This Privacy Policy explains how FullCircle uses your personal data when you visit our website, interact with us, or purchase our products and services.
It also explains your privacy rights and how the law protects you.
It is important that you read this Privacy Policy, as well as any other privacy policies we may make available to you, so that you are always aware of how and why we use your data.
This Privacy Policy was last updated on May 28, 2018. If you would like to view previous versions, please contact us and we will provide them to you.
If you have any questions or wish to exercise any of your rights, simply follow the instructions provided in this Privacy Policy. See the section titled “How to Contact FullCircle” for information on privacy-related matters.
Our website, fullcircle.es, is designed to clearly explain our work methodology, as well as provide information about our great team and our studio’s contact details. This website is not intended for children, and we do not collect any data related to minors.
FullCircle is comprised of the following legal entity:
Full Circle S.L., located at 125 Fuencarral Street, 2nd Floor – Door D, Madrid 28010, Spain
Full Circle S.L. offers comprehensive design and communication solutions for all types of services to clients around the world and is also the data controller for this website and responsible for the processing of personal data carried out through it. When we refer to “FullCircle,” “we,” “our,” or “us” in this Privacy Policy, we are referring to Full Circle S.L.
When we refer to “personal data” or “personal information,” we mean any information relating to an individual that allows that person to be identified. This does not include data from which the identity has been removed (anonymous data).
We collect various types of data about our customers (that’s you!) and the people who visit the FullCircle website. This personal data falls into the following categories:
Identifying information: title, first name, last name, username, or any other similar identifier. If you interact with us through social media, your social media username will also be included in this information.
Contact information: billing address, shipping address, email address, and phone numbers.
Financial information: bank account details and other related products.
Transaction data: information about payments, both made and received, as well as details about the products and services you have purchased from us.
Technical data: Internet Protocol (IP) address, login information, browser type and version, time zone and location settings, browser plug-in type and version, operating system and platform, as well as other technologies you may use on your devices to access this website.
Tracking data: information that we, or third parties, collect about you through the use of cookies and similar tracking technologies, such as web beacons, pixels, or mobile identifiers.
Usage data: relevant information about your use of our website, as well as our products and services.
Marketing and communication data: information about your preferences regarding direct marketing from us or third parties, as well as your communication preferences.
We also collect, use, and share aggregated statistical or demographic data, regardless of the purpose. Aggregated data may be derived from your personal data, although it is not legally considered personal data, as it does not reveal your identity either directly or indirectly. For example, we may aggregate your usage data to calculate the percentage of users who access a particular feature of the website. In order to improve the service and content we offer, the FullCircle website uses the Google Analytics web analytics service. Google Analytics tracks mouse clicks and scroll movements. All information about you collected by Google Analytics is completely devoid of personal data. Please review their privacy policy.
However, if we combine or link aggregated data with your personal data in a way that allows you to be identified directly or indirectly, we will treat the combined data as personal data, in accordance with this Privacy Policy.
At FullCircle, we do not collect any special categories of personal data about you, such as data related to your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, or medical, genetic, and biometric data. We also do not collect data regarding your criminal convictions or offenses. We will treat all personal data that is part of your projects or products as standard personal data.
Please note that if you choose not to share your personal information with us or do not consent to certain types of contact, we may not be able to provide you with the products and services you have requested.
We use various methods to collect data about you, including:
Direct interactions. You can provide us with your personal, financial, and contact information via email or by contacting us by phone, mail, or social media.
This includes the personal information you provide to us when:
Please contact any member of our team.
You can make an inquiry or request that information be sent to you.
You can reach us on social media.
You are taking a survey.
Please leave comments or reviews about our products or services (be nice to us, okay?).
Automated interactions or technologies. When you interact with us, we may automatically collect technical data about your device, your browsing activities, and related patterns. We may also collect tracking data when you use our website. However, this data will be linked to your personal data.
Third parties or publicly available sources. We may also receive personal data about you from third parties, including:
Contact, financial, and transaction data from payment service providers and fraud prevention providers.
Identifying and contact information from partners with whom we share data.
Data from third parties that have your permission or legal authorization to share your personal data with us, such as social media platforms or review websites.
We only use your personal data when permitted by law. Generally, this will occur in the following circumstances:
When we need to fulfill the contract we are about to enter into or have already entered into with you. For example, a design proposal or a strategy consulting engagement.
When it is necessary for our legitimate interests (or those of third parties) and your fundamental interests and rights do not override those interests. For example, when we conduct a fraud investigation as part of the payment process.
When we are required to comply with a legal or regulatory obligation. For example, maintaining sales records to meet our tax obligations.
Generally, we do not need your legal consent to process your personal data, except in cases where the law requires it, such as for sending certain direct marketing communications. In cases where the law requires us to obtain your consent, you always have the right to withdraw that consent at any time.
Please refer to the section titled “Explanation of the Legal Basis for the Processing of Your Personal Data” for more information about the legal grounds on which we rely to process your personal data.
This table describes all the ways we plan to use your personal data, as well as the legal basis on which we rely to do so. Where applicable, we have also identified our legitimate interests.
Please note that, depending on the specific purpose for which we use your personal data, the processing of such data may be based on more than one legal basis.
Our decision-making process is not automated in any way.
If you have any questions about this topic, please don’t hesitate to ask us. See the “How to Contact FullCircle” section for information on privacy-related issues.
We reserve the right to use your tracking and usage data to create a profile of what we believe you might want or need, or what might be of interest to you. This allows us to improve the layout and structure of our website, fullcircle.es.
We conduct our marketing activities via email, phone calls, or instant messaging. This means you might receive a newsletter in your inbox or a phone call.
However, there are many different ways to see FullCircle ads out there, and not all of them involve the use of your personal data. For example, on websites or social media. If you see FullCircle ads on websites or social media, they may not be specifically targeted at you; we may simply have purchased the ad space to promote ourselves. On the other hand, here are some of the things we do that may be specifically targeted at you:
Emails, such as a newsletter.
Phone calls or instant messages to share information that might be of interest to you or your company.
Cookies are a tool that we (and anyone or any company operating online) use for advertising purposes. But that’s just one of the reasons we use cookies—which are, generally speaking, quite clever.
Some cookies collect information about how visitors use fullcircle.es, such as which pages receive the most visits or whether they generate error messages. These cookies do not collect information that can be used to identify visitors. All information collected by these cookies is aggregated and used to improve the performance of fullcircle.es.
If you’d like to learn more about tracking data, especially cookies, check out the “Cookie Policy” section.
We reserve the right to share your personal data with the parties listed below and for the purposes set forth in this Privacy Policy. We also reserve the right to share your personal data whenever permitted by applicable law.
We reserve the right to share your personal data with the third parties described below:
Suppliers of products and services (such as technology service providers, payment processing and fraud prevention providers, manufacturers, and postal and courier services).
Professional auditors and advisors (such as bankers, lawyers, accountants, and insurance agents).
Governments, regulatory bodies, and competent authorities.
We also reserve the right to share data with third parties to whom we decide to sell, transfer, or merge part of our business or assets. We also reserve the right to acquire or merge with other companies. If there is a change in ownership of our company, the new owners may use your personal data in the manner set forth in this Privacy Policy.
We require all third parties with whom we work to respect the security of your personal data and to process it in accordance with applicable laws. Furthermore, we do not allow third-party service providers to use your personal data for their own benefit, and we ensure that they process it only for the specified purposes and in accordance with our instructions.
Whenever we transfer your personal data outside the European Economic Area, we will comply with the applicable data protection laws. Here are some of the mechanisms we may use when making an international transfer:
Your personal data is transferred to a country that the European Commission officially recognizes as providing an adequate level of protection for personal data.
We reserve the right to use specific contracts approved by the European Commission that provide the same level of protection for personal data as that provided in Europe (the so-called EU standard contractual clauses).
We have appropriate security measures in place to prevent your personal data from being accidentally lost, disclosed, or subject to unauthorized modification, use, or access. In addition, access to your personal data is limited to those employees, agents, contractors, and third parties who need to know it to fulfill their contractual obligations. These individuals and entities, who are bound by confidentiality obligations, will only process your personal data in accordance with our instructions.
We have established procedures to manage potential personal data breaches and are committed to notifying both you and the relevant regulatory authority of any breach that applicable law requires us to report.
Our website may include links to third-party websites, plug-ins, and applications (for example, the option to log in with Facebook). Clicking on these links or enabling these connections may allow third parties to collect or share data related to you. We do not control these external websites and cannot be held responsible for their privacy policies. When you leave our website, we recommend that you always read the privacy policy of every website you visit.
We will only retain your personal data for as long as necessary to fulfill the purpose for which it was collected, including to comply with applicable legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we take into account the amount, nature, and sensitivity of the data; the potential harm that could result from unauthorized use or disclosure of your personal data; the purpose of processing the data; and whether we can achieve the same result through other means, in addition to the applicable legal requirements.
For tax purposes, we are required by law to retain our customers’ basic information (including identifying information, financial data, contact information, and transaction details) for six years after they cease to be customers.
Under certain circumstances, you may also ask us to delete your data from our records. See the “Your Rights” section for more information.
In other cases, we will anonymize your personal data (so that it cannot be linked to you) for analytical or statistical purposes. In such cases, we may use the resulting information indefinitely and without prior notice.
If you leave a comment on our site, you can choose to save your name, email address, and website in cookies. This is for your convenience, so you don’t have to re-enter your information when you leave another comment. These cookies will last for one year.
If you are located in the European Union and are subject to the General Data Protection Regulation, data protection laws grant you the following rights regarding your personal data:
Right to be kept informed: We are required to inform you about how we use your personal data (which is exactly what we do in this Privacy Policy).
Right of access: This right allows you to submit what is known as a “subject access request,” which consists of a copy of the personal data we hold about you.
Right to rectification: This gives you the right to require us to correct any personal data about you that is inaccurate or incomplete.
Right to erasure: commonly known as the “right to be forgotten,” this right allows you to request the deletion of any personal data we may hold about you (unless there is a compelling legal reason requiring us to retain it).
Right to restrict processing: Under certain circumstances, this right allows you to ask us to suspend the processing of your personal data.
Right to data portability: This allows you to request a copy of the personal data we hold about you. The copy will be provided in a commonly used format (for example, a .csv file).
Right to object: This right allows you to object to our continued processing of your personal data (for example, to refuse to allow us to continue processing your data for direct marketing campaigns).
Rights related to automated decision-making and profiling: This right allows you to request transparency from us regarding both automated decision-making and profiling.
These rights are subject to certain rules regarding their exercise. If you are interested in this topic, you can find much more information on the Spanish Data Protection Agency’s website.
If you wish to exercise any of the rights listed above, please don’t hesitate to contact us (see the section “How to Contact FullCircle” for privacy-related matters).
Access to your personal data, as well as the exercise of any of your rights, does not entail the payment of any fees. However, if we consider your request to be manifestly unfounded, repetitive, or excessive, we may require you to pay a reasonable fee. Furthermore, under these circumstances, we may refuse to comply with your request.
We may need to ask you for certain information to help us verify your identity and ensure your right to access your personal data (or exercise any other rights). This is a security measure to ensure that personal data is not disclosed to anyone who is not entitled to receive it. We also reserve the right to contact you to request additional information regarding your request in order to expedite our response.
We strive to respond to all legitimate requests within one month. If your request is particularly complex or if you have submitted multiple requests, our response may take longer. If this is the case, we will notify you and keep you updated on the status of your request or requests.
We have appointed a Data Protection Officer who is responsible for handling questions related to this Privacy Policy. If you have any questions regarding this Privacy Policy or wish to exercise your legal rights, please feel free to contact the Data Protection Officer as described in the section titled “How to Contact FullCircle Regarding Privacy Matters.”
You have the right to file a complaint at any time with the Spanish Data Protection Agency (AEPD), the Spanish authority responsible for overseeing data protection (www.aepd.es). However, we would appreciate it if you would give us the opportunity to address your complaint before contacting the AEPD, so please do not hesitate to contact us first.
If you have any questions regarding this Privacy Policy or wish to exercise any of your rights, please feel free to email us at welcome@fullcircle.es or send a letter to the following address: Full Circle S.L., located at 125 Fuencarral Street, 2nd Floor – Door D, Madrid 28010, Spain
If you need help with our products and services or with any aspect of this website, you can contact us at this email address: welcome@fullcircle.es
It is important that the personal information we have on file is accurate and up to date. That is why we ask that you let us know if your personal information changes at any time during our relationship. To do so, simply update your account. Thank you in advance.
The General Data Protection Regulation is new, and the AEPD continues to publish new guidance on how companies should comply with it. This means we will likely be posting minor updates to our Privacy Policy over the coming months. Be sure to check back from time to time to see if there are any changes. Thank you in advance.
