Your privacy is important to us. DemandCircle is committed to protecting your privacy while providing you with an exceptional online experience. This policy applies to information collected by us on our website.

This Privacy Statement, including GDPR privacy compliance, describes:

1. Why we collect personal information.
2. What personal information we collect and when it is collected.
3. How your information is used and protected.
4. How we collect and use your personal data.
5. When and with whom your information is shared.
6. Your choices regarding your personal information.

By using this Website, you consent to the data practices described in this Privacy Policy. We will post notices of all changes that materially affect the way in which your personally identifiable information may be used or shared in updates to our Privacy Policy. If you continue to use the Website after these notices of changes have been posted to the site, you hereby provide your consent to the changed practices.

If you have any questions about this Privacy Policy, please feel free to contact us through our Website or write to us at:

Data Privacy Officer 
DemandCircle, Inc.
8 The Green, Ste A,
Dover, Delaware 19901, USA
Email: dpo@demandcircle.com

Data Protection Officer (DPO): DemandCircle has appointed a Data Protection Officer (DPO) to oversee data protection and GDPR compliance. You can contact the DPO at the provided email address.

Information We Collect

1. Personal Information You Give Us

We collect personal information when you voluntarily provide it to us through specific forms provided on our website. In general, you may browse our website without providing any Personally Identifiable Information about yourself. We do automatically collect certain information when you visit our website, such as the type of operating system, the pages browsed, the type of browser you are using, and your IP address to provide better usability and a personalized experience.

The information we collect from you may include:

• Your name
• Your e-mail address
• Your phone number

You agree that the personal information you provide to us is reliable for its intended use, accurate, complete, and current. You will notify us of any changes to the personal information you have provided to us.

2. Automatic Information

Like many other websites, we also collect information through cookies and other automated means. Cookies are commonly used by websites to save data on your computer. The information we collect from cookies may include your IP address, browser, and device characteristics, referring URLs, and a record of your interactions with our Website. We use cookies to create a more personalized experience on our Website. We will respect your choices relating to online tracking, whether you choose to reject individual cookies or set your web browser to reject cookies and other tracking technology. However, refusing a cookie may, in some cases, preclude you from using, or negatively impact the display or function of, the Service or certain areas or features of the Service.

Our application collects cookies and uses them for the following purposes:

• Required cookies
• Functionality cookies

We do not collect data categorized as sensitive personal data under GDPR under Article 9, such as race or ethnic origin, biometric, medical, political opinions, religious or philosophical beliefs, or trade union membership.

Identity and Contact Details of the Data Controller

DemandCircle is the Data Controller and is committed to protecting the rights of individuals in line with the new General Data Protection Regulation (GDPR).

Legal Basis for Processing Any Personal Data

To meet DemandCircle’s contractual obligations to its clients and to also respond to client inquiries.

Legitimate Interests Pursued by DemandCircle and/or Its Clients

To provide lead generation, email Marketing, appointment setting, call center services, and advanced IT/back-office solutions.

Sources of Personal Data

DemandCircle collects personal data from various sources, including vendor portals. We also collect some personal data directly from individuals who contact us to request changes or updates to data in our databases.

How We Use the Information We Collect

Registration forms on our website require you to provide accurate contact information, which helps us deliver a high-quality service. By checking the box on the registration form and submitting your details, you are indicating your consent to receiving marketing emails from us. Personally identifiable information that you provide (such as name, email address, telephone number) may be used to send you information about our company, products, services, special offers, and newsletters. To view or modify information previously submitted or to opt-out of receiving future communications, click the personalized link provided at the bottom of the email communication you receive.

How We Share the Information We Collect

The personal data which we collect will be used for the following purposes:

• To subscribe to our email notifications and/or newsletters
• For marketing communication – email marketing
• For sales-related communication

The legal basis for this is the consent that you may provide to us as contained in the Consent section of this privacy policy.

Categories of Recipients

DemandCircle may, on occasions, pass your Personal Information to third parties exclusively to process work on its behalf. DemandCircle requires these parties to agree to process this information based on our instructions and requirements, consistent with this Privacy Notice and GDPR.

On receiving your explicit consent, we may also pass your information to our client under contractual obligation to allow them to process the data as needed and as agreed with DemandCircle. We may also disclose your Personal Information to meet legal obligations, regulations, or valid governmental requests.

Sometimes we may be required to share personal information in response to a regulation, court order, or subpoena. We may also share information when we believe it’s necessary to comply with the law or to respond to a government request or when we believe disclosure is necessary or appropriate to protect the rights, property, or safety of DemandCircle, our customers, or others, to prevent harm or loss, or in connection with an investigation of suspected or actual unlawful activity.

We may also share personal information in the event of a corporate sale, merger, acquisition, dissolution, or similar event, in which case we will require any such buyer to agree to treat your information in accordance with this Privacy Policy.

Non-disclosure of Personal Information

We will not sell, share, or otherwise distribute your personal information to third parties except as provided in this Privacy Policy. We may disclose your Personal Data to our partners and affiliates that agree to treat it in accordance with this Privacy Policy.

Details of Data Storage

Your Personal data is stored in on-premise CRM which has built-in secure Role-based data access. Audit logs are available to identify any potential data breaches.

Our clients are also based in the USA, Canada, and the EU. Some of our clients are part of the Privacy Shield program, and we ensure that our clients in the USA provide an adequate level of data protection as mandated by GDPR.

Apart from this, we at DemandCircle have adopted and implemented adequate information system controls and rules as required by GDPR to ensure effective levels of data protection, particularly relating to transfers of personal information outside the EEA.

International Data Transfers: We may transfer your personal data to recipients located outside the European Economic Area (EEA). When we do so, we ensure an adequate level of data protection in accordance with GDPR requirements, including the use of Standard Contractual Clauses or other lawful mechanisms.

Privacy Impact Assessments (PIAs): We conduct privacy impact assessments for high-risk data processing activities to identify and mitigate potential risks to data subjects.

Data Protection by Design and by Default: DemandCircle is committed to implementing data protection measures as an integral part of our processes and systems to ensure data protection by design and by default.

Data Breach Notification: We have procedures in place to promptly identify, report, and manage data breaches in compliance with GDPR requirements.

Records of Processing Activities: DemandCircle maintains records of processing activities as required by GDPR.

Supervisory Authority: If you have concerns about our data processing activities, you have the right to lodge a complaint with the data protection supervisory authority.

Updates: We will inform users of updates to the privacy policy and when such updates will take effect.

User Consent Mechanisms: We rely on user consent for processing data. You can provide and withdraw consent by following the procedures outlined in this privacy policy.

Protection of Minor’s Information

The website is not directed to children under the age of sixteen (16). DemandCircle does not knowingly solicit PII from or market to anyone under sixteen (16) years of age. If you believe that we have received information from a minor, please notify us immediately, and we will ensure that reasonable efforts will be made by us to delete such information from our database.

Our Commitment to Security

DemandCircle utilizes appropriate physical, technical, and administrative procedures to safeguard the information we collect. We take reasonable steps to ensure that all dealings in personally identifiable information are processed fairly and lawfully after receiving the consent of the information provider.

Your Choices Regarding the Information We Collect

We give you access to your personal information. You may choose to:

• Stop receiving marketing or promotional e-mails, direct mail, or other marketing communications.
• Update, correct, or amend your personal information.
• Opt-out of having your personal information disclosed to a third party or used for a purpose that is incompatible with the purpose(s) for which it was originally collected or subsequently authorized by you.
• Cancel your account or request that we no longer use your information to provide you services.
• Request removal of your personal information from our Website.

To do any of these, simply notify us of this decision by one of these methods:

• Follow the unsubscribe link in any marketing email or following the directions included in any other promotional material received from DemandCircle.
• Send an email to us at customerservice@demandcircle.com.
• Write to us at:

DemandCircle Inc.
8 The Green, Ste A,
Dover, Delaware 19901
Attn: Customer Service/Privacy

Please note that any opt-out request sent via postal mail may take at least sixty (60) days to become effective.

Links to Other Websites

Our website may contain links to other websites, many of which have their own privacy policies. Be sure to review the privacy policy on the site you’re visiting.

Changes to this Privacy Policy

Please note that this Privacy Policy may change from time to time. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice. Each version of this Privacy Policy will be identified by its effective date found at the bottom of this page.

If you have any additional questions or concerns about this Privacy Policy, please feel free to contact us anytime through this Website, email us at privacy@demandcircle.com, or write to us at:

DemandCircle, Inc.
8 The Green, Ste A,
Dover, Delaware 19901
Attn: Customer Service/Privacy

Date: 04/04/2023