Privacy policy
Last updated on May 28, 2024
Preamble
The software product CircleLink (hereinafter "CircleLink" or “the Platform”) is provided by UAB CircleLink, Dariaus ir Girėno g. 42A, LT-02189 Vilnius (hereinafter "we" or "us") as the controller within the meaning of the applicable data protection law.
Within our product, we enable you to plan charging trips and access public charging stations. When using the product, we process personal data about you. By personal data, we mean all information relating to an identified or identifiable natural person. Because the protection of your privacy when using the Platform is important to us, we would like to use the following information to inform you which personal data we process when you use the Platform and how we handle this data. In addition, we inform you about the legal basis for processing your data and, insofar as processing is necessary to protect our legitimate interests, also about our legitimate interests.
1. Information on the Processing of Your Data
1.1 Creation of a User Account (Registration) and Login
To use certain features of our platform, users are required to register and create a user account. During registration, we collect the following personal information:
- Name
- Email address
- Phone number
- Other information you provide voluntarily
This data is collected via forms on our website or app and is used to provide our services, communicate with you, and manage your account. The processing of this data is necessary for the fulfillment of the contract between you and us pursuant to Art. 6 para. 1 lit. b) GDPR.
1.2 Cookies and Usage Data
We use cookies and similar technologies to collect usage data to improve our services and provide a better user experience. Usage data may include information such as your IP address, browser type, pages visited, and the time and date of your visit. This data helps us understand how our platform is used and where improvements are needed.
1.3 Service Provision, Marketing, and Analytics
We process your data to provide the services you request, as well as for marketing and analytics purposes. This may include sending you promotional materials or information about updates to our services, as well as analyzing how users interact with our platform to improve functionality and user experience. The legal basis for this processing is Art. 6 para. 1 lit. f) GDPR, as it is in our legitimate interest to keep you informed about our services and improve them.
1.4 Carrying out and Paying for Charging at Public Charging Stations
To facilitate charging at public charging stations, we work with third-party service providers to process your charging sessions and payments. We do not process payment information directly; instead, this is handled through our partner RevenueCat. The legal basis for this processing is Art. 6 para. 1 lit. b) GDPR, as it is necessary for the fulfillment of the contract between you and us.
2. Sharing and Transmission of Data
2.1 Third-Party Services
We share your personal data with third parties only as described in this privacy policy or as required by law. For example, we use the following third-party services to help us provide and improve our services:
- RevenueCat: We use RevenueCat to manage our subscriptions and payments. RevenueCat handles the financial transactions and payment processing, ensuring that your payment information is securely processed and stored. RevenueCat Inc., 633 Taraval Street, San Francisco, CA 94116, USA. For more information, please refer to RevenueCat's Privacy Policy https://www.revenuecat.com/privacy.
- Contabo: Our server hosting and infrastructure are managed by Contabo. This service provider ensures that our platform operates smoothly, providing the necessary server space and maintenance services to keep our platform online and accessible. Contabo GmbH, Aschauer Str. 32a, 81549 Munich, Germany. For more information, please refer to Contabo's Privacy Policy https://contabo.com/en/legal/privacy-policy/.
- Cloudflare: For website security and performance optimization, we rely on Cloudflare. This service protects our site from malicious attacks and helps improve load times by using a content delivery network (CDN) to distribute our content efficiently. Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. For more information, please refer to Cloudflare's Privacy Policy https://www.cloudflare.com/privacypolicy/.
- Hotjar: We use Hotjar for website analytics and user feedback. Hotjar allows us to analyze user behavior on our site through heatmaps and session recordings, helping us understand how users interact with our platform and where improvements can be made. Hotjar Ltd., Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian’s STJ 3141, Malta. For more information, please refer to Hotjar's Privacy Policy https://www.hotjar.com/legal/policies/privacy/. You can opt-out of Hotjar tracking by following the instructions on the Hotjar Opt-out page https://www.hotjar.com/policies/do-not-track/.
- Mailjet: For sending email communications, we utilize Mailjet. This service helps us manage our email marketing campaigns, newsletters, and transactional emails, ensuring that our communications are delivered effectively to our users. Mailjet SAS, 13-13 bis, Rue de l’Aubrac, 75012 Paris, France. For more information, please refer to Mailjet's Privacy Policy https://www.mailjet.com/security-privacy/.
We ensure that these third parties comply with GDPR requirements and use your data only for the purposes specified by us.
2.2 Legal Requirements and Protection of Our Services
If necessary, we may disclose your personal data to legal authorities to comply with legal obligations or to protect our rights, property, or safety and that of our users or others. This disclosure is justified by our legitimate interest in protecting our business and complying with legal requirements pursuant to Art. 6 para. 1 lit. c) and f) GDPR.
3. Data Security
We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, use, or disclosure. All data is stored and transmitted using encryption protocols, ensuring the security and confidentiality of your information.
4. Data Retention
We retain your personal data only as long as necessary to fulfill the purposes for which it was collected or to comply with legal obligations. As a rule, we store your data for the duration of your use of our services plus a period of 6 months for backup purposes. Data that is no longer needed will be deleted or anonymized.
5. Your Rights as a Data Subject
5.1 Right of Access
You have the right to obtain from us information on the personal data we process about you. To request this information, please contact us via email at support@circlelink.app.
5.2 Right to Rectification
If your personal data is incorrect or incomplete, you have the right to request rectification. Please contact us at support@circlelink.app to update your information.
5.3 Right to Erasure
Under certain conditions, you have the right to request the deletion of your personal data. This applies, for example, if your data is no longer necessary for the purposes it was collected for or if you withdraw your consent. Please contact us at support@circlelink.app to request data deletion.
5.4 Right to Restriction of Processing
You can request that we restrict the processing of your data under certain circumstances, such as if you contest the accuracy of the data or if the processing is unlawful. Please contact us at support@circlelink.app to request restriction.
5.5 Right to Data Portability
You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format. Please contact us at support@circlelink.app to request data portability.
5.6 Right to Object
You have the right to object to the processing of your personal data at any time, for reasons arising from your particular situation. If you object, we will cease processing your data unless we can demonstrate compelling legitimate grounds for the processing. Please contact us at support@circlelink.app to object to data processing.
5.7 Right to Complain
If you believe that our processing of your personal data violates data protection laws, you have the right to lodge a complaint with a supervisory authority. In Lithuania, this is the State Data Protection Inspectorate.
6. Contact Information
For any questions or concerns regarding our handling of your personal data or to exercise your rights, please contact us at:
- Email: support@circlelink.app
7. Changes to This Privacy Policy
We reserve the right to update this privacy policy as necessary. Changes will be posted on our website and within the app under "Data Protection." Continued use of our services after changes have been made constitutes acceptance of those changes.