This policy 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 sensitive information and how we will deal with it. For the purposes of the Data Protection Act and the GDPR, sensitive information includes what is defined as your ‘personal data’.
Who We Are
More formally, we are Six Circles Limited. We are a company registered in England and Wales with Company number 10727106 and our registered office is at A6 Kingfisher House, Kingfisher Way, Team Valley Trading Estate, United Kingdom, NE11 0JQ.
For the purposes of the Data Protection Act 1998 (the ‘DPA’) and in-line with the forthcoming European Union General Data Protection Regulations (the ‘GDPR’) Six Circles Limited is the Data Controller.
Our Data Protection Officer (‘DPO’) is David Cook and you can contact them via email at firstname.lastname@example.org
What we do with your information
We will use your information to allow you to sign up and register for the services that we provide. We provide a web platform that allows you to create your own branded and bespoke networking and social community.
We compile statistics about user trends on our Website, which are used by third party organisations to understand how users interact with businesses, brands, and one another online and to advise about these things. These statistics are drawn from a dataset which does not contain any information from which you can be identified.
Information we collect from you
We will collect and process the following information about you:
Information you give us – this is information about you that you give us by filling in forms on our site or by corresponding with us by phone, email or otherwise. It includes any information that is inputted on your registration form and any user information that is upload through your web platform. We will only request from you the minimum data required for you to use our service. The information we require from you to register for our services will include your full name, your address, your email, your telephone and your company’s name and registration number (when applicable).
Information we collect about you – Whenever you visit our site we will automatically collect the following information:
technical information – including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
information about your visit – this includes the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), pages you have visited, page response times, download errors, length of visits to certain page and page interaction information (such as scrolling, clicks, and mouse-overs).
Information we receive from other sources – This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
Where we hold and what we do with your information
The information and content held on our Website is deployed geographically to maximise user experience. All information that could identify individuals within the European Union is stored exclusively within the European Union. We will never share your user information with third parties for promotional purposes.
We hold our data with Linode and Amazon Web Servers (European Server Farm) who are contracted by use for the provision of technical services. We remain responsible at all times for the security of your information, but if you want to know more about how we interact with Linode and Amazon Web Servers you can view their Privacy Policies, amongst their other policies https://www.linode.com/privacy and https://aws.amazon.com/privacy/
What we do to ensure the security of your personal information
We take the security of your personal data very seriously. Our approach to information security is constantly evolving and continually reviewed.
We have adopted industry best practices from both technological and business process perspectives in order to make the security of your data a key part of the way we do business.
We have policies and practices in place that not only ensure our compliance under the DPA but also the GDPR, including training and adequate procedures put in place for any staff that handle or have access to sensitive information.
Your rights regarding your personal information
We may contact you via email with updates about the services that we offer or any changes that we have made to our Website.
You can opt in or out at any time by clicking the ‘Unsubscribe’ link in our emails.
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which our service may be advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we are not responsible or liable for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
Access to Information
You have the right to find out about what information we hold about you. Your can exercise that right by contacting us and we will send you any request for information in a suitable electronic form within 20 working days. Please contact email@example.com
You also have the right ‘to be forgotten’ and to have your personal data permanently deleted from our systems. Again, if you would like to exercise this right then please contact us at firstname.lastname@example.org
There will be no charge made for electronic access to your information or for your right to be forgotten from our systems.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
As part of our overall approach to privacy and transparency, this section describes what cookies are in the context of our web and mobile interfaces, and what their use means to you. At the end, we’ve included some links to help you research cookies and their impact, and how you can use your web browser to control the way it manages cookies.
We use the following types of cookies:
- Strictly necessary cookies –these are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-payment system.
- Analytical/performance cookies – these allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies –these are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies –these cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose but this will be contain no information capable of identifying you personally.
You can find more information about the individual cookies we use and the purposes for which we use below:
We use Google Analytics to understand general trends about our content and traffic sources; for example, where users come from, which pages are most popular, which sites provide most traffic, how our marketing efforts impact the amount of visits we receive.
Google’s statement about privacy can be found here.
More information about cookies
Links which provide more information about cookies:
Link explaining how to switch off cookies in various browsers:
Contact the Information Commissioner if there is a problem
If you consider we have not addressed your problem, you can contact the UK Information Commissioner’s Office for assistance. Further information can be found via https://ico.org.uk/for-the-public/raising-concerns/.