Privacy Policy

Last Updated: 2021-05-11 

Circa Lighting values your trust and we take your privacy seriously and we are committed to protecting and respecting your privacy. The purpose of this Privacy Policy is to inform you what information we collect from you, how we use your information and the choices that you have regarding our use of your information. This Privacy Policy applies to information we collect about you in our stores, through our websites and mobile applications, and anywhere else we interact with you.

By accessing or using this website, you agree to this Privacy Policy.  This Privacy Policy may change from time to time.  Your continued use of the website after we make changes is deemed acceptance of those changes, so please check this Privacy Policy periodically for updates.

If you are a resident of California, please also see our California Consumer Privacy Act Policy at Section XII of this Privacy Notice below.

Our Commitment to You

The following document outlines our privacy practices and policies in great detail. In summary, Circa Lighting takes great care with your data and never shares personally identifiable information about our customers with third parties for their direct marketing use. We send commercial emails only to customers who have asked to receive them. Please read on for more information.

I. Personal Information Collected

We will collect personal information from users in a variety of ways, including, but not limited to, when users visit the site, register on the site, place an order, fill out a form, respond to a survey, subscribe to a newsletter and in connection with other activities, services, features or resources we make available on our website anonymously.  If we provide links to websites of other organizations, this privacy policy does not cover how that organization processes personal information.  We encourage you to read the privacy notices on the other websites you visit.

How do we collect your data?

The following are examples of the ways in which information will be collected:

  • Directly from you (e.g., during account registration, filling out a form, subscription to a newsletter or emails)
  • Indirectly from you (e.g., observing your actions on the website)
  • From third parties (e.g., third party social networking providers, data aggregators, affiliates)
  • From publicly available sources (e.g., online database searches)
What data do we collect?

The following are examples of the types of personal information collected:

  • Information you provide: name, email address, mailing address (billing and shipping), phone number, transaction information, payment card information, etc.
  • Information associated with the use of our site: information gathered from cookies and web pixels, such as IP address and interactions on the website to enhance your experience on our website, aggregations of multiple visits to the website, chat information
  • Non-personal identification information: the browser / system information, the type of computer and technical information about users means of connection to our website, such as the operating system and the Internet service provider(s) utilized and other similar information.
How will we use your data?

We use your personal information for the following purposes:

  • Fulfill the order and delivery of products along with tax collection and remittance
  • Live chat and servicing an order or inquiry
  • Provide relevant information based on location – e.g. nearby showrooms
  • Determine eligibility for admittance into trade discount program
  • Account activation and maintenance
  • Analytics, business trends, and insights
  • Interaction on social media

We may share your personal information with one or more of the third parties described here:

  • between and among companies which are affiliated or under common ownership with Circa Lighting or Visual Comfort & Co.,
  • vendors, service providers and consultants that perform services on our behalf,
  • companies which store and process data on our behalf,
  • companies which perform data analytics for us,
  • companies which help deliver and track our products,
  • companies which send you information about products on our behalf, and,
  • companies which you request us to share your personal information with.

Sharing of personal information with service providers or disclosures to third parties may involve the storage or processing of personal information outside of the jurisdiction in which you are located.  Local privacy laws may require the disclosure of personal information to governmental authorities under circumstances that are different than those that apply in your country of residence.

In addition to what is listed in this Privacy Policy, we may also collect, use, and share your personal information in other ways with your consent or as otherwise permitted or required by law.

II. Data Retention

When you place an order through the website, we will maintain your order information for our records unless and until you ask us to delete this information.

We will not save your personal information longer than necessary with respect to the purpose of the processing, unless otherwise required or permitted by law.  Your information is securely stored in the cloud via Amazon Web Services.

III. Communications

We may use your personal information to contact you with newsletters, marketing, or promotional materials.

IV. Cookies

Cookies are files placed on your computer to collect standard Internet log information and visit behavior information.  You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent though some features of the website require cookies, including registration for an online account.  When you visit our website, we may collect information from you automatically through cookies or similar technology in order to enhance and personalize your online experience and permit us to remember you when you return to our website, to deliver personalized marketing, and to better understand the way you use our website.  For further information about cookies, visit allaboutcookies.org/.

V. Data Collection 

We collect information using the following technologies in order to analyze the functionality and effectiveness of the website, to measure the performance of a marketing effort on our behalf, including email marketing, or to place advertising on our behalf across the Internet.

  • “Cookies” as explained above.
  • “Log files” track actions occurring on the website and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
  • “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the website.
VI. “Do Not Track” Signals

Our website does not support Do Not Track (DNT) at this time.  DNT is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites.  For more details, including how to turn on Do Not Track, visit www.donottrack.us.

VII. Security

The security of your personal information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure.  We strive to use commercially acceptable means to protect your personal information.

VIII. Google Analytics

We use a tool called “Google Analytics” to collect some information we listed above, including usage and website activity information.  We use the information we get from Google Analytics to improve the services.  In order to collect this information, Google Analytics may set cookies on your browser or mobile device, or read cookies that are already there.  Google Analytics may also receive information about you from apps you have downloaded, that partner with Google.  We do not combine the information collected through the use of Google Analytics with personally identifiable information.

Google’s ability to use information collected by Google Analytics about your visits and share it with another application which partners with Google is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.  Please review those and see http://www.google.com/policies/privacy/partners/ for information about how Google uses the information provided to Google Analytics and how you can control the information provided to Google.  To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics, which can be found here: https://tools.google.com/dlpage/gaoptout/.

IX. European Union Residents’ Privacy Rights according to the General Data Protection Regulation (GDPR)

If you are a resident of the European Union ("EU") or the United Kingdom (“UK”), you may have certain additional rights, as detailed below.

You have the following rights:

  • Right to be informed about the collection and use of your personal information;
  • Right to request access to your personal information;
  • Right to rectification – you can request that your personal information be corrected or amended if the personal information held is incorrect in some way;
  • Right to be forgotten: under certain circumstances you can request that your personal information be deleted;
  • Right to restrict processing of your personal information;
  • Right to data portability – you can request a transferable copy of personal information that has been provided to us;
  • Right to object to our processing of your personal information which is inconsistent with the primary purpose for which it was collected; and
  • Right to object to decisions being taken by automated means. 

Under the GDPR, the lawful bases we rely on for processing your information are:

  • consent,
  • contractual obligation, and
  • legitimate interests.

We are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the website), to pursue our legitimate business interests listed above, and otherwise in accordance with what you have consented to. 

Additionally, please note that your information may be transferred outside of Europe, specifically to the United States.Any transfers of data outside the EU/EEA will be made in line with applicable data protection laws, for the purposes specified above, and are normally based on the EU Commission’s standard contractual clauses.

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy.  Affiliates include our parent company and any subsidiaries or other companies that we control or that are under common control with us.

Please contact us at [email protected] if you have any questions.  Additionally, if you are unhappy with how we have used your data, you can also contact the ICO.

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

ICO website: https://www.ico.org.uk

X. Your Rights

To the extent a specific element of our processing, use, or disclosure of your personal information relies upon your consent, you may withdraw such consent at any time by contacting us by email at [email protected]  Such a withdrawal will not affect the lawfulness of the processing, use, or disclosure prior to the consent withdrawal.

If you wish to object to the processing, use, or disclosure of your personal information on the basis of legitimate interest and no opt-out mechanism is available to you directly, please send your request to [email protected]

If you do not provide us with certain portions of your personal information, we may not be able to fulfill the requested purpose of collection, such as to respond to your queries or to provide our website to you.  However, unless otherwise specified, not providing your personal information will not result in legal consequences for you.

XI. Exercise your Rights

For any questions regarding the Privacy Policy or to exercise your rights, please contact [email protected].

XII. California Consumer Privacy Act Policy

The California Consumer Privacy Act provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

1. Personal Information Collected:

The chart below shows the category of information that we have collected during the past 12 months and the purpose for which we may use such information.  We obtain the personal information listed in the chart below from the following categories of sources:

  • Directly from you (e.g., during account registration).
  • Indirect from you (e.g., observing your actions on the website)
  • From third parties (e.g., third party social networking providers, data aggregators, affiliates)
  • From publicly available sources (e.g., online database searches)

We may share your personal data with one or more of the third parties described here: between and among companies which are affiliated or under common ownership with Circa Lighting or Visual Comfort & Co., vendors, service providers and consultants that perform services on our behalf, companies which store and process data on our behalf, companies which perform data analytics for us, companies which help deliver and track our products, companies which send you information about products on our behalf, and, companies which you request us to share your personal information with.

Category

Examples

Collected

Purpose

Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol ("IP") address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

 

Yes

a)      Fulfill the order and delivery of products along with tax collection and remittance

b)     Live chat and servicing an order or inquiry

c)      Provide relevant information based on location – e.g. nearby showrooms

d)     Determine eligibility for admittance into trade discount program

e)      Account activation and maintenance

f)      Analytics, business trends, and insights

g)      Interaction on social media

 

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

 

Yes

a)      Fulfill the order and delivery of products along with tax collection and remittance

b)     Live chat and servicing an order or inquiry

c)      Provide relevant information based on location – e.g. nearby showrooms

d)     Determine eligibility for admittance into trade discount program

e)      Account activation and maintenance

f)      Analytics, business trends, and insights

g)      Interaction on social media

Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

No

--

Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Yes

a)   Fulfill the order and delivery of products along with tax collection and remittance

b)   Live chat and servicing an order or inquiry

c)   Provide relevant information based on location – e.g. nearby showrooms

d)   Determine eligibility for admittance into trade discount program

e)   Account activation and maintenance

f)    Analytics, business trends, and insights

g)   Interaction on social

Biometric Information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

No

--

Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

Yes

a)   Analytics, business trends, and insights

 

Geolocation data.

Physical location or movements.

No

--

Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

No

--

Professional or employment-related information

Current or past job history or performance evaluations.

Yes

a)   Determine eligibility for admittance into trade discount program

 

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

No

--

Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Yes

a)   Determine eligibility for admittance into trade discount program

b)   Analytics, business trends, and insights

c)   Interaction on social media

 

 

2. Right to Access:

You have the right to request disclosure of the following categories of information that we have collected, used, disclosed, or sold about you in the previous 12 months:

  • Personal information we have collected about you;
  • Sources from which the personal information is collected;
  • The business or commercial purpose for collection or selling personal information;
  • Third parties with whom we share your personal information; and
  • Specific pieces of personal information we have collected about you.
3. Right to Delete:

You have the right to request that we delete personal information that we collected from you to the extent required under CCPA and subject to certain exceptions.  We retain personal information to maintain your account, to comply with applicable laws and regulations, and other permissible purposes.  Accordingly, we may not be able to delete all of your personal information. 

Please note that, for your safety, we cannot fulfill certain requests if we cannot verify your identity.

4. Right to Opt-Out / Do Not Sell Information:

You have the right to direct us to not sell your personal information at any time. The law defines “sale” very broadly to include simply making data available to third parties in some cases. Advertising and analytics companies collect information through our sites.

Please note that, for your safety, we cannot fulfill certain requests if we cannot verify your identity.

5. Right to Opt-In:

We do not knowingly collect personal information from individuals under 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

6. Non-Discrimination:

We will not discriminate against you for exercising any of your CCPA rights.  

7. Appointing an Agent:

You may designate an authorized agent to make a request under the CCPA on your behalf.

8. Exercise your Rights:

For any questions or to exercise your rights under the CCPA, please contact privacy@circalighting.com.