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Effective: September 24, 2018

Privacy Policy

This privacy policy describes how CastCircle collects uses and discloses information. CastCircle is not in the business of selling your data, and we do not run advertising. We have tried to make our privacy policy as simple as possible.

Applicability

This privacy policy applies to CastCircle’s iOS and Android apps and http://app.castcircle.com web application. If you do not agree to these terms, do not access the services of CastCircle or any other aspect of CastCircle’s business.

Marketing Web Site

Our marketing http://www.castcircle.com website has the additional third-party data collection and tracking from Google Analytics. You can read more about how Google uses data when you use one of our partner sites. We do not use Google Analytics on our apps, or web application app.castcircle.com.

Information we collect

Information you volunteer

CastCircle collects the following information that you voluntarily disclose to us:

1. Customer data - email address and password of customers or individuals that are granted access to a circle

2. Billing information - paid customers provide us with a credit card, banking information, and billing address.

Information that is automatically collected

CastCircle automatically collects information when you use our sites and apps.

1. Service usage. We log your usage of the CastCircle system. For example, your interaction with videos, messages, people, and documents.

2. Log information. We collect log information about your browser’s IP address, Operating System, Versions, Language preferences, plugins.

3. Device data. We collect information about your device to help us improve the stability of our application. We capture device identifiers, device settings, the operating system used, applicationID and crash data.

Cookie information

1. CastCircle stores information in cookies to help the operation of its website. No personal information is stored in our cookies and most cookies are available to improve your user experience.

No one is under a statutory or contractual obligation to provide customer information, however, certain information is collected automatically and if the information is not provided a circle may not be able to be set up.

How we use your information.

Customer data will be used by CastCircle in accordance with Customer’s instructions and to deliver the CastCircle service. CastCircle is the processor Customer data and the customer is the controller.

CastCircle uses customer information to:

1. To provide, update, maintain and protect our service, website, and business. CastCircle requires your customer information to deliver you the CastCircle application and service.

2. As required by applicable law, legal process or regulation . If we are required by law, we may need to inspect your data to respond.

3. To develop and enhance features like search. CastCircle aims to continually improve the effectiveness of its business and uses historical insights and machine learning to improve your experience.

4. To communicate with you by responding to requests comments and questions . If you contact us we need to be able to use your customer information to respond to your issues.

5. For billing and account management. CastCircle may need to contact you for invoicing and billing and to help you manage your users.

6. To investigate and prevent security issues and breaches.We may use your information to keep our apps and site safe and secure.

If the information is aggregated and anonymized so it is no longer associated with an identifiable person then CastCircle may use if for any business purpose.

Data Retention

CastCircle will retain customer data in accordance with the customer’s instructions, and as required by applicable law. Customers can ask CastCircle to change their retention policy by circle or channel. CastCircle may need to keep information after you have deactivated your account for a period of time to pursue legitimate business interests, conduct audits, comply with legal obligations, resolve disputes and enforce our agreements.

How do we share and disclose information

CastCircle will only share and disclose your information in the following situations:

1. Customer instructions.CastCircle will solely share and disclose customer data with a customer’s instruction.

2. Displaying a user’s information for direct messaging and collaboration. A user’s name, email, photo, and other information will be displayed to other people in the circle to allow direct messaging.

3. Customer access. Owners, administrator, and other customer representatives may be able to modify, access or restrict access to a user’s information.

4. Vendors, Consultants, and Third-Party Service Providers.We may engage third party companies or individuals as service providers to process information and support our business.

5. Corporate Affiliates.We may share your information with affiliates, in which case we will require affiliates to honor this privacy policy.

6. Business Transfers. We may share or transfer your information in connection with, or during negotiations of any merger or sale of company assets, financing or acquisition of all or a portion of our business by another company.

7. To comply with laws.We may disclose your information if we are legally required to do so. See our data request policy.

8. To enforce our rights, prevent fraud and for safety.To protect and defend our rights, property or safety of CastCircle or third parties.

9. With your consent.We may disclose your personal information for any other purpose with your consent.

Security

CastCircle takes security very seriously and works hard to protect your information from loss, misuse or unauthorized access. We have implemented appropriate technical and organizational security measures to protect the information we collect. However, due to the nature of communications and information processing technology CastCircle cannot guarantee that information during transmission through the internet or while stored on our systems or otherwise in your care will be absolutely safe from intrusion by others.

Age Limitations

CastCircle is a workplace app and to the extent prohibited by applicable law, CastCircle does not allow the use of our services and website by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us at dpo@castcircle.comso that we can take steps to delete this information.

Changes to this privacy policy

CastCircle may change this privacy policy from time to time. Laws, regulations and industry standard evolve, which may make those changes necessary. We will post the changes to this page and we encourage you to visit frequently. If we make changes that materially alter your privacy rights, CastCircle will provide additional notice via email.

International Data Transfers

CastCircle may transfer your personal data to countries other than the one you live in. If CastCircle transfers personal data originating from the European Union or Switzerland to other countries who may not have as comprehensive protections as your country, CastCircle will endeavor to take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.

EU-US Privacy Shield Framework.

CastCircle complies with EU-US Privacy Shield framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. These frameworks were developed to enable companies to comply with data protection requirements when transferring personal data from the European Union and Switzerland to the United States. For more information, including the types of Information covered, see CastCircle US’s Privacy Shield Notice. To learn more about the Privacy Shield Program, please see .

Data Protection Office

To communicate with our Data Protection Office, please email dpo@castcircle.com

Your rights

In some countries and regions like the European Economic Area, you have certain statutory rights in relation to your personal data. You have to right to:

1.request a copy of your personal information,

2. to request rectification or erasure or

3. to restrict the processing of your personal information

4. if applicable, data portability

In certain circumstances, you may have the right to object to the processing of your personal information. If you would like to make a request, please email dpo@castcircle.com.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict CastCircle’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority Commissioner. If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to our lead supervisory authority:

European Data Protection Supervisor

Rue Wiertz 60

1047 Bruxelles/Brussel

Office: Rue Montoyer 63, 6th floor

Tel. +32 2 283 19 00

Fax +32 2 283 19 50

e-mail: edps@edps.europa.eu

Contacting CastCircle

Please also feel free to contact CastCircle if you have any questions about this Privacy Policy or CastCircle’s practices, or if you are seeking to exercise any of your statutory rights. You may contact us at support@castcircle.com or at our mailing address below:

CastCircle Inc

123 Mission St

Fl 16

San Francisco, CA 94105

USA

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