an account with Circle Locker or after making a payment to Circle Locker.
Contact Form or Emails. By providing contact information on a contact form or email to Circle Locker, you authorize Circle Locker to use these details to reply to requests for information, quotes, or any other kind of request in your email and as indicated by the form's header.
Managing Contacts and Sending Messages. This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with you. These services may also collect data concerning the date and time when the message was viewed by you, as well as when you interacted with it, such as by clicking on the links included in the message.
Platform Services and Hosting. These services have the purposes of hosting and running key components of Circle Locker, therefore allowing the provision of Circle Locker from within a unified platform. Such platforms provide a wide range of tools to Circle Locker e.g. analytics, consumer registration, commenting, database management, e-commerce, payment processing – that require the handling of personal information. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the personal information is stored.
Aggregate Consumer Information. Circle Locker may at times, sell "Aggregate Consumer Information" which is information relating to a group or category of consumers, from which individual consumer identities have been removed and is not linked or reasonably linkable to any consumer or household. Circle Locker may sell Aggregate Consumer Information without your consent.

6. Who does Circle Locker share information with

Circle Locker may share your information, including Personal Information as follows:

Service Providers. At times, Circle Locker may disclose the information collected from you to a third party or other service provider. Circle Locker utilizes third parties and service providers to help achieve our purpose and render services offered. The third parties and service providers, in order to benefit Circle Locker, are allowed to access Personal Information stored with Circle Locker in order to perform their functions and for no other purpose.

Affiliates. Circle Locker may disclose the Personal Information to corporate affiliates or subsidiaries, their use, and disclosure of Personal Information is subject to this Privacy Policy.

Mergers. In the event of a merger with another company, or Circle Locker is acquired by another company, we may transfer the information we have collected to the other company.

Protection. Circle Locker may disclose collected Personal Information where it is reasonably necessary to investigate, prevent or take action regarding illegal activities, including but not limited to, fraud, threats to the safety of a person, or violations of this Privacy Policy or our Terms of Service.

7. Where Information is Processed and Stored

Your information may be stored and processed on our servers located in the United States. Data is processed at the operating locations of Circle Locker and any other places where the parties involved in the processing are located. Any of the corporate affiliates or third parties who receive or purchase your information may store your information on their servers in the United States or another country.

Depending on your location, data transfers may involve transferring your personal information to places other than your own. To find out more about the place of processing and storing of such transferred personal information, you can check the section containing details about the processing of personal information.

You are also entitled to learn about the legal basis of data transfers of personal information to a country outside the European Union or any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by Circle Locker to safeguard your personal information.

If any such transfer takes place, you can find out more by checking the relevant sections of this document or inquire with Circle Locker using the information provided in the contact section.

Personal information shall be processed and stored for as long as is required to achieve the purpose it has been collected for. Personal information collected for purposes related to the performance of a contract between Circle Locker and you shall be retained until such contract has been fully performed and, personal information collected for Circle Locker's legitimate interests shall be retained as long as needed to fulfill such purpose. You may find specific information regarding the legitimate interests pursued by Circle Locker within the sections of this Privacy Policy or by contacting Circle Locker.

Circle Locker may be allowed to retain personal information for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, Circle Locker may be obliged to retain personal information for a longer period whenever required to do so for the performance of a legal obligation or upon the order of a legal authority.

Once the retention period expires, all personal information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

8. Your Rights and Data Protection

You may exercise certain rights regarding your personal information processed and retained by Circle Locker. In particular you have the right to:

Be informed. You have the right to know what rights and protections are offered to you as a consumer and/or user of Circle Locker.
Withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your personal information.
Object to processing of your data. You have the right to object to the processing of your personal information if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access your Data. You have the right to learn if your data is being processed by Circle Locker, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
Verify and Seek Rectification. You have the right to verify the accuracy of your personal information and ask for it to be updated or corrected.
Restrict the processing of your Data. You have the right, under certain circumstances, to restrict the processing of your data. In this case, Circle Locker will not process your data for any other purpose than storing it.
Have your personal information deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your personal information from Circle Locker.
Receive your Data and have it transferred to another controller. You have the right to receive your data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data is processed by automated means and that the processing is based on your consent, on a contract which Circle Locker is part of or on pre-contractual obligations thereof.
Lodge a complaint. You have the right to bring a claim before their competent data protection authority.
Not to be subject to automated decision-making including profiling.

Where personal data is processed for a public interest, in the exercise of an official authority vested in the Circle Locker or for the purposes of the legitimate interests pursued by Circle Locker, you may object to such processing by providing a ground related to their particular situation to justify the objection.

You must know that, should your personal information be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether Circle Locker is processing personal information for direct marketing purposes, you may refer to the relevant sections of this document.

Any requests to exercise your rights can be directed to Circle Locker through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by Circle Locker as quickly as possible and always within one month. However, Circle Locker may refuse or charge for any request that is unfounded or excessive. Circle Locker will notify you of the refusal and the basis of that refusal and that you will have the right to complain to the supervisory authority and seek a judicial remedy within one month of the request.

9. Data Breaches and Data Security

Circle Locker takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of data. Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Circle Locker, in some cases, data may be accessible to certain types of persons in charge involved with the operation of Circle Locker (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary as Data Processors by Circle Locker. The updated list of these parties may be requested from Circle Locker at any time.

Circle Locker safely secures personal information to prevent misuse, unauthorized access, disclosure and loss by ensuring a level of security appropriate to the risk of information. Such levels of security include encrypting and pseudonymization of personal data wherever possible and considering all other technical and administrative procedures, generally accepted practices in the industry. Personal information is additionally stored on secured servers.

However, despite Circle Locker's best efforts nothing can guarantee 100% security of your information. If you have any questions concerning the protection of your personal information, please contact Circle Locker.

In the event of a data breach, Circle Locker will notify the corresponding supervising authority within seventy-two (72) hours of learning of the breach or after 72 hours with an explanation for the delay, to the supervising authority.

10. Miscellaneous

In addition to the information contained in this Privacy Policy, Circle Locker may provide you with additional and contextual information concerning particular services or the collection and processing of personal information upon request.

California Civil Code Section § 1798.83 permits users of Circle Locker that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. You may make two requests per 12-month calendar year. To make such a request please see below Contact Information for Circle Locker. Please allow up to thirty (30) days for a response.

Circle Locker complies with all applicable laws, codes and regulations related to the protection of children's privacy, including, but not limited to the Children's Online Privacy Protection Act of 1998 (COPPA). Circle Locker is not intended for children under sixteen (16) years of age. No one under such age may provide information to Circle Locker. We do not knowingly collect personal information from anyone under the age of 16. If you are under the age of 16 please do not provide any personal information to Circle Locker. If we learn that we have collected or received personal information from an individual under 16 without verification of parental consent, we will delete that information. Please feel free to contact us if you believe we may have any information from or about an individual under the age of 16.

11. Contact Information

If you wish to contact Circle Locker with questions or comments about this Privacy Policy or privacy practices or, wish to exercise any of your rights detailed in the above Privacy Policy, please contact us at:

Circle Locker, LLC
Broomfield, CO 80023
Circle Locker.com