Published: November 2019
Effective: December 2019
Complying with all applicable copyright laws is the responsibility of the user. Without limiting the rights under copyright, no part of this document may be reproduced, stored in or introduced into a retrieval system, or transmitted in any form or by any means (electronic, mechanical, photocopying, recording, or otherwise), or for any purpose, without the express written permission of Circuit ID™.
Circuit ID™ may have patents, patent applications, trademarks, copyrights, or other intellectual property rights covering subject matter in this document. Except as expressly provided in any written license agreement from Circuit ID™, the furnishing of this document does not give the customer any license to these patents, trademarks, copyrights, or other intellectual property.
©2019 Circuit ID™. All rights reserved.
How does Circuit ID™ define “Information” under this Policy?
• information collected from you through access to or use of Circuit ID™’s websites; and
• if you are a current customer, private label reseller or affiliate of Circuit ID™,
o your Data, if and as such term is defined in your Master Service Agreement,
Private Label Reseller Agreement, Affiliate Agreement or other agreement with Circuit ID™ (the “Agreement”);
o if your Agreement does not define the term “Data”, any information collected through your and your users’ access to or use of our platform or services (the “Services”), including as the term “Services” is defined in the Agreement.
What is the Scope of this Policy?
What are Circuit ID™’s Guidelines Regarding Children?
Circuit ID™ requires that all account holders be 18 years of age or older. In addition, our websites and Services are not designed for or directed to children under the age of 13, and Circuit ID™ will not knowingly collect or maintain Information about any person under the age of 13. If you believe Circuit ID™ has collected any Information from or about any person under 13, please contact us at firstname.lastname@example.org.
What about My Use of Circuit ID™ Forums?
Circuit ID™ may make chat rooms, forums, message boards, news groups and similar media, including social media, available to you. Please remember that any Information that is disclosed in these areas may become public and you should exercise caution when deciding to disclose any Information in any of these areas.
What Kind of Information Does Circuit ID™ Collect?
Circuit ID™ may collect the following Information:
• personal and non-personal information that you voluntarily provide when using our websites or Services, including contact information (e.g., email address, name, telephone number, home or work address, and ZIP code) and billing information (e.g., credit card number, bank account number and billing address);
• standard information sent by your browser during visits to our websites or your use of our Services without identifying you as an individual, including IP address, your computer’s operating system, language preference and browser type; and
When you visit one of our websites, advertising companies such as Google may place a cookie on your computer and may collect certain information about your use of our websites. These companies may use this information, as well as information they collect from your use of other websites, to display advertisements on the Internet about products and services they believe you may be interested in. You can learn more about this practice and can learn about your choices with respect to the use of this information about you for customizing advertisements, at www.aboutads.info/choices.
How Does Circuit ID™ Use, Store and Retain Information?
Circuit ID™ may use, store and retain Information in the following ways:
• to provide you with information regarding the status of your account, to determine your tax status, and to bill you for our Services;
• to provide you with information and Services that you request from Circuit ID™ and to carry out Circuit ID™'s obligations arising from any agreement entered into between you and Circuit ID™, including the Agreement;
• to administer, test, analyze and improve Circuit ID™’s Services and to facilitate marketing, including providing you with information about available Services and related products and services;
• to gather broad demographic and statistical information, and other non-personally identifiable information, which Circuit ID™ may use for purposes such as understanding broad demographic trends and statistical information;
• to notify you about changes to the Services, welcome letters, billing reminders, technical notifications, security announcements; and
• for other purposes to which you may provide your consent.
If you are an existing customer, unless you ask Circuit ID™ to provide you with additional marketing information we will only contact you by electronic means (e-mail or by posting to your account with Circuit ID™). Circuit ID™ will not review, share, distribute, print, or reference any of your Information except as provided in the Terms of Service, or as may be permitted in this Policy or required by law.
How Does Circuit ID™ Access, Release and Disseminate Information?
Except as described in this statement, we will not disclose your personal information outside of Circuit ID™ without your prior consent.
Circuit ID™ will release your Information as is reasonably necessary for the provision of Services.
This includes, but is not limited to:
• provision of billing information to organizations such as VeriSign, LinkPoint and similar organizations;
• provision of aggregated or otherwise non-personal Information to third parties, such as our provision of non-personal usage information to our service and license providers for the purpose of licensing compliance, licensing usage calculation, billing and support purposes;
• provision of Data to vendors and contractors providing services in support of Circuit ID™'s provision of Services to you. Circuit ID™ will only release data that is needed to deliver the service for which the third-party vendor has been contracted. These vendors are required to maintain strict security and confidentiality of the information and are prohibited from using it for any other purposes other than in accordance with Circuit ID™’s instructions and policies.
In addition, Circuit ID™ may access and release your Information without notice or consent under the following circumstances:
• In response to subpoenas, warrants, government inquiries, court orders, or legal process, or to establish or exercise our rights to defend against legal claims, as determined by Circuit ID™ in each case;
• If we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, safety of person or property, violation of our policies, or as otherwise required by law (this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction); and
• If Circuit ID™, any of its websites or Services or a related asset or line of business is acquired by, transferred to, or merged with another company.
What if I am Located within the European Economic Area or Switzerland?
If you are located within the European Economic Area (“EEA”) or Switzerland, your Information may be transferred outside the EEA or Switzerland for processing. These countries may not have similar data protection laws to the EEA or Switzerland. If Circuit ID™ transfers your Information outside of the EEA or Switzerland in this way, it will take steps to ensure that your privacy rights continue to be protected. In addition, if you access our websites or Services while you are outside of the EEA or Switzerland, your Information may be transferred outside of the EEA or Switzerland in order to provide you with such access.
Circuit ID™ adheres to the European and Swiss Safe Harbor principles as set forth by the United States Department of Commerce regarding the collection, use, and retention of personally identifiable information collected from citizens of the European Union or Switzerland. Circuit ID™ has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. For more information and to view Circuit ID™’s certification, please visit http://www.export.gov/safeharbor. By submitting your personal information to us, you agree to this transfer, storing or processing.
Is My Information Secure?
Although Circuit ID™ uses reasonable efforts to protect your Information, transmission via the
Internet is not completely secure. Therefore, Circuit ID™ cannot guarantee the security of your
Information transmitted using our websites or Services and any transmission is at your own risk.
How Do I Terminate or Opt-Out?
You have the right to request that Circuit ID™ not contact you or use your Information for purposes which are not reasonably necessary for the administration of our websites and/or the provision of Services. If you wish to exercise this opt-out right or to terminate your account, please contact Circuit ID, Inc. You may also send an e-mail to email@example.com or access any available termination or opt-out features in the administrative control panel for your Account.
Please note that you cannot unsubscribe from certain correspondence from us regarding our provision of Services to you, including messages relating to your account. In addition, certain Information may be required in order to use our websites or Services; as such, the only practicable method to opt out of providing Information in connection with the use of those websites or Services would be to refrain from subscribing to or using those websites or Services.
You may also revise your contact and financial information or terminate your account through the administrative control panel for your Account.
Circuit ID, Inc.
Attn: Legal Department
1055 West 7th Street
Penthouse 33rd Floor
Los Angeles, California 90017
Circuit ID™ has further committed to refer unresolved privacy complaints under the US-EU and
US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Circuit ID™, please visit the BBB EU SAFE HARBOR web site at http://www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.”