Privacy Policy

1. Introduction

TERRITORY Influence GmbH as operator and provider of the site www.incircles.co.uk is responsible for the protection of your personal data that you leave or have entered during your visit to the pages of www.incircles.co.uk.

We take the protection of your personal data very seriously. In the following, we would like to explain to you how we stand by data protection, how we protect your data and what this means for you when you use our offers and services.

Territory Influence will only collect, process and use this data in accordance with the General Data Protection Regulation ("GDPR") and within the framework of the relevant legal provisions. Please read below to find out which data is collected during your visit on the website and how it is used.

If you have any questions about data protection or would like information about the data stored about you at www.incircles.co.uk, please contact datenschutz@incircles.de.

Our data protection officer:

TERRITORY Influence GmbH
c/o Territory Influence Data Protection Officer
Winzererstraße 47d-e
D-80797 Munich, Germany

Phone +49 (0) 5241 / 234 80 – 305
Fax +49 (0) 5241 / 234 80 – 274
E-Mail: datenschutz@incircles.de or dataprotection@incircles.de

You can contact our data protection officer directly at any time with all questions and suggestions concerning data protection.

Summary of your rights:

You have the right to request information about your personal data stored by InCircles at any time. You also have the right to correct, block or delete your personal data, apart from the prescribed data stored for business purposes. Please contact our data protection officer for this purpose. You will find a detailed explanation of your rights in this data protection declaration.

Applicable legal bases

In accordance with Art. 13 GDPR we inform you about the legal basis of our data processing. Insofar as the legal basis is not stated in the data protection declaration, the following applies: The legal basis for obtaining authorisations is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the purpose of providing our services and implementing contractual measures and for answering enquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing for the purpose of fulfilling our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing for the purpose of protecting our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that the vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) lit. d GDPR serves as the legal basis.

Information on other data processing

As a company we process personal data in various processes. In order to be able to provide you, as a data subject, with the most detailed information possible for these processing purposes as well, we have compiled this information here for the following processing activities, thus fulfilling the legal obligations to provide information in accordance with Art. 12-14 GDPR:

Should you require further information that you cannot find here or in the following detailed data protection declaration, please contact our data protection officer in confidence.

2. Personal data

What is personal information?

First of all, we would like to explain what we mean by personal data. "Personal identifiable information" is information that can be used explicitly to find out your identity. This includes information such as your correct name, address, postal address, telephone number. Information that is not directly associated with your real identity, such as favourite websites or number of users of a site, does not fall under this category.

Where is personal information collected?

In order to use the services of InCircles, you must register as an Influencer. Registered Influencers decide which social media channels they want to connect to. At InCircles.co.uk it is possible to connect a Facebook, YouTube, Instagram or blog account via interfaces. Through the connection, the account or profile information is released, which the respective operator of a social media platform plans to release. The scope of access can change during the connection. Only the operator of the respective social media platform decides on the scope of access. If you use Google when using our services, you must comply with the applicable rules of Google (https://www.google.com/intl/en/policies/privacy/) in the versions valid at the time of use of these services. Furthermore, you can revoke access to your data at any time via the Google security settings page at (https://security.google.com/settings/security/permissions).

As soon as you visit and use our website https://app.incircles.co.uk, we collect, store and use the personal data from your social media accounts to which we have access due to the connection. In addition, we use your usage data such as IP address and characteristics for identification purposes and information on the scope of use and duration of use of our offer in order to be able to continuously improve our services. This information is stored by us on a specially protected server in Germany, whereby all information on your identity is only collected by us if you expressly make it available to us. The legal basis for this data processing is the fulfilment of the service requested by you (Art. 6 para. 1(b) GDPR) in accordance with our terms of use and participation agreed with you.

Do we share personal information with third parties?

Except as otherwise described in this Privacy Policy and Cookie Policy, Territory Influence and the Territory Group Companies will not transfer or otherwise disclose your information to any third party without your express consent, unless it is necessary for the purpose of fulfilling the contract or unless there is an express legal permission or obligation. This may be necessary in particular in the event of criminal prosecution or averting of danger.

In order to find out whether you meet the requirements for Brand's offers, a profile is created with your data, which is then compared with Brand's requirements. For this purpose, we pass on your data to Brands as a profile. By registering, you agree that InCircles.co.uk may collect, process, store, use and pass on your personal data to third parties to the aforementioned extent, as far as this is necessary for the execution of the contract or film projects. The legal basis for this data processing is the fulfilment of the service requested by you (Art. 6 para. 1(b) GDPR) in accordance with our terms of use and participation agreed with you.

To operate InCircles and to provide the associated services, service providers ("contract processors" e.g. hosting or logistics) are also used. The service providers are only granted access to your data to the extent and for the period of time necessary to provide the respective service. Contractual agreements for order processing ensure that the service providers process your data only in accordance with instructions and in compliance with data protection standards. If the service providers process your data outside the European Union (including access only), this may result in your data being transferred to a country that does not guarantee the same standards of data protection as in the European Union ("transfer to third countries"). In this case, we will ensure by contract or otherwise, in accordance with the requirements of the GDPR, that the service provider guarantees an equivalent standard of data protection law (e.g. by means of the conclusion of EU standard contractual clauses, EU Commission decision for safe third countries). The current EU standard contractual clauses can be found at https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=CELEX%3A32010D0087. An up-to-date overview of safe third countries can be found at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.

If and insofar as the cookies of the Territory Platform are also used with the involvement of service providers, the contractual agreements on order processing also apply here. The same applies to a possible transfer to a third country.

Possibility of objection: If you do not wish to participate in our services in the future, please unsubscribe on our website.

3. How we collect and use your data

Browser data

We automatically collect and store in special files information transmitted by your web browser that you use to access the web pages of www.incircles.co.uk. This includes in particular details of the browser and operating system used, a reference to the origin of the previously visited pages (so-called referral URL), the IP address or host name of the accessing computer and the time of the page request. This data is used for long-term statistical evaluation of the pages of www.incircles.co.uk and is deleted at the end of the evaluation phase.

Area subject to registration

We collect other information that is provided by www.incircles.co.uk-Besuchern or www.incircles.co.uk-members in the course of registration or other contact with Territory Influence or that relates to the use of an www.incircles.co.uk-Accounts. These personal data are used by Territory Influence exclusively within the framework of the relevant legal provisions, in particular to provide the services offered at www.incircles.co.uk.

Contact details (i.e. name, address, telephone number, e-mail address) of www.incircles.co.uk-Members or www.incircles.co.uk-Usern will not be passed on to third parties unless the relevant consent has been obtained.

The e-mail address provided by a www.incircles.co.uk-Mitglied uses Territory Influence to advertise and run www.incircles.co.uk-Aktionen of interest to the www.incircles.co.uk-Member at the request of the www.incircles.co.uk-member for which the www.incircles.co.uk-Mitglied has applied.

Profile data, i.e. the other data provided when registering as www.incircles.co.uk-Mitglied and when applying to participate in www.incircles.co.uk-Aktionen, is requested in order to enable Territory Influence to offer and market the services offered at www.incircles.co.uk in this form.

Cookies

Cookies are small text files that are currently used by thousands of websites to provide users with the most personalised offer possible. If a user accesses such a website, the provider's server sends back the cookie to the user's browser in addition to the HTML page. The browser then decides, depending on the local settings, whether the cookie will be stored on the user's computer.

As pure text files, cookies cannot penetrate the user's system or cause damage there. In particular, cookies are blocked by your browser in such a way that only the page that has set them can read them. The text files are set by the server of a selected website and are sent to our server by your browser the next time you visit this site, e.g. to show other advertisements during this visit or to provide you with information about your last visits to this site.

Most of the cookies we use are so-called "session cookies", which are deleted when you end your browser session. Long-term cookies enable us, among other things, to recognise you as a visitor to our site and thus make this site more convenient for you.

The acceptance of cookies is not a prerequisite for visiting our online offer. If you disable cookies, certain functions on the https://www.incircles.co.uk website may not be available to you and some pages may not be displayed correctly. In order to be able to make full use of our offered functions, cookies must be accepted.

Possibility of objection: If you do not wish the use of cookies or wish to delete existing cookies, you can switch them off and remove them via your Internet browser. You can find more detailed information on deleting or preventing cookies in the help texts for your browser or on the Internet, for example, under the search words "Deactivate cookies" or "Delete cookies" (Instructions for deleting in Microsoft Internet Explorer. Instructions for deleting in Mozilla Firefox. How to delete in Safari). However, we would like to point out that in this case you may not be able to use all the functions of this website to their full extent.

The legal basis for the use of session cookies is the provision of the service requested by you (Art. 6 para. 1 lit. b GDPR).

Furthermore, we use so-called tracking cookies (e.g. Google Analytics). We process the usage information collected by these cookies to analyse and statistically record the use of our services. In this way we would like to improve our services.

The legal basis for this is Art. 6 para. 1 lit f GDPR. The legitimate interest we are pursuing is the improvement and optimisation of our service and our products and services, from which our users also benefit.

Usage evaluations with the help of Google Analytics

We use Google Analytics, a web analysis service of Google Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA ("Google"), which uses so-called cookies (see above), to evaluate the use of our offer. The information generated by the cookie about your use of our website is usually transferred to a Google server in the USA and stored there. However, due to the activation of IP anonymisation on this platform, your IP address will be shortened by Google within member states of the European Union or in other states which are party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On our behalf, Google will use the information generated to evaluate your use of our website, to compile reports on website activity for our site and to provide other services associated with website and internet use. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Under no circumstances will Google link your IP address to other Google data. You can prevent the storage of cookies by adjusting your browser settings accordingly (see previous section). By using our site, you agree to the processing of the data collected about you by Google in the manner and for the purpose described above.

Right of objection: The collection and storage of data by Google Analytics can be objected to at any time with effect for the future. You have the possibility to install a browser plug-in published by Google for this purpose. This is available for various browser versions and can be downloaded at https://tools.google.com/dlpage/gaoptout?hl=de.

If you visit our site via a mobile device (smartphone or tablet), you mustclick this linkinstead to stop Google Analytics tracking within this website in the future.

In view of the discussion about the use of analysis tools with complete IP addresses, we would like to point out that this website uses Google Analytics with the extension "_anonymizeIP()" and that IP addresses are therefore only processed in a shortened form in order to exclude the possibility of a direct personal link. This website uses the following cookies for Google Analytics

  • "_ga" cookie is used to distinguish visitors and expires after 2 years
  • "_gat" cookie is used to reduce the request rate and expires after 10 minutes
  • "ga-disabled" cookie is used to log off tracking and expires after 100 years

No connection with contact details from www.incircles.co.uk-members

We will not combine the above-mentioned usage data with your name or address data, which are requested, for example, when you register for https://www.incircles.co.uk. The collection, processing and use of this data is therefore anonymised or pseudonymised.

4. information on stored data and right of objection

Users of www.incircles.co.uk can request written information free of charge about which personal data is stored by Territory Influence. We will carry out possible corrections, blocking or deletion without delay - insofar as permitted by law. You can object to the use and processing of your personal data for marketing purposes at any time by notifying us in text form.

In particular, upon termination of www.incircles.co.uk-Memberchaft, the contact data and profile data of www.incircles.co.uk-Member available at Territory Influence will be deleted immediately.

You can also object to the creation of pseudonymous user profiles with your data at any time. If you wish to do so, please deactivate the cookies in your browser.

Do you have any further questions? If you have any questions, suggestions or comments on the subject of data protection, please contact us at the following e-mail address: datenschutz@incircles.de.

In particular, you have, without limitation, the following rights under applicable European data protection law:

  • You have the right to receive confirmation from us as to whether or not we are processing your personal data and you have the right to obtain information about your personal data held by us, or a copy thereof, at any time. According to Art. 15 GDPR.
  • If your personal data is incorrect or incomplete, you have the right to have it corrected. According to Art. 16 GDPR
  • In accordance with Art. 17 GDPR, you have the right to demand the immediate deletion of relevant data or, alternatively, to demand a restriction of data processing in accordance with Art. 18 GDPR.
  • You have the right to receive the personal data relating to you and provided by you or to transfer this data to another responsible party. According to Art. 20 GDPR.
  • In accordance with Art. 77 GDPR, they also have the right to lodge a complaint with the competent supervisory authority.

Right of withdrawal

You have the right to revoke the consent you have given in accordance with Art. 7 (3) GDPR with future effect.

Right of objection

You may at any time object to the future processing of data concerning you in accordance with Art. 21 GDPR. The objection may be raised in particular against processing for direct marketing purposes.

If you have any questions or concerns regarding the collection, processing and use of your personal data or wish to exercise your aforementioned rights, please contact us or our data protection officer (contact details see above).

5. Storage periods

We only store your data for as long as is necessary to fulfil the purposes for which the data is collected and processed or - if legal regulations provide for longer retention and storage periods - for as long as is legally required. Your personal data will then be deleted.

In particular, your personal data will be deleted if you contact us for this purpose in accordance with section 1 of this privacy policy.

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No liability for partner sites

Please note that our partners and other Internet sites and services accessible through our sites, as well as partners who collect data in connection with contests, promotions and the like, have their own privacy policies that are independent of ours. We assume no responsibility or liability for these unrelated policies and procedures.

Our right to change the guidelines with notice

We reserve the right to change these guidelines at any time in compliance with data protection regulations.

You should check back periodically to see whether InCircles has made any changes to this privacy statement to ensure that you are always fully informed about the collection, processing and use of your personal information during your visits to the website.

Status: September 2020