Privacy and Cookies Policy

About Us

We are Circus Street London Limited, a company registered in England with registered number 6958392 whose registered office is at 3rd Floor, 1 Alfred Place, Fitzrovia, London, WC1E 7EB (and we refer to ourselves as "we""us" or "our" in this document). Our "Website" means the Circus Street website, URLs are currently circusstreet.com or any relevant sub domain, such as my.circusstreet.com or a Customer specific sub domains, where "my" is substituted with a Customer name e.g. [customername.circusstreet.com]. We own and operate this "Website" on our own behalf.

About this Privacy and Cookies Policy

In this Privacy and Cookies Policy, references to "you" means any person submitting any data to us or to this Website about himself or herself or about any other living individual in respect of any use of the Website or the products available through the Website (each being a "Product").

When you use different aspects of the Website, we may ask you to supply us with various information about you or anyone whom you represent. This Privacy and Cookies Policy sets out the way in which we may use such information.

We are committed to protecting and respecting your privacy. This Privacy and Cookies Policy (together with our " Circus Street London Limited eLearning Terms & Conditions" and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purpose of the Data Protection Act 1998 (the Act), the data controller is Circus Street London Limited.

If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy and Cookies Policy. This policy may change from time to time (see Changes to this Privacy and Cookies Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. 

 

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at support@circusstreet.com.

 

Contacting us

Questions, comments, requests or suggestions regarding this Privacy and Cookies Policy are welcomed and should be addressed to support@circusstreet.com.

Your Privacy

Your privacy is very important to us. We shall therefore only use your name and other information which relates to you in the manner set out in this Privacy and Cookies Policy. We will only use your personal data in a way that is fair to you. We will only collect information where it is necessary for us to do so and we will only collect information if it is relevant to our dealings with you.

We will only keep your information for as long as we are either required to by law or as is relevant for the purposes for which it was collected.

Data that we collect

We may collect and process your personal data for processing your purchase of a Product on the Website. We may obtain the following information about you:

  1. your title, name, address, email address, telephone numbers, username, password and such other contact details as we require. This includes information provided at the time of purchasing a Product through the Website. We may also store information relating to any Products that you purchase; and
  2. payment information provided by you, for example, on placing an order for a Product available on the Website. This may include credit or debit card or bank account details.

Why we collect your personal data

We use the information collected for the purpose of fulfilling your order, in case we have any queries and for our record keeping. We may also use that data to prove payment for the Product and deliver the Product to you. We also use that data to inform you when an order has been confirmed and a Product is about to be delivered.

We may also use your data in order to manage the Website, collect payment from you (or through our payment service provider), detect fraud or Website abuses, send you information relevant to the Website or the Products and in case we have any queries.

We may also use your email address and other contact details, in particular, for sending you information relating to the Website and the services we offer. This includes (without limitation) the following:

  1. To allow you to go ahead and register for an account on the Website, which allows you to purchase Products. This includes (where applicable) sending an email to you to confirm your details, to give you initial information about the service we offer, and to enable you to commence ordering Products.
  2. To respond to you over any queries you raise with us.
  3. To enable you to have a password resent to you if you tell us or the Website that you have forgotten it.
  4. To record and track details of transactions you carry out through or via the Website and of the fulfilment of your orders.
  5. To collect details of your visits to the Website including, but not limited to, traffic data, location data, web blogs and other communication data, whether this is required for our own purposes or otherwise and the resources that you access.
  6. To contact you once you have used a Product.
  7. To provide you with information, products or services that you request from us or which we feel may interest you.

 

We may also need to use your contact details and other information for any aspect of the Website (including, but without limitation, providing customer support, preventing or investigating prohibited activity, enforcing the Circus Street London Limited eLearning Terms & Conditions and verifying information).

Your obligations as to your data

You must only submit to us, or the Website, information which is accurate and not misleading and you must keep it up-to-date and inform us of changes. By submitting data in respect of you and anyone else, you must ensure that you have full authority and consent to supply us with that data on their behalf and you warrant to us that you have that authority.

Third Parties and Links

We will disclose your personal data (including details of your credit or debit card or bank account) to our payment providers should you wish to make an order for a Product through the Website.

We may pass your details to our agents and subcontractors to help us with any of our uses of your data set out in our Privacy and Cookies Policy. For example, we may use third parties to assist us with collecting payments from you, to analyze data and to provide us with marketing or customer service assistance.

We may exchange information with third parties for the purposes of fraud protection and credit risk reduction.

We may transfer our databases containing your personal information if we sell or may our business or part of it to an actual or potential purchaser.

We may also disclose your details as described elsewhere in this Privacy and Cookies Policy.

Other than as set out in this Privacy and Cookies Policy, we shall NOT sell or disclose your personal data to third parties without obtaining your prior consent unless this is necessary for the purposes set out in this Privacy and Cookies Policy or unless we are required to do so by law (for example, by order of a court or governmental body or authority of competent jurisdiction).

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: 

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.      If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.     
  • Disclosure of Your Information for Third-Party Advertising. We do not share your personal information with third parties for the purposes of advertising..     Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own      products or services, then please use our opt-out features available in the communications we send.      This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
  • Targeted Advertising. We      do not      use your information that we collect or that you provide to us to deliver advertisements.     

          

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request support@circusstreet.com. However, please know we do not currently sell data triggering that statute's opt-out requirements.

 

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website and visiting your account profile page. 

You may also send us an email at support@circusstreet.com to request access to, correct or delete any personal information that your employer has      provided to us. We will forward your request on to your employer's Data Controller that provided us this information.     

     

Your California 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, please visit the section on this page [anchorlink to section below CCPA Privacy Notice for California residents].                     

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. 

 

Our use of Cookies on this site

Cookies are small text files which identify your computer to our server as a unique user when you visit certain pages on the website and they are stored by your internet browser on your computer's memory.

We use cookies to understand how you interact with our site(s) and to improve the information we present to you and the performance you experience from the site. Your browser can be set to not accept cookies. If you want to find out more information about cookies, go to http://www.allaboutcookies.org or to find out about removing them from your browser, go to http://www.allaboutcookies.org/manage-cookies/.

We operate 2 sites on the internet: Our marketing site (https://circusstreet.com) and our blog site https://blog.circusstreet.com. Both websites use the undermentioned cookies. The cookies are all first party cookies meaning that the data is returned to our domain. We use the Google Analytics service to present the data we collect in a way that helps us make the decisions noted below. Technical details for the cookies is explained on Google site https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

Cookie Provider

Data the cookies collect

Use made of cookie data by Circus Street

What is the cookie expiry date?

Google Analytics (set of cookies)

Includes:

  • Visitors device type
  • O/S version
  • Browser type
  • Country connecting
  • Page count visited
  • Page names visited
  • Page response time
  • Internet Service Provider

Marketing Site:

All data is anonymous but by inferring interests and location we can give our visitors a better experience of our website. We also use the Google Adwords tagging function in conjunction with the Analytics cookie data to help do this.

Blog Site: As above

Some cookies have a lifetime of just the browsing session and others have a longer lifetime before self-erasing after 26 months from when they were set. Cookies can be expired sooner by the user by the method described above.

Where we store your personal data

We store your personal details on a secure server. We use industry standard security and firewalls on our servers. When we collect payment card details electronically, our payment service provider, Stripe Payments Europe Ltd, uses encryption. Whilst we are unable to guarantee 100% security, this makes it hard for a hacker to decrypt your details.

We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

You are responsible for protecting against unauthorized access to your password and to your computer.

Security

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will take reasonable steps to protect your personal data, we cannot guarantee the security of your data transmitted over the Internet; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Your Rights

You have the right to ask us not to process your personal data to provide marketing information about Products or the Website.

Please note that our payment provider may have its own terms of use and privacy and cookies policy. Please read the terms of those documents before you submit any payment information through the Website and/or our payment provider.

The Website may, from time to time, contain links to and from the websites of suppliers, partner networks, advertisers and affiliates. If you follow a link to any of those websites, please note that those websites have their own privacy and cookies policies and that we do not accept any responsibility or liability for those policies. Please check those privacy and cookies policies before you submit any personal data to those websites.

Changes to this Privacy and Cookies Policy

We may amend this Privacy and Cookies Policy from time to time. Any amended Privacy and Cookies Policy will be posted on the Website. The amended Privacy and Cookies Policy will apply immediately for new users and 30 days (or such other timeframe as we say when posting) after first posting for all existing users. Each time you enter the Website or order a Product, you agree that the Privacy and Cookies Policy current at that time shall apply to all information which we hold about you.

Consent

By submitting data to us and using the Website, you consent to our use of your data and of anyone you represent in the manner set out in this Privacy and Cookies Policy (as amended from time to time, as described above) and you are responsible for ensuring that you have authority to consent on behalf of anyone about whom you submit data to us.

You also consent to us (or third parties working through our website) placing cookies on your hard drive. You can turn these off if you want, through the settings on your browser. See the “IP addresses and cookies” section above. Please note that we may place cookies on your hard drive by which you can be personally identified; by using the Website, you consent to this placement of cookies in accordance with this Privacy and Cookies Policy.

 

Effective Date: 21st May 2021     

Last Reviewed on: 21st May 2021[DATE]

 

CCPA Privacy Notice for California residents

This Privacy Notice for California Residents      applies solely to all 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 Notice. 

Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B personal information") from some of its      requirements.

 

Information We Collect

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) or clinical trial 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 its 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.

YES

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.

YES     

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. For example, from forms you complete when you give feedback to our lessons.     
  • Indirectly from you. For example, when your employer provides your information to us       or observing your actions on our Website.

 

Use of Personal Information

We may use or 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 when you           ask a question about our products or services, we will use that personal information to respond to your inquiry.      
  • To provide, support, personalize, and develop our Website, products, and services.
  • To create, maintain, customize, and secure your account with us.
  • 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 Website experience and to deliver our Website product      to you.               .
  • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Website, 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 Website 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.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. 

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose: 

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category D: Commercial information.

We may disclose your personal information for a business purpose to service providers. 

Sales of Personal Information 

In the preceding twelve (12) months, Company had not sold personal information.

 

Your Rights and Choices 

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.

 

Disclosure of Personal Information We Collect About You

You have the right to know:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purpose for collecting or selling personal information;
  • The categories of third parties with whom we share personal information, if any; and
  • The specific pieces of personal information we have collected about you.
  • Please note that we are not required to:
  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
  • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
  • Provide the personal information to you more than twice in a 12-month period.

Personal Information Sold or Used for a Business Purpose

We do not sell any personal information to third parties. In connection with any personal information we may disclose to a third party for a business purpose, you have the right to know:

The categories of personal information about you that we shared and the categories of third parties to whom the personal information was shared; and

The categories of personal information that we disclosed about you for a business purpose.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the disclosure of your personal information. If you exercise your right to opt-out of the disclosure of your personal information, we will refrain from sharing your personal information, unless you subsequently provide express authorization for the sharing of your personal information. To opt-out of the disclosure of your personal information, see Exercising Access, Data Portability, and Deletion Rights [LINK].

Note that we do not provide these access and data portability rights for B2B personal information.     

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

  • Delete your personal information from our records; and
  • Direct any service providers to delete your personal information from their records.
  • Please note that we may not delete your personal information if it is necessary to:
  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with an existing legal obligation; or
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Note that we do not provide these deletion rights for B2B personal information.     

Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

  • Deny goods or services to you;
  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Provide a different level or quality of goods or services to you; or
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

 

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at support@circusstreet.com. 

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request 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:
  • 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. 

Making a verifiable consumer request does not require you to create an account with us. 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 a verifiable consumer request to verify the requestor's identity or authority to make the request.

     

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 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 the verifiable consumer request's receipt. 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 usable      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 

We do not sell your personal information.



Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@circusstreet.com .

 

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

 

Contact Information

If you have any questions or comments about this notice, the ways in which Circus Street London Limited collects and uses your information described here and in the Privacy and Cookies Policy [LINK], your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to email us at:

Email: privacy@circusstreet.com

                                        

 

Version / Modified date: 2.2      / 2021      05      06