CIRCO Privacy Policy


[Last updated on December 12, 2019]


CIRCO (“CIRCO”, “we”, “us”, “our” and terms of similar meaning) take your privacy rights very seriously. We are committed to transparently describing our privacy practices, including how we collect, use and disclose your information and data as part of the normal operation of our Services, as defined in our Terms and Conditions of Use (“Terms”).


We encourage you to read and understand our Terms and this Privacy Policy before accessing the Site. By accepting the Terms and/or Privacy Policy in registration or by accessing or using the Services (including by visiting the Site), you expressly consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to our Terms. 


All capitalized terms that are not otherwise defined herein obtain their meaning from the Terms. 


What Information Do We Collect?


Our primary purpose in collecting personal information from you is to provide you with a safe, smooth, efficient, and customized experience. This allows us to provide services and features that most likely meet your needs, and to customize our service to make your experience safer and easier. We only collect personal information about you that we consider necessary for achieving this purpose.


Personal and Identifying Information


Users of the Site must provide the requested contact and identity information and other personal information as indicated where appropriate on the Site. Where possible, on these forms we indicate which fields are required and which fields are optional.  In addition, as you use the Site, you can from time to time enter or send to us personal information.


You always have the option to not provide certain personally identifying information by choosing not to become a User or by not using the particular feature of the Site for which the information is being collected.


Information Collected Automatically


When you use the Services, CIRCO automatically receives and records information from your browser or device, including your location, IP address, browser type, operating information, device and Site IDs, cookie information, and the page you requested. Unless otherwise stated in this Privacy Policy, CIRCO only uses this data in aggregate form. 


“Cookies” are small files placed on your hard drive that assist us in providing our Services. We use cookies to allow you to enter your password less frequently during a session, and we use data collection devices, including cookies, on certain pages of the Site to help analyze our web page flow and to offer certain features that are only available through the use of a cookie and to allow us to provide information that is targeted to your interest. 


Information Collected from Third Parties


We may receive and store information that is received from third parties that interact in some way with the Services or that provide services to us. For example, you may choose to connect social media accounts and other third party applications to the Site to enable you to share information. The third party applications may, if you permit, share your personal information and data with CIRCO. 


Please read the privacy policy of any such application so that you understand its privacy practices.


How We Use Your Information


We may use personal information in the file we maintain about you, and other information we obtain from your current and past activities on the Site, to provide to you the Services; resolve service disputes; troubleshoot problems; deliver information to you that, in some cases, is relevant to your interests; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our Terms; provide you with system or administrative messages, and as otherwise described to you at the time of collection. 


We may also use personal information about you to improve our marketing and promotional efforts, to analyze the Site usage, to improve our content and product offerings, and to customize the Site’s content, layout, and services. These uses improve the Site and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Site.


Please see our Terms for information on what we do to account information when you terminate your account with us. 


Our Disclosure of Your Information


We will share your personal information with third parties only in the ways that are described in this Privacy Policy and in accordance with your permissions. We will not sell or rent your personally identifiable information to third parties without your explicit consent. 


The following describes some of the ways that your information may be disclosed in the normal scope of business to provide our services:


Anonymized Aggregated Data. We aggregate and anonymize data and use and disclose such information for a variety of purposes, including analytics. However, in these situations, we do not disclose any information that could be used to identify you personally.


Subsidiaries and Affiliates; Service Providers.  We may from time to time use the services of affiliates, subsidiaries and unrelated service providers in the operation of the Site and the provision of our Services, and may disclose personal information to them in the course of our use of their services.  For example, we may use the services of third-party hosting companies to host the operation of the Site and the Services. This may involve the hosting of data, including personal information, on servers operated by those hosting companies. We may also use service providers to process payments of Users who pay by accepted cryptocurrencies. We take care to use only service providers that we believe are reputable and able to live up to our and your expectations, including about the handling of confidential information.


Law and Harm; Jurisdictions. Notwithstanding anything to the contrary in this policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or any other person’s rights or property. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.  


Sale of Business 


We may also disclose personal information to the acquiror or its agents in the course of the sale of our business.  If we do this, the disclosure will be subject to confidentiality arrangements customary in such transactions.


Storing or Processing Your Data Outside of Canada


Finally, please note that in some cases, personal information that we collect may be stored or processed outside of Canada.  In such cases, we continue to protect the information with appropriate safeguards, but it may be subject to the legal jurisdiction of those countries and governmental authorities in those countries. 


Correcting and Updating Your Personal Information 


Users may review, delete and update their personal information to ensure it is accurate through the Site. Alternatively, Users may contact us at to update or delete their personal information. 


Children’s Privacy


The Services are not intended for children under the age of eighteen (18). CIRCO does not target its Services or the Site to children under eighteen (18). CIRCO does not knowingly collect personal information from children under the age of eighteen (18). 




If applicable, your User Account is protected by a password for your privacy and security. You must prevent unauthorized access to your account by selecting and protecting your password appropriately, and limiting access to your device. The user is encouraged and responsible to enable two factor authentication.


While we strive to protect your information and data we cannot guarantee the security of your User Account information. Unauthorized entry or use, hardware or software failure and other factors, may compromise the security of User information at any time. 


Other Information Collectors


Except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties through the Site, different rules may apply to their use, collection and disclosure of the personal information you disclose to them. Since we do not control the information use, collection or disclosure policies of third parties, you are subject to their privacy policies. We encourage you to ask questions before you disclose your personal information to others.


Managing Communications with CIRCO


All communications made by CIRCO to Users shall be in compliance with all anti-spam legislation and regulation. Users may manage their communication preferences and will be able to unsubscribe from all communications with CIRCO by clicking the appropriate links contained in the footer of all marketing communications made by CIRCO.


You may also manage your communication preferences by e-mailing CIRCO at 


Changes to This Privacy Policy


CIRCO may amend this Privacy Policy from time to time. The use of information we collect is subject to the Privacy Policy in effect at the time the information is used. If we make any material changes in the way we use your personal information or data, we may notify you by e-mailing you at your e-mail address used to register for the Services (if any) and/or by posting an announcement in a visible location on the Site. Users are bound by any changes to the Privacy Policy when they use the Services after such changes have been first posted.




It is our goal to make our privacy practices easy to understand. If you have questions, concerns or if you would like more detailed information, please email our privacy officer at