Privacy Policy

1.   Introduction

At Crimson Circle Energy Company, Inc ("us", "we", "our" or the "Company") we value your privacy and the importance of safeguarding your data. This Privacy Policy (the "Policy") describes our privacy practices for the activities set out below. As per your rights, we inform you how we collect, store, access, and otherwise process information relating to individuals. In this Policy, personal data ("Personal Data") refers to any information that on its own, or in combination with other available information, can identify an individual.

We are committed to protecting your privacy in accordance with the highest level of privacy regulation. 

Scope

This policy applies to the Crimson Circle Energy Company, Inc websites, domains, applications, services, and products.

This Policy does not apply to third-party applications, websites, products, services or platforms that may be accessed through (non-Crimson Circle Energy Company, Inc) links that we may provide to you. These sites are owned and operated independently from us, and they have their own separate privacy and data collection practices. Any Personal Data that you provide to these websites will be governed by the third-party’s own privacy policy. We cannot accept liability for the actions or policies of these independent sites, and we are not responsible for the content or privacy practices of such sites.

Processing Activities

This Policy applies when you interact with us by doing any of the following:

• Make use of our application and services as an authorized user
• Visit any of our websites that link to this Privacy Statement
• Receive any communication from us, including newsletters, emails, calls, or texts / SMS

2.  Personal Data we Collect

When you make a purchase, or attempt to make a purchase, we collect the following types of Personal Data:

• Account Information such as your name, email address, and password
• Payment Information such as your billing address, phone number, credit card, debit card or other payment method

When you use our products and/or features, we collect the following types of Personal Data:

• Account Information such as your name, email address, and password
• Payment Information such as your billing address, phone number, credit card, debit card or other payment method

How We Collect Your Personal Data

We collect Personal Data from the following sources:

From You. You may give us your Account Information, Payment Information, Financial Information, Demographic Data, Purchase Information, Content, Feedback, Product Information, by filling in forms, using our products or services, entering information online or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide, for example, when you:

• Create an account or purchase products on our website;
• Use our products or services;
• Create content through our products or services;
• Express interest in our products or services;
• Downloading software and/or our mobile application;
• Subscribe to our monthly magazine;
• Complete a voluntary survey;
• Contact us with an inquiry or to report a problem (by phone, email, social media, or messaging service);
• When you log in to our website

Automated technologies or interactions: As you interact with our website, we may automatically collect the following types of data (all as described above): Device Data about your equipment, Usage Data about your browsing actions and patterns, and Contact Data where tasks carried out via our website remain uncompleted, such as incomplete orders or abandoned baskets. We collect this data by using cookies, server logs and other similar technologies. 

Third parties: We may receive Personal Data about you from various third parties, including:

• Account Information and Payment Information from another individual when they purchase a gift for you on our website;
• Device and Usage Data from third parties, including analytics providers such as Google;
• Account Information and Payment Data from social media platforms when you log in to our website using such social media platforms;
• Content from communication services, including email providers and social networks, when you give us permission to access your data on such third-party services or networks;
• Account Information and Payment Data from third parties, including organizations (such as law enforcement agencies), associations and groups, who share data for the purposes of fraud prevention and detection and credit risk reduction; and
• Account Information, Payment Data, and Financial Data from providers of technical, payment and delivery services.

If you provide us, or our service providers, with any Personal Data relating to other individuals, you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Policy. If you believe that your Personal Data has been provided to us improperly, we may provide information about our relationship with that third party, but we cannot control or enforce their data practices.

Device and Usage Data

When you visit a Crimson Circle Energy Company, Inc website, we automatically collect and store information about your visit using browser cookies (files which are sent by us to your computer), or similar technology. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help Feature on most browsers will provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use some features of our Service and we recommend that you leave them turned on.

We also process information when you use our services and products. This information may include:

• Device IDs
• Login information
• IP Address
• Time stamps
• Web terms or searches that led you to the site

Data We Collect From Third Parties

We may receive your Personal Data from third parties such as companies subscribing to Crimson Circle Energy Company, Inc services, partners and other sources. This Personal Data is not collected by us but by a third party and is subject to the relevant third party’s own separate privacy and data collection policies. We do not have any control or input on how your Personal Data is handled by third parties. As always, you have the right to review and rectify this information. If you have any questions you should first contact the relevant third party for further information about your Personal Data. 

Our websites and services may contain links to other websites, applications and services maintained by third parties. The information practices of such other services, or of social media networks that host our branded social media pages, are governed by third parties’ privacy statements, which you should review to better understand those third parties’ privacy practices.

Purpose and Legal Basis for the Processing of Personal Data

We collect and use your Personal Data with your consent to provide, maintain, and develop our products and services and understand how to improve them.

These purposes include:

• To deliver your product or service
• To fulfill orders including electronic and non-electronic shipment
• Building a Safe and Secure Environment
• To verify or authenticate your identity;
• Investigate and prevent security incidents such as breaches, attacks and hacks
• Provide you with technical and customer support
• To communicate with you about the Products and Services

Where we process your Personal Data to provide a product or service, we do so because it is necessary to perform contractual obligations. All of the above processing is necessary in our legitimate interests to provide products and services and to maintain our relationship with you and to protect our business for example against fraud. Consent will be required to initiate services with you. New consent will be required if any changes are made to the type of data collected. Within our contract, if you fail to provide consent, some services may not be available to you.

Third Party Tools

Our web platforms may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

International Data Transfer and Storage

Data may be processed in multiple jurisdictions depending on our service providers. We do not guarantee data localization but rely on contractual and technical safeguards to protect your data. . Your Personal Data may also be transferred to, and maintained on, servers residing outside of your state, province, country or other governmental jurisdiction where the data laws may differ from those in your jurisdiction. We will take appropriate steps to ensure that your Personal Data is treated securely and in accordance with this Policy as well as applicable data protection law. 

Sharing and Disclosure

We will share your Personal Data with third parties (listed below) only in the ways set out in this Policy or set out at the point when the Personal Data is collected.

• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors, and insurers
• Government bodies that require us to report processing activities.

We also use Google Analytics to help us understand how our customers use the site. You can read more about how Google uses your Personal Data here: https://www.google.com/intl/en/policies/privacy/

You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout?hl=en

Legal Requirement

We may use or disclose your Personal Data in order to comply with a legal obligation, in connection with a request from a public or government authority, or in connection with court or tribunal proceedings, to prevent loss of life or injury, or to protect our rights or property. Where possible and practical to do so, we will tell you in advance of such disclosure.

Type of Data we may process

We may process the following categories of personal data about you:

• Communication Data that includes any communication that you send to us, whether that be through the contact form on our web platforms, through email, text, social media messaging, social media posting, or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
• Customer Data that includes data relating to any purchases of products/events and/or services such as your name, billing address, shipping address, email address, phone number (optional), contact details, purchase details and your card details. We process this data to supply the products/events and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
• User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our web platforms, to maintain back-ups of our web platforms and/or databases, and to enable publication and administration of our web platforms, other online services, and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
• Technical Data that includes data about your use of our web platform and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our web platforms, time zone settings and other technology on the devices you use to access our web platforms, accordingly to our Cookie Policy. The source of this data is from our analytics tracking system. We process this data to analyze your use of our web platforms and other online services, to administer and protect our business and web platforms, to deliver relevant content and advertisements to you and to understand the effectiveness of our advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our web platforms and our business and to grow our business and to decide our marketing strategy.

We may use Customer Data, User Data, and Technical Data to deliver relevant website content and advertisements to you (including Social Media adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to provide superior customer satisfaction and grow our business. We may also use such data to send other marketing communications to you.

• Sensitive Data: We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us, and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for the purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at customerservice@crimsoncircle.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

4. Marketing Communications

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if:

• You made a purchase or asked for information from us about our goods or services or
• You agreed to receive marketing communications, and in each case, you have not opted out of receiving such communications.

Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at customerservice@crimsoncircle.com at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, registrations etc.

5.  Data Security

We have implemented security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your personal data only to those employees who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

The communication between your browser and our website uses a secure, encrypted connection wherever your Personal Data is involved.

We require any third party who is contracted to process your Personal Data on our behalf to have security measures in place to protect your data and to treat such data in accordance with the law.

In the unfortunate event of a suspected Personal Data breach, we have procedures in place to deal with it and will notify you and any applicable regulator of a breach if we are legally required to.

6.  Data Retention and Deletion

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for, we look at its amount, nature, and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means, and legal requirements.

For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for six years after they stop being customers.

7.  Your Legal Rights

Depending on your location and applicable data protection laws, you may have certain rights in relation to your personal data, such as the right to access, correct, delete, restrict, or object to certain processing of your data, and where applicable, the right to data portability or to withdraw consent. These rights apply only to personal data under our control and are subject to legal, technical, and contractual limitations. Not all rights apply in all circumstances, and we will assess each request on a case-by-case basis in accordance with applicable law.
 

Exercising data protection rights does not limit our ability to refuse, suspend, or discontinue services where necessary for operational, security, or safety reasons, or in cases of abusive, disruptive, or unreasonable behavior, provided such decisions are not based on the exercise of those rights.

Withdrawing consent

If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge, such as where you wish to opt out from marketing messages that you receive from us. If you wish to withdraw your consent, please contact us using the information found at the bottom of this page.

How to Exercise Your Rights

If you wish to exercise any of the rights set out above, please email us at customerservice@crimsoncircle.com.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. If we cannot verify your identity, we may be unable to fulfill your request. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, we would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

8. Cookies

A cookie is a small file with information that your browser stores on your device. Information in this file is typically shared with the owner of the site in addition to potential partners and third parties to that business. The collection of this information may be used in the function of the site and/or to improve your experience.

You can refuse some browser cookies by changing your browser’s settings or when accessing our web platforms. For more information about the cookies we use, please see the Cookie Policy.

9. Children's Privacy

We do not knowingly collect Personal Data from children under the age of 13 Years

10. Changes

We may modify this Policy at any time. If we make changes to this Policy, then we will post an updated version of this Policy on this website. When using our services, you will be asked to review and accept our Privacy Policy. In this manner, we may record your acceptance and notify you of any future changes to this Policy.

11. Contact Us

To request a copy for your information, unsubscribe from our email list, request that your data be deleted, or ask a question about your data privacy, here are our contact details:

• Full name of legal entity: Crimson Circle Energy Company, Inc.
• Email address: customerservice@crimsoncircle.com 
• Postal address: P.O. Box  7394, Golden, CO 80403