Welcome to 'Circles Innovation Platform'
- an online virtual innovation website where users can create an innovation ecosystem,
share ideas and respond to other users’ ideas (the Service”).
The Service is owned and operated by CIRCLES IT INNOVATION LTD. (“we”, “our”, “us”, “Circles”).
Through the Service, you may upload content in various forms, such as textual, visual, audio or any
combination thereof (collectively, the “User Content”).
(“you” or “your”).
This policy explains our privacy practices for the Service, including the ways your personal
information is collected and used by us.
The personal information you provide (as described below) depends on your volition and consent.
You are not legally obligated to provide or give access to this information, but we do require it to let
you use the Service.
(the “Terms”) and constitutes an integral part of them.
Information we collect. To create a User Account, you will be asked to provide your full name,
your email account, password, gender and faculty. User Content that you choose to upload to the Service may contain,
or be indicative of, your personal information. Such User Content is not treated as private and you should not have any
expectation of privacy with respect to it, as it may be available to other users of the Service.
Children's Privacy. We do not knowingly or intentionally collect personal information of
minors. If you are a minor, you may not use the Service and may not provide any personal
details to us.
Use of collected information. We use the personal information we collect, to operate and facilitate your use of the Service,
and for other ancillary purposes.
Sharing collected information.Your personal information will be shared with service providers who help us
with the internal operations and administration of the Service.
Retaining and controlling your personal information. You may ask to review the personal information about you
that is stored in our systems, or have us update, correct or delete it, subject to applicable law.
Data anonymization. We may anonymize personal information we have collected,
and use it (in its anonymized form) with others, for any purpose.
Commercial messages. We will send you newsletters and marketing messages via your email or phone, as provided to us. In any event,
you may opt-out of our newsletters and marketing messages by following the instructions within such messages.
Transfer of data outside your territory. We may store and process information in various locations throughout the globe,
including countries that may provide a lower degree of data protection than the laws of your own country.
Information Security. We use measures to secure your personal information,
but they do not provide absolute information security.
Information we collect
Information you actively provide us
Authentication and creating a User Account. To create a user account (“User Account”), you will be asked to provide us with your full name,
your email account, password, your gender and your faculty or organization name.
Content that you post on or to the Service may contain, or be indicative of, your personal
information, depending on the particulars of the content (“User Content”). Such User Content is not
treated as private and you should not have any expectation of privacy or confidentiality with respect
to it, as it may be available to other users of the Service.
BECAUSE THE USER CONTENT YOU UPLOAD MAY HAVE TO DO WITH THE PRIVACY OF OTHERS, YOU
MUST LAWFULLY OBTAIN THE CONSENT OF ALL INDIVIDUALS (AND THE CONSENT OF THE PARENTS
OR LEGAL GUARDIANS OF ALL MINORS), WHO ARE DEPICTED, SHOWN OR REFERRED TO IN THE USER
CONTENT, TO INCLUDE THEM IN THE USER CONTENT AND TO USE THAT USER CONTENT FOR THE
PURPOSES AND IN THE MANNER CONTEMPLATED BY THIS POLICY AND THE TERMS.
IN ANY CASE, USE CAUTION AND COMMON SENSE WHEN YOU UPLOAD USER CONTENT CONTAINING
OR DEPICTING PERSONAL INFORMATION OF YOURSELF OR OTHERS. YOU ARE SOLELY RESPONSIBLE
FOR ANY USER CONTENT THAT YOU UPLOAD.
Contacting us. To contact us via e-mail, you may be required to provide us with personal
information, such as your name and contact details.
You must provide complete, accurate and correct details. If you do not provide the required
information, or provide false, incorrect, or outdated information, we may not be able to process your
request or inquiry or contact you. We may also require additional personal information from you, to
verify your account and identity.
Information we automatically collect
Analytical data. We may collect information about your use of the Service.
For example, we may record the frequency and scope of your use of the Service, the duration of your sessions,
the interactions and communications you make with the Service’s interface, and Content or User Content that
you view or create while using the Service.
Device Information. We may collect information about your personal computer or mobile device, including its model, operating system, unique device identifiers,
mobile network information and the Internet Protocol (IP) address through which you accessed the Service.
We do not knowingly or intentionally collect personal information of minors. If you are a minor, you
may not use the Service and may not provide any personal details to us.
Use of collected information
We use the personal information we collect for the following purposes:
To operate and facilitate the access to and use of the Service, its features and functionalities,
develop, improve and customize the Service, to manage the administrative and operational
aspects of the Service;
To assess your entrepreneurship skills and work with you to help you develop your skills.
To draw conclusions in order to improve and encourage innovation processes within the
Send you administrative updates and announcements, provide you with support, handle
complaints and contact you when we believe it to be necessary, either directly or through others
on our behalf, including by e-mail messages;
Send you newsletters and marketing messages (which you may opt-out of by following the
instructions within such messages);
Enforce the Terms and this Policy and prevent unlawful activities and misuse of the Service;
Comply with any applicable law and assist law enforcement agencies and competent authorities,
when we have a good faith belief that our cooperation with them meets the applicable legal
Take any action in any case of dispute involving you, with respect to the Service.
Sharing collected information
We share personal information outlined in this Policy, with others, in the following instances:
User Content that you upload on to the Service will be shared with, and viewable by, other
users of the Service.
With our service providers, in order to operate, maintain and enhance the Service. These
companies are authorized to use your Information only as necessary to provide these services to
us and not for their own promotional purposes.
We do not sell your Information to third parties.
If you have breached the Terms, abused your rights to use the Service, or violated any applicable
law. Your information may be shared with competent authorities and with any third party, as
may be required;
With third parties to whom we believe that we are required by law to disclose your information;
With attorneys, courts and relevant third parties, in any case of dispute, or legal proceeding of
any kind involving you with respect to the Service;
If the operation of the Service is organized within a different framework, or through another
legal structure or entity (such as due to a merger or acquisition), provided that those entities
agree to be bound by the provisions of this Policy, with reasonably necessary changes taken into
We may share personal information with our corporate group entities (companies that we
control, control us, or are under common control with us – whether directly or indirectly), but
their use of such information must comply with the Policy.
In any case other than the above, your personal information will be shared with others only if you
provide your explicit prior consent.
Retaining and controlling your personal information
Data retention. We retain the personal information we collect for as long as we deem
necessary for our business needs, and delete it thereafter from our systems, without notice to you.
Please remember that the Service does not provide back-up services for any Content.
Accessing, updating or deleting Your personal information. If the law grants you such rights, you
may ask to access the personal information about you that is stored in our systems. You may also ask
for our confirmation as to whether or not we process personal data concerning you.
Subject to the limitations in law, you may request that we update, correct or delete inaccurate or
outdated information, and have us suspend the use of personal data whose accuracy you contest
while we verify the status of that data.
Subject to law, you may also be entitled to obtain from us the personal data you directly provided us
(excluding data we obtained from other sources) in a structured, commonly used and machine-readable format,
and may have the right to transmit those data to another party.
If you wish to exercise any of these rights, contact us at: [firstname.lastname@example.org].
When handling these requests, we may ask for additional information to confirm your identity and
At any time, we may anonymize (de-identify) personal information we have collected. We may use
the de-identified information in any way, including by selling, or making it available, to any other
BY SUBMITTING YOUR CONTACT DETAILS, YOU PROVIDE US WITH YOUR EXPRESS CONSENT TO
RECEIVE COMMERCIAL MESSAGES FROM THE COMPANY OR OTHERS ON ITS BEHALF. AT ANY TIME,
YOU MAY WITHDRAW YOUR CONSENT AND NOTIFY US THAT YOU REFUSE TO RECEIVE COMMERCIAL
MESSAGES, ALTOGETHER OR OF SPECIFIC KIND, BY SENDING A NOTICE OF CONSENT WITHDRAWAL.
THE CHANNELS THROUGH WHICH YOU MAY SEND SUCH NOTICE WILL BE DETAILED IN THE
COMMERCIAL MESSAGES SENT TO YOU BY THE COMPANY OR OTHERS ON ITS BEHALF.
packets of information sent by our servers to your web browser and then sent back by the browser
each time it accesses our servers. The cookies may contain information, such as your interactions
with the Service’s features and functionality, your session durations and IP addresses. We use the
cookies to collect analytical information about your use of the Service.
Cookies are saved on your computer's hard drive. If you wish to block cookies, you may do so
through your browser’s settings. Please refer to the browser's help menu for further information.
HOWEVER, BEAR IN MIND THAT DISABLING COOKIES MAY ADVERSELY AFFECT YOUR USER
EXPERIENCE ON THE SERVICE.
Transfer of data outside your territory
We may store and process information in various locations throughout the globe. We may also
process information using cloud services. In certain cases, the laws in some of these countries may
provide a lower degree of data protection than the laws of your own country. You agree to the
transfer of your information to such other countries for the purpose of processing as described in
this Policy, including through cloud services.
We use measures to reduce the risks of damage, loss of information and unauthorized access or use
of information. However, these measures do not provide absolute information security. Therefore, it
is not guaranteed, and you cannot reasonably expect that the Service and its related databases will
be immune from any wrongdoings, malfunctions, unauthorized interceptions or access, or any other
kinds of abuse and misuse.
We may change this Policy, but putting you on notice of such changes. The most up-to-date Policy is
accessible through on our website, at: [https://circles.eco/privacy ].
If you do not agree to the amended Policy, we may cancel your User Account and terminate your use
of the Service.
You may contact us at any time with any questions or comments you may have with respect to our
Service, at: [email@example.com]