Privacy Policy

LAST UPDATED: FEBRUARY 28, 2020

This privacy policy (the “Policy”) explains how BVRio UK Limited collects, uses and discloses personal information through its websites, and other online products and services that link to this Policy (collectively, the “Services”) or when you otherwise interact with us.

We encourage you to read the Policy carefully as it forms part of Circular Action Hub terms and conditions.

APPLICATION OF THIS POLICY

For the purposes of applicable international data protection laws, BVRio is the “controller” of personal information collected through Circular Action Hub (www.circularactionhub.org).

COLLECTION OF INFORMATION
INFORMATION YOU PROVIDE TO US

We collect information you provide directly to us. For example, we collect information when you create an Circular Action Hub account, participate in any interactive features of the Services, fill out a form, participate in a call for projects, communicate with us via third party social media sites, request customer support, or otherwise communicate with us.

WHEN YOU SIGN UP OR REGISTER FOR A CIRCULAR ACTION HUB ACCOUNT OR SERVICES

If you sign up for a Circular Action Hub account or Services, we will collect basic information about you including your name, email address and telephone number. We will use the information that we collect about you to:

Create and maintain your account;
Allow you to log in to Circular Action Hub;
Contact you about your account and/or the services that Circular Action Hub offers.

WHEN YOU PROVIDE INFORMATION TO BUILD YOUR ORGANISATION PROFILE OR REGISTER YOUR PROJECT

Once you have created a Circular Action Hub account, we will ask you to provide additional optional information about yourself to complete your “Profile”.

We may also ask you to provide a copy of an identification document, such as a passport, residency, visa or national identity card, a utility bill and such other documents as may be required by us in order to comply with our regulatory obligations and to verify your identity. We may use the information you provide in your Profile to:

verify your identity and your organisation’s credentials and carry out checks that we are required to conduct by applicable laws and regulations, including without limitation, “know your customer”, anti-money laundering, fraud, sanctions and politically exposed person checks;
contact you on matters related to your account, including, to request any additional information or documentation;
provide you with notices related to your account, general updates, market updates and other marketing materials, including, the Services offered by Circular Action Hub.
tailor the products and services offered through the Site to you, including without limitation, to perform any suitability or appropriateness assessments for using our services.

You can update your Profile at any time by logging into your account. We recommend that you update your Profile regularly, to ensure that Circular Action Hub’s functions offered to you are appropriate for your current circumstances. You further agree to update such information upon our request, if we consider the information provided as untrue, incorrect, incomplete and/or inconsistent with other information provided by you at any time. You acknowledge that we may rely upon such information and that you are responsible for any damages or losses which may result from any inaccuracies, including without limitation, the inappropriateness of our Services to your profile. You do not have to provide the information to complete your Profile, however if you choose not to, we may be unable to offer Circular Action Hub’s full functionalities to you.

WHEN YOU CONTACT US

If you contact us by telephone, email, post or use another function, such as the chat feature, we will may collect any information about the communication and any additional information that you choose to give us. We may use this information to review, investigate and respond to any comment or question that you may raise. Please note that we may record and retain all telephone calls and other communication with us and may use it in our dealings with you including any dispute resolution or legal proceedings.

INFORMATION ABOUT YOUR USE OF CIRCULAR ACTION HUB SERVICES
USAGE INFORMATION

We collect information about your use of the Services:

AUTOMATICALLY COLLECTED INFORMATION

When you access or use our Services, we may automatically collect information about you, including:

Log Information: We may collect log information about your use of the Services, including the type of browser you use, app version, access times, pages viewed, your IP address, any other network identifiers, and the page you visited before navigating to our Services.
Device Information: We may collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
Activities on the Site: We may collect records of activities on the Site, including, any content you post, your account details, the time, value and currency of any deposit, withdrawal, or transaction made and the payment method.
Location Information: In accordance with your device permissions, we may collect information about the precise location of your device.
Information Collected by Cookies and Other Tracking Technologies: We may use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness.

USE OF INFORMATION

We may use the information we collect to provide, maintain, and improve our services, such as to administer and verify your account, to provide the services you request and customize your experience with us. We also may use the information we collect to:

carry out our obligations owed to you;
comply with our regulatory and other legal obligations;
monitor any content, you post;
compile statistical analysis of the pages of our platform and websites;
investigate and to manage enquiries, disputes and legal proceedings and to comply with court orders, mandatory dispute resolution determinations and mandatory government authority or law enforcement orders or directions;
participate in crime prevention, legal and regulatory compliance and to assist regulatory, cybercrime, data and information protection agencies and police with their enquiries and enforcement, even if not compelled to do so;
develop and to market other products and services; and
SHARING OF INFORMATION

We will not share the personal information we hold about you.

ADVERTISING AND ANALYTICS SERVICES PROVIDED BY OTHERS

We may allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by us to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices if you are in the United States and if you are in the EU, please visit www.youronlinechoices.eu/.

YOUR CHOICES

Depending on where you or your data resides you may have certain rights and protections under the law regarding the processing of your personal data. For example, you may also have the right to object to, or request that we restrict, certain processing and in some circumstances to obtain a copy of the personal information in machine readable format.

Basis for Processing: When we process your personal data we will only do so in the following situations:

Entering into and Performing the Contract with You: If you have an Circular Action Hub account or have registered on the Site or for the Services, our legal basis for processing your personal information is that it is necessary for the performance of the relevant Circular Action Hub Services.

Data Subject Requests: You have the right to access personal data we hold about you and to ask that your personal data be updated, corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you can log into your account or emailing us at data@bvrio.org. If you wish to delete or deactivate your account, please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Questions or Complaints: If you would like to exercise any of these rights, you can log into your account or contact us. Any such request should be submitted in writing to:……. If you have a concern about our processing of personal data that we are not able to resolve, you may have the right to lodge a complaint with the data privacy authority where you reside. If you have registered to the services of BVRio UK Limited, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

COOKIES

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

TRANSFER OF INFORMATION TO OTHER COUNTRIES

When using our services, your data is processed and stored in the EU and other countries. We and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it.

RETENTION OF PERSONAL INFORMATION

We store the information we collect on you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. The period for which we will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation.

If you have an account with Circular Action Hub, we will store your personal information for as long as you maintain that account, and after you cease holding an account, for as long as we are required to by laws and regulations that are applicable to us.

CHANGES TO THIS PRIVACY POLICY

The Policy will be reviewed from time to time to take account of changes to our operations or practices and, further, to make sure it remains appropriate to any changes in law, technology and the business environment. Any personal information held will be governed by our most current Policy.

LINKS

The Site may include links to other websites on the internet. We are not responsible for the content of these sites or for any other privacy practices on these internet sites. You should read the terms of use and the privacy statements of any such websites. Our terms of use and our Privacy Policy apply only to information collected by us in accordance with this Policy.

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