Advisor Privacy Policy

Information on the processing of personal data of Advisors – TheCircle

The site www.thecircle.com (hereinafter “the platform” or “the site”) is owned by adviqo UK Limited, a company registered in England and Wales with company number 03487227 whose registered office is at Anglia House, 6 Central Avenue, St Andrews Business Park, Thorpe St Andrew, Norwich, Norfolk. NR7 0HR (referred to herein as "We", "Us" or "Ours") and whose VAT registration number is GB 896109096

This information on the processing of personal data is aimed at those who use the website https://www.thecircle.com or the TheCircle application.

If you are an Internet user and want to know the information regarding the processing of your personal data on TheCircle, please read the information on the processing of personal data addressed to users.

The purpose of this document is to inform on how the personal data of Advisors are processed by TheCircle and on how to exercise the rights in the matter.

To have a precise view of the various types of personal data processing used on our site, please read this document in full.

For a simple overview of the various types and main characteristics of personal data processing used by TheCircle, below you will find a summary diagram containing the list of all types of personal data processing in question.

In order for you to understand all the terms in this Personal Data Processing Policy, you will find a glossary of the main terms used in the first part of the document.

For any questions or comments relating to the processing of personal data, you can write to us at the following email address: [email protected]

You can request the erasure of your personal data at any time. To do so, simply send an email to [email protected] specifying your request. We will then erase all your personal data from our database and send you a confirmation email

SUMMARY

• Definitions
• Who is responsible for processing personal data?
• What personal data does TheCircle process and when is it recorded?
• Why does TheCircle process personal data?
• What are the legal bases for processing personal data?
• Are Advisors required to provide their personal data?
• How can I manage my cookie preferences?
• How long will personal data be kept?
• Is my personal data protected?
• Where is personal data recorded?
• With whom is personal data shared?
• Who are the recipients of personal data?
• What are my rights in relation to personal data?
• Changes to this Personal Data Processing Policy

Definitions

Personal data: any data that makes it possible to directly or indirectly identify a natural person

Processing of personal data: any operation concerning the use of personal data (consultation, extraction, storage, transfer, etc.)

Data processor: the body that determines the purposes (why) and means (how) of processing personal data

Sub-processor: the body that processes personal data on behalf of and under the instruction of the Data Processor

Recipient: the natural or legal person, public authority, service or other body that receives communication of personal data, whether or not a third party

Purpose: the objectives pursued through the processing of personal data

Legal basis or “legal grounds”: basis established by law which legitimises the processing of personal data in a specific situation.

Who is responsible for processing personal data?

The data controller is the adviqo UK Limited, a company registered in England and Wales with company number 03487227 whose registered office is at Anglia House, 6 Central Avenue, St Andrews Business Park, Thorpe St Andrew, Norwich, Norfolk. NR7 0HR (referred to herein as "We", "Us" or "Ours") and whose VAT registration number is GB 896109096

You can contact TheCircle:

• By post at the above address
• By email at the following email address: [email protected]

What personal data does TheCircle process and when is it recorded?

Under current legislation, personal data collected and processed by TheCircle must be adequate, relevant and limited to what is necessary for the purposes of their processing.

The nature of the personal data collected varies according to the context that justifies its collection.

In any case, we will inform you of the collection of your personal data by indicating at least the identity of the controller, the purpose(s) pursued as well as your main rights regarding personal data.

For example, when registering on the site https://Advisors.thecircle.com, the following personal data will be requested from you:

• Gender
• First name/Last name
• Date of birth
• Email address
• Landline or mobile phone number
• Postal address
• Professional activity carried out

In conjunction with the personal data communicated directly, we may also collect personal data without direct communication; while browsing our site, subject to your consent, we use cookies in order, specifically, to create a profile, put you in contact with Advisors and users, connect more quickly, compile statistics and offer you relevant advertising.

The use of cookies implies the collection of the following personal data:

• Browser used
• Device used
• IP address
• Browsing data

Further information relating to the cookies used can be found in art. 7 of this article.

Why does TheCircle process personal data?

All personal data is collected for specified, explicit and legitimate purposes, and not further processed in a way that is incompatible with those purposes.

The purposes vary according to the processing.

In general, personal data is collected and processed by TheCircle for the following purposes:

• Membership and Advisor profile management on https://www.thecircle.com
• Contacts with users
• Management of services
• Payment management
• TheCircle's accounting
• Contacts between Advisors and Client Services via the site's chat
• Contacts between Advisors and Client Services via the contact form on the site
• Contacts between Advisors and Client Service by post, email or telephone, within the framework of the performance of the contract
• Processing, verification and publication of user comments
• Handling of grievances and complaints
• With prior consent, recording of conversations with users
• Subject to consent, sending of newsletters
• Subject to consent, sending of commercial offers
• Subject to consent, use of cookies in order to create a profile, put you in touch with Advisors, connect more quickly, compile statistics and offer you relevant advertising.
• Site fraud prevention
• Respond to requests from Advisors to exercise their personal data rights
• Creation of statistics

Personal data will not be processed for any purpose without first informing Advisors and, if necessary, without asking for their consent.

• What are the legal bases for processing personal data?

The current regulation establishes that the processing of personal data must be based on a legal basis. The legal basis is what legally authorises the processing of personal data.

The regulation provides for various legal bases capable of justifying the processing of personal data such as consent, the need for the processing with respect to the performance of the contract or compliance with a legal obligation.

The personal data processed by TheCircle is based alternatively on the following legal bases:

• The necessity of the processing for the purpose of performing the concluded contract or related pre-contractual measures between the Advisor and the company: for example, when data relating to identity and details are collected to manage the registration or data such as email address to contact you to communicate with you about a service you have provided
• Compliance with legal obligations: for example, when we keep invoices for accounting purposes
• Subject to explicit consent: for example, when email addresses are used to send newsletters or commercial offers
• The legitimate interests of the company: in particular, when we keep logs of our website connection for security and fraud prevention purposes

The legal basis for the processing of personal data also varies in relation to the processing itself.

To find out the legal basis associated with each processing of personal data, you can consult the summary table shown in the introduction.

Are Advisors required to provide their personal data?

In general, there is no obligation to provide your personal data.

However, the communication of some personal data is necessary in order to access the services offered by the site.

For example, the inclusion of an email address is mandatory in order to allow exchanges between the company and the Advisor in the context of the performance of the contract.

These data are identifiable by the presence of an asterisk “*”.

In the event of failure to provide the above data, access to the services in question will not be guaranteed.

How can I manage my cookie and social network preferences?

On our platform, cookies are used to create a profile, put you in contact with Advisors, connect faster, compile statistics and offer you relevant advertising.

Cookies are small files that are stored on the user's hard disk by the server of the site visited or by a third-party server.

When you visit our site for the first time, the banner that appears on the screen allows you to make a choice about the use of cookies on the site.

In this way, you will have the possibility to accept the use of cookies, refuse them or even customise your preferences.

In order to make the choice and get more information about the use of cookies, you can consult our Policy on the use of cookies.

In the absence of your prior consent, TheCircle will only use cookies that are necessary for the website to function.

Furthermore, the site contains various links to social networks whose activation can generate the registration of cookies by the third-party companies in question.

Similarly, we will systematically request your consent before registering or transferring data to third parties.

How long will personal data be kept for?

Personal data is kept only for the time necessary to pursue the purposes that justify its collection.

The retention period varies according to the type of data and processing.

At the end of this period, and unless expressly indicated otherwise by the Internet user, personal data will be deleted.

To find out the retention time based on the processing, you can check it in the summary diagram shown in the introduction of this document.

If the Advisor decides to cancel the personal data before the deadline, they can send their request by the methods indicated in article 13 of this Personal Data Processing Policy.

Is my personal data protected?

In order to protect personal data, we have adopted physical and logical security measures which allow us to guarantee, as far as possible, its protection and confidentiality.

For further information regarding the protection of personal data, please do not hesitate to contact us.

Where is personal data recorded?

The data is transferred to third countries outside the UK or EEA (e.g. to the USA). This is done in principle on the basis of statutory contractual provisions and, if necessary, additional technical and organisational guarantees to ensure adequate protection of your data, which you can consult upon request. In some cases, we may also base this data transfer on consent.

As a result of our global business activities, your personal data will also be transferred to, among others, affiliates located outside the EEA. In some cases, the staff of some service providers may also be located outside the EEA.

We have entered into a data transfer agreement with our affiliates which govern the cross-border transfer of your personal data within the group. This agreement is based on the standard contractual clauses of the European Commission, which you can find here - https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX:32021D0914&locale=en.

If third parties transfer your personal data outside the EEA, we will take steps to ensure that your personal data receives an adequate level of protection, for example by entering into data transfer agreements or ensuring that the third parties are certified in compliance with appropriate data protection rules.

With whom is personal data shared?

With our affiliated companies. Due to our global business activities, your personal data will also be transferred to affiliated companies, among others. "Affiliated companies" are legally independent companies that are affiliated with us under company law and/or are part of the same group of companies. For the purposes of data transfer, this refers to adviqo GmbH (Germany), Ingenio Europe GmbH (Germany) and Ingenio, LLC (USA).

The personal data processed by TheCircle may be shared with third-party companies in the following cases:

• In the event that the services of a Sub-processor are used for the pursuit of the purposes of processing

In this case, an agreement is stipulated between TheCircle and the sub-processor in order to regulate the processing of personal data which may be carried out by the latter upon delegation by us.

• If you use the services of intermediary providers who host our databases (hosting)

If needed, the hosting of our databases is the company Jaguar Network, with registered office in France, 71 avenue André Roussin, 13016, Marseilles

• If the law provides for it, personal data may be forwarded to follow up on disputes and to comply with the obligations established by administrative and judicial procedures
• If the TheCircle company is involved in a merger, acquisition, asset transfer or receivership procedure, it may have to transfer or share all or part of its assets, including personal data. In this case, Advisors will be informed before personal data is transferred to third parties.

In any case, TheCircle undertakes to:

• Only forward personal data if necessary and once the purposes of the processing have been achieved
• Only forward personal data to providers who have sufficient guarantees to ensure the protection of personal data
• Strictly regulate the processing of personal data carried out, on our behalf, by sub-processors
• Not sell personal data or, in general, never use them for purposes incompatible with the initial processing

Who are the recipients of personal data?

The recipients of personal data are:

• Our sales and marketing teams
• Our accounting teams
• TheCircle Internet users interested in placing an order with a Advisor

As a result of our global business activities, your personal data will also be passed on to affiliated companies, among others. “Affiliated companies” are legally independent companies that are affiliated to us under company law (see §§ 15 ff. of the German Stock Company Act) and/or belong to the same group of companies. For data transmission, this includes viversum GmbH (Germany), Ingenio Europe GmbH (Germany), Barges Technologies, Inc (USA), Horoscope.com Inc. (USA), Peer Labs LLC (USA) and Ingenio, LLC (USA).

What are my rights in relation to personal data?

Given our activity, we need to perform different types of processing of personal data. However, Advisors remain the owners of their personal data and manage its use.

For this reason, Advisors have the following rights regarding personal data:

• Right to access to all of their personal rights processed by TheCircle, within the limits of the rights and freedoms of others
• Right to update or rectify the data provided
• Right to request the erasure of personal data pursuant to EU Data Protection Regulation (EU GDPR) and the UK Data Protection Regulation (UK GDPR), in particular when personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed, when the data subject withdraws consent or objects to the processing
• Right to object to the processing if there is no overriding legitimate reason for TheCircle to proceed with the processing or the right to request its limitation
• Right to withdraw consent when this does not affect the legality of the processing
• Right to data portability, or the possibility of requesting that the personal data processed by TheCircle be forward using an interoperable format, provided that such processing is carried out with the consent of the data subject or by contract
• Right to not be subjected to a decision based solely on the automated processing of data that causes legal effects or significant effects on the data subjects, provided that this decision is not necessary for the conclusion or execution of the contract, that it is not legally authorised or that the data subject has not given consent.

To exercise your rights, you can contact us:

• By email to: [email protected]

• By post at: adviqo UK limited, TheCircle, 117 Waterhouse Business Park, Chelmsford, CM1 2QE, United Kingdom.

As part of the processing of your request, we may request an identity document in order to verify the truthfulness of the information provided and to protect your personal data.

In any case, TheCircle undertakes to provide an answer within one month, this can be extended to two months depending on the complexity and number of requests.

Finally, it should be remembered that, in the event of a dispute regarding the processing of personal data, Advisors can lodge a complaint with the competent judicial authority. In the UK, the authority to which you can lodge a complaint is the Information Commissioner's Office (ICO), and the link to access the website is as follows: https://ico.org.uk/

• Changes to this Personal Data Processing Policy

TheCircle reserves the right to make any changes to this Privacy Policy at any time. TheCircle undertakes to inform data subjects by all reasonable means of any changes made to this document. The date of the last update will be systematically published at the end of this document.

Data subjects will be informed of the change, where possible, as soon as possible and before the effective date. If the Advisor does not agree with the terms in the new version, s/he can request the erasure of their personal data.

Last update 2^nd of March 2023