©2019 by Canal Circle Pte. Ltd.

PRIVACY POLICY

Effective Date: July 11th, 2019


This is the Privacy Policy for products owned and operated by Canal Circle Pte. Ltd., which comprises the website located at www.canalcircle.com, www.canalcircle.com, and all other related online and mobile applications and services owned and operated by Canal Circle Pte. Ltd. or Canal Circle™ in short (all of the foregoing, collectively, the “Canal Circle™ platform”). In this Privacy Policy, we inform you of what information we collect from and about you on the Canal Circle™ platform, how the information is used and with whom it may be shared, and what choices are available to you regarding your information. This Privacy Policy constitutes a part of the Terms of Use for the Canal Circle™ platform.

NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS

Under California Civil Code Section 1798.83 (known as the “shine the light” law), California residents have a right to request an information-sharing disclosure from a business to which they have provided personal information and which has disclosed their personal information to a third party in the prior calendar year for that third party’s direct marketing use (i.e., not for use in the business’s own marketing).

Other than as specifically described in this Privacy Policy, we do not share your personal information with a third party for that third party’s direct marketing use, unless we have your opt-in consent. To make a request for information-sharing disclosure under this law, please email us at support@canalcircle.com. Please note that, under this law, we are not required to respond to your request more than once in a calendar year, nor are we required to respond to any requests that are not sent to the above-designated email address.

DO NOT TRACK (DNT) DISCLOSURE:

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (DNT) or similar feature that can signal to websites that a user does not want to have his/her online activity and behavior tracked. If a website responds to a web browser’s DNT signal, the browser can block that website from collecting certain information about a user. Because the technological standards for DNT signals are not yet uniform, presently responding to DNT signals is optional for websites and many websites do not respond to DNT signals. The Canal Circle™ platform does not currently respond to DNT signals of web browsers. However, should the industry establish uniform technological standards for recognizing and implementing DNT signals, we would be open to following such industry standards.

WHAT INFORMATION WE COLLECT

PERSONALLY IDENTIFIABLE INFORMATION (“PII”):

This is information that identifies you personally, such as your real name, email address, mailing address, phone number, photos of yourself, and your account username and password. We do not collect PII from you unless you voluntarily provide it to us or allow us to receive it from a third-party source. We collect your PII when you engage in an activity on the Canal Circle™ platform that identifies who you are or how you may be contacted, such as creating an account, posting content for others to view, submitting a request or inquiry to us, subscribing to our emailing list, etc. (each, an “Identification Activity”). An Identification Activity also includes linking your account on a third-party social media site with your account on the Canal Circle™ platform. For example, if you have an account with Facebook or Instagram, you can register on the Canal Circle™ platform using your Facebook or Instagram account, provided that you allow us to access and import your profile (including your name, email address, and profile photo) from Facebook or Instagram, as the case may be, to the Canal Circle™ platform.

Whether or not to disclose PII is completely your choice. However, without providing PII you will not be able to engage in or complete an Identification Activity. You must be at least 13 years of age to engage in an Identification Activity on the Canal Circle™ platform.

AGGREGATE AND ANONYMOUS INFORMATION (“AAI”):

This refers to information that does not identify you personally. For example, we use Google Analytics (tools provided by Google) to collect and analyze statistical data about users of the Canal Circle™ platform, and the data collected through Google Analytics helps us measure and understand the demographics, usage patterns, interests, trends, etc. about users. Google Analytics collects information anonymously and reports website trends and usage data without identifying individual users. For more information about our use of Google Analytics, please see the “Cookies and Similar Technologies” section of this Privacy Policy. Also, from time to time we may aggregate our users’ PII by removing personally-identifiable elements (such as names) so as to “anonymize” or “de-personalize” the information.

USER ACTIVITY INFORMATION (“UAI”):

This refers to certain information that we automatically collect when you use the Canal Circle™ platform, which includes, for example: (i) information about the device you use to access the Canal Circle™ platform (such as device type, operating system, browser type, etc.); (ii) your device’s Internet Protocol (IP) address and information related to that IP Address (such as domain information, your Internet service provider and general geographic location); and (iii) information about your visit to the Canal Circle™ platform, such as the date, time and duration of your visit, the pages and content you viewed, your search queries, and your other interactions with the Canal Circle™ platform; information in this category may also include what website you came from before visiting the Canal Circle™ platform and what website you navigate to when leaving the Canal Circle™ platform. Similarly, if you use the Canal Circle™ platform on a mobile device, we automatically collect certain information about your device, such as your device IP address, device type and operating system, browser type, and your device location data (based on GPS or WiFi signals, if turned on by you). Please note that the Canal Circle™ platform does not collect your mobile device’s precise real-time location information, unless you affirmatively allow the Canal Circle™ platform to access such information on your device. For more information about how we automatically collect information through the use of cookies and other similar technologies, please see the “Cookies and Similar Technologies” section of this Privacy Policy.

UAI does not tell us who you are and we do not link or combine UAI with our users’ PII. Accordingly, we treat UAI as AAI under this Privacy Policy.

WHAT WE DO WITH THE INFORMATION

The following describes how we use and share your information (including PII) collected on the Canal Circle™ platform:

TO OPERATE, MANAGE, MAINTAIN AND IMPROVE THE CANAL CIRCLE™ PLATFORM:

This includes using your PII to enable, process, administer, and respond to your Identification Activities on the Canal Circle™ platform. For example, when you create an account on the Canal Circle™ platform, we collect and use your PII to set up, maintain and administer your account.

TO COMMUNICATE WITH YOU IN CONNECTION WITH YOUR USE OF THE CANAL CIRCLE™ PLATFORM:

This includes communicating with you regarding your Canal Circle™ platform account, content you have posted, a request or inquiry you have submitted to us, important changes to the Canal Circle™ platform (including material changes to this Privacy Policy and/or our Terms of Use), etc. Please note that when you create an account on the Canal Circle™ platform, your email address may automatically be added to our emailing lists.

TO SHARE WITH OUR SERVICE PROVIDERS:

We may share your information (including PII) with third-party service providers who have a legitimate need to access your information in order to provide services or support for the operation, maintenance or security of the Canal Circle™ platform. We require that our service providers limit their use of your information solely to providing services to us and that they safeguard your information and not make unauthorized use or disclosure of the information.

TO PROTECT OUR RIGHTS, ETC.:

We may disclose user information (including PII) if doing so, in our good faith belief, is necessary to: (i) protect the rights, property, safety or security of the Canal Circle™ platform, our users, and/or the public (including enforcement of the terms of this Privacy Policy and/or any of our other terms and policies pertaining to the Canal Circle™ platform); (ii) detect, prevent, or otherwise address fraud, security or technical issues; (iii) comply with law or legal process (including a court order or subpoena); and/or (iv) to cooperate with law enforcement (including investigation of an alleged or suspected crime, fraud or other illegal activity).

TO COMPLETE A MERGER, SALE OF BUSINESS OR ASSETS, ETC.:

If Canal Circle™ is involved in a merger, acquisition, financing, or sale of business or assets, our user information (including PII) may be transferred to one or more third parties involved in such transaction and, upon such transfer, the relevant third-party privacy policy or policies may govern further use of the information. In the event of such a change of ownership, we will endeavor to notify our customers of the change as well as any choices our customers may have regarding the change.

USE AND SHARING OF AAI:

Because of the anonymous, non-personally identifiable nature of AAI, there are no restrictions under this Privacy Policy on how we may use and share AAI.

COOKIES AND SIMILAR TECHNOLOGIES

The following describes how we use cookies and similar technologies on and in connection with the Canal Circle™ platform:

COOKIES:

Cookies are small data files that websites and online services send to and store on your computer or mobile device through your web browser (if you allow). Cookies enable websites and online services to recognize your browser and record certain information about your visits. If a cookie is placed by the website or online service you’re currently using, it is called a “first-party cookie.” If a cookie is placed by a website or online service other than the one you are currently using, then it is called a “third-party cookie.”

We use first-party cookies on the Canal Circle™ platform to help us remember who you are, to enhance and personalize your experience, to understand and save your preferences for future visits, to compile information about our users, and to carry out other tasks relating to the operation or improvement of the Canal Circle™ platform. We do not use cookies to access information on your computer or mobile device. Most web browsers are initially set to accept cookies, but you can change your browser settings to notify you when you are sent a cookie, giving you the ability to accept or reject it, or you can choose to routinely and manually delete cookies stored on your computer or mobile device. Each time you revisit the Canal Circle™ platform, your ability to restrict our use of cookies on that service is subject to your browser settings and limitations at the time. Please note that if you choose to disable or reject cookies from the Canal Circle™ platform, the Canal Circle™ platform or portions thereof may become inaccessible or may not function properly.

For more information on how to manage cookies, visit http://www.aboutcookies.org/.

NOTE: Flash cookies (also known as “local shared objects” or “LSOs”) cannot be rejected, disabled, turned off, opted out, or deleted in the same way as regular cookies such as HTML cookies. Flash cookies may remain on your computer even after you have rejected, disabled, opted out or deleted regular cookies. For information on how to manage and remove Flash cookies, please visit:https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html,http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

WEB BEACONS:

The Canal Circle™ platform may also use “web beacons” (also known as “clear GIFs,” “pixel tags,” etc.) – which are small bits of code embedded in web pages or in emails – to deliver or communicate with cookies, to count users who have visited a web page, and to understand usage patterns. We may also include web beacons in emails to help us recognize activities such as when an email was opened, how many times an email was forwarded, which links in the email were clicked on, etc. Web beacons cannot be declined when delivered via a regular web page. However, web beacons can be refused when delivered via email. If you do not wish to receive web beacons via email, you will need to disable HTML images or refuse HTML (select Text only) emails via your email software.

GOOGLE ANALYTICS:

We use Google Analytics, a web analytics tool provided by Google that helps websites and online services collect and analyze information about how visitors use and interact with their sites and services, and based on information collected and analyzed through Google Analytics websites and online services can measure the performance of and make improvements to their sites and services. Google Analytics uses first-party cookies to track visitor interactions on the Canal Circle™ platform and to collect information about how visitors use the Canal Circle™ platform. We use the information collected through Google Analytics to help us understand the demographics, usage patterns and interests, trends, etc. about visitors to the Canal Circle™ platform. Google Analytics collects and reports usage information anonymously without identifying any particular visitor individually.

Google’s ability to use and share information collected by Google Analytics about your visits to the Canal Circle™ platform is subject to the Google Analytics Terms of Use published athttps://www.google.com/analytics/terms/us.htmland the Google Privacy Policy published at http://www.google.com/intl/en/policies/privacy/. Disabling cookies on your browser may be able to prevent Google Analytics from recognizing you on return visits to the Canal Circle™ platform. Google also offers a browser add-on for users to install to opt out of being tracked by Google Analytics at https://tools.google.com/dlpage/gaoptout.

INFORMATION ACCESS; DATA RETENTION

INFORMATION ACCESS:

If you have an account on the Canal Circle™ platform and you wish to view or update your information, please email us at support@canalcircle.com.

DELETION OF INFORMATION:

If you have an account on the Canal Circle™ platform, you may request to cancel your account and have your information deleted from our database by emailing us atsupport@canalcircle.com. Please note that account cancellation will also terminate further access to the Canal Circle™ platform.

DATA RETENTION:

Notwithstanding the foregoing, you acknowledge and agree that we reserve the right to retain your information (including PII) for as long as we deem reasonably necessary to comply with law or legal process (including a court order or subpoena), to cooperate with law enforcement (including investigation of an alleged or suspected crime, fraud or other illegal activity), to complete a transaction you have made with us, to resolve a claim or dispute between you and us, and/or to enforce an applicable agreement between you and us. Because of its non-personally-identifiable nature, AAI may be retained indefinitely.

USER CHOICES

CHOICE REGARDING MARKETING COMMUNICATIONS FROM CANAL CIRCLE™:

This refers to communications from Canal Circle™ (such as emails) that contain advertising or promotional information, such as information about special offers, promotions, discounts, etc. from brands/retailers. You have the choice to stop receiving further marketing communications from us. To exercise such choice, please email your request to us atsupport@canalcircle.com. Alternatively, to stop receiving further marketing emails from us, you may also use the “unsubscribe” link provided in a marketing email you previously received from us.

CHOICE REGARDING NON-MARKETING COMMUNICATIONS FROM CANAL CIRCLE™:

This refers to communications of a transactional or relationship nature or as required by law (such as email notifications regarding your account, content you have posted, our response to a request or inquiry you have made, important changes to the Canal Circle™ platform (including material changes to this Privacy Policy and/or our Terms of Use), an actual or suspected security breach that affects your PII stored by or for us, etc.). There is no opt-out for non-marketing communications. For as long as you continue to use the Canal Circle™ platform, you agree to receive non-marketing communications from Canal Circle™.

SECURITY

We use commercially reasonable measures to safeguard the security of the Canal Circle™ platform and our user information, including limiting access to our user information to only those of our employees, agents, contractors and service providers who need to access such information in order to perform tasks for us, and we require that they not make any unauthorized use or disclosure of the information.

Unfortunately, no security system is impenetrable and no data transmission over the Internet can be 100% secure. Consequently, Canal Circle™ cannot warrant or guarantee the security of the Canal Circle™ platform, nor can Canal Circle™ warrant or guarantee that any information you provide to Canal Circle™ will not be intercepted while being transmitted over the Internet. Canal Circle™ is not liable for the illegal acts of third parties, such as criminal hackers.

LINKS TO THIRD PARTIES

The Canal Circle™ platform may contain links to third-party websites or products or services, such as those of third-party service vendors (e.g., Stripe) and third-party brands/retailers (each, a “Linked Third-Party Site/Product/Service”). Canal Circle™ is not responsible for the privacy practices of a Linked Third-Party Site/Product/Service. Once you leave the Canal Circle™ platform, this Privacy Policy will no longer apply. When you visit a Linked Third-Party Site/Product/Service, you are subject to that third party’s privacy policy, and not this Privacy Policy. The privacy policy and data practices associated with a Linked Third-Party Site/Product/Service may be substantially different from those of Canal Circle™. Third parties may send their own cookies, web beacons, etc. to your computer or mobile device, and may collect information about you and make use of the information in ways that Canal Circle™ would not. You should always read the privacy policy associated with a Linked Third-Party Site/Product/Service prior to disclosing personal information.

YOUR POSTS ON CANAL CIRCLE™ PLATFORM

When you post content on the Canal Circle™ platform for others to view, only your username (not your real name) will be made visible to others in connection with your posts. However, if you choose to reveal personal or private information (including your or another’s identity) in your posts on the Canal Circle™ platform, such information will be visible to others. Please exercise caution when revealing information about yourself or another in your posts on the Canal Circle™ platform. Others could use information revealed by you to harm or harass you or another. Canal Circle™ cannot control and is not responsible or liable for how others may use information obtained from your posts on the Canal Circle™ platform.

PROTECTING CHILDREN

The Canal Circle™ platform is a general audience website and is not directed to children under the age of 13. We do not knowingly collect personal information from children under the age of 13. If we become aware that a user from whom we have collected personal information is a child under the age of 13, we will make every effort to promptly delete that user’s information from our database. We urge parents and guardians to participate in and supervise the online activities of their children.

INTERNATIONAL USERS

The Canal Circle™ platform is operated by us in and from the United States and information collected on the Canal Circle™ platform is processed, used and stored within the United States. If you are using the Canal Circle™ platform and submitting your personal information to us from outside the United States, you consent to the transfer of your personal information to the United States for processing, use, sharing and retention as described in this Privacy Policy.

CHANGES TO PRIVACY POLICY

From time to time, we may update and modify this Privacy Policy to accommodate new technology, industry practices, regulatory requirements, or for other purposes. If the changes are material (e.g., if we change in a material way how we collect, use or share our users’ personal information), we will provide you with notice (which notice may be posted on the Canal Circle™ platform and/or be sent to you via email or postal mail). If you have an account on the Canal Circle™ platform, we may ask you to affirmatively agree to the changes (such as by checking a box or clicking a button) at the time of your next account log-in. By continuing to use the Canal Circle™ platform after such notice (and consent, if applicable), you are bound by this Privacy Policy as modified.

CONTACT US

For privacy related questions or requests, please contact us at support@canalcircle.com.