Privacy Policy
Privacy Notice
How Circle Waste collects, uses, stores and protects your personal data, together with information about cookies and your rights.
1 Scope
Circle Waste Ltd., a Reconomy Group Company (“We”, “Us”, “Our”), respects your privacy and is committed to protecting your personal data. Circle Waste Ltd. is a "data controller", which means we are responsible for deciding how we hold and use personal information about you; this policy explains how we collect, process and share your personal data.
Your right to privacy and the protection of your personal data is controlled by “Data Protection Laws”. Data Protection Laws will be different depending on the country you are located in. In Europe and the UK, the General Data Protection Regulation (“GDPR”) and associated Domestic Law will protect your data rights. Data Protection Laws regulate the way your personal data is used.
This privacy notice applies to the processing of your personal data when you visit our website www.circlewaste.co.uk, when you contact us by e-mail, post or telephone, when we subsequently provide services to you or when you are providing services to us.
2 Definitions
| “Data Protection Laws” | Means applicable law and regulatory requirements relating to the processing, privacy and use of personal data and protection of individuals, including, but not limited to. Regulation (EU) 2016/679 (“GDPR”) Regulation (EU) 2016/679 (“GDPR”) as incorporated into domestic UK law by the European Union (Withdrawal Agreement) Act 2020 and amended by The Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2020 (together the “UK GDPR”). any legislation enacted in the country of establishment of the data controller in respect of the protection of personal data or any corresponding or equivalent national laws or regulations. all as amended, updated, or replaced from time to time; |
| “Personal Data” | Means any information relating to an identified or identifiable natural person, who can be identified, directly or indirectly, such as a name, identification number, location, online identifier. |
3 Our Contact Details
| Name: | Circle Waste Ltd | Tel. No. | 03300 948 148 |
| Address: | Tottenhill Retail ParkLynn Road, TottenhillKing’s LynnNorfolk, PE33 0SR | compliance@reconomy.com |
4 Type of Personal Data we Collect
Depending on your relationship with us and the services you use, we may collect and process the following categories of personal data:
- Identity and contact information, including your name, job title, employer, address, e-mail address and phone number
- Profile and preference information, including your interests, preferences, marketing preferences and demographic information such as postcode or location.
- Financial and transaction information, including payment card details, billing information and records of transactions with us.
- Technical information, including your IP address, browser type and version, operating system, device information and other technology identifiers.
- Website usage data, including details of how you use our website, such as page viewed, duration of visit, referral sources, dates and times of access, content accessed and other analytical data.
- Cookie and consent information, including your cookie preferences and records of marketing and privacy preferences.
- Communication and enquiry information, including information contained in correspondence, enquiries, complaints, feedback and other communications with us.
- Recruitment and employment application information, including details contained in your application, CV or resume, employment history, educational background, qualifications, skills, references, interview notes and any supporting documentation you choose to provide or that we reasonably require as part of our recruitment process.
- Survey, research and promotional information, including your participation in surveys, promotions, events and special offers, together with any responses you provide.
- Social media information, including information you share with us through social media platforms, your interactions with our social media content and any communications you send to us through those channels.
5 How we obtain your Personal Data and why we process it
We collect personal data both directly from you and from other sources. We only process your personal data when we have a valid lawful basis to do so, as described in Lawful Basis for Processing.
Personal data collected directly from you
Most of the personal data we process is provided directly by you for one or more of the following purposes:
- To enter into, administer and fulfil contracts with you, including processing any payments and managing contractual relationships.
- To provide information, products and services that you request from us.
- To respond to your enquiries, requests, complaints or feedback.
- To register your attendance at, administer and follow up on events, webinars, conferences or other activities that you attend or express an interest in attending.
- To send you marketing communications about products, services and offers where we are permitted to do so by law and, where required, with your consent.
- To conduct market research and better understand the needs of our customers and prospective customers.
- To invite you to complete customer satisfaction surveys and collect feedback to help improve our products and services.
- To assess and manage applications for employment, secondment or other opportunities with us.
Personal data collected when you contact us
When you contact us by telephone, email or other means, we may process your personal data to:
- provide you with information about our products and services that you request from us.
- respond to an enquiry, request or complaint.
- enter into, administer and fulfil contracts with you, including processing any payments and providing customer support.
- maintain records of communications for quality assurance, training, compliance and business administration purposes.
Calls are recorded and retained for a limited time for the purposes outlined below:
- As evidence of verbal instructions or transactions.
- Dispute prevention and complaint handling
- To support fraud detection and security monitoring.
- Your call data may be used for training and quality assurance purposes for our customer service teams
Personal data collected for recruitment purposes
When you apply for a role with us, we may collect personal data about you from the following sources:
- Directly from you, including through our careers website, online job sites, email, application forms, interview and/or by any other communication method.
- Individuals who refer or recommend you for a role.
- Recruiters and other trusted third-party service providers.
- From publicly available sources, such as LinkedIn and other publicly accessible information relevant to assessing your suitability for a role.
Further information about how we collect and process your data during recruitment can be found in our Reconomy Careers Privacy Notice.
Personal data collected indirectly through our website
When you use our website, we may automatically collect information about your device, browsing activity and interactions with our website through cookies and similar technologies. We use this information to:
- personalise and improve your experience of our website, including providing content and advertising that may be relevant to your interests.
- measure or understand the effectiveness of advertising and marketing activities.
- administer, secure and improve our website and related services, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- remember your preferences and make it easier for you use our website in future.
Further information about our use of cookies, including how you can manage preferences, can be found in our Cookie Declaration.
6 Why we share your Information
To provide you with some services, we may act as an intermediary and have established relationships with third parties to support with relevant services.
We may share your information with third parties in the following scenarios:
- To provide goods or services to fulfil contractual obligations, for example, with waste management, transport, shipping or payment service providers.
- To enable other companies within the Reconomy Group to fulfil contractual obligations or provide information to you about similar products or services which you have requested, or which we think may be relevant for you, we will share your information with other companies within the Reconomy Group.
- To provide you, or permit carefully selected third parties to provide you, by telephone, post or email, with information about other goods and services that are similar to those that you have already purchased or enquired about.
- To provide you with targeted information about services or products, so you get relevant messages from us.
- If we are obliged to do so by law, by court order or due to an enforceable official order.
In the event that we transfer your personal data to a data processor, we will ensure that a data processing agreement (DPA) is in place.
7 Lawful Basis for Processing
Under Data Protection Laws, the lawful bases we rely on for processing this information are:
- Contractual Necessity: We process your personal data to enter into and fulfil our contractual obligations.
- Comply with legal obligations: We are obligated to retain certain information due to legal requirements, such as for tax and business regulations.
- Legitimate interest: The legitimate interests can be our own interests or the interests of third parties. When necessary, we will conduct a Legitimate Interests Assessment, in order to consider the impact that any processing activities could have on individuals, including in the following scenarios:
- Promotion of our offers and services;
- Analysis of the use of our website;
- Recruitment;
- Social media engagement analysis;
- Ensuring the confidentiality and integrity of our IT systems; and
- Cooperation with authorities.
- Consent: If you have provided explicit consent to allow us to process your personal data, we will process it only within that scope and based on your consent. Your consent might refer to, for example, receiving marketing communications. You can remove your consent at any time by contacting gdpr@reconomy.com.
8 How we store your Personal Information
We have implemented appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, unauthorised change or damage. All personal data we collect will be stored on our secure servers. All electronic transactions entered into via our website will be protected by SSL encryption technology.
We will store your personal information for as long as necessary to fulfil the purposes for which we collect the personal data, in accordance with our legal obligations and legitimate business interests.
We may retain any personal data to investigate or defend claims against us, or to prosecute or bring claims against you, us or any third party.
We may also store your personal data collected through the recruitment process for future roles that may become available, based on your consent and unless you choose otherwise.
If at any time we transfer your personal data to, or store it in, countries located outside of the UK or EEA (for example, if our hosting services provider changes), we will ensure that appropriate safeguards, such as International Transfer Agreements are in place for that transfer and storage as required by Data Protection Laws.
9 Your Data Protection Rights
Under Data Protection Laws, you have the following rights:
- Right of access: You have the right to ask us for copies of your personal information.
- Right to rectification: You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Right to erasure: You have the right to ask us to erase your personal information in certain circumstances, for example when the organisation no longer needs it for the original reason it was collected, or the organisation has collected or used your data unlawfully.
- Right to restriction of processing: You have the right to ask us to restrict the processing of your personal data in certain circumstances, for example the organisation no longer needs your personal data, but you want the organisation to keep it in order to create, exercise or defend a legal claim.
- Right to object to processing: You have the the right to object to the processing of your personal information in certain circumstances.
- Right to data portability: You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You can exercise your rights at any time by emailing us at gdpr@reconomy.com, however there are certain circumstances when a request may be refused, for example when it is manifestly unfounded or excessive, for example when:
the individual clearly has no intention to exercise their right of access.
the request is malicious in intent and is being used to harass an organisation with no real purpose other than to cause disruption.
the request is clearly or obviously unreasonable.; the request should be proportionate when balanced with the burden or costs involved in dealing with the request.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
10 EU & UK Representation
Where a UK-established Reconomy entity is processing and monitoring the personal data of individuals in the EU, and is required by Data Protection Laws to designate an EU Representative, the following person is hereby appointed:
Managing Director
Cycleon B.V.
Vliegend Hertlaan 71 14e etage
3526 KT Utrecht
Netherlands
Tel: +31 30 299 5500
Where an EU-established Reconomy entity is processing and monitoring the personal data of individuals in the UK, and is required by Data Protection Laws to designate a UK Representative, the following person is hereby appointed:
Company Secretary
Reconomy (UK) Limited
Kelsall House
Stafford Court
Stafford Park 1
Telford
Shropshire TF3 3BD
UK
Tel: 0800 988 5618
Or contact us via email: gdpr@reconomy.com
11 Lodging a Complaint
If you are dissatisfied with our actions and wish to make a complaint, this should be made in writing to compliance@reconomy.com or sent to the following address:
Tottenhill Retail Park
Lynn Road, Tottenhill
King’s Lynn
Norfolk, PE33 0SR
If you would like to make a complaint to the Reconomy Group, email: gdpr@reconomy.com.
You also have the right to lodge a complaint with your local Supervisory Authority (“SA”) if you are unhappy with how we have used your data.
For UK:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113 or email: enquiries@ico.org.uk
ICO website: https://www.ico.org.uk
A list of EU SAs is maintained by the European Data Protection Board (EDPB) and can be accessed here.
12 Changes to our Privacy Notice
Any changes we make to our Privacy Notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Notice.
Cookie Notice
13 What are cookies?
Cookies are small text files that are placed on your device by websites that you visit. They are widely used to enable website to function properly, making visitor experience more efficient, and provide information to site owners.
14 Why we use cookies
We use cookies to:
- Enable some website functionality
- Personalise content and advertisements
- Set your preferences, such as language settings
- Provide social media features
- Analyse our website traffic
- Understand how visitors interact and behave when visiting our website:
We may share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services.
The purpose of each cookie is outlined in the below Cookie Declaration.
15 Types of cookies we use
This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages. See the Cookie Declaration below which identifies each cookie’s type.
The cookies used on our website have been categorised as follows:
| Category 1: Necessary | Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies. Necessary cookies are always on when you visit us, and you can only turn them off if you change your browser settings. |
|---|---|
| Category 2: Statistics | Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously. |
| Category 3: Preferences | Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in. |
| Category 4: Marketing | Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers. The legal basis for the processing of personal data in connection with Targeting Cookies or Advertising Cookies (if any) is Art. 6 Para. 1.1 GDPR. |
| Category 5: Unclassified | Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies. |
Where cookies are categorised as necessary, we process on the basis of legitimate interests (GDPR Art. 6(1)(f)), and process based on consent (GDPR Art. 6(1)(a)) for other categories of cookies.
16 How long do cookies last?
The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other categories of cookies, we need your permission.
The Cookie Declaration below specifies the maximum storage duration of each applicable cookie.
17 How to control cookies
You can at any time change or withdraw your consent from the Cookie Declaration on our website. Click the cookie button and then withdraw your consent.
If you have any issues regarding your consent, email us at gdpr@reconomy.com. Please provide your consent ID and date when you contact us.
Changing cookie settings
You can use your web browser’s cookie settings to determine how our website uses cookies. If you do not want our website to store cookies (including necessary cookies) on your computer or device, you should set your web browser to refuse cookies. However, this may affect how our website functions and some pages and services may become unavailable to you.
Unless you have changed your browser to refuse cookies, our website will issue necessary cookies when you visit it.
Find out how to manage cookies on popular browsers:
To find information relating to other browsers, visit the browser developer's website.
To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.
