Privacy Policy

My Circle Green® and its subsidiaries (collectively, the ‘Company,’ ‘We’, “Our” or ‘Us’) are committed to protecting and respecting your privacy. This privacy policy (‘Statement’) sets out how We use, share and protect the personal data or personal information (‘Personal Data’) information we collect about you, and rights you may have regarding this information.  This Statement does not cover information we collect about employees, independent contractors, job applicants, or people with whom We transact or communicate in their capacities as representatives of businesses with which we do business. 

Personal Data means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. 

We may change this Statement from time to time by updating this page. If We make any material changes to this Statement, we will notify you by including a prominent notice on the website before the changes are effective.  Please check this page from time to time for updates. By using our websites, blog, subscribing to our newsletter, taking our quiz, becoming an affiliate partner, and using any of our other services, you consent to our collection and use of your Personal Data as described in this Statement.  

> Legal basis for processing personal data:
We may use Personal Data for our legitimate business interest that include marketing our goods and services, running Our business, as well as engaging and developing great talent. Our processing of Personal Data collected from Our website is based primarily on this justification. However, some uses of Personal Data is necessary to comply with applicable legal or regulatory requirements.

> Types of personal data we collect:

This section describes the categories of Personal Data we may have collected about you in the past 12 months.  It also describes the categories of Personal Data we may continue to collect and our uses of it. Contact information and other identifiers, such as your name, email address, phone number, physical addresses, date of birth (optional) account number if applicable, and identifying information of people that you refer to us.

• Unique device and online identifiers, such as IP address, device IDs, browsing history, geographical information and other similar identifiers.
• Demographic information, such as age, family member information.
• Commercial and financial information, such as records of products or services purchased, obtained or considered.
• Internet or other electronic activity information, such as information regarding your interaction with our website or application, calls and emails sent and received.
• Audio, electronic, visual, thermal, or olfactory information, such as photographs you provide to us or post on Our website.
•  Educational, professional information, individual profiles, preferences, characteristics, behavior, geolocation, income, and collagen usage from surveys we conduct. 

> Sources from which we collect personal data:

We collected the categories of Personal Data described above from the following sources: you or other individuals who may have provided your name or contact information to Us in connection with a referral program and automated collection on Our websites and applications, including through cookies as described in greater detail below.  Even though We can automatically process Personal Data, We will not use solely automated means of processing your Personal Data in such a way to have any significantly adverse impact to you.

Please note that information which cannot reasonably be related to you, directly or indirectly, is not considered Personal Data and is not subject to this Statement. 

> How we use the information we collect:

With respect to each of the categories of Personal Data above, this section describes the reasons We may have collected and used such data in the past 12 months and how We may continue to collect and use it:

• To ensure that content from Our website is presented in the most effective manner for you and for your computer.
• To provide you with the information, products and services that you request from us or which we feel may interest you.
• To facilitate your participation in interactive features of Our website.
• To notify you about changes to what we do.
• To protect the integrity of Our website, Our services, and Our reputation.
• To prosecute or defend legal claims.
• To protect other users of Our website, and to ensure no unlawful or unethical activity occurs through Our systems.

We may also use your Personal Data, or permit selected third parties to use your Personal Data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by post or telephone.

We will not sell, distribute or lease your Personal Data to third-parties except as described in this Statement, as permitted by law, or are required by law to do so. We may use your Personal Data to send you promotional information about third-parties which we think you may find interesting if you tell us that you wish this to happen.

If you do not want us to use your Personal Data in this way, or to pass your details on to third-parties for marketing purposes, please indicate your choice on the relevant box on the form when we collect your Personal Data.  You may also contact us at customerservice@mycirclegreen.com to notify us of your preferences in this regard.

> Categories of third-parties with which we have shared Personal Data:

We have in the last 12 months disclosed for a business purpose and may continue to disclose for a business purpose (to the extent relevant to the purpose for which we collect Personal Data), the categories of Personal Data above with the following categories of third parties:

• Service providers, including payment processors, entities that facilitate shipping, and providers of customer relationship management tools, information technology providers, companies that facilitate connections with Our customers and their referrals.
• Third-parties to comply with legal or regulatory obligations or in response to valid legal requests, to detect and protect against fraud or any technical or security vulnerabilities, to respond to an emergency or otherwise to protect the rights, property, safety, or security of our business, third-parties, or the public.
• Our internet, IT, telecommunications and other service providers, including legal advisers, accountants, payroll administrators, client relationship management services, insurance and employee benefits providers and administrators.
• Any person, as directed by you; or
• Any person to whom we transfer any of Our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of Our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee.

> Categories of personal data we sell:

We do not sell Personal Data obtained about Our customers or other consumers.   

> Security:

We aim to protect Personal Information by implementing and maintaining reasonable security, such as by using reasonable organizational, technological and physical safeguards appropriate to the sensitivity of the Personal Information we hold.  We take measures, which are at least as strict as the law requires, to safeguard your Personal Information, but we cannot guarantee its absolute security.

> How we use IP addresses and cookies:

Like most websites, Our website uses cookies and web beacons principally to enhance your viewing experience.  A cookie is a piece of data that Our website automatically transfers to the hard drive of your PC or mobile device when your browser accesses our website. Some cookies and similar technologies will maintain Personal Data. Some do not.

You can find out more about this type of technology through your internet browser.

You may refuse to accept cookies by changing the settings on your browser. Your browser will tell you in simple terms how to do this, usually through a ‘help’ section. If you are at all uncertain about how to do this, your browser manufacturer should be able to show you how. However, if you change the settings to refuse cookies you may be unable to access certain parts of Our website. Unless you have adjusted your browser settings so that the browser refuses cookies, Our system will issue cookies when you log on to Our website. 

The system may also use web beacons which are similar but not identical to cookies in the way they operate. You can find out more about web beacons on Wikipedia.

If you are only browsing Our website and have not logged in, we will not ask you to directly submit in any Personal Data. However, certain information (which may be considered Personal Data) – including computer and connection information, browser type and version, operating system and platform details and the time of accessing the website – will be automatically collected. This technology helps us to improve Our website and to deliver a better and more personalized service. It helps us:

• To estimate Our audience size and usage pattern.
• To store information about your preferences, and so allow Us to customize Our website according to your individual interests.
• To speed up your searches.
• To recognize you when you return to Our website.
• We do use third-party cookies on Our website, as well as third-party provided web beacons. This is to help Us and Our partners track your interests and make sure that any advertising content you may receive as a result of your visits to this site are relevant to your interests.  For information on all of these categories of cookies, and for more information generally on cookies please refer to aboutcookies.org.

We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”).  Google Analytics uses cookies to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States.  Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity, and providing other services relating to website activity and internet usage for us and our affiliates. Google may also transfer this information to third-parties where required to do so by law, or where such third-parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.  You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.

To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device.

Advertisements on third-party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-personal information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes.

> How We respond to Do Not Track Requests:

The major browsers have attempted to implement the draft “Do Not Track” (“DNT”) standard of the World Wide Web Consortium (“W3C”) in their latest releases. As this standard has not been finalized, Our website is not compatible with DNT.  We do not recognize DNT instructions or any other automated browser signals regarding tracking mechanisms.

> Where We store your data:

Our primary servers are in the United States of America. Data may also be processed by staff around the world working for us, or for one of Our suppliers. These staff maybe engaged in, among other things, the fulfillment of your information requests, or the provision of support services. By submitting your Personal Data, you agree to this transfer, storing, or processing. We will store Personal Data we collect about you as long as it is necessary to fulfill the purposes for which we collected it or where there is a legal obligation – laws or regulations that may set a minimum period for which we have to keep your Personal Data.

> Links to other websites:

Our website may contain links to other websites of interest. However, once you have used these links to leave Our website, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Statement. You should exercise caution and look at the privacy statement applicable to the website in question.

> Personal Data of minors:

Our website is not directed to minors under the age of 18.  We do not knowingly collect or sell the Personal Data of minors under 18. 

> Controlling your Personal Data:

You may also choose to restrict the collection or use of your Personal Data in the following ways:

• Whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes.Click here
• If you have previously agreed to Us using your Personal Data for direct marketing purposes, you may change your mind at any time by writing to or emailing us at customerservice@mycirclegreen.com

> California residents’ rights:

If you are a California resident whose information is covered by the California Consumer Privacy Act (“CCPA”), you may have the following rights. The CCPA includes exemptions from certain of its provisions for information about our personnel (including employees, directors, officers, and contractors) and job applicants as well as information processed exclusively in the business-to-business context (e.g., information about an individual acting in his or her capacity as a representative of an entity). 

> Right to request disclosure of Personal Data:

You can submit a request to Us for the following Personal Data:

• The categories of Personal Data we’ve collected about you.
• The categories of sources from which we collected the Personal Data.
• The business or commercial purposes for which we collected or sold the Personal Data.
• The categories of third-parties with which we shared Personal Data.
• The categories of third-parties to whom we sold Personal Data.
• The specific pieces of Personal Data we collected.

We are also committed to ensuring that you know what information we share about you.  You can submit a request to Us for the following further information: 

• The categories of Personal Data we have sold about you, and the categories of third-parties to which we have sold that data.
• The categories of Personal Data that we have disclosed about you for a business purpose. 

Our responses to any of these requests will cover the 12-month period preceding our receipt of the request.  Note that requests can be submitted on behalf of yourself individually or on behalf of your household, provided that we can verify that the request comes from each member of your household.

> Right to request deletion of Personal Data:

Upon request, We will delete the Personal Data we have collected about you that is covered by the CCPA, except for situations where specific information is necessary for us to: provide you with a product or service that you requested; perform a contract We entered into with you; maintain the functionality or security of our systems; or comply with or exercise the rights provided by the law. The law also permits Us to retain specific data for our exclusively internal use, but only in ways that are compatible with the context in which you provided the data to Us or that are reasonably aligned with your expectations based on your relationship with Us.

> How to exercise your CCPA rights:

To exercise your right to request the disclosure of your Personal Data, to ask us to delete your Personal Data, either email us at customerservice@mycirclegreen.com or contact us at 1 866 770 8658.  Depending on the nature of your request, We may ask you for information to verify your request and identity and a declaration attesting to your identity, signed under penalty of perjury. We will respond to requests for access or deletion as soon as practicable and in any event generally not more than within 45 days after receipt of your request.  We may extend this period to 90 days in some cases. Please note that you may designate an agent to submit requests on your behalf. 

> Shine the Light:

California Civil Code Section 1798.83 requires any operator of a website to permit its California-resident customers to request and obtain from the operator a list of what personal information the operator disclosed to third-parties for direct marketing purposes, for the preceding calendar year; and the addresses and names of such third-parties. Should you desire a list of those entities we share Personal Data collected from this site with third-parties for their direct marketing purposes, please contact us at customerservice@mycirclegreen.com

> Your rights

In addition to the rights spelled out in this Statement, in some countries you may have the right to exercise a number of legal rights in relation to restricting the processing of your personal information that we hold about you and you can exercise your rights by contacting us using the details set out below. 

These rights include: obtaining and accessing information regarding the processing of your personal information, requesting that We erase your personal information in certain circumstances, objecting to, and requesting that We restrict Our processing of your personal information in certain circumstances, lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by Us. We can, on request, tell you which data protection authority is relevant to the processing of your personal information. You can exercise those rights by emailing customerservice@mycirclegreen.com

Please note that whilst you may exercise these rights, there may be circumstances where We are legally entitled to refuse a request to exercise your rights. Generally, this is when your attempt to exercise your rights infringe on another’s rights, or when We must retain certain types of information for business or legal purposes.

If you believe that any information We are holding on you is incorrect or incomplete, please email Us as soon as possible, at customerservice@mycirclegreen.com We will do Our best to promptly correct any information found to be incorrect.

> Honoring your rights:

We are committed to complying with the law.  If you exercise any of the rights explained in this Policy, we will continue to treat you fairly. 

> Accessibility:

We are committed to ensuring that our communications are accessible to people with disabilities.  To make accessibility-related requests or report barriers, please contact us at 1 866 770 8658 or customerservice@mycirclegreen.com

>> Contact us

If you have any questions about this Statement, please contact us.

Call us at 1 866 770 8658 – A customer service representative will answer your questions between 9:00AM and 5:00PM PST, Monday through Friday, except holidays. Or submit a request online at customerservice@mycirclegreen.com