This policy describes the types of information BlueCircle Advisors, LLC(the “Company,” “we,” “our,” or “us”) may collect from you or that you may provide when you visit the website https://www.bluecircleadvisors.com/ (“Website”)and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy does not apply to information collected by us offline or through any other means, including on any other website operated by the Company or a third party or through any application or content (including advertising) that may link to or be accessible from the Website.
II. INFORMATION WE COLLECT ABOUT YOUAND HOW WE COLLECT IT
We collect several types of information from and about users of our Website, which may include information defined as personal data under the General Data Protection Regulation (“personal data”). For example, we may collect information such as your name, e-mail address, telephone number, country, job function, company/organization name, annual revenue, industry, current customer status, file uploads by you, product interests, and information related to inquiries and requests. We may also collect bank account information and bank account and routing information. We may also collect information about your internet connection and the equipment you use to access our Website. As you navigate through the Website, we may automatically collect information such as your usage details, IP addresses, and information collected through cookies.
1. Information You Give to Us
The information we collect on or through our Website may include:
- Information that you provide by filling in forms on our Website. This includes information provided when you sign up for newsletters, blog subscriptions and other types of information material; when we process and respond to your inquiries related to products and customer service; and when you provide feedback on our Website. The personal data that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal data.
- Records and copies of your correspondence with us (including email addresses).
2. Information We Collect About You
As with many other websites, as you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Website, including resources (e.g. videos and PDFs) that you access, download and use on our Website, traffic data, location data, logs, language, date and time of access, frequency, and other communication data.
- Information about your computer and internet connection, including your IP address, operating system, host domain, and browser type.
- Details of referring websites (URL).
The information we collect automatically is statistical data that helps us improve our Website and deliver a better and more personalized service, including by enabling us to
- Determine web site traffic patterns.
- Count web visits.
- Determine traffic sources so we can measure and improve the performance of our site.
- Help us to know which pages and content are the most and least popular.
- Observe site search patterns to provide more intuitive navigation cues.
- Determine user frequency.
3. Google Analytics
Google will use this information on behalf of us as the operator of this Website for the purpose of evaluating your use of the Website, compiling reports on Website activity and providing other services relating to Website activity and internet usage to us.
In case IP anonymization is activated on this Website, your IP address will be truncated within the area of Member States of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases the whole IP address will be first transferred to a Google server in the United States and truncated there. The IP anonymization is active on this Website.
You can also opt-out from being tracked by Google Analytics with effect for the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser: (click here: https://tools.google.com/dlpage/gaoptout?hl=de).
4. Social Media Plug-ins
On our Website we use website elements from the social networks Facebook, Twitter, LinkedIn and YouTube. Suppliers of the plug-ins are the companies Facebook Inc., Twitter Inc., LinkedIn Corporation and YouTube LLC (“Providers”).Web page elements are e.g. buttons (so-called “social plug-ins”) or integrated content from the providers.
The operator of Facebook is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland (“Facebook”). For an overview of Facebook web page elements and their look go to https://developers.facebook.com/docs/plugins.
The operator of Twitter is Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA (“Twitter”). For an overview of Twitter webpage elements and their look go to: https://dev.twitter.com/web/overview.
The operator of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Website elements of LinkedIn are recognizable by the LinkedIn logo.
The operator of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA94066, USA, a company belonging to Google Inc., Amphitheatre Parkway, Mountain View, CA 94043, USA. Website elements of YouTube are recognizable by the YouTube logo.
Your browser establishes a direct connection to the server of the respective Provider when you visit a page from our Website that contains such a website element. The content of the website element is transmitted by the respective Provider directly to your browser and integrated into the Website. By integrating the website elements, the Providers gain knowledge that your browser has accessed the corresponding page of our Website, and even if you do not have a profile with the respective Provider or are not logged in at the time. This information (including your IP address) is transmitted by your browser directly to a server of the respective Provider in the USA and stored there.
If you are logged into one of the services, the respective Provider can directly assign the visit to our Website to your profile with this Provider.
You would need to log out of each Provider’s services if you want to prevent Providers from directly associating the data collected through our Website with your profile in that service. Finally, there is the possibility of completely preventing the loading of the website elements with browser add-ons.
5. Web Beacons
We currently contract with several online partners to help manage and optimize our Internet business and communications. We use the services of a marketing company to help us measure the effectiveness of our advertising and how visitors use our Website. To do this, we use Web beacons and cookies provided by the marketing company. A “web beacon,” is also called a web bug or a pixel tag or a clear GIF. Used in combination with cookies, a web beacon is an often-transparent graphic image, usually no larger than 1pixel x 1 pixel, that is placed on a website or in an e-mail that is used to monitor the behavior of the user visiting the website or sending the e-mail. By supplementing our records, this information helps us learn things about, for example, what pages are most attractive to our visitors and which of our services most interest our customers. Although the marketing company logs the information coming from our Website on our behalf, we control how that data may and may not be used. If you do not wish to help us learn how to improve our site, products and offers, you can Opt-out of this Website analysis tool by emailing us at firstname.lastname@example.org.
6. Cookies Used on This Website
III. HOW WE USE YOUR INFORMATION
Below please find information about how we process information collected about you (including personal data) as well as the corresponding legal basis. We may process your information where the processing is:
IV. DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. Subject to applicable law and regulations, we may disclose personal data that we collector you provide as described in this policy:
If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us at email@example.com.
V. CROSS-BORDER TRANSFERS OF PERSONALDATA
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”), including the USA. It may also be processed by staff operating outside the EEA who work for us or other entities acting as data processors processing data on behalf of us. This includes staff engaged in, among other things, the fulfillment of your requestor order and the provision of support services. For intra-group data transfers, the Company has implemented international data transfer agreements on the basis of EU Standard Contractual Clauses in order to provide appropriate and suitable safeguards for personal data being transferred to countries outside the EEA where an adequate level of protection is not already guaranteed. For transfers to third party processors the Company has implemented different safeguards such as EU Standard Contractual Clauses or certification under the EU-US Privacy Shield, as the case may be. To obtain a copy of the relevant safeguards, please contact us at firstname.lastname@example.org.
VI. DATA RETENTION
Unless otherwise required by law, the Company will erase personal data when it is no longer necessary in relation to the purposes for which it was collected or otherwise processed; when you withdraw your consent (where lawfulness of processing was based on your consent) and there is no other legal ground for the processing; when you object to the processing and there are no overriding legitimate grounds for the processing; when your personal data has been unlawfully processed; and when it is necessary to comply with legal obligations.
VII. CHOICES ABOUT HOW WE USE ANDDISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with the following control over your information:
VIII. YOUR RIGHTS WITH REGARD TO YOURPERSONAL DATA
We remind you that you may at any time exercise certain rights you mayhave under applicable law and regulation, including the following rights:
Any requests related to the above rights may be made by sending an email to email@example.com.
IX. DATA SECURITY
We have implemented measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure. Personal data provided to us in accordance with this policy will be encrypted in transit and at rest.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website. Any transmission of your personal data is at your own risk.
X. THIRD-PARTY WEBSITES
Our Website may contain links or references to other websites outside of our control. Please be aware that this policy does not apply to these websites. The Company encourages you to read the privacy statements and terms and conditions of linked or referenced websites you enter. These third-party websites may send their own cookies and other tracking devices to you, log your IP address, and otherwise collect data or solicit personal data.
THE COMPANYDOES NOT CONTROL AND IS NOT RESPONSIBLE FOR WHAT THIRD PARTIES DO IN CONNECTIONWITH THEIR WEBSITES, OR HOW THEY HANDLE YOUR PERSONAL DATA. PLEASE EXERCISECAUTION AND CONSULT THE PRIVACY POLICIES POSTED ON EACH THIRD-PARTY WEBSITE FORFURTHER INFORMATION.
XI. CHILDREN UNDER THE AGE OF 16
Our Website is not intended for children under 16 years of age, and the Company does not knowingly collect or use any personal data from children under the age of 16. No one under the age of 16 may provide any information to or on the Website. If we learn we have collected or received personal data from a child under the age of 16, we will delete that information. If you believe we might have any information from or about a child under the age of 16, please contact us at
We reserve the right to change this policy at any time. Any changes we make will be posted on this page. If we make material changes to how we treat your personal data, we will notify you through a notice on the Website home page. The date this policy was last revised is identified at the top of the page. You are responsible periodically monitoring and reviewing any updates to this policy. Your continued use of our Website after such amendments will be deemed your acknowledgement of these changes to this policy.
XIII. DATA CONTROLLER & CONTACT INFORMATION
The data controller is:
BlueCircle Advisors, LLC, PO Box 81,Uxbridge, MA 01569, USA
Should you have any questions or concerns about this policy and ourprivacy practices, you may also contact us at