Ballerton B.V. ("Cirqle") provides sales and marketing services, operates online websites at (the "Site") that create technological and commercial relationships between third-party retailers, advertisers and other businesses associated with Cirqle ("Merchants"), individuals and entities with websites, blogs, social media presence, agents or agencies, digital publishers and other content platforms ("Content Publishers"), and consumers to facilitate sales ("Sales") of products and services (collectively, "Products") and the promotion of Merchants (collectively, the "Services"). This Privacy Policy ("Policy") covers how Cirqle treats personal information that Cirqle receives, tracks or collects in connection with your use of the Services.

This Policy tells you, among other things, what information we gather from you through our Services, how we may use or disclose that information, how to review or edit it, and our efforts to protect it.

Please read this Policy carefully. By registering for, accessing, using, and/or downloading any Services, you agree to this Policy and that you will abide by Cirqle's Terms of Service (Insert Link) Among other things, you consent to the collection, tracking and use of your personal information as outlined in this Policy, as such Policy may be amended from time to time.

Any capitalized terms not defined herein shall have the meaning provided in the Cirqle Terms of Service (Insert Link). 

You agree not to access the Services from a jurisdiction which has data and personally identifiable information protection requirements that are greater than those provided herein.

1. Notice of Information We Collect or Track.
We may collect or track the following information:

Application Information. When you apply for an invitation, you are required to give certain information, such as your name, email address, blog or other content platform name, and blog or other content platform address.
Registration Information. If you receive and accept our invitation, we will request certain information from you, including your contact information (such as name, address, and phone number), social security number and/or tax identification number, and financial information (such as bank account information).
Interaction with Services and Access. As is true of most websites, we gather certain information automatically when you interact with the Services, including data relating to Sales. We may also receive information from the mobile phone, tablet, computer or other device that you use to access the Services. This information may include, but is not limited to, your domain and/or Internet Protocol ("IP") addresses, browser type, Internet Service Provider ("ISP"), the referring or exiting website address, operating system, access times and history, information relating to your activities and preferences on the Services, geo-location, device, telephone number, mobile carrier, language, images or other content users post, content users download, communications on the Services with other users, posts in public forums, and information from cookies or other technology.
Consumer Data. We collect and track data from consumers who visit Content Publishers' sites and click on a Merchant link. Among other things, this information allows us to facilitate commissions and generate reports for Content Publishers and Merchants.
Correspondence. If you send us personal correspondence, such as an email or via your Dashboard, we may collect such information into a file specific to you.
Third Party Referral. We may collect certain information regarding you when a third party voluntarily provides such information, such as when using the "Pitches" option with respect to our communications.
Public/Sponsored Events. Cirqle may participate in public events and events with multiple sponsors, such as trade shows and seminars. The events generally collect certain information from all attendees and distribute this data in whole or in part to all the event sponsors including Cirqle. We do not control and are not responsible for the practices of other sponsors for these events.
SNS. We may collect information from social networking systems ("SNS") used in connection with the Services, such as name, gender, date of birth, geo-location, interests, when you "Like" or click links provided by or through the App and other information available through your SNS page. It is your responsibility to read and accept the relevant terms of service and privacy policy associated with the particular SNS service.
Information Collected, Tracked or Analyzed by Third Parties. We may permit advertisers or other partners to collect information from the Services. We may also utilize third parties to analyze data collected from the Services. We may permit third parties to collect personally identifiable information over time and across different websites.

2. Notice of How We Use Collected/Tracked Information.
We use the information we collect or track about you to:

  • Assess your website's suitability;
  • Pay you the commissions you earn, including providing data to payment processors like PayPal;
  • Operate, maintain, and provide to you the services, features and functionality of the Services;
  • Help you quickly find information and prevent you from having to enter information more than once;
  • Improve the quality and design of the Services;
  • Provide customized content and services, including without limitation advertising and promotional information, such as targeted Campaigns;
  • Diagnose problems with the Services;
  • Create new features, functionality, and services;
  • Provide customized content and services, including without limitation advertising and promotional information, such as targeted Campaigns;
  • Communicate with you;
  • Provide customer support;
  • Provide reports and other data to Merchants that may identify you and include data about your performance;
  • Facilitate use of the Services, including indexing your name and relevant business information to make it available to other Cirqle users;
  • Perform research and analysis on your use of the Services;
  • Manage your account;
  • Protect the security and integrity of the Services, as well as the property, rights and personal safety of Cirqle, our users or others; and
  • Enforce the Terms of Service, this Policy and any other agreements you have entered into with Cirqle.

3. Notice of Disclosure of Collected / Tracked Information.
Information from the Services. We may provide information about you and your business to our affiliates and other businesses or individuals, including our Merchants, Content Publishers and API Developers. We may also share aggregated non-personally identifiable information publicly.
Legal Compliance. Cirqle will cooperate with law enforcement inquiries, other government agency inquiries and requests, and criminal or civil subpoenas. Cirqle will also disclose your personal information when necessary to comply with local laws and regulations.
Sale or Other Transfer. As we develop our business, we may buy or sell some or all of our assets and, depending on the transaction, your personal information may be one of the transferred assets. Similarly, if Cirqle should ever merge with or be acquired by another company, we may share your personal information with any entity resulting from such transaction and if Cirqle should ever file for bankruptcy, the bankruptcy trustee has the right to sell the information you provide to us to a third party.
Disclaimer. We cannot ensure that all of your private communications and other personal information will never be disclosed in ways not otherwise described in this Policy. By way of example (without limiting the foregoing), we may be required to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmission of private communications, or users may abuse or misuse your personal information that they collect from the Services

4. Changes to personal information.
If your personal information changes, or if you no longer desire some or all of our Services, you may correct or update it by contacting us.

5. Abuse of Terms of Service Agreement.
You authorize us to disclose any information about you with our attorneys, law enforcement, or other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, violation of obligations to us under our Terms of Service Agreement or any other agreement or policy, or other illegal or harassing activity.

6. Cookies / Tracking Technologies.

We may use cookies, log files, clear gifs, web beacons or other technology. We may use these technologies in a variety of ways, including but not limited to:

  • Providing custom, personalized content and information;
  • Remembering information so that you will not have to re-enter it during your visit or the next time you visit the Services;
  • Keeping count of return visits to our Services;
  • Accumulating and reporting statistical information on Services usage;
  • Determining which features users like best;
  • Assessing the popularity and effectiveness of the Services;
  • Determining whether and when an email was opened;
  • Tracking Sales;
  • Facilitating Commissions; and
  • Improving our Services and creating new services.

You can refuse cookies by turning them off in your browser. However, if you turn off cookies, then you may not be able to utilize certain features of the Services.
This Privacy Policy covers the use of cookies by these Services only and does not cover the use of cookies by any advertisers or third parties.

Cirqle or an affiliate network (each an "Affiliate Network Partner") may drop cookies on a consumer's device and/or web browser. For example, once a Content Publisher uses a Product or Merchant link during our Services, visitors to that Content Publisher's website who click on the particular link will be directed by Cirqle or the Affiliate Network Partner to a Merchant's e-commerce site, at which point Cirqle or the Affiliate Network Partner drops a cookie on the visitor's browser. These cookies are dropped so that our Services can monitor and/or monetize visits to our Content Publishers.

You agree Cirqle is not liable for the content or use of personal information by third parties, including, without limitation, Content Publishers and Merchants, and including their use of cookies. Users and readers of Content Publisher websites and applications, as well as Merchants' websites, should consult the privacy policies and terms of service for those individual websites.

By agreeing to the terms of this Policy and by using our Services, you consent to the cookies referenced above being dropped on your and your visitors' web browsers and machines. It is your responsibility to inform your visitors of the relevant data collection, use and disclosure practices through a privacy policy – see Section 7. In order for you to be a registered and active user of the Services, you must agree to accept cookies. If you wish to opt-out of cookies altogether, send an email [email protected] to request your account be deleted.

7. Content Publishers' Websites/Applications/Other Content.
General. When you begin using links provided by Cirqle, we will collect and store information about each link that your users and readers click on. We use this information for data analysis, among other things.
Requirement of Privacy Policy. Content Publishers are solely responsible for ensuring that their own website, application or other content take all necessary and proper measures to protect personal privacy, including following a written Privacy Policy posted on such sites, and adhering to all appropriate regulations, laws and other requirements.
Promotion and Publicity. We may collect and store information about publicly accessible content on your website, application or other content (such as your website name and website content). Among other things, we may use this information to recommend certain Merchants and for advertising and marketing related activities.

8. Links.
The Services may contain links to third party sites or third party applications, including advertisers. However, please be aware that Cirqle is not responsible for and cannot control the terms of service or privacy policies of such other sites. We encourage you to be aware when you leave the Services, and to read the applicable agreements for each and every site or application. The Policy applies solely to these Services. Cirqle is not responsible for and makes no representations or warranties regarding links, including without limitation, the content, accuracy, opinions, functionality, or services provided in such linked sites or applications. Inclusion of any linked site or application on the Services does not imply approval or endorsement by Cirqle.

9. Third-Party Applications.
Cirqle may, in its sole discretion, provide Content Publishers with access to third-party Developer Apps which interface with Cirqle APIs. Such Developer Apps use Cirqle APIs, but are not endorsed by Cirqle. Use of such Developer Apps by Content Publishers is voluntary and subject to the election by the Content Publisher, in its sole discretion, to use any Developer Apps.

Use at your own risk. By using Developer Apps, you are granting Developer Apps access rights to your Content, including without limitation related metadata. Cirqle makes no representations or warranties regarding Content Publishers' use of any Developer Apps, or the privacy or security of data or information provided to third parties or their Developer Apps. You agree Cirqle has no liability whatsoever for the Developer Apps, including, without limitation, the third party use of personal information provided to third parties or through Developer Apps, nor the use of cookies by third parties or Developer Apps. Content Publishers using Developer Apps should consult the privacy policies and terms of service for those individual Developer Apps.

10. Age Restrictions; Children's Privacy.
These Services are not for use for anybody under the age of 16. By using these Services, you verify that you are 13 or older and in compliance with this provision. Cirqle will not knowingly collect or use personal information from anyone under 16 years of age. If Cirqle obtains actual knowledge that it has obtained personal information about a child under the age of 16, that information will be permanently deleted from our records.

11. Choice/Opt Out.
You may opt out at any time by using the Opt-Out or Unsubscribe option at the bottom of most of our mass email communications, or by contacting us through the "Contact Us" section of the Services. You may also choose to delete your account at any time.

12. Security.
To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before creating your account. The user who created the account is responsible for maintaining the secrecy of their unique password and account information at all times.

Payment processing will be performed by a third party vendors, such as PayPal, which have their own security policies that relate to the data they process. We use what we believe to be appropriate procedures to protect information against unauthorized access and disclosure. However, information you elect to post on our Services, emails and other information you send to us are not encrypted and such transmissions cannot be considered a secure means of transmitting sensitive information.

You should be aware of the limitations of security, authentication, encryption, and privacy measures used in connection with the Internet and that any information you transmit through the Services may be damaged, corrupted, "sniffed" and/or accessed by another person without your permission. Regardless of the precautions taken by you or by us, "perfect security" does not exist on the Internet. Third parties may unlawfully intercept or access transmissions or private communications, and other users may abuse or misuse your personal information that they collect from the Services. Therefore, although we work very hard to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private. We cannot ensure or warrant the ultimate security of any information you transmit.

13. File a Complaint.
If for some reason you believe Cirqle has not adhered to the principles of this Policy, please notify us at [email protected]

14. Changes to this Policy.
Cirqle may modify this Policy or any other terms, such as the Terms of Services, at any time. You should review all applicable terms regularly. Cirqle will post notice of modifications at (Insert Link) You may also visit (Insert Link) to review any revised terms of the Policy. All such changes will be binding on you 14 calendar days after they are initially posted at (Insert Link), unless you are a new user, in which case they are binding on you immediately.

15. Contact Us.
Any notices or communication sent to you by Cirqle will be sent to your email address on file with Cirqle, which may be updated by you in writing at any time. It is your responsibility for ensuring that Cirqle has your current email address at all times. Any notice sent to you via such email address by Cirqle shall be deemed given, received, and read by you, whether or not it actually is received and/or read.

Any notices or communications sent by you to Cirqle pursuant to this Policy must be in writing and sent to the address specified herein or such other address as Cirqle may specify in writing.

All notices will be sent to: 

Ballerton B.V. 
Overtoom 141-3
1054 HG Amsterdam
Email: [email protected]

The Cirqle, 2017