Privacy Policy

Welcome to the website of Circle Unlimited GmbH. Circle Unlimited is highly committed to protecting your personal data.

The information below provides details on the collection of personal data while you are using our services. Personal data includes details related to you, e.g. your name, your address, your e-mail addresses, your user behavior. We have taken elaborate technical and operational safety precautions to protect your data against accidental or deliberate manipulation, loss, destruction or the access of unauthorized parties. Our safety procedures are regularly reviewed and updated in line with the latest technological developments.

1. Party responsible for data protection

The company responsible according to Art. 4, para. 7 of the EU General Data Protection Regulation (GDPR) is Circle Unlimited GmbH, Südportal 5, 22848 Norderstedt (see our imprint).

Circle Unlimited GmbH is jointly responsible for some data processing with valantic GmbH, Ainmillerstraße 22, 80801 Munich and its subsidiaries in accordance with Art. 26 GDPR. The joint data processing operations with the valantic group are marked accordingly in this data protection declaration.

2. Contacting the data protection officer

You can contact our data protection officer via datenschutz(at)cuag.de or via our postal address with the addition of “data protection officer”.

3. Your rights

You have the following rights towards us regarding your personal data:

3.1 General rights

You are entitled to access, rectify, delete, restrict the processing of your personal data, object to the processing of your personal data and are entitled to the right to data portability. If the processing is based on your consent, you can revoke your consent with effect for the future.

3.2 Rights in data processing due to justified interest

According to Art. 21, para. 1 GDPR and on the grounds relating to your particular situation you are entitled to the right to object to the processing of personal data that occurs due to Art. 6, para. 1e GDPR (Task in Public Interest) or due to Art. 6, para. 1f GDPR (Data Processing for the Purposes of the Legitimate Interests) at any time; this also applies to a profiling based on these regulations. In the case of your objection we will no longer process your personal data, except if we can show that there are compelling legitimate grounds for the processing that outweigh your interests, rights and liberties, or the processing enables the enforcement, exercise or Defence of legal claims.

Pursuant to Art. 21 (1) GDPR, you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 (1) (e) GDPR (data processing in the public interest) or on the basis of Art. 6 (1) (f) GDPR (data processing for the purposes of safeguarding a legitimate interest); this also applies to profiling based on this provision.

3.3 Rights in direct advertising

Given that we process your personal data for direct advertising, according to Art. 21, para. 2 GDPR you have the right to object to the processing of your personal data for the purposes of advertising. This also applies to profiling if it is relatable to the direct advertising activity.

In the case of your objection to the processing for the purpose of direct advertising we will no longer process your personal data for these purposes.

3.4 Right to report a complaint with a supervisory authority

In addition, you have the right to report a complaint with the relevant supervisory authority regarding our processing of your personal data

4. Collection of personal data when visiting our website

When using our website for the purpose of information only, i.e. if you do not register user or otherwise transmit data to us, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data which is technically required in order to display the website to you and to ensure stability and security. The legal basis for this is Art. 6, para. 1f GDPR.

IP address, date and time of request, page accessed, protocol, access status/http status code, website from which the request came (referrer), user agent and domain accessed.

5. Contact via e-mail or contact form and registration for events

If you would like to register for one of our events or when contacting us via e-mail or via a contact form, the personal data you provide us with via these means will be used by us exclusively for the purpose you specify when making your data available to us. The communication of your personal data takes place on a voluntary basis and in such cases is initiated by you. By providing data that refers to communication channels (e-mail address, telephone number) we will use these communication channels for contacting you in accordance with your request. The purpose of processing your data is to handle and respond to your request. This is our legitimate interest for processing your data is based on Art. 6 (1)(f) GDPR. If we receive your express consent to process data for a particular case, the processing is based on Art, 6 (1)(a) GDPR. In this case, you will have the right to withdraw your consent given to us or our data protection officer at any time.

We will delete the data we received via your communication with us when it is no longer needed for fulfilling the request, when your request has been fully processed and no further communication is necessary or desired by you. Regarding the deletion of your data related to your request you can contact our data protection officer at any time. However, we may then not be able to fully process your request.

6. Free participation in webcasts and events, download of whitepapers

On our website or the valantic.com website you can download free whitepapers and participate in free webcasts and events. Your e-mail address will be stored by us and used to contact you by e-mail for promotional purposes. The personal data provided represents the contractual consideration for the provision of the documents and participation in the events or webcasts.

The legal basis for the data processing is therefore Art. 6 para. 1b GDPR. You can revoke the use of your data for promotional purposes any time with effect for the future.

For advertising by e-mail, we use the so-called double-opt-in procedure. This means that after your registration, we will send you an e-mail to the e-mail address you provided, in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration within 24 hours, your information will be blocked and automatically deleted after one month.

Furthermore, we store your IP addresses, times of registration, and confirmation. The purpose of this procedure is to be able to prove your registration and, if necessary, to clarify a possible misuse of your personal data.

7. Data processing of business partners and interested parties

In order to provide our services and to initiate and process the existing contractual relation between you and us or when you contact us, we store and process your personal data (Art. 6 para. 1 b GDPR). In addition, we also process your personal data, among other things, to fulfill legal obligations (for example, to comply with retention obligations under tax law), to protect a legitimate interest or based on your consent.

If we send you requested information about our products, webcasts or events this is done on the basis of your consent (Art. 6 para. 1 a GDPR). In addition, we store data relating to communication with contacts, business customers or interested parties on the basis of our legitimate interest as well as for direct advertising for similar products within the scope of our business relations (Art. 6. Para. 1 GDPR)

Depending on the legal basis and the contractual relation with us, these are the following categories of personal data:

  • First name, last name
  • Company
  • Business address
  • Business communication data (telephone, e-mail address)

Circle Unlimited GmbH is jointly responsible with the valantic group for the storage of data in the groupwide CRM system of valantic. We are responsible for the fulfilment of your rights as a data subject. Nevertheless, you can also contact any person in charge of the valantic group regarding the exercise of your rights.

The data is exchanged with the valantic group on the basis of our legitimate interest in exploiting synergy effects, also in your interest, in organizing intra-group cooperation on projects and in enabling the central administration of customer data by valantic GmBH. We store your personal data as long as it is necessary to fulfil our legal and contractual obligations. If no contract has been concluded and is not expected to be concluded, we will delete your data within a reasonable period of time.

To fulfill this purpose, your data will be shared with the provider of our CRM system, which has been obligated to maintain an appropriate level of data protection under an order processing agreement. We store your personal data as long as it is required to fulfill our legal and contractual obligations. According to tax and commercial law retention obligations, for example, a retention period of up to ten years is provided for.

8. Newsletter

8.1 General information

With your consent in line with Art. 6, para. 1a GDPR you can subscribe to our newsletter in which we inform you about our latest offers and services.

For the subscription of the newsletter we use the so-called double opt-in method. This means that after your subscription we will send an e-mail to the specified e-mail address in which we ask you to confirm the subscription of the newsletter. If you do not confirm your subscription within 24 hours, your information will be locked and deleted automatically after one month. In addition, we will save your respective used IP addresses and times of subscription and confirmation. Purpose of the procedure is to provide proof of your subscription and to resolve potential misuse of your data.

The sole compulsory information required for the transmission of the newsletter is your e-mail address. The specification of company, form of address, first name and last name is voluntary and will be used to address you personally. After your confirmation we will save your e-mail address for the purpose of sending you newsletters. Legal basis is Art. 6, para. 1a GDPR.

8.2 Newsletter Tracking

We inform you that we analyse your user behavior on dispatch of the newsletter. For the purposes of this analysis the dispatched e-mails contain so-called web beacons or tracking pixels that are saved on our website. For the analyses we will link the mentioned data and the web beacons with your e-mail address and a unique ID. Links received via the newsletter also contain this ID.

Data will only be collected in a pseudonymous way, i.e. the IDs will not be connected to other personal data of you to prohibit direct personal reference.

You can object to the tracking at any time by clicking the unsubscribe link separately provided in every e-mail and thus by opting out of receiving our newsletter. The information will be stored for as long as you have subscribed to the newsletter. After you have unsubscribed, we save the data only for statistical purposes and only in an anonymized form. Moreover, such tracking is not possible if you prohibit the display of images in your e-mail application by default. In this case the newsletter will not be displayed to you in full and you may not use all functions. If you display images manually, the stated tracking will be carried out.

9. Job applications

You can apply to our company by electronic means, especially via e-mail or web forms. As part of your application, we regularly process the following data from you:

  • Applicant master data
  • Contact information
  • Qualification data
  • (Work) References and certificates

The information that you provide will be only used for processing your application. Circle Unlimited is jointly responsible for data processing within the scope of applicant management according to a contract pursuant to Art. 26 GDPR with valantic GmbH. The data is exchanged with valantic GmbH on the basis of a legitimate interest (Art. 6 para. 1f GDPR) by organizing the recruitment centrally. Your applicant data will not be passed on to other group companies for use without your consent and a strict role and authorization concept will be adhered to.

Other service providers, e. g. IT service providers, are used for the use of the applicant management system and are similarly obligated to comply with data protection regulations and processing in accordance with our instructions.

As a data subject, you have the possibility to contact us or valantic GmbH as the data controller at any time, in order to exercise your rights under Art. 12-22 GDPR.

Please be aware that unencrypted e-mails will not be transmitted in an access-protected manner.

If you have applied for a particular position and it has been filled in the meantime or if we consider you equally or more suitable for a different position, we would forward your application within the company. Please let us know if you do not agree to forwarding your application.

After the application process your personal data will be deleted immediately or after a maximum of 6 months, given that you have not given us your express permission for processing your data for a longer period of time or if a contract was concluded. Legal basis are Art. 6, para. 1a, b, and f GDPR as well as § 26 BDSG (Bundesdatenschutzgesetz, German privacy law).

10. Use of social plug-ins

This website uses social plug-ins by the following providers:

  • Facebook (operator: Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA)
  • Twitter (operator: Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA)
  • Google+ (operator: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA)
  • YouTube (operator: YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA)
  • kununu (operator: kununu GmbH, Neutorgasse 4-8, Top 3.02, 1010 Wien, Austria)
  • XING (operator: XING SE, Dammtorstraße 30, 20354 Hamburg, Germany).

Usually, these plug-ins collect data from you by default and transmit it to the servers of the respective providers. To safeguard the protection of your privacy we have taken technical precautions that ensure that your data can not be collected by the provider of the respective plug-in without your prior consent. When calling up a site that uses plug-ins, they will be inactive at first. Only when clicking the respective symbol the plug-ins will be activated and through this action you consent that your data will be transmitted to the respective provider. Legal basis for the use of the plug-in are Art. 6, para. 1a and f GDPR.

After activation, the plug-ins will collect personal data such as your IP address and send this to the server of the respective provider, where they will be stored. In addition, the active social plug-ins will place a cookie with a unique identification number when calling up the respective website. In this way providers can compile profiles of your user behavior. This also happens if you are not a member of the social network of the respective provider. If you are a member of the social network of the provider and you are logged in to the social network while using this website, your data and information on your visit on this site can be connected to the profile of the social network. We have no influence on the scope of the data collected about you through the respective provider. More information on the scope, nature and purpose of the data processing and on your rights and setting options with regards to the protection of your privacy can be found in the privacy policy of the respective provider of the social network. These can be accessed via the following addresses:

11. Use of cookies

12. Website analytics

For purposes of analyzing and optimizing our websites we use different services, which are outlined in the following. In this way we can analyze, for instance, how many users have visited our site, which information are most sought after or how users find our offer. We collect data among others on the website from which a user comes to another website (so-called referrer), the sub-sites the user accessed or how often and for how long a sub-site was looked at. This helps us in improving our services and making them more user friendly. The data collected therein are not used to identify individual persons. Data will be collected in an anonymized or at least pseudonymized form. The legal basis is Art. 6, para. 1f GDPR.

12.1 Google Analytics

This website uses Google Analytics, a web analysis service of Google Inc, (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). Use includes the operating mode Universal Analytics. This makes it possible to allocate data, sessions and interactions on several devices to one pseudonym user ID and thus to analyze the activities of a user across devices.

Google Analytics uses cookies that enable an analysis of the website. The information about your use of this website collected by the cookie will usually be transmitted to a server in the USA and stored there. In case that 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 USA and truncated there. The IP-address that your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google. Google will use this information on behalf of the operator of this website for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing them other services relating to website activity and internet usage. The legal basis for the use of Google Analytics is Art. 6 para. 1 a GDPR. The data sent by us that is connected to cookies, user IDs or advertising IDs will be deleted automatically after 14 months. The deletion of data whose storage period has ended is executed once a month. More information on the terms of use and data protection can be found at www.google.com/analytics/terms/de.html or at policies.google.com.

13. Advertising

We use cookies for marketing purposes to approach users with interests-based advertising. In addition, we use cookies to restrict the probability of the broadcasting of an advertisement and to measure the effectiveness of our advertising. This information may be shared with third parties such as ad networks. Legal basis for this is Art. 6, para. 1 a or f GDPR. You have the option to revoke your consent in the cookie settings at any time.

14. Data transfer

Your personal data will not be transmitted to third parties, except if we are obligated to do so by law or the transfer of data is necessary for implementing the contract or you have priorly expressly consented to the transfer of your data.

External service providers and partners such as online payment providers or the shipping company charged with the delivery will receive your data only in the scope of processing your order. In these cases the extent of the transferred data is limited to the necessary minimum. Where our service providers might come into contact with your personal data, we will ensure in line with the data processing on behalf according to Art. 28 GDPR that these adhere to the same level of provisions of the data protection. Please also note the respective data protection guidelines of the respective service provider. The respective service provider is responsible for the contents of foreign services, but we review the services for the adherence to the legal requirements within reasonable limits.

We attach great significance to processing your data within the EU / EEA. Nonetheless, it might be the case that we use service providers who process data outside of the EU / EEA. In these cases, we ensure that there is an adequate level of data protection at the receiving institution. This means that via EU standard contracts or an adequacy decision such as the EU Privacy Shield a data protection level can be achieved that is comparable to the standards within the EU.

15. Data protection

We have taken elaborate technical and operational safety precautions to protect your data against accidental or deliberate manipulation, loss, destruction, or the access of unauthorized parties. Our safety procedures are regularly reviewed and updated in line with the latest technological developments.

November 2021

Do you have questions about the privacy policy?

datenschutz(at)cuag.de