Encircled Inc. (“Encircled”) is committed to respecting the privacy of individuals and recognizes the rights of those with whom we do business, and our employees to appropriate protection, fair handling and access to the personal information you agree to disclose.
PERSONAL INFORMATION WE COLLECT
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”
We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visithttp://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers, paypal information, apple or google pay data, email address, and phone numbers). We refer to this information as “Order Information.”
Third party service providers may at some point handle personal information collected by us in the course of their relationship with, and service to us. We actively utilize double-opt ins for our mailing list to ensure we have obtained appropriate consent in accordance with Canada’s anti-spam Law (CASL). We never spam or add people to our mailing list without express consent.
Encircled makes all reasonable efforts to fully inform individuals about the planned use and disclosure of their personal information. Encircled limits the collection and use of personal information to that required for valid business purposes and to comply with PIPEDA legislation.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:
Communicate with you and send you shipping and order updates;
Screen our orders for potential risk or fraud; and
When in line with the explicit preferences you have shared with us, provide you with information or advertising relating to our products or services.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns). We also from time to time, use this information to retarget you with relevant products and offers through the platforms listed below under “BEHAVIOURAL ADVERTISING”. You may opt out of this advertising by visiting the links below under “BEHAVIOURAL ADVERTISING”.
You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.
SHARING YOUR PERSONAL INFORMATION
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
Encircled respects individuals’ rights to access the personal information collected by the organization. Access will be provided according to established procedures. In addition to the care that Encircled takes directly, we also work with our third party service providers to limit use of personal information to what is authorized by our organization. Each third party partner has agreed to meet our standards of privacy, confidentiality and security.
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by visiting:
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
DO NOT TRACK
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.
Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.
Encircled will securely store personal information using hard copy and/or electronic means in such a way to prevent unauthorized collection, access, use, disclosure or disposal of the personal information.
Any banking or credit card information transmitted to us is encrypted, and not available to be used post-transaction except for refunds, and adjustments to your order similar to this. We are not consequently able to charge your credit card after purchase as the data is encrypted. Through the various systems in which your data is stored, Encircled aims to provide secure storage through using two-factor authentication (where applicable), secure and trackable login history.
When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.Encircled has a minimum data retention policy of one year, and a maximum policy for as long as your account is active with Encircled or that the data is reasonable to keep for purposes of servicing you as a customer. We will keep personal information only as long as it is necessary to satisfy our business purposes and will dispose of information that does not have a specific purpose or no longer fulfills its intended purpose. This period may be related to legislation other than PIPEDA. Upon request, Encircled will delete any data about you within 30 days of request, including data stored on third party servers and software. Encircled will retain and use your information to the extent required by law to comply with tax/revenue reporting, and resolve disputes.
DATA BREACH NOTIFICATION
Encircled will notify the Privacy Commissioner of any personal data breaches that are likely to present a significant risk to your data without undue delay, and within 72 hours, if feasible after becoming aware of the breach. If the breach is high risk, Encircled will communicate it to the affected data subjects without undue delay.
DATA PRIVACY OFFICER
The appointed Data Privacy Officer/Privacy Officer at Encircled is Kristi Soomer, CEO.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by email at firstname.lastname@example.org or by mail using the details provided below:
1485 Dupont St, Unit 201, Toronto, ON, M6P3S2, Canada
Attn: Data Privacy Officer/Privacy Officer