Privacy Policy

Last Revised: September 16, 2020

I. General

SMB Resources LLC (d/b/a Circl) (“we,” “us” or “Circl”) is committed to protecting the privacy of your personal information. This Privacy Policy (the “Policy”) sets forth our policies and procedures regarding the collection, use and sharing of your personal information that we collect about you when you use our websites (collectively, the “Website”), widgets, and other online products and services (collectively, the "Products" and together with the Website, the “Services”) or when you otherwise interact with us or receive a communication from us. We also explain the steps we take to protect your information and how you can limit the collection, use and sharing of your information.

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.

II. Information We Collect

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.

A. Information You Provide.

Through your use of the Services, you may provide us with personal information that we may collect, including the following:

  • full legal name
  • personal email address to verify your identity
  • mobile phone number to verify your identity
  • business name
  • entity type
  • zip code
  • year established
  • industry
  • size (number of employees)
  • website url
  • business address
  • main phone number for business
  • main email address for business
  • other personal information necessary to verify you
  • other personal information you provide to us for customer support purposes or product feedback
  • other personal information you provide for purposes of your business profile

B. Information We Collect.

Depending on your use of the Services, we may automatically collect the following information:

  • Service-related diagnostic and performance information, including how you use our Website and performance logs
  • information about your device, including computer type, screen resolution, operating system version, Internet browser, Internet browser version, device identifiers and numbers, hardware settings, and Internet connection speed
  • browsing, searching and buying activity
  • IP address
  • search terms
  • Websites visited and websites you come from and go to next
  • Website feature usage and stored content
  • device location information
  • information collected from cookies and similar technologies

C. Information Provided by Third Parties.

When you access or use certain of our Services, we may obtain the following information from third party sources:

  • business bank account transaction information

III. How We Use Information.

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.

A. Our Services.

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 may communicate with you about our Services and features and let you know about our terms and policies and other important updates;
  • we may use personal information collected about you to provide you with products, services or information that you request;
  • we may share your information with our affiliates and business partners to provide you with specific commercial finance products such as loans;
  • we may target particular advertisements or other content to you based on information we have collected, or you provided;
  • 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;
  • we may also use personal information for our internal business purposes, such as data analysis and audits;
  • we use your information to respond to you when you contact us. Our communications with you, including phone conversations, chats and emails, may be monitored and recorded by us for quality assurance or for legal, regulatory or training purposes; and
  • we verify accounts and activity, and promote safety and security, such as by investigating suspicious activity or violations of our terms, to ensure our Services are being used legally.

B. Web Technologies.

The Websites may use certain web technologies such as “cookies” or “web beacons.” Cookies are data that a web server transfers to an individual’s computer for record keeping purposes. Cookies are an industry standard used by many websites, and can facilitate your ongoing access to and use of a particular website; cookies do not cause damage to your computer systems or files. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular website, to your computer. We use cookies to operate, provide, improve and customize our Services and your experiences. For example, we use cookies to understand which of our Services are most popular and to show you relevant content related to our Services. Additionally, we may use cookies to remember your choices, such as your language preferences. We, our service providers, and/or non-affiliated third-parties, may also use so-called “pixel tags,” “web beacons,” “clear GIFs” or similar means (collectively, “Pixel Tags”) in connection with some Website pages and HTML-formatted e- mail messages to, among other things, compile aggregate statistics about Website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1×1), that is ordinarily not visible to Website visitors and may be associated with cookies on the visitors’ hard drives. Pixel Tags allow us to count users who have visited certain pages of the Website, to deliver branded services, to provide online advertising, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted e-mail messages, Pixel Tags can tell the sender whether and when the e-mail has been opened. These technologies do not collect personal information. We do not honor any web browser “do not track” signals or other mechanisms that provide you the ability to exercise choice regarding the collection of information about your online activities over time and across third-party websites or online services. We use and share this data and information to deliver customized content and advertising, to ensure that you see the correct product information, to manage the frequency with which you see an advertisement, to tailor advertisements to better match your interests, and to understand the effectiveness of our advertising. The content may be delivered on the Websites, by our representatives, and via email, SMS, or push notifications. In addition, if you respond to or interact with a particular advertisement, you may later receive a targeted advertisement as a result of an ad server or ad network concluding that you fit within a particular audience we are trying to reach.

C. Web Analysis.

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.

IV. How We Share Information.

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.

A. Information Shared with Third Parties.

We work with various third-party vendors and partners for a variety of business purposes such as to help us offer, operate, provide, improve, understand, customize, support and market our Services. We may partner with other companies to offer you products or services or to fulfill the products or services that you request. We may disclose personal information and/or non-personal or de- identified information collected about you to such third-party partners for the purposes described in this Policy. We work with third parties who provide services including but not limited to data analysis, list enhancement and other administrative services. We may disclose personal information to such third parties for the purpose of enabling these third parties to provide services to us. Such services may include: marketing distribution, email list management services, advertising, certain product functionalities, customer support, web hosting, customer data management and enhancement, research and surveys, data analysis and email service. When we share information with third parties, we request that all these vendors and partners protect your information and limit their use of the data to the purposes for which it was provided. Certain Services on the Website may be offered jointly by Circl and one of our partners, or just one of our partners. Your customer information may be received by both Circl and our partner that is providing the Service. For these jointly offered Services, you should also review the partner company's privacy policy, which may include practices that are different from the practices described here.

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.

B. Special Circumstances.

We may share information in certain special circumstances. For example:

  • to comply with valid legal process including subpoenas, court orders and search warrants, and as otherwise permitted or required by law;
  • to assist law enforcement in cases involving danger of death or serious physical injury to any person or in other emergencies;
  • to protect our rights or property, or the safety of our customers or employees;
  • to enforce our Terms of Service;
  • to protect against fraudulent, malicious, abusive, unauthorized or unlawful use of our Services and to protect our network, Services, devices and users from such use;
  • to advance or defend against complaints or legal claims in court, administrative proceedings and elsewhere;
  • to prospective purchasers of all or part of our business or assets;
  • to outside auditors, lawyers and regulators;
  • to an affiliate or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings);
  • to permit us to pursue available remedies or limit the damages that we may sustain;
  • for any other purpose permitted by applicable law; and
  • with your consent.

C. Information Shared with Third-Party Advertising Entities or Social Networks.

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.

D. When You Share Information.

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.

V. How to Limit Sharing of Information.

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.

A. Telemarketing.

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.

B. Email, Text Messages and Push Notifications.

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.

C. Online Information.

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.

VI. Other Information.

A. Keeping Children Safe.

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.

B. Security.

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).

C. Contact Information.

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
[Telephone]
[Email]

Please note that email communications will not necessarily be secure; accordingly you should not include sensitive information in your email correspondence with us.

D. Links to and from non-Circl Websites and Content.

The Website may contain links to non- Circl sites. We provide such links only as a convenience, and the inclusion of a link on the Website does not imply endorsement of the linked site by us. If you provide any personal information through any such third-party website, your transaction will occur on the third party’s website (not the Website) and the personal information you provide will be collected by, and controlled by the privacy policy of, that third party. We have no control over these non-Circl sites and are not responsible for the content on these sites or platforms or the privacy policies and practices employed by these sites and platforms. We recommend that you review the policies and practices of the sites you visit. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES.

E. Social Networking.

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.

F. California Customers.

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.

G. Location.

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.

Rights Under the California Consumer Privacy Act.

Last Revised: September 16, 2020

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of SMB Resources LLC (d/b/a Circl) (“we,” “us” or “Circl”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

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.

I. Our Use of Personal Information.

Circl does not sell your personal information to anyone, including to third-parties as defined under the CCPA. The chart below outlines the categories of personal information (which are defined by the CCPA, not us) that we have collected and/or disclosed for a business purpose in the preceding twelve months. The examples of personal information provided for each category are taken from the CCPA and are included to help you understand what the categories mean. The examples are not meant to indicate what we actually collect or disclose, and more information about our specific practices can be found in our Privacy Policy.

Category
We Collect
We Dosclose
We Sell

A. Identifiers

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.

Yes

No

No

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.

Yes

No

No

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.

No

N/A

N/A

D. Commercial Information

Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Yes

No

No

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.

No

N/A

N/A

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.

Yes

Yes

No

G. Geolocation Data

Example: Precise physical location.

No

N/A

N/A

H. Sensory Information

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

No

N/A

N/A

I. Professional or employment-related information

Examples: Job application or resume information, past and current job history, and job performance information.

No

N/A

N/A

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.

No

N/A

N/A

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.

Yes

Yes

No

II. Your California Privacy Rights.

Access to Specific Information and Data Portability Rights

II. Your California Privacy 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:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • isclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights.

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:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights.

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 support@joincircl.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

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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.

Response Timing and Format.

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.

Non-Discrimination.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice.

We reserve the right to amend this privacy notice at our discretion and at any time.

Contact Information.

If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Email: support@joincircl.com
Address: SMB Resources LLC
6611 San Vicente St.
Coral Gables, FL 33146