By using the Services, you agree to the terms of this Policy. If you do not agree to the terms of this Policy, please do not use the Services. We reserve the right to change this Policy at any time without prior notice. Any changes to our Policy will become effective upon our posting of the revised Policy on the Website. You can determine when this Policy was last revised by referring to the “Last Revised” legend at the top of this page. Use of the Services following such changes constitutes your acceptance of the revised Policy then in effect. Therefore, we encourage you to review this Website from time to time for changes to our Policy. You agree to obtain annual notices of, and changes to, this Policy electronically by visiting this Website.
You should also read our Terms of Service, which can be found on the Website.
We receive and collect both personal and non-identifying information from you through your use of our Services. Personal information means information either on its own or in conjunction with other data that enables a specific person to be identified, but does not include “de-identified,” “anonymous,” or “aggregate” information, which is not otherwise associated with a specific person. Non-identifying information means information that by itself cannot be used to identify a specific person, including aggregated information, demographic information, Internet Protocol (IP) addresses and any other information that does not reveal your specific identity.
Through your use of the Services, you may provide us with personal information that we may collect, including the following:
Depending on your use of the Services, we may automatically collect the following information:
When you access or use certain of our Services, we may obtain the following information from third party sources:
We use all the information we collect and receive to help us operate, provide, improve, understand, customize, support, and market our Services, to monitor and analyze trends, usage and activities in connection with our Services and to research and develop new Services. In addition, we use your information for general, operational and administrative purposes, including maintaining your account, authenticating you, providing customer service, and contacting you. We may share or make available anonymous or aggregate information that cannot be used to identify you with third parties for research, marketing and promotional purposes, and with users of our Services for purposes of comparison of their business financial situation relative to the broader community. As used in this Policy, the terms “use,” “using” and “processing” information include using cookies or other similar technologies on a computer/phone/device, subjecting the information to statistical or other analysis and using or handling information in any way, including but not limited to, scanning, collecting, storing, evaluating, aggregating, modifying, deleting, using, combining, disclosing and sharing information among our affiliates and to select third parties.
We analyze how our customers use our Services and use that information to evaluate and improve our Services, to research, develop, and test new services and features, and to conduct troubleshooting activities. For example:
We use analytics partners (such as Google Analytics) to help analyze usage and traffic for our Services. As an example, we may use analytics partners to analyze and measure, in the aggregate, the number of unique visitors to our Services. Google Analytics is a web analysis service provided by Google that allows us to collect data about the traffic on the Websites through Google cookies and other identifiers, which enables us, among other things, to create user segments based on demographic or interest data and to deliver relevant advertising. Google utilizes the data collected to track and examine the use of our Websites and to prepare reports on the activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. You may be able to opt out of the Google Analytics advertising features through your browser ads settings or by visiting Google’s Ads Settings page.
We share the information we collect and receive with our affiliates and to select third parties, to help us operate, provide, improve, understand, customize, support, and market our Services, and for general, operational and administrative purposes, including maintaining your account, authenticating you and contacting you. In addition, you share your information as you use and communicate through our Services.
Some of our features enable you to connect to a social media account or share information on social media platforms, like Facebook and Twitter. Any information you choose to share on social media may potentially be visible to a global audience and will be subject to the social media provider's privacy policies (not this Policy). You should take care only to share information on social media that you are comfortable sharing.
We may share information in certain special circumstances. For example:
You may see third-party advertisements on the Website. We may share aggregated information (i.e., information about you and other customers collectively, but not specifically identifiable to you) and other non- personal, de-identified, or anonymous information we collect with third parties to develop and deliver targeted advertising on our Website and on the websites of third parties. Some advertisements are chosen by companies that place advertisements on behalf of other third-party advertisers. These companies, often called ad servers, may place and access cookies on your device to collect information about your visit. The information they collect from our sites is in a form that does not identify you personally. This information may be combined with similar data obtained from other websites to help advertisers better reach their targeted audiences. Targeting may be accomplished by tailoring advertising to interests that they infer from your browsing of our sites and your interaction with other websites where these ad servers also are present. If you choose to interact with specific advertisers who advertise on the Website, the information you provide to them is subject to the conditions of their specific privacy policies. The Website also includes social network or other third- party plug-ins and widgets that may provide information to their associated social networks or third- parties about the page you visit, even if you do not click on or otherwise interact with the plug-in or widget.
You share your information as you use and communicate through our Services. Certain information you provide may be available to anyone who uses our Services, although you can configure your Services settings to manage certain information available to other users. Users may store or share your information with others on and off our Services.
You have choices about how we use and share your information and there are additional protections that may apply with regard to certain information we collect.
Federal “Do Not Call” laws allow you to place your phone numbers on the National Do Not Call Registry to prevent telemarketing calls to those numbers. To add your numbers to this list, please call 1-888-382-1222, or visit www.donotcall.gov. Most telemarketing laws allow companies to contact their own customers without consulting the Federal or State Do Not Call lists. If you would like to be removed from our telemarketing list, please contact us at [_____]. We will endeavor to comply with your request as soon as reasonably practicable. Please note that we may still call you regarding your Services and account even if you remove your number from our telemarketing list.
Marketing emails you receive from us will include an unsubscribe feature usually found at the bottom of the email that you may use to opt out of receiving future marketing emails. Marketing text and SMS messages from us also contain an opt- out feature that you can use to prevent future marketing text and SMS messages from us. You may refuse to consent to receive calls and texts from Circl that require your consent, including autodialed, pre-recorded or artificial voice telemarketing calls. You may also withdraw your previously given consent to receive such calls and texts. Your ability to manage some of our Services could be limited if you withdraw your consent to receive text and SMS messages. Circl does not recommend using those Services without authorization to receive such messages. Please note that if you opt-out as described above, we will not be able to remove personal information about you from the databases of third parties with which we have already disclosed personal information as of the date that we implement your opt-out request. If you wish to cease receiving marketing-related e-mails from third parties, please contact such third parties directly or utilize any opt-out mechanisms set forth in their respective privacy policies or marketing-related emails.
You have choices about whether certain information collected on the Website is used to customize advertising based on predictions generated from your visits over time and across different websites. Similarly, many mobile devices offer controls you can set to limit the advertising use of information collected across mobile apps on your device. Please note that many opt outs use browser cookies or device controls and are specific to the device and browser you are using. If you buy a new computer, change web browsers or devices or delete the cookies on your computer, you may need to opt out again. In addition, ads you receive may still be tailored using other techniques such as publisher, device or browser-enabled targeting. You should check the privacy policies of the products, sites, apps and services you use to learn more about any such techniques and your options. You also can limit the collection of certain website information by deleting or disabling cookies. Most browsers enable you to erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. Disabling cookies may prevent you from using specific features on our sites and other websites.
We do not knowingly market to or collect information from children under the age of 18 without obtaining verifiable parental consent. If you allow a child to use your device or our Services, you should be aware that their information could be collected as described in this Policy. We encourage parents to be involved in the online activities of their children to ensure that no information is collected from a child without parental permission. If you are under 18 years of age, you may browse our Website; however, you may not provide personal information to us such as name, address, or email address.
We have technical, organizational and physical safeguards in place to help protect against unauthorized access to, use or disclosure of the information we collect and store. Although we work hard to protect your information that we collect and store, no program is 100% secure and we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use or disclose that information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us of the problem as soon as possible (note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem).
If you have questions, concerns or suggestions related to our Policy or our privacy practices you may contact us at:
SMB Resources LLC
6611 San Vicente St.
Coral Gables, FL 33146
Please note that email communications will not necessarily be secure; accordingly you should not include sensitive information in your email correspondence with us.
Some of our Services may allow you to participate in blog discussions, message boards, chat rooms, and other forms of social networking. Please be aware that these forums are accessible to others. We urge you to not submit any personal information to these forums because any information you post can be read, collected, shared, or otherwise used by anyone who accesses the forum. Circl is not responsible for the information you choose to submit in these forums. If you post content to information sharing forums, you are doing so by choice and you are providing consent to the disclosure of this information.
California residents may be entitled to additional rights over their personal information. For more information about those rights and how to exercise them, please see our California privacy notice here [INSERT HYPERLINK], which is incorporated by reference into this policy.
We control and operate the Website from the United States, and the Website is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. We do not represent or warrant that the Website, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the Website do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the Website’s availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.
The CCPA provides California residents with specific rights regarding their personal information. This notice describes your CCPA rights and explains how to exercise those rights. This notice also includes information regarding the collection, use, disclosure, and sale of personal information and the rights of consumers regarding their own personal information.
Examples: Name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
B. Categories of Personal Information in Cal. Civ. Code 1798.80(e)
Examples: Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
C. Characteristics of Protected Classifications under California or Federal Law
Examples: Race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status.
D. Commercial Information
Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric Information
Examples: Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
F. Internet or Other Electronic Network Activity Information
Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.
G. Geolocation Data
Example: Precise physical location.
H. Sensory Information
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information
Examples: Job application or resume information, past and current job history, and job performance information.
J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)
Examples: Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.
K. Inferences Drawn from Personal Information
Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either by completing the Request Form, located here https://forms.gle/CHYLYQdErp4B3myB7 or by contacting us at email@example.com.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
We reserve the right to amend this privacy notice at our discretion and at any time.
Address: SMB Resources LLC
6611 San Vicente St.
Coral Gables, FL 33146