Circus Technologies Inc. (“Circus,” “we,” “us,” or “our”) recognizes the importance of privacy to our customers ("Producer"). This Privacy Policy describes the manner in which we treat the Producer’s workers ("Users") personal information, as well as the personal information we collect where we have linked to this Privacy Policy, such as through our websites,  https://www.circushr.com and https://app.circushr.com (collectively, the “Website”).

Before using the Website, please review our Terms of Use and our collection, use and disclosure practices, and other activities as described in this Privacy Policy.

This Privacy Policy does not govern information we process on behalf of our Producers. For details about the processing of User personal information, please see the “Information from Our Producers” section below.

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section. If you are a resident of Nevada or California, please see the additional disclosures at the end of this Privacy Policy.

Information collected automatically through our platform

Visiting our Website

We automatically collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity, and to monitor and improve our Website.

Location Data

We collect imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level) and, with your consent, precise location data (such as latitude/longitude data).

COOKIES

Our Website uses a technology called "cookies". A cookie is a tiny element of data that our Website sends to a User's browser, which may then be stored on the Users's hard drive so that we can recognize the User when they return. We use cookies to remember your preferences and to authenticate you. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the Website features.

PIXELS (OR WEB BEACONS)

We use pixels, which is code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from separate entities which allow us to track our conversions, bring you advertising off the Website, and provide you with additional functionality.

AnALYTICS

We use analytics services, such as Google Analytics, to help us understand how users access and use the Website. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through LinkedIn, X, and Google that you may view on their platforms as well as on other websites and services.

THIRD PARTY LINKS

Our Website may contain links to other websites that Circus does not own or operate, such as The Canadian Audio-Visual Certification Office, Canada Revenue Agency or US government agencies. Also, links to our Website may be featured on third party websites on which we advertise. Except as provided herein, we will not provide personal information to these third parties without consent. We provide links to third party websites as a convenience to the User. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information

Brand Pages and Chatbots

We may offer our content through social media and chatbots on the Website. Any information you provide to us when you engage with our content (such as through our brand page) or via our chatbot on the Website is treated in accordance with this Privacy Policy. Also, if you publicly reference our Website on social media (e.g., by using a hashtag associated with Circus in a tweet or post), we may use your reference on or in connection with our Website.

Collection and use of personal information

Information from PRODUCERS

Circus offers human resource and payroll software through which personal information can be uploaded about an organization’s Users, including but not limited to names, addresses, contact information, health concerns, taxpayer and residency details. Producers choose the types of Users personal information that may be uploaded into our software. We do not collect or use the User's personal information of Producer's for any purpose other than to provide the services or as otherwise agreed to by Producer. In the event we are permitted to process User personal information for our own purposes, we will process the User personal information in accordance with the practices described in this Privacy Policy. We are not responsible for how our Producers treat User personal information, and we recommend you review their own privacy policies.

We may otherwise collect and use personal information when you:

• Create an Account: When you sign up for a Circus account we collect your username, password, and information for authentication and account access.
  
  

• Request a Demo: When you request a free demo, we may collect your name, email address and certain information about your production company. We use this information to contact you and otherwise facilitate your free demo.
  
  

• Sign-up for Newsletters: When you sign-up to receive mail or e-mail regarding our products and services, we will collect information such as your name or email.
  
  

• Make a Purchase: If you choose to purchase Circus services, we may collect your payment information, such as your name, address, phone number, email address, billing address, and payment card information. This information is used to process and fulfill your order.
  
  

• Submit a Job Application: If you apply for a job at Circus, you may provide us with certain personal information about yourself, such as that contained in a resume, cover letter, or similar employment-related materials. We use this information for the purpose of processing and responding to your application for current and future career opportunities.
  
  

• Participate in Surveys or Promotions: We may also ask you for information, such as your name and email address, when you enter a contest or promotion sponsored by Circus or participate in one of our surveys or other forms of research. The information we collect from these contests, promotions and surveys may be used by us to facilitate your participation in the contest, promotion, survey or research and to improve our overall experience by helping us understand our Users.
  
  

• Contact Us: When you contact us with a comment, question or complaint, you may be asked for information that identifies you, such as your name, address and a telephone number, along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future and to improve our customer service, service offerings, and our Website.

In addition, we collect and use information for other business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information include:

• Operating and managing our Website.

• Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.

• Preventing and addressing fraud, breach of policies or terms, and threats or harm.

• Monitoring and analysing trends, usage, and activities.

• Improving the Website and other Circus websites, apps, marketing efforts, products and services.

• Fulfilling any other purpose at your direction.

• With notice to you and your consent.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the 'Your Rights and Choices' section below.

Disclosure of personal information

We will not disclose, trade, rent, sell or otherwise transfer personal information, without consent, except as otherwise set out herein. 

We will not disclose, trade, rent, sell or otherwise transfer personal information, without consent, except as otherwise set out herein. We absolutely will not sell Producer or User data to third parties or advertisers.

We will not disclose, trade, rent, sell or otherwise transfer personal information, without consent, except as otherwise set out herein. 

We may transfer or disclose information as follows:

To Provide the Services

In connection with the services we provide to Producer, we may disclose information to Platform Partners (as defined in the Terms of Service), including but not limited to User representatives, unions, guilds, other payroll companies, tax credit administrators, or other third parties at the request of Producer. Producer may need to give permissions to certain members of the production office, such as Producers, Production Managers and Accountants, to access the data and documents that you provide.

Service Provider Arrangements

In connection with our Website or the services we provide to Producer, we may transfer (or otherwise make available) personal information to parties who provide services on our behalf. For example, we may use service providers to process payments, host our website and store information on our behalf. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes. Personal information may be maintained and processed by service providers in the US, such as billing information, and Canada, for data and document storage, and may be accessed by the courts, law enforcement and national security authorities as required under the laws of those jurisdictions.

For more information about the way in which our service providers treat personal information, contact us as set out in the “Contact Us” section below.

Sale of Business

Circus may transfer personal information as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceeding) involving all or part of Circus or as part of a corporate reorganization or other change in corporate control.

LEGAL

Circus and our Canadian, US and other affiliates may provide personal information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable Canadian, US or other law. Where a disclosure of Producer information is required by applicable law, we promptly notify Producer prior to complying with such requirements (to the extent we are not prohibited from doing so). We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

VENDORS AND OTHER PARTIES

We share information with vendors and other parties for analytics purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information.

PRODUCERS

We share information with Producers in connection with the services we provide to them. For example, we share information with Producers in order to maintain and administer your accounts, respond to your questions, comply with your requests, and otherwise comply with the law. Producers are independent entities and their processing of information is subject to their own privacy policies.

FACILITATING REQUEST

We share information at your request or direction.

CONSENT

We share information with notice to you and your consent.

OTHER

Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the 'Your Rights and Choices' section below.

Your rights and choices

Deletion of Personal Information

Users have the right to delete their accounts. However, if Circus has collected data and documents on behalf of a Producer, the Producer may need to retain this information as required by law or for accounting and tax purposes. While future Producers won't access a deleted User's data, previous collections may still be retained by the Producer.

ACCESS TO PERSONAL INFORMATION

If we receive a request from User to access or update personal information we have collected on behalf of a particular Producer, we will direct that User to the relevant Producer if necessary. We will assist Producer wherever possible in responding to User access requests. If you submit personal information via our Website or otherwise provide us with your personal information, you may request access, updating or correction of your personal information by submitting a written request to our Privacy Officer (see 'Contact Us' below). We may request certain personal information for the purposes of verifying your identity.

COOKIES AND PICELS

Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.

DO NOT TRACK

Your browser settings may allow you to automatically transmit a 'Do Not Track' signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to 'Do Not Track' signals.  For more information visit http://www.allaboutdnt.com.

Please be aware that if you disable or remove tracking technologies some parts of the Website may not function correctly.

EMAILS

You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails and click on the unsubscribe link. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations.

PUSH NOTIFICATIONS

If you have opted-in to receive push notification on your device, you can opt-out at any time by adjusting your account settings. Please note that your opt out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions.

Children

The Website is intended for general audiences, and is not directed to children. We do not knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information in violation of COPPA, contact us at privacy@circushr.com. We will remove the personal information in accordance with COPPA. We do not sell, as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents.

Security of Personal Information

We have implemented reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control. To learn more about this, please access our Security Policies. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

International transfer

Please be aware that information collected through the Website may be transferred to, processed, stored, and used in Canada, the U.S. and other jurisdictions. Data protection laws in Canada, the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Website or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in Canada, the U.S. and other jurisdictions as set out in this Privacy Policy.

Changes

This Privacy Policy may be updated periodically to reflect changes to our information practices. The revised Privacy Policy will be posted on the Website. We strongly encourage you to please refer to this Privacy Policy often for the latest information about our information practices.

Contact us

Please contact us at privacy@circushr.com if (i) you have any questions or comments about this Privacy Policy; (ii) you wish to access, update, and/or correct inaccuracies in your personal information; or (iii) you otherwise have a question or complaint about the manner in which we or our service providers treat your personal information. This Privacy Policy has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us at disability@circushr.com.

Additional disclosures for Nevada residents

Nevada consumers have the right to submit requests directing a business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. We do not sell personal information. Nevertheless, if you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at privacy@circushr.com

Additional disclosures for California residents

These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt-out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.

Our Website is intended to provide information and services to job applicants and Creators. You understand and agree that information collected about you is solely within the context of (i) your role as an employee, job applicant, owner, director, officer, or contractor or (ii) Circus providing a service to or from your employer or Creators.

Notice of Collection

In the past 12 months, we have collected the following categories of personal information as described in the CCPA:

• Identifiers, including name, postal address, email address, and online identifiers (such as IP address).

• User records, including phone number, billing address, and financial account information.

• Characteristics of protected classifications under California or federal law, including country of citizenship.

• Commercial or transactions information, including records of products or services purchased, obtained, or considered.

• Internet activity, including browsing history, search history, and interactions with our website, email, application, or advertisement.

• Geolocation data.

• Inferences drawn from the above information about your predicted characteristics and preferences.
  
  

For further details on information we collect, including the sources from which we receive information, review the information collection sections above. We collect and use these categories of personal information for the business purposes described in the 'Collection and Use of Personal Information' section above, including to manage our Website.

We do not sell personal information, nor have we sold personal information in the past twelve months.

Right to Know and Delete

We acknowledge that you may have rights to know and delete under the CCPA in connection with the personal information we process on behalf of Producer. If personal information about you has been processed by us as a service provider on behalf of Producer and you wish to exercise any rights you have with such personal information, please inquire with Producer directly. If you wish to make your request directly to us, please provide the name of Producer on whose behalf we processed your personal information. We will refer your request to Producer, and will support them to the extent required by applicable law in responding to your request.

AUTHORIZED AGENT

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment by us for the exercise of any your rights.

SHINE THE LIGHT

Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email set out in 'Contact Us' above and specify that you are making a 'California Shine the Light Request'. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

Additional disclosures for data subjects in Europe.

ROLES

Data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). In limited circumstances, Circus operates as a controller, such as in connection with data collected from users who browse our website. However, Circus generally operates as a processor on behalf of Producer. Producers are the controllers and determine the purposes for which and the manner in which personal data are to be processed by Circus. Please visit the applicable Producer’s privacy policy for information about their privacy practices. Any questions that you may have relating to the processing of personal data by Circus on behalf of Producer and your rights under data protection law should be directed to Producer as the controller, not to Circus.

Lawful Basis for Processing

Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers, Platform Partners, or Producer; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third countries subject to appropriate or suitable safeguards, such as standard contractual clauses.

Your Data Subject Rights

You have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

To exercise any of these rights, please email us at privacy@circushr.com and specify which right you are seeking to exercise. We will respond to your request within 30 days. We may require specific information from you to help us confirm your identity and process your request. If personal data about you has been processed by us as a processor on behalf of a Creator and you wish to exercise any rights you have with such personal data, please inquire with the Creator directly.

Please note that we retain information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

If you have any issues with our compliance, please contact us to resolve the issue.  You also have the right to lodge a complaint with the data protection regulator in your jurisdiction.