PRIVACY POLICY and TERMS OF USE
Please read this Privacy Policy and Terms of Use carefully.  By accessing, browsing or using this website, or by using any of the services provided through it, you acknowledge that you have read and understood the terms outlined below and that you AGREE to be bound to this Privacy Policy and Terms of Use (collectively known as “Terms and Conditions”).  If you do not agree to these terms, please exit this page and do not access or use the website.  


1. General
CirQl, located at www.cirql.ph, is an online membership platform that provides an interactive promotional service consisting of information services, content and transactional capabilities provided by CirQl, its affiliates and other third parties (“Website”).  CirQl is owned and operated by Sumo Limited (collectively referred to as “We” or “us”).


2. CirQl Membership
By registering to our Website or subscribing to our newsletter, you agree to receive offers, promos, marketing materials and other content pertaining to our member websites, member companies, affiliates and other partners.

• You may opt out of receiving information and other marketing materials by clicking on the Unsubscribe button or by emailing us at info@cirql.ph.

• You may also opt to fully discontinue your membership with CirQl anytime by emailing us at info@cirql.ph.  Your personally identifiable information will be functionally deleted should your membership be deactivated or account be deleted, and we will not sell, transfer or use your information in any way moving forward.


3. Types of Data Collected
We collect two types of information about you: Personally Identifiable Information and Non-Personally Identifiable Information.

• Personally Identifiable Information refers to any information about you which is personally identifiable, including but not limited to your name, email address, mailing address, telephone number, birthdate, financial details, and any other information which can be directly associated with you and which you may disclose to us in the course of using our website and other associated services.

• Non-Personally Identifiable Information is information that does not identify you. This type of information may include things like the Uniform Resource Locator (“URL”) of the website you visited before coming to our Website, the URL of the website you visit after leaving our Website, the type of browser you are using and your Internet Protocol (“IP”) address. We, and/or our authorized Third Party Service Providers and Advertisers, may automatically collect this information when you visit our Website through the use of electronic tools like Cookies.


4. Collection of Personal Information
• We collect information about you to effectively execute and enhance the services provided by our Website, our member websites, member companies, affiliates and partners. We will collect this information from you by lawful means and not in an unreasonably intrusive manner.

• Depending on the activity, some of the information we ask you to provide is identified as mandatory and some is identified as voluntary. If you do not provide the mandatory information for a particular activity that requires it, you will not be permitted to engage in that activity.

• The data we collect include, but are not limited to, information you provide to us when you register to or create an account in our Website, subscribe to our newsletter, complete a transaction on our Website, participate in our promos including those conducted outside of the Website, participate in our surveys, or contact us for any reason such as to make an inquiry, file a complaint, provide feedback, or apply for a job in our organization.

• The personal information we gather from you may include, but is not limited to, your name, email address, billing and delivery addresses, phone number, and other personal information you may voluntarily provide to us in the course of completing a transaction.

• We may collect personal information from individuals who are not customers of our business but whose personal information is voluntarily given to us by those individuals via our Website or social media accounts.

• When you visit our Website, we, and/or third parties, may place cookies on your browser to enhance and manage our website and improve the services we provide to you. In addition, third parties may place and read cookies on your browser, or use web beacons or similar technologies to collect information, including, where applicable, for the Google Trusted Stores program.

• Cookies can be managed by accessing the individual settings in your browser.

• We will not identify users or their browsing activities, except where required by law or in accordance with our Privacy Policy and Terms of Use.


5. Using and Disclosing Your Personal Information
• We will generally use or disclose your personal information only for the primary purpose for which it was collected; or for a related secondary purpose where you would reasonably expect us to use or disclose the personal information for that secondary purpose. We may otherwise use and disclose your personal information if you have given us consent for the use or disclosure or it is required or authorised by law.

• We generally use and disclose your personal information to create and maintain your personal account on the Website; process and complete your transactions on our Website; process any inquiries, requests or complaints received from you; and send you information about new offers, promos, marketing materials and other content related to our Website, our member websites, our member companies, affiliates and partners.

• If those purposes for which we have collected the information involve providing personal information about an individual to any third party, we will take appropriate and reasonable steps to ensure any personal information is protected.

We will not use or share your Personally Identifiable Information with other parties except as provided below:
• We may use but not disclose your information to provide support to other member companies, affiliates and other partners of Sumo Limited, including members that are located outside of Philippines. Use of such information may include, but not limited to, sending you offers and other content, studying market trends and user behaviour, and optimising and improving the products and services of our member companies, affiliates and partners.  Use of such information would remain subject to this Privacy Policy and Terms of Use.

• We may also provide your information to third parties that provide services to us, including third parties that provide, marketing, logistics and technology support services.  We may share your Personally Identifiable Information with such Service Providers to deliver packages, send email, administer promotional activities, remove repetitive information on customer lists, analyze data, provide marketing assistance, provide search results and links, operate the Website, troubleshoot, and provide customer service.

• We may share your information in a Business Transfer. As with any other business, we could merge with or be acquired by another company. If this occurs, the successor company would acquire the information we maintain, including Personally Identifiable Information. However, Personally Identifiable Information would remain subject to this Privacy Policy and Terms of Use.

• We may share your information for our protection and the protection of others. We may also disclose Personally Identifiable Information when we believe release is appropriate to comply with the law or a court order; enforce or apply this Privacy Policy, our Website Terms and Conditions or other agreements; or protect the rights, property or safety of the Website, its Users or others.

We may disclose or share Non-Personally Identifiable Information with Partners, Affiliates and Advertisers as provided below:
• We use Third Party Advertising Companies to serve ads when you visit our Website. These companies may use Non-Personally Identifiable Information about your visits to this and other websites in order to provide, through the use of network tags, advertisements about goods and services that may be of interest to you.

• We may remarket your information. Remarketing is a way for us to connect with users, based upon your past interactions with our Website. Third-party marketing vendors may be hired by us to perform remarketing services. As a result, third-party vendors, including Google, may show CirQl ads on sites on the internet. Third-party vendors, including Google, use cookies to serve ads based on a your prior visits to our website. You may opt out of Google's use of cookies by visiting the Google advertising opt-out page.

• We also use Third Party Service Providers to track and analyze Non-Personally Identifiable usage and volume statistical information from our Users to administer our Website and constantly improve its quality. We may also publish this information for promotional purposes or as a representative audience for Advertisers. Please note that this is not Personally Identifiable Information, only general summaries of the activities of our Users. Such data is collected on our behalf, and is owned and used by us.


6. Data Security
• We take steps to protect the personal information we hold against loss, unauthorised access, use, modification or disclosure and against other misuse.

• Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we employ commercially reasonable security measures to protect data and seek to partner with companies which do the same, we cannot guarantee the security of any information transmitted to or from the Website, and are not responsible for the actions of any third parties that may receive any such information.

• When no longer required, personal information is destroyed in a secure manner or deleted.


7. Data Tracking
Cookies:
• To facilitate and customize your experience with the Website, we store cookies on your computer. A cookie is a small text file that is stored on a User’s computer for record-keeping purposes which contains information about that User. We use cookies to save you time while using the Website, remind us who you are, and track and target User interests in order to provide a customized experience.

• Cookies also allow us to collect Non-Personally Identifiable Information from you, like which pages you visited and what links you clicked on. We and/or Google may use this information to gather demographic information, analyze trends in user behaviour, optimise our website, and place advertisements, including advertisements of third party vendors, on our own and third party websites. Google’s ability to use and share information collected by Google Analytics is restricted by the Google Analytics Terms of Use and Privacy Policy.

• Cookies may be used by us to collect the information such as, but not limited to, the device you are using to access our website, your browser type and capabilities, your IP and geolocation, websites you visited including how you were referred to each web page, and usage statistics.

• In addition, we may use Third Party Advertising Companies to display advertisements on our Website. As part of their service, they may place separate cookies on your computer. We have no access to or control over these cookies.

• Most browsers automatically accept cookies, but you may be able to modify your browser settings to decline cookies. Please note that if you decline or delete these cookies, some parts of the Website may not work properly.

• By using the website and agreeing to this policy, you grant us permission to place and store cookies on your browser.  This Privacy Policy covers the use of cookies by our Website only and does not cover the use of cookies by any Advertiser or other third parties.

Other Tracking Devices :
• We may use other industry standard technologies like pixel tags and web beacons to track your use of our Website pages and promotions, or we may allow our Third Party Service Providers to use these devices on our behalf. Pixel tags and web beacons are tiny graphic images placed on certain pages on our Website, or in our emails that allow us to determine whether you have performed a specific action.

• When you access these pages or open or click an email, pixel tags and web beacons generate a Non-Personally Identifiable notice of that action.

• Pixel tags allow us to measure and improve our understanding of visitor traffic and behaviour on our Website, as well as give us a way to measure our promotions and performance. We may also utilize pixel tags and web beacons provided by our Affiliates and/or Marketing Partners for the same purposes.


8. Access to Your Personal Information
• We will allow you access to the personal information we hold about you within a reasonable time after it is requested. When requesting such access please identify the precise type/s of information requested. You may make a request by contacting us via info@cirql.ph.

• We take those steps reasonable in the circumstances to ensure that the personal information we collect, use and disclose are accurate, up to date and complete. Should you request to correct or delete your information, we will take reasonable steps to correct or delete the information, having regard to the purpose for which it is held. You may lodge a request to correct or delete personal information by emailing us at info@cirql.ph.


9. Other Terms
Children:
• Minors under the age of 18 may not use the Website, subscribe to, or register as a member of CirQl. We do not collect or maintain information from anyone known to be under the age of 18, and no part of the Website is designed to attract anyone under the age of 18. If you are under 18, you may use the Website only with the involvement and supervision of a parent or guardian.  Otherwise, please exit this page and do not use or access our Website.

Public Areas:
• We may provide areas on our Website where you can publicly post information about yourself, link to your own social media posts, communicate with others, or provide reviews and submit media content. This information may be accessible by other consumers and companies and may appear on other websites or web searches, and therefore this information could be read, collected, and used by others. For example, if you post your email address along with a review, you may receive unsolicited messages. We are not responsible for the information you voluntarily and publicly make available on our website and have no control over who reads your postings or what other users may do with the information you voluntarily post, so please use caution when posting any personal information.

Links to Third Party Websites:
• Our website may contain links to third party websites. We are not responsible for the terms of use of any third party websites and we recommend that you review the terms and privacy policies of each website you visit.


10. Changes to the Privacy Policy and Terms of Use
Sumo Limited reserves the right to make changes to this Website including its Terms and Conditions.  Should the Terms and Conditions be updated, we will place a notification on this page. The revised Terms and Conditions is effective immediately when posted on the Website. It is the responsibility of each User to review the Website’s Privacy Policy and Terms of Use periodically to review the current terms.
Your continued use of the Website after the effectiveness of such revisions will constitute your acknowledgment and acceptance of the modified Terms and Conditions.

This Privacy Policy was last updated on 24 September 2017.