PureCircle’s Privacy Policy describes our practices in connection with information that we collect through our websites. By providing Personal Information to us, you agree to the following terms and conditions of this Privacy Policy.

PERSONAL INFORMATION

Personal Information We May Collect

“Personal Information” is the information that identifies you as an individual, such as:

• Name
• Postal Address
• Telephone Number
• Email address
• Job description

If you submit any Personal Information relating to someone other than yourself, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

How We May Collect and Use Personal Information

We may collect Personal Information through our websites.

To the extent permitted by applicable law, we may use Personal Information:

• to respond to your inquires and fulfill your requests, such as to send you newsletters or to respond to your questions and comments.
• to send administrative information to you, for example, information regarding changes to our terms, conditions, and policies.
• to provide you with updates and announcement concerning our products, promotions and programs and to send you invitations to participate in special programs.
• to contact you if we have not heard from you in a while.
• for our business purposes, such as analyzing and managing our businesses, market research, audits, developing new products, enhancing our websites, improving our services and products, identifying usage trends, determining the effectiveness of our promotional campaigns, tailoring the websites experience and content based on your past activities, and gauging customer satisfaction and providing customer service (including troubleshooting in connection with customer issues).
• as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our and/or your rights, privacy, safety or property; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

How Personal Information May Be Disclosed

To the extent permitted by applicable law, your Personal Information may be disclosed:

• to our third-party service providers who, under confidentiality obligations, provide services such as website hosting, data analysis, infrastructure provision, IT services, customer service, email delivery services and other services, to enable them to provide services.
• as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our and your rights, privacy, safety or property; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

OTHER INFORMATION

Other Information We May Collect

“Other Information” is any information that does not reveal your specific identity, such as:

• Demographic information and other information provided by you
• Location information
• Aggregated information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then, in addition to the uses listed in the “How We May Collect Other Information” section below, we may use and disclose Other Information for all the purposes for which we use and disclose Personal Information.

How We May Collect Other Information

We may collect Other Information in a variety of ways, including:

• From you: Information such as hobbies and interests, consumption habits, zip code, and your preferred means of communication, may be collected when you voluntarily provide it. Unless combined with Personal Information, this information does not personally identify you.
• By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the sites (for example, we may use Personal Information to calculated the percentage of our users who have a particular telephone area code)

If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as the information is combined.

SECURITY

We use reasonable, organizational, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us through the “Contact Us” page at www.PureCircle.com.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use of your Personal Information.

• If at any time you wish to stop receiving phone, mail, SMS, and e-mail marketing communications from us, please just let us know by using the unsubscribe feature in the e-mail you received.
• In addition, we will not disclose your Personal Information to any third parties for direct marketing purposes.

How you can change your Personal Information

To review, correct, or update your Personal Information that has been previously provided to us, please use the unsubscribe feature on our website and re-enter your updated information.

Note that despite our efforts, there may be residual information that will remain within our databases and other records, which will not be removed or changed but will not be used for marketing or other purposes.

RETENTION PERIOD

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health or medical condition, criminal background or trade union membership) on or through the Websites or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy. Please take a look at the “Last Updated” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on a Site. Your use of the Websites following these changes means that you accept the revised Privacy Policy.