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91心頭 Privacy Policy


This Privacy Policy provides our policies and procedures for collecting, using, and disclosing your information. Users can access the 91心頭 service (the Service) through our website (www.getencircle.com), applications on devices, and through APIs. A Device is any computer used to access the 91心頭 Service, including without limitation a desktop, laptop, mobile phone, tablet, or other consumer electronic device. This Privacy Policy governs your access of the 91心頭 Service, regardless of how you access it, and by using our Services you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy. All of the different forms of data, content, and information described below are collectively referred to as information.


THE PRINCIPLES WE ABIDE BY

We comply with all applicable privacy laws respecting our processing and storage of any personal information that may be used in conjunction with the Services, and we deal with your data under these general principles:

  • Lawfulness, fairness, transparency and right to access: We may not reveal the granular details of how we protect your data, because that would compromise its security but we will let you know why we need it, what we need it for, and process it securely and in accordance with applicable laws. If you have any questions respecting your data and how its being used, you need only ask us, and we will answer. This includes any questions you may have about the types and categories of personal information that we may have collected about you.
  • Limitations of purpose: We will limit use of your data to the extent necessary to provide you with our products and services, with the clear exceptions that are set out in this Privacy Policy
  • Minimization of data: We only collect information that we need, and that you choose to give to us. We will not collect personal information gratuitously from you for no reason.
  • Accuracy: We make reasonable efforts to keep your data accurate and up to date, based on your input; if you notify us of any changes to your data, we will make sure to change it in our systems in a timely manner.
  • Limitation of data retention and right to deletion: We believe in streamlining the way that we handle data so that it minimizes data redundancy and unnecessary retention. We have instituted processes to delete personal information from our systems when it is no longer required, and to delete personal information upon request (subject to the exceptions set forth in this Privacy Policy).
  • Integrity and confidentiality: We process your information using appropriate technical or organizational measures designed to ensure appropriate security of your personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage.
  • Non-discrimination: We believe in treating our customers fairly and equally. We will never treat any customer differently simply because they have chosen to exercise their rights under any applicable privacy legislation, such as requesting access to, or requesting deletion of, personal information. Having said that, use of the Service may be dependent upon the use of certain personal information to provide results requested by you, and therefore a request for deletion of personal information will require an investigation into whether there are any other parties with rights in and to that information (such as any insurance provider that you used in relation to your claim), and may result, from a purely technical standpoint, in a limitation of, or inability to use, the Service.

This Privacy Policy contains more detail as to how we live up to these principles.



THE INFORMATION WE COLLECT AND STORE

We may collect and store the following information when running the 91心頭 Service:

Information You Provide
When you register an account, we collect some personal information, such as your name, phone number, email address, home postal address, and home insurance policy. When you invite others to join 91心頭 by using our referral page, we send them a one-time email for that referral.

Files
We collect and store the files you upload, download, or access with the Service (Files). If you add a file to your account that has been previously uploaded by you or another user, we may associate all or a portion of the previous file with your account rather than storing a duplicate.

Log Data
When you use the Service, we automatically record information from your Device, its software, and your activity using the Services. This may include the Device's Internet Protocol (IP) address, browser type, the web page visited before you came to our website, information you search for on our website, locale preferences, identification numbers associated with your Devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata concerning your Files, and other interactions with the Service.

Cookies
We also use cookies to collect information and improve our Services. A cookie is a small data file that we transfer to your Device.

We may use cookies to do the following:

  • Store your current session token, a unique identifier allowing us to authenticate the requests you make to the service as being your own.
  • Store information identifying your current browser uniquely, allowing us to correlate present and past visits to the site, to better understand how you interact with the Service, to monitor aggregate usage and web traffic routing on the Service, and to help prevent fraudulent payments.

You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of the Service.

Personalization
We may use cookies to deliver targeted content specific to your interest using ad platforms such as AdRoll, Facebook, LinkedIn, HubSpot. You may opt out of receiving targeted ads by changing your browser options, or utilizing third party opt-out or ad blocker tools.


HOW WE USE PERSONAL INFORMATION

Personal Information
In the course of using the Service, we may collect personal information that can be used to contact or identify you (Personal Information). Personal Information is and may only be used by us: (i) to provide and improve our Service, (ii) to administer your use of the Service, (iii) to better understand your needs and interests, (iv) to personalize and improve your experience, (v) to provide or offer software updates and product announcements, and (vi) as otherwise expressly set forth in this Privacy Policy. If you no longer wish to receive communications from us, please follow the unsubscribe instructions provided in any of those communications, or update your account settings information.

Geo-Location Information

Some Devices allow applications to access real-time location-based information (for example, GPS). Our mobile apps do not collect such information from your mobile device at any time while you download or use our mobile apps as of the date this policy went into effect, except where the app requests and receives your consent, and in such cases, the information will be used only in accordance with that consent. Some media that you upload to 91心頭s platform or otherwise share with 91心頭 may contain recorded location information. We may use this information to optimize your experience. If you do not wish to share files embedded with your geo-location information with us, please do not upload them. If you don't want to store location data in your photos, please consult the documentation for your camera to turn off that feature. Also, some of the information we collect from a Device, for example IP address, can sometimes be used to approximate a Device's location.

Analytics
We also collect some information (ourselves or using third party services) using logging and cookies, such as IP address, which can sometimes be correlated with Personal Information. We use this information for the above purposes and to monitor and analyze use of the Service, for the Services technical administration, to increase our Services functionality and user-friendliness, and to verify users have the authorization needed for the Service to process their requests.


INFORMATION SHARING AND DISCLOSURE

Subject to any exceptions stated in this document, should 91心頭 collect any of your Personal Information, we will follow these practices regarding the disclosure and distribution of that information.


YOUR PERSONAL INFORMATION IS ALWAYS PROTECTED

91心頭 uses reasonable precautions to protect your Personal Information and store it securely. Access to your Personal Information is restricted to those personnel who need it, and 91心頭 takes reasonable steps to prevent the unauthorized use or disclosure of your personal information.

91心頭 only uses and discloses your Personal Information if it helps us facilitate your needs, improve our products and services, meet legal and regulatory requirements, or to the limited extent possible manage our internal business operations. Additionally, if there are any disclosure or use restrictions in your consent to the collection of your personal information, 91心頭 will abide by those restrictions.

91心頭 may combine your information with other information into an aggregate form, so your information no longer personally identifies you. We may then disclose the aggregate information to third parties, so they can obtain an overall picture of 91心頭s products, services, customer sectors and/or usage patterns. We may also disclose any other information that is not considered to be private or personal information by law.


WE ONLY SHARE YOUR INFORMATION WITH YOUR CONSENT

91心頭 provides your information to third parties only for purposes to which you have consented, and we require such third parties to keep your information confidential.In a few situations, 91心頭 may be required to disclose your information without your prior consent. For example, 91心頭 may disclose your information if we are required to do so by law, or if we believe in good faith that such disclosure is necessary to:

  • Comply with law or legal process
  • Protect and defend our rights and property, or the rights and property of a third party
  • Protect against misuse or unauthorized use of any of 91心頭s products, software, services, or other proprietary materials
  • Protect the personal safety of any person
  • Allow for a change of ownership of 91心頭 and associated transfer of all personal information to the new owner of 91心頭 this does not affect the protection of your information under this Privacy Policy

91心頭 will always try to provide you with prior notice of such disclosure; however, such notice may not always be possible or reasonable given the circumstances.

Additionally, the nature of the Services requires the routine use of your information in the provision of the Services. Your Personal Information will only be used to the limited extent necessary to provide the services that you have requested, and may include the following uses:

  • To allow third party suppliers, vendors, contractors and other parties to provide products and services to us or to you, or to otherwise act on our behalf (this may include, without limitation, our authorization of such third parties to email our users regarding updates, surveys and other inquiries regarding their experience with our software and service)
  • To allow for audits, and surveys to, among other things, validate the size and composition of the users of 91心頭s services, and understand their experience with 91心頭s software and Services.

WE DO NOT SELL YOUR INFORMATION

We do not rent, sell, or share your Personal Information with non-affiliated companies for their direct marketing purposes. In fact, we do not rent, sell, or share your Personal Information with non-affiliated companies for any reason, unless we have your express permission. As stated above, however, we do combine your information with other information into an aggregate form, so your information no longer personally identifies you and we may, on occasion, sell that anonymized data set as part of our products and services.


CHANGING OR DELETING YOUR INFORMATION

If you are a registered user, you may review, update, correct, or delete the Personal Information provided in your registration or account profile by changing your account settings. If your personally identifiable information changes, or if you no longer desire our service, you may update or delete it by making the change on your account settings. In some cases we may retain copies of your information if required by law.

A situation may arise where you desire to have all of your personal information that is contained in 91心頭s records deleted or destroyed. If this is what you wish, please contact our Privacy Officer, who will take care of your request, as described below. However, there may be situations where we are obligated to retain copies of your information to allow us to comply with laws or respond to legal processes, to complete outstanding transactions with you, or maintain the integrity of our systems. The applicability of these exceptions to your information will be fully communicated with you when we process your request.

For questions about your Personal Information on our Service, or to review, update, correct or delete any Personal Information that is not included in your registration or account profile, please contact support@encircleapp.com. We will respond to your inquiry within 30 days.


DATA RETENTION

We will retain your information for as long as your account is active or as needed to provide you services. We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Consistent with these requirements, we will try to delete your information quickly upon request. Please note, however, that there might be latency in deleting information from our servers and backed-up versions might exist after deletion. In addition, we do not delete from our servers files that you have in common with other users; however, all confidentiality and privacy protections remain in place with respect to such files.


COMMUNITY

Our Service offers publicly accessible community services such as blogs, forums, and wikis. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Your posts may remain even after you cancel your account. For questions about your Personal Information on our Service, please contact support@encircleapp.com.

Our Site includes links to other websites whose privacy practices may differ from those of 91心頭. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Web site you visit.


SECURITY

We follow generally accepted standards to protect the information submitted to us, both during transmission and once we receive it. No method of electronic transmission or storage is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our website contact us at support@encircleapp.com.


OUR POLICY TOWARD CHILDREN

Our Services are not directed to persons under 13. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at support@encircleapp.com. If we become aware that a child under 13 has provided us with Personal Information, we will take steps to delete such information from our files.


CONTACTING US

If you have any questions about this Privacy Policy, please contact us at support@encircleapp.com or at:

C/O 91心頭
151 Charles St W #100,
Kitchener, ON N2G 1H6
Phone: 1-888-937-1077


CHANGES TO OUR PRIVACY POLICY

This Privacy Policy may change from time to time. If we make a change to this privacy policy that we believe materially reduces your rights, we will provide you with notice (for example, by email). And we may provide notice of changes in other circumstances as well. By continuing to use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

This privacy policy supplements any agreements you already have with 91心頭, such as your Terms of Service, Acceptable Use Policy, and any software license agreement. Our privacy policy does not replace the terms of those agreements. By agreeing to those terms and using 91心頭s website, products, software and services, you are consenting to the collection and use of your personal information by 91心頭 in accordance with this privacy policy.

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