Privacy Policy

At Circulaire, we protect your personal privacy and always strive to ensure a high level of data protection. This privacy policy ("Privacy Policy") explains how we collect and use your personal data. It also describes your rights and how you can act on them.

It is important that you understand the Privacy Policy and feel secure with our processing of your personal data. You are always welcome to contact us if you have any questions. For questions regarding our Privacy Policy, you can contact us by emailing to [email protected].

What is personal data and what is processing of personal data?

Personal data is all kinds of information that can be directly or indirectly associated to a physical living person. For example, images and sound recordings by or from individuals that are processed can be personal data even if no names are mentioned. Encrypted data and different types of electronic identifiers (such as IP numbers) are personal data if they can be linked to physical people.

Processing of personal data is everything that occurs in terms of handling personal data. Any action performed with personal data counts as a form of processing, regardless of whether it is automated or not. Examples of common processing are collection, registration, organising, structuring, storing, revising, transfer or deletion.

Who is responsible for the personal data we collect?

Matter Impact, Swedish corporate ID number: 559255-5840, address Becksjudarvägen 35, 13136, Nacka, Sweden ("Circulaire", "we", "our" or "us"), is the data controller in accordance with the SE data protection laws (such as the EU Regulation 2016/679 as incorporated and amended into SE domestic law (the "GDPR")) and the Data Protection Act 2018. If you have any questions regarding the processing of your personal data, please contact our data protection team by writing to [email protected].

What personal data do we collect about you as a website user and for what purpose (why)?

Purpose:

To process service issues.

Processing performed:

Communication and answering any questions via phone or via digital channels, including social media. Identification. Investigating any complaints and support cases (including technical support).

Categories of personal data:

Name. Contact details (e.g. address, e-mail or phone number). Your correspondence. Data about event occurrence, retailer involved, any errors/complaints. Technical data about your equipment. User data for members.

Legal basis:

Legitimate interest (Art 6(1)(f) GDPR). The processing is necessary to meet our legitimate interest in processing service matters.

Storage period:

Until the service case has been completed. Valid personal data for representatives of retailers - so the data will be saved as long as the company is a customer of Circulaire.

Purpose:

To implement and manage participation in competitions and/or events.

Processing performed:

Communication before and after participation in a contest or event (e.g. confirmation of notifications, questions or evaluations). Identification and age check. The choice of winner and award of any prize(s) (e.g. payouts or travel vouchers).

Categories of personal data:

Name. Age. Contact details (e.g. address, e-mail or phone number). Potential personal data submitted in contest submission. Potential personal data provided in evaluations of events.

Legal basis:

Legitimate interest (Art 6(1)(f) GDPR). The processing is necessary to meet our legitimate interest in processing your participation in competitions and/or events.

Storage period:

For the duration of the contest/event (including any evaluation).

Purpose:

To evaluate, develop and improve our services, products and systems for customers and users.

Processing performed:

Adaptation of services to be more user-friendly (e.g. change the user interface to simplify the flow of information or to highlight features commonly used by customers in our digital channels). Analyses of data in order to improve features and tools. Analyses of data to develop, broaden and change product categories and product data to make the service more relevant to users and customers. Analyses of data in order to develop and improve our resource efficiency from an environmental and sustainability perspective (e.g. by informing about efficient resource utilisation per category, environmentally-friendly products and more efficient deliveries). Analyses of data in order to prioritise and plan the choice of retailers on the site. Analyses of data to enable our users and customers to influence the appearance and contents of our services. Analyses of data to improve IT systems and to enhance security for Circulaire, its users and customers. Based on the data we collect (e.g. clicks to retailers, age and gender) you can be sorted into a user group, upon which analyses are then performed on an aggregate level using non-identifiable or pseudonymised data without any link to you as an individual. The insights from the analyses form the basis for which products, product categories, and the design of tools for which users and customers have access to.

Categories of personal data:

Age. Gender. City. Correspondence and feedback regarding our services and products. Purchase and user-generated data (e.g. clicks and visit history). Technical data pertaining to devices used and their settings (e.g. language setting, IP address, browser settings, time zone, operating system, screen resolution and platform). Information about how you interacted with us, in other words how you used the service, login method, where and how long different pages were visited, response times, download errors, how you access and leave the service, etc.

Legal basis:

Legitimate interest (Art 6(1)(f) GDPR). The processing is necessary to meet Circulaires, the users and our customer legitimate interest in evaluating, developing and improving our services and systems.

Storage period:

From the time of collection and for a period of 36 months thereafter.

Purpose:

To prevent abuse of a service or to prevent, avoid and investigate fraud or other crimes against Circulaire or other group companies which consists of companies related by common ownership or control, such as companies with Circulaire.

Processing performed:

Prevention and investigation of possible fraud or other crimes (e.g. clicks to retailer manipulation). Prevention of spam, phishing, unauthorised retrieval of price or product data from our services, harassment, unauthorised login to user accounts, or other actions prohibited by law or by our membership, service or customer agreement. Protecting and improving our IT environment against attacks and intrusions.

Categories of personal data:

Purchase and user-generated data (e.g., clicks and visit history). Technical data pertaining to devices used and their settings (e.g. language setting, IP address, browser settings, time zone, operating system, screen resolution and platform). Data about how our digital services are used.

Legal basis:

Compliance with legal obligation (Art 6(1)(c) GDPR). If no legal obligation exists, processing is necessary to meet our legitimate interest (Art 6(1)(f) GDPR in preventing abuse of a service or preventing, avoiding and investigating fraud or other crimes against Circulaire/Matter Impact AB.

Storage period:

From the time of collection and for a period of 36 months thereafter.


Last updated: 21-03-2024