Full Circle Technologies Privacy Policy - For PermitEyes Only

User Submitted Data - For PermitEyes Only

User Submitted Data is information that identifies you as an individual such as your name, postal address, email address, and home and/or wireless telephone numbers. This information is typically collected from you when you visit the Site and submit an application (via the Site or directly to a municipal government) for a permit, registration, license, or other product or service. User Submitted Data also includes information obtained from you by phone, a mobile application, email, a service provider, or any other means.

If you provide information to us about others, we will only use the information provided for the specific reason for which it is provided.

We may use User Submitted Data for several purposes, including without limitation to:

• provide a requested service or product
• respond to your questions
• send you information about the Site, the Company, or our products and services
• send you information regarding the Site, changes to our terms, conditions, and policies, and other administrative information
• personalize your experience on the Site by presenting products and offers tailored to you, and
• assist with our business purposes, such as analyzing and managing our business, improving our services and products and developing new ones, gauging customer satisfaction and providing customer service (including troubleshooting in connection with customer issues).

User Submitted Data you provide through the Site, to our municipal government clients and partners, or otherwise may be combined with other information you provide (via online or offline means), with demographic information and other information that is publicly available, or with other information about you that we may otherwise obtain either online or offline.

We may disclose User Submitted Data to:

• our agents, employees, contractors and affiliates for the purposes described in this Privacy Policy
• our municipal government clients and partners and their agents and affiliates, that play a role in a transaction with you
• third-party service providers that provide services for us (such as website hosting, data analysis, payment processing, order fulfillment, IT services, customer service, email delivery services and other similar services), in each case to enable them to provide such services
• identify you to anyone to whom you send messages through the Site or otherwise, and
• a third-party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Our agents, employees, contractors, and affiliates have access to your User Submitted Data on a need-to-know basis for the purpose of performing services on our behalf.  All such individuals and entities with access to such information have agreed to keep such information confidential and abide by the terms of this Privacy Policy, and not to use any such information other than to carry out the services they are performing on our and your behalf, or as otherwise required by law.

The parties with whom we share your User Submitted Data, including our municipal government clients, may in turn share that information with others in order to generate permits, registrations and licenses and otherwise fulfill transactions with you. They may contact you directly at the phone number(s) or email address(es) you provide to collect additional information, answer questions, complete transactions or provide you with information about other products and services (even if, in the case of phone calls, you have registered the phone number(s) provided on local or national Do Not Call lists).

Please be aware that many applications, once submitted, are covered under the Freedom of Information Act (“FOIA”), which allows the public to request information pertaining to a government agency’s functions, practices, and future plans. FOIA is mandated by Congress and applies to all government agencies, including municipal governments. Anyone may request records under the FOIA. Public disclosure is mandatory unless exempted under Title 5 U.S.C. 552. If you choose to upload any images, PDFs, or other attachments using our Site, please be aware that (i) images may contain geographic information (EXIF GPS) and you may wish to remove this data before uploading; and (ii) although Full Circle Tech attempts to request all submissions not be indexed, search engines may read and report your upload or submission in search results.

We assume no responsibility or liability for the policies or practices of our municipal government clients or any third parties with whom they may share your information in accordance with their own policies or practices. We strongly urge users to review the laws and practices of the municipal governments and third parties with which they conduct business.

We will not rent, sell or license any User Submitted Data constituting personal information or potentially personally-identifying information to any third parties.

Browser Derived Data

Browser Derived Data is information that is not submitted by you but that is instead provided by or results from your access and use of the Internet and an Internet browser to connect to the Site. Browser Derived Data includes browser specific information such as browser type, IP address, Internet Service Provider or “ISP” information, server log file information, referring/exit pages, date/time stamps, information collected through cookies, pixel tags and other technologies, and location information.

We receive Browser Derived Data by your access to the Site, including in the following manner:

• Certain information is collected by most internet browsers, such as MAC address, type of computer, operating system details, browser software details, screen resolution, and whether it is a mobile device.
• Your “IP Address” is a number that is automatically assigned to the computer or device that you are using by your ISP. An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many websites. We use IP Addresses for purposes such as calculating usage levels of the Site, helping diagnose server problems, and administering the Site.
• Cookies allow a web server to transfer data to a computer or device for recordkeeping and other purposes. We and our partners use cookies, analytics, remarketing and other similar tracking technologies to, among other things, better serve you with more tailored information and facilitate your ongoing access to and use of the Site. A cookie enables the Site to label you as a particular user, but it does not identify you by name or address unless you have provided such information or set up preferences in your browser to do so automatically. If you do not want information collected through the use of cookies, your internet browser has a tool to disable cookies.
• We may use applications, including mobile applications or widgets, to collect information from you.
• The Site may also use pixel tags, web beacons, clear GIFs or other similar technologies. These may be used in connection with the Site and HTML-formatted email messages to, among other things, track the actions of the Site’s users and compile statistics about the Site’s usage and response rates.

We may use Browser Derived Data and other data that does not identify you personally for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Browser Derived Data with User Submitted Data (such as combining your name with your geographical location). If we combine any Browser Derived Data with User Submitted Data, the combined information will be treated by us as User Submitted Data as long as it is combined.

We may share, rent, sell or license Browser Derived Data regarding our users to third parties, including service providers, but not in a manner in which the recipient would be able to identify you personally.

Third-Party Data

Third-Party Data is information that is not submitted directly by you but that is instead provided by third-party service providers to us or our municipal government clients and partners in connection with our fulfillment of a transaction for you. If required, your consent will be obtained before such third-party data is obtained.

We may use Third-Party Data for several purposes, including to

• assist with the fulfillment of a transaction you requested
• respond to your questions
• provide you with email updates and announcements concerning our products, promotions and programs
• personalize your experience on the Site by presenting products and offers tailored to you, and
• assist with our business purposes, such as analyzing and managing our businesses, improving our services and products and developing new ones, and gauging customer satisfaction and providing customer service (including troubleshooting in connection with customer issues).

We may combine Third-Party Data with User Submitted Data (such as combining your name with your application history). The combined information will be treated by us as User Submitted Data.

Other Use and Disclosure

We also may use and/or disclose User Submitted Data, Browser Derived Data and/or Third-Party Data as we believe to be necessary or appropriate to:

• comply with legal process
• respond to requests from public and government authorities, including public and government authorities outside the United States
• enforce this Privacy Policy and any terms of use governing the Site and our services
• protect our operations or those of any of our affiliates or clients
• protect our rights, privacy, safety or property, and/or that of our affiliates, clients, you or others
• allow us to pursue available remedies or limit the damages that we may sustain, and
• as otherwise permitted by law, including laws of jurisdictions outside the United States and/or the country of your residence.

As noted above, in certain situations we may be required to disclose personal data in response to lawful requests from public or government authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena, when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others, or to investigate fraud.

Linked Sites

This Privacy Policy does not address, and we are not responsible for, the privacy, security or other practices of any third-party websites for whom we may include a link within the Site. Without limiting the foregoing, Full Circle Tech specifically disclaims any responsibility if such third-party sites do not provide adequate security for your personal information. Such links are provided for your convenience only. We are not endorsing, in any manner, any of the linked sites that may be referenced in or linked to the Site.

Although we believe that each of the sites to which we provide links should post a privacy statement that fully describes the data collection, use and advertising practices of such site, we can give no guarantee that all of those sites have or post such a privacy policy. We encourage you to read the terms of use and privacy policies of any such linked third-party site, as they may differ from ours.

Additionally, certain personal information may be made available to third parties using our Application Programming Interface, or “API.” Use of third-party applications developed using our API are subject to the terms of use and privacy policies of such third-party developers.

Remarketing and Retargeting

We may use third-party remarketing services (such as Google AdWords, AdRoll and Facebook) to advertise on third-party websites to previous visitors of the Site. It could mean that we advertise to previous visitors who haven’t completed a task on the Site. This could be in the form of an advertisement or posting on the Google search results page, Facebook, or various other websites within these networks or on the worldwide web. Any data collected will be used in accordance with our own privacy policy and the privacy policies of these third-party remarketing services. You can set your preferences for how these services advertise to you by visiting their consumer opt-out pages.

Advertising Vendors

Please note that our online and email advertising-related vendors may use pixel tags, web beacons, clear GIFs or other similar technologies in connection with the Site to help manage our online and email advertising campaigns and strengthen the effectiveness of such campaigns. For example, if a vendor has placed a unique cookie on your computer, the vendor may use pixel tags, web beacons, clear GIFs or other similar technologies to recognize the cookie during your visit to the Site and to learn which of our online advertisements may have brought you to the Site, and the vendor may provide us with such Browser Derived Data for our use. Please note we may link such Browser Derived Data provided to us by our vendors to User Submitted Data about you that we have previously collected. Such combined information will be treated as User Submitted Data hereunder as long as it is so combined, as noted above.

Security Measures

We employ commercially reasonable organizational, technical and administrative measures to protect User Submitted Data under our control and prevent its unauthorized use or disclosure. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any User Submitted Data, which you transmit at your own risk.

Access by Minors

Our Site is not intended for or directed to individuals under the age of thirteen (13). We request that these individuals not provide User Submitted Data through the Site. If you become aware that information has been submitted by or collected from a child under the age of 13, please contact us directly at:

Full Circle Technologies, Inc.
11 Beacon Street Suite 340
Boston, MA 02108

Email: help@fullcircletech.com

Once such a request has been received and verified, we will delete the information collected within a reasonable time.

Sensitive Personal Data

We ask that you not send or disclose to the Company any sensitive personal information about yourself and your identity via the Site. We do not collect via the Site for any purpose, nor do we have any need for, your race, religion, national origin, work history, political participation, health information, criminal background, or similar information.

In the event you are requested to provide such personal information to enable us or our clients or partners to fulfill a transaction with you, make and process payments, and facilitate interactions with third-party service providers, such information should only be submitted directly to the individual or entity authorized to make such request related to a proper business purpose. It is always your choice as to whether to provide such personal information. If you elect not to provide the personal information, we and/or or clients may not be able to engage in a transaction with you. Sensitive personal data is considered User Submitted Data under this Privacy Policy and treated accordingly.

For highly sensitive information, such as social security number, and payment information, we restrict access to employees, agents, and others who use such information only as permitted by law and to provide you products and services.

Other Information

Any communication or material you provide or transmit to the Site that is not User Submitted Data, such as questions, comments or suggestions, will be treated as non-confidential and non-proprietary and may be used by us for any purpose and without restriction or obligation to you.

Changes to this Privacy Policy

Full Circle Tech may at any time in its sole discretion, and without notice, revise this Privacy Policy by updating this posting. You are bound by any such revisions and should therefore periodically visit this page to review the current Privacy Policy. The date of the most recent update is noted below. Your continued use of the Site after any change(s) will constitute acceptance of such change(s).

Law and Jurisdiction

This Privacy Policy is governed by the laws of the Commonwealth of Massachusetts, USA, without regard to its choice of law provisions, except where preempted by federal law. The courts of general jurisdiction located within the City of Boston, Massachusetts, USA, will have exclusive jurisdiction over any and all disputes arising out of, relating to or concerning this Privacy Policy or in matters in which this Privacy Policy is a material fact.

In the event that a court of competent jurisdiction holds any provision of this Privacy Policy to be invalid or unenforceable, then such provision shall be severable from and shall not affect the validity or enforceability of the remaining provisions.

The Site is controlled, operated and intended for use solely within the United States of America. We do not represent or warrant that the Site, any content thereon, or any use of the Site or any such content are appropriate or lawful for use outside of the United States of America. Use of the Site is void where prohibited.

Contact Us with Questions or Comments

If you have any questions about the Privacy Policy, please contact us at the address above.

Updated: May 3, 2022.

Website Terms of Use

Last Modified: November 4, 2024

Acceptance of the Terms of Use

The website located at www.fullcircletech.com (the “Website”) is owned and operated by and is a copyrighted work belonging to Full Circle Technologies, Inc. (the “Company,” “us,” “our,” and “we”).  The following terms and conditions, together with any documents they expressly incorporate by reference (collectively, these “Terms of Use”), govern your access to and use of the Website, including any content, functionality and services offered on or through the Website.

Please read these Terms of Use carefully before you use the Website. By using the Website or by clicking to accept or agree to theSe Terms of Use when this option is made available to you, you accept and agree to be bound and abide by these Terms of Use and our Privacy Policy WHICH IS incorporated herein by reference.  If you do not agree to these Terms of Use or the Privacy Policy, you must not access or use the Website.

This Website is available only to individuals who can form legally binding contracts under applicable law.  By using this Website, you represent and warrant that you are (i) at least eighteen (18) years of age and (ii) otherwise recognized as being able to form legally binding contracts under applicable law.  If you do not meet all of these requirements, you must not access or use the Website.

Changes to the Terms of Use

We may revise and update these Terms of Use from time to time in our sole discretion. All changes are effective immediately when we post them and apply to all access to and use of the Website thereafter.  However, any changes to the dispute resolution provisions set forth in the section of these Terms of Use entitled “Governing Law and Jurisdiction” will not apply to any disputes for which the parties have actual notice prior to the date the change is posted on the Website.

Your continued use of the Website following the posting of revised Terms of Use means that you accept and agree to the changes. You are expected to check this page each time you access this Website so that you are aware of any changes, as they are binding on you.

Accessing the Website and Account Security

We reserve the right to withdraw or amend this Website and any service or material that we provide or make available on the Website in our sole discretion and without notice.  We will not be liable if for any reason all or any part of the Website is unavailable at any time or for any period.  From time to time, we may restrict access to all or certain parts of the Website.

You are responsible for:

• making all arrangements necessary for you to have access to the Website.
• ensuring that all persons who access the Website through your internet connection are aware of these Terms of Use and comply with them.

When accessing the Website, contacting us directly via telephone or email, or submitting a request to contact us, you may be asked to provide certain information about yourself, including your first and last name and your email address.  It is a condition of your use of the Website that all the information you provide to us on the Website is correct, current, and complete.  You agree that all information that you provide to us when using the Website is governed by our Privacy Policy and you consent to all actions we take with respect to your information consistent with our Privacy Policy.

Intellectual Property Rights

The Website and all of its contents, features, and functionality (including but not limited to all information, software, text, displays, images, video and audio, and the design, selection, and arrangement thereof), are owned by the Company, its licensors or other providers of such material and are protected by United States and international copyright, trademark, patent, trade secret and other intellectual property or proprietary rights laws.

These Terms of Use permit you to use the Website for your personal, non-commercial use only. You must not reproduce, distribute, modify, create derivative works of, publicly display, publicly perform, republish, download, store or transmit any of the material on our Website, except as follows:

• Your computer may temporarily store copies of such materials in RAM incidental to your accessing and viewing those materials.
• You may store files that are automatically cached by your Web browser for display enhancement purposes.
• You may print or download one copy of a reasonable number of pages of the Website for your own personal, non-commercial use and not for further reproduction, publication or distribution.

You must not:

• Modify copies of any materials from this Website.
• Use any illustrations, photographs, video or audio sequences or any graphics separately from the accompanying text.
• Delete or alter any copyright, trademark or other proprietary rights notices from copies of materials from this Website.

You must not access or use for any commercial purposes any part of the Website or any services or materials available through the Website.

If you print, copy, modify, download or otherwise use or provide any other person with access to any part of the Website in breach of the Terms of Use, your right to use the Website will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.  No right, title or interest in or to the Website or any content on the Website is transferred to you, and all rights not expressly granted are reserved by the Company.  Any use of the Website not expressly permitted by these Terms of Use is a breach of these Terms of Use and may violate copyright, trademark and other laws.

Trademarks

The Company name and all related names, logos, product and service names, designs, and slogans are trademarks of the Company or its affiliates or licensors.  You must not use such marks without the prior written permission of the Company.  All other names, logos, product and service names, designs, and slogans on this Website are the trademarks of their respective owners.

Prohibited Uses

You may use the Website only for lawful purposes and in accordance with these Terms of Use.  You agree not to use the Website:

• in any way that violates any applicable federal, state, local or international law or regulation (including, without limitation, any laws regarding the export of data or software to and from the US or other countries);
• for the purpose of exploiting, harming or attempting to exploit or harm minors in any way by exposing them to inappropriate content, asking for personally identifiable information or otherwise;
• to transmit, or procure the sending of, any advertising or promotional material, including any “junk mail,” “chain letter” or “spam” or any other similar solicitation;
• to impersonate or attempt to impersonate the Company, a Company employee, another user or any other person or entity (including, without limitation, by using e-mail addresses associated with any of the foregoing); or
• to engage in any other conduct that restricts or inhibits anyone’s use or enjoyment of the Website, or which, as determined by us, may harm the Company or users of the Website or expose them to liability.

Additionally, you agree not to:

• use the Website in any manner that could disable, overburden, damage or impair the Website or interfere with any other party’s use of the Website, including their ability to engage in real time activities through the Website;
• use any robot, spider or other automatic device, process or means to access the Website for any purpose, including monitoring or copying any of the material on the Website;
• use any manual process to monitor or copy any of the material on the Website or for any other unauthorized purpose without our prior written consent;
• use any device, software or routine that interferes with the proper working of the Website;
• introduce any viruses, trojan horses, worms, logic bombs or other material which is malicious or technologically harmful;
• attempt to gain unauthorized access to, interfere with, damage or disrupt any parts of the Website, the server on which the Website is stored, or any server, computer or database connected to the Website;
• attack the Website via a denial-of-service attack or a distributed denial-of-service attack; or
• otherwise attempt to interfere with the proper working of the Website.

Website Disclaimer

The information presented on or through the Website is made available solely for general informational purposes. All information on the Website is provided in good faith, however, we make no representations or warranties of any kind, whether express or implied, regarding the accuracy, adequacy, validity, reliability, availability, usefulness or completeness of any information on the Website. UNDER NO CIRCUMSTANCE SHALL WE HAVE ANY LIABILITY TO YOU OR TO ANYONE WHO MAY BE INFORMED OF ANY OF ITS CONTENTS FOR ANY LOSS OR DAMAGE OF ANY KIND INCURRED AS A RESULT OF THE USE OF THE WEBSITE OR RELIANCE ON ANY INFORMATION PRESENTED ON OR THROUGH THE WEBSITE. YOUR USE OF THE WEBSITE AND YOUR RELIANCE ON ANY INFORMATION POSTED OR MADE AVAILABLE ON THE WEBSITE IS SOLELY AT YOUR OWN RISK.

External Information and Links Disclaimer

The Website may contain (or you may be sent through the Website) links to other websites or content belonging to or originating from third parties or links to websites and features in banners or other advertising. All statements and/or opinions expressed in these materials, and all articles and responses to questions and other content, other than the content provided by the Company, are solely the opinions and the responsibility of the person or entity providing those materials. Such external links are not investigated, monitored or checked for accuracy, adequacy, validity, reliability, availability, usefulness or completeness by us. WE DO NOT WARRANT, ENDORSE, GUARANTEE, OR ASSUME RESPONSIBILITY FOR THE ACCURACY OR RELIABILITY OF ANY INFORMATION OFFERED BY THIRD-PARTY WEBSITES LINKED THROUGH THE WEBSITE OR ANY WEBSITE OR FEATURE LINKED IN ANY BANNER OR OTHER ADVERTISING. WE WILL NOT BE A PARTY TO OR IN ANY WAY BE RESPONSIBLE FOR MONITORING ANY TRANSACTION BETWEEN YOU AND THIRD-PARTY PROVIDERS OF PRODUCTS OR SERVICES. We are not responsible, or liable to you or any third party, for the content or accuracy of any materials provided by any third parties.

Changes to the Website

We may update the content on this Website from time to time, but its content is not necessarily complete or up-to-date. Any of the material on the Website may be out of date at any given time and we are under no obligation to update such material.

Information About You and Your Visits to the Website

All information we collect on this Website is subject to our Privacy Policy. By using the Website, you consent to all actions taken by us with respect to your information in compliance with the Privacy Policy.

Links from the Website

If the Website contains links to other websites and resources provided by third parties, these links are provided for your convenience only. This includes links contained in advertisements, including banner advertisements and sponsored links. We have no control over the contents of those websites or resources and accept no responsibility for them or for any loss or damage that may arise from your use of them. If you decide to access any of the third party websites linked to this Website, you do so entirely at your own risk and subject to the terms and conditions of use for such websites.

Geographic Restrictions

The owner of the Website is based in the Commonwealth of Massachusetts in the United States. We make no claims that the Website or any of its content is accessible or appropriate outside of the United States. Access to the Website may not be legal by certain persons or in certain countries. If you access the Website from outside the United States, you do so on your own initiative and are responsible for compliance with local laws.

Disclaimer of Warranties

You understand that we cannot and do not guarantee or warrant that files available for downloading from the internet or the Website will be free of viruses or other destructive code. You are responsible for implementing sufficient procedures and checkpoints to satisfy your particular requirements for anti-virus protection and accuracy of data input and output, and for maintaining a means external to our Website for any reconstruction of any lost data. WE ARE NOT LIABLE FOR ANY LOSS OR DAMAGE CAUSED BY A DISTRIBUTED DENIAL-OF-SERVICE ATTACK, VIRUSES OR OTHER TECHNOLOGICALLY HARMFUL MATERIAL THAT MAY INFECT YOUR COMPUTER EQUIPMENT, COMPUTER PROGRAMS, DATA OR OTHER PROPRIETARY MATERIAL DUE TO YOUR USE OF THE WEBSITE OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE OR TO YOUR DOWNLOADING OF ANY MATERIAL POSTED ON IT, OR ON ANY WEBSITE LINKED TO IT.

YOUR USE OF THE WEBSITE, ITS CONTENT AND ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE IS AT YOUR OWN RISK. THE WEBSITE, ITS CONTENT, AND ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS, WITHOUT ANY WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. NEITHER THE COMPANY NOR ANY PERSON ASSOCIATED WITH THE COMPANY MAKES ANY WARRANTY OR REPRESENTATION WITH RESPECT TO THE COMPLETENESS, SECURITY, RELIABILITY, QUALITY, ACCURACY OR AVAILABILITY OF THE WEBSITE. WITHOUT LIMITING THE FOREGOING, NEITHER THE COMPANY NOR ANYONE ASSOCIATED WITH THE COMPANY REPRESENTS OR WARRANTS THAT THE WEBSITE, ITS CONTENT OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE WILL BE ACCURATE, RELIABLE, ERROR-FREE OR UNINTERRUPTED, THAT DEFECTS WILL BE CORRECTED, THAT OUR WEBSITE OR THE SERVER THAT MAKES IT AVAILABLE ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS OR THAT THE WEBSITE OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE WILL OTHERWISE MEET YOUR NEEDS OR EXPECTATIONS.

THE COMPANY HEREBY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, STATUTORY OR OTHERWISE, INCLUDING BUT NOT LIMITED TO ANY WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT AND FITNESS FOR PARTICULAR PURPOSE.

Limitation on Liability

IN NO EVENT WILL THE COMPANY, ITS AFFILIATES OR THEIR LICENSORS, SERVICE PROVIDERS, EMPLOYEES, AGENTS, OFFICERS OR DIRECTORS BE LIABLE FOR DAMAGES OF ANY KIND, UNDER ANY LEGAL THEORY, ARISING OUT OF OR IN CONNECTION WITH YOUR USE, OR INABILITY TO USE, THE WEBSITE, ANY WEBSITES LINKED TO IT, ANY CONTENT ON THE WEBSITE OR SUCH OTHER WEBSITES OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE OR SUCH OTHER WEBSITES, INCLUDING ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO, PERSONAL INJURY, PAIN AND SUFFERING, EMOTIONAL DISTRESS, LOSS OF REVENUE, LOSS OF PROFITS, LOSS OF BUSINESS OR ANTICIPATED SAVINGS, LOSS OF USE, LOSS OF GOODWILL, LOSS OF DATA, AND WHETHER CAUSED BY TORT (INCLUDING NEGLIGENCE), BREACH OF CONTRACT OR OTHERWISE, EVEN IF FORESEEABLE.

Indemnification

You agree to defend, indemnify, and hold harmless the Company, its affiliates, licensors and service providers, and its and their respective officers, directors, employees, contractors, agents, licensors, suppliers, successors and assigns from and against any claims, liabilities, damages, judgments, awards, losses, costs, expenses or fees (including reasonable attorneys’ fees) arising out of or relating to your violation of these Terms of Use or your use of the Website, including, but not limited to, any use of the Website’s content, services, and products other than as expressly authorized in these Terms of Use or your use of any information obtained from the Website.

Governing Law and Jurisdiction

All matters relating to the Website and these Terms of Use and any dispute or claim arising therefrom or related thereto (in each case, including non-contractual disputes or claims), shall be governed by and construed in accordance with the internal laws of the Commonwealth of Massachusetts without giving effect to any choice or conflict of law provision or rule (whether of the Commonwealth of Massachusetts or any other jurisdiction).

Any legal suit, action or proceeding arising out of, or related to, these Terms of Use or the Website shall be instituted exclusively in the federal courts of the United States or the courts of the Commonwealth of Massachusetts in each case located in the City of Boston and County of Suffolk although we retain the right to bring any suit, action or proceeding against you for breach of these Terms of Use in your country of residence or any other relevant country. You waive any and all objections to the exercise of jurisdiction over you by such courts and to venue in such courts.

Limitation on Time to File Claims

ANY CAUSE OF ACTION OR CLAIM YOU MAY HAVE ARISING OUT OF OR RELATING TO THESE TERMS OF USE OR THE WEBSITE MUST BE COMMENCED WITHIN ONE (1) YEAR AFTER THE CAUSE OF ACTION ACCRUES, OTHERWISE, SUCH CAUSE OF ACTION OR CLAIM IS PERMANENTLY BARRED.

Waiver and Severability

No waiver by the Company of any term or condition set forth in these Terms of Use shall be deemed a further or continuing waiver of such term or condition or a waiver of any other term or condition and any failure of the Company to assert a right or provision under these Terms of Use shall not constitute a waiver of such right or provision.

If any provision of these Terms of Use is held by a court or other tribunal of competent jurisdiction to be invalid, illegal or unenforceable for any reason, such provision shall be eliminated or limited to the minimum extent such that the remaining provisions of the Terms of Use will continue in full force and effect.

Entire Agreement

The Terms of Use and our Privacy Policy constitute the sole and entire agreement between the Company and you with respect to the Website and supersede all prior and contemporaneous understandings, agreements, representations and warranties, both written and oral, with respect to the Website.

Digital Millennium Copyright Act (the “DMCA”)

We respect the intellectual property rights of others and ask that users of our Website do the same. In connection with our Website, we have adopted and implemented a policy respecting copyright law that provides for the removal of any infringing materials and for the termination, in appropriate circumstances, of users of our Website who are repeat infringers of intellectual property rights, including copyrights. If you believe that one of our users is, through the use of our Website, unlawfully infringing the copyright(s) in a work, and wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the U.S. Digital Millennium Copyright Act, 17 U.S.C. § 512) must be provided to our designated copyright agent:

Full Circle Technologies, Inc
11 Beacon Street Suite 340
Boston, MA 02108
Attention: DMCA Agent

Email: help@fullcircletech.com

To submit a valid notice of alleged copyright infringement, ensure you provide:

1. A signature (either electronic or physical) of the person authorized to act on behalf of the copyright owner.
2. A detailed description of the copyrighted work you believe has been infringed.
3. The specific location of the purported infringing material on our Website.
4. Your contact details, including your address, phone number, and email.
5. A statement that you have a good faith belief that the use of the material is not sanctioned by the copyright owner, its agent, or the law.
6. A declaration, made under the penalty of perjury, confirming the accuracy of the information in your notice and that you are either the copyright owner or have the authority to act on their behalf.

General Contact Information

All other feedback, comments, requests for technical support and other communications relating to the Website should be directed to: help@fullcircletech.com

Privacy Policy

Last Modified: November 4, 2024

Full Circle Technologies, Inc. (the “Company,” “us,” “our,” and “we“) respects your privacy and is committed to protecting it through our compliance with this privacy policy (this “Privacy Policy”).

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit our website located at www.fullcircletech.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• on this Website; and
• in e-mail, text, and other electronic messages between you and this Website.

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by the Company or any third party; or
• any third party, including through any application or content (including advertising) that may link to or be accessible from the Website.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you should refrain from accessing and using our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Website Users Under 18 Years of Age

Our Website is not intended for any users under 18 years of age. Accordingly, no one under 18 years of age may provide any personal information to or on the Website. We do not knowingly collect personal information from any users under 18 years of age. If you are under 18 years of age, you are prohibited from using the Website, providing any information on this Website or through any of its features or providing any information about yourself to us, including your name, address, telephone number, email address or any screen name or username you may use. If we learn we have collected or received personal information from any user under 18 years of age, we will delete that information. If you believe we might have any information from or about any user under 18 years of age, please contact us at help@fullcircletech.com

Information We Collect About You and How We Collect It

We collect various types of information from and about users of our Website, including:

• personally identifiable information, such as your first and last name, email address, telephone number, and other similar contact information, as well as any other non-public information about you that is associated with or linked to any of the foregoing data (sometimes referred to as “Personal Data”);
• information our servers automatically collect when you access the Website, such as your IP address, browser type, the dates and times of your visits, the pages or content you view, your interactions with the Website’s features, and other similar data, and other Anonymous Data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons.

We collect this information:

• directly from you when you provide it to us, such as when contact us via the Website, email, or phone; and
• automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses and information collected through cookies and other tracking technologies.

Information You Provide to Us.

The information we collect on or through our Website may include:

• information that you provide by filling in forms on our Website. This may include information that you provide to us when contacting us or requesting additional services; and
• records and copies of your correspondence (including e-mail addresses), if you contact us.

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• To make our Website more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP“) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
• Like many other websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, internet service provider (“ISP“), referring/exit pages, operating system, date/time stamp, and clickstream data.
• Like many websites, we use cookies to collect information. “Cookies” are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a website or mobile application. Cookies are then sent back to the originating site on each subsequent visit, or to another site that recognizes those cookies. Cookies are widely used in order to make sites work, or to work more efficiently, as well as to provide information to the owners of the platform. We use cookies to enhance the online experience of our visitors and to better understand how our site is used. Cookies may tell us, for example, whether you have visited our site before or whether you are a new visitor. This type of information is collected to make the Website more useful to you.
• We may use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user.
• We use Google Analytics to help analyze how users use the Website. Google Analytics uses Cookies to collect information such as how often users visit the Website, what pages they visit, and what other sites they used prior to coming to the Website. We use the information we get from Google Analytics only to improve the Website. Google Analytics collects only the IP address assigned to you on the date you visit the Website, rather than your name or other personally identifying information. We do not combine the information generated through the use of Google Analytics with your Personal Data. Although Google Analytics plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Website, the Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Use of Your Personal Data and Anonymous Data

In general, Personal Data you submit to us is used to respond to requests that you make. We use your Personal Data in the following ways:

• to provide improved administration of the Website;
• to improve the quality of experience when you interact with the Website;
• to send you follow-up communications when you contact us via e-mail, submit feedback, or post an event; and
• to send you administrative e-mail notifications, such as updates regarding the Website, security, or support and maintenance advisories.

We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of, and improve navigation on, the Website. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.

Website Users Outside the United States

If you are a user of the Website who resides in a country other than the United States this section applies to you:

• If you reside in the UK or any country within the European Economic Area (“EEA“):
  • The Company is the Controller (for the purposes of the General Data Protection Regulation 2016/679 (“GDPR”) and any implementing legislation or legislation having equivalent effect in the UK (together, “EU Data Protection Legislation”)) of your Personal Data.
  • The legal basis of our processing of your Personal Data as described in this Privacy Policy is our legitimate interests where those interests are not overridden by the impact on you (unless our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, please contact us at the address or phone number above.
  • We ask that you not provide us with any Special Category Personal Data (as defined in the GDPR), e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or trade union membership, or any criminal background information. If you do not consent to our processing and use of such sensitive information, you must not submit such sensitive information through the Website.
  • We may transfer your Personal Data to a country outside the UK or EEA in accordance with requirements prescribed under EU Data Protection Legislation. When we transfer your Personal Data outside the UK or EEA, we hold it subject to appropriate safeguards and controls and ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:
  • We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en(opens in a new tab).
• If you reside in Singapore:
  • You agree that your accessing or using the Website in any way constitutes your agreement that (a) we may process your Personal Data for the purposes identified in the Privacy Policy, and (b) your Personal Data may be transferred to and processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country.
  • We may transfer your Personal Data to a country or territory outside Singapore in accordance with requirements prescribed under the Singapore Personal Data Protection Act (“PDPA”) to ensure that we provide a standard of protection to Personal Data so transferred that is comparable to the protection under the PDPA. By providing your Personal Data, you consent to such transfer.

Accessing and Correcting Your Information

You may send us an e-mail at help@fullcircletech.com to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to help@fullcircletech.com

Additional Rights Related to Personal Data for Users Outside of the United States.

If you reside in the UK or EEA, you have certain, you have certain rights regarding your Personal Data and may, in certain circumstances, ask us to take the following actions in relation to such data:

• provide you with information about our processing of your Personal Data and give you access to such data;
• update or correct inaccuracies in your Personal Data;
• delete your Personal Data;
• transfer a machine-readable copy of your Personal Data to you or a third party of your choice;
• restrict the processing of your Personal Data;
• object to our reliance on our legitimate interests as the basis of our processing of your Personal Data that impacts your rights.

If you reside in Singapore, you may request to access and/or correct your Personal Data currently in our possession by writing to us. Please note that we may charge you a reasonable fee for the handling and processing of your requests to access your Personal Data.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, please contact us at: help@fullcircletech.com

Privacy Policy (updated May 2022)

This Privacy Policy shall apply to all information Full Circle Technologies, Inc. and its clients and partners receive from you, including via a visit to www.fullcircletech.com and any domains and affiliated websites, or via use of our PermitEyes programs at permiteyes.com, permiteyes.us, permiteyes.net and fctpermit.com, all of which we refer to in this Privacy Policy collectively as the “Site.” This policy also covers any information obtained about you as a result of your use of the Site, as well as any information you provide to our municipal government clients and partners, and any information we may collect about you from third-party sources, in connection with your pursuit of a permit, registration, license or the like.

We use the terms “we”, “us”, “Full Circle Tech” or the “Company” in this Privacy Policy to refer to Full Circle Technologies, Inc., a Massachusetts corporation.

Please read this Privacy Policy carefully. By using the Site or otherwise submitting information to us or our clients in any format, you agree to be bound by this Privacy Policy.

Respecting Your Privacy

Full Circle Tech values its relationship with you and respects your privacy. We have provided this Privacy Policy in order for you to know how we protect the information you provide to us or to our clients and partners while visiting the Site, utilizing our services, or utilizing the services of our clients and partners, what other information we may collect, and how and under what circumstances we use and disclose such information. If you use the Site and provide information as requested on the Site or otherwise, then you do so in full agreement with the terms and conditions described in this Privacy Policy.

Information Gathering

We may collect information about you, and your use of the Site, in several different ways:

1. User Submitted Data is information you personally elect to provide, such as your name and address, whether by means of typing the information into an application form or permit, providing information in a telephone call or email, or otherwise;
2. Browser Derived Data is information we collect from your use of the Site-for example, whether you are accessing the Site using a smartphone or home computer; and
3. Third-Party Data is information we may obtain about you from third-party sources (if any).

Our collection and use of these types of information is covered by this Privacy Policy as described below.

User Submitted Data

User Submitted Data is information that identifies you as an individual such as your name, postal address, email address, and home and/or wireless telephone numbers. This information is typically collected from you when you visit the Site and submit an application (via the Site or directly to a municipal government) for a permit, registration, license, or other product or service. User Submitted Data also includes information obtained from you by phone, a mobile application, email, a service provider, or any other means.

If you provide information to us about others, we will only use the information provided for the specific reason for which it is provided.

We may use User Submitted Data for several purposes, including without limitation to:

• provide a requested service or product
• respond to your questions
• send you information about the Site, the Company, or our products and services
• send you information regarding the Site, changes to our terms, conditions, and policies, and other administrative information
• personalize your experience on the Site by presenting products and offers tailored to you, and
• assist with our business purposes, such as analyzing and managing our business, improving our services and products and developing new ones, gauging customer satisfaction and providing customer service (including troubleshooting in connection with customer issues).

User Submitted Data you provide through the Site, to our municipal government clients and partners, or otherwise may be combined with other information you provide (via online or offline means), with demographic information and other information that is publicly available, or with other information about you that we may otherwise obtain either online or offline.

We may disclose User Submitted Data to:

• our agents, employees, contractors and affiliates for the purposes described in this Privacy Policy
• our municipal government clients and partners and their agents and affiliates, that play a role in a transaction with you
• third-party service providers that provide services for us (such as website hosting, data analysis, payment processing, order fulfillment, IT services, customer service, email delivery services and other similar services), in each case to enable them to provide such services
• identify you to anyone to whom you send messages through the Site or otherwise, and
• a third-party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Our agents, employees, contractors, and affiliates have access to your User Submitted Data on a need-to-know basis for the purpose of performing services on our behalf. All such individuals and entities with access to such information have agreed to keep such information confidential and abide by the terms of this Privacy Policy, and not to use any such information other than to carry out the services they are performing on our and your behalf, or as otherwise required by law.

The parties with whom we share your User Submitted Data, including our municipal government clients, may in turn share that information with others in order to generate permits, registrations and licenses and otherwise fulfill transactions with you. They may contact you directly at the phone number(s) or email address(es) you provide to collect additional information, answer questions, complete transactions or provide you with information about other products and services (even if, in the case of phone calls, you have registered the phone number(s) provided on local or national Do Not Call lists).

Please be aware that many applications, once submitted, are covered under the Freedom of Information Act (“FOIA”), which allows the public to request information pertaining to a government agency’s functions, practices, and future plans. FOIA is mandated by Congress and applies to all government agencies, including municipal governments. Anyone may request records under the FOIA. Public disclosure is mandatory unless exempted under Title 5 U.S.C. 552. If you choose to upload any images, PDFs, or other attachments using our Site, please be aware that (i) images may contain geographic information (EXIF GPS) and you may wish to remove this data before uploading; and (ii) although Full Circle Tech attempts to request all submissions not be indexed, search engines may read and report your upload or submission in search results.

We assume no responsibility or liability for the policies or practices of our municipal government clients or any third parties with whom they may share your information in accordance with their own policies or practices. We strongly urge users to review the laws and practices of the municipal governments and third parties with which they conduct business.

We will not rent, sell or license any User Submitted Data constituting personal information or potentially personally-identifying information to any third parties.

Browser Derived Data

Browser Derived Data is information that is not submitted by you but that is instead provided by or results from your access and use of the Internet and an Internet browser to connect to the Site. Browser Derived Data includes browser specific information such as browser type, IP address, Internet Service Provider or “ISP” information, server log file information, referring/exit pages, date/time stamps, information collected through cookies, pixel tags and other technologies, and location information.

We receive Browser Derived Data by your access to the Site, including in the following manner:

• Certain information is collected by most internet browsers, such as MAC address, type of computer, operating system details, browser software details, screen resolution, and whether it is a mobile device.
• Your “IP Address” is a number that is automatically assigned to the computer or device that you are using by your ISP. An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many websites. We use IP Addresses for purposes such as calculating usage levels of the Site, helping diagnose server problems, and administering the Site.
• Cookies allow a web server to transfer data to a computer or device for recordkeeping and other purposes. We and our partners use cookies, analytics, remarketing and other similar tracking technologies to, among other things, better serve you with more tailored information and facilitate your ongoing access to and use of the Site. A cookie enables the Site to label you as a particular user, but it does not identify you by name or address unless you have provided such information or set up preferences in your browser to do so automatically. If you do not want information collected through the use of cookies, your internet browser has a tool to disable cookies.
• We may use applications, including mobile applications or widgets, to collect information from you.
• The Site may also use pixel tags, web beacons, clear GIFs or other similar technologies. These may be used in connection with the Site and HTML-formatted email messages to, among other things, track the actions of the Site’s users and compile statistics about the Site’s usage and response rates.

We may use Browser Derived Data and other data that does not identify you personally for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Browser Derived Data with User Submitted Data (such as combining your name with your geographical location). If we combine any Browser Derived Data with User Submitted Data, the combined information will be treated by us as User Submitted Data as long as it is combined.

We may share, rent, sell or license Browser Derived Data regarding our users to third parties, including service providers, but not in a manner in which the recipient would be able to identify you personally.

Third-Party Data

Third-Party Data is information that is not submitted directly by you but that is instead provided by third-party service providers to us or our municipal government clients and partners in connection with our fulfillment of a transaction for you. If required, your consent will be obtained before such third-party data is obtained.

We may use Third-Party Data for several purposes, including to

• assist with the fulfillment of a transaction you requested
• respond to your questions
• provide you with email updates and announcements concerning our products, promotions and programs
• personalize your experience on the Site by presenting products and offers tailored to you, and
• assist with our business purposes, such as analyzing and managing our businesses, improving our services and products and developing new ones, and gauging customer satisfaction and providing customer service (including troubleshooting in connection with customer issues).

We may combine Third-Party Data with User Submitted Data (such as combining your name with your application history). The combined information will be treated by us as User Submitted Data.

Other Use and Disclosure

We also may use and/or disclose User Submitted Data, Browser Derived Data and/or Third-Party Data as we believe to be necessary or appropriate to:

• comply with legal process
• respond to requests from public and government authorities, including public and government authorities outside the United States
• enforce this Privacy Policy and any terms of use governing the Site and our services
• protect our operations or those of any of our affiliates or clients
• protect our rights, privacy, safety or property, and/or that of our affiliates, clients, you or others
• allow us to pursue available remedies or limit the damages that we may sustain, and
• as otherwise permitted by law, including laws of jurisdictions outside the United States and/or the country of your residence.

As noted above, in certain situations we may be required to disclose personal data in response to lawful requests from public or government authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena, when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others, or to investigate fraud.

Linked Sites

This Privacy Policy does not address, and we are not responsible for, the privacy, security or other practices of any third-party websites for whom we may include a link within the Site. Without limiting the foregoing, Full Circle Tech specifically disclaims any responsibility if such third-party sites do not provide adequate security for your personal information. Such links are provided for your convenience only. We are not endorsing, in any manner, any of the linked sites that may be referenced in or linked to the Site.

Although we believe that each of the sites to which we provide links should post a privacy statement that fully describes the data collection, use and advertising practices of such site, we can give no guarantee that all of those sites have or post such a privacy policy. We encourage you to read the terms of use and privacy policies of any such linked third-party site, as they may differ from ours.

Additionally, certain personal information may be made available to third parties using our Application Programming Interface, or “API.” Use of third-party applications developed using our API are subject to the terms of use and privacy policies of such third-party developers.

Remarketing and Retargeting

We may use third-party remarketing services (such as Google AdWords, AdRoll and Facebook) to advertise on third-party websites to previous visitors of the Site. It could mean that we advertise to previous visitors who haven’t completed a task on the Site. This could be in the form of an advertisement or posting on the Google search results page, Facebook, or various other websites within these networks or on the worldwide web. Any data collected will be used in accordance with our own privacy policy and the privacy policies of these third-party remarketing services. You can set your preferences for how these services advertise to you by visiting their consumer opt-out pages.

Advertising Vendors

Please note that our online and email advertising-related vendors may use pixel tags, web beacons, clear GIFs or other similar technologies in connection with the Site to help manage our online and email advertising campaigns and strengthen the effectiveness of such campaigns. For example, if a vendor has placed a unique cookie on your computer, the vendor may use pixel tags, web beacons, clear GIFs or other similar technologies to recognize the cookie during your visit to the Site and to learn which of our online advertisements may have brought you to the Site, and the vendor may provide us with such Browser Derived Data for our use. Please note we may link such Browser Derived Data provided to us by our vendors to User Submitted Data about you that we have previously collected. Such combined information will be treated as User Submitted Data hereunder as long as it is so combined, as noted above.

Security Measures

We employ commercially reasonable organizational, technical and administrative measures to protect User Submitted Data under our control and prevent its unauthorized use or disclosure. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any User Submitted Data, which you transmit at your own risk.

Access by Minors

Our Site is not intended for or directed to individuals under the age of thirteen (13). We request that these individuals not provide User Submitted Data through the Site. If you become aware that information has been submitted by or collected from a child under the age of 13, please contact us directly at:

Full Circle Technologies, Inc.
11 Beacon Street Suite 340
Boston, MA 02108

Email: help@fullcircletech.com

Once such a request has been received and verified, we will delete the information collected within a reasonable time.

Sensitive Personal Data

We ask that you not send or disclose to the Company any sensitive personal information about yourself and your identity via the Site. We do not collect via the Site for any purpose, nor do we have any need for, your race, religion, national origin, work history, political participation, health information, criminal background, or similar information.

In the event you are requested to provide such personal information to enable us or our clients or partners to fulfill a transaction with you, make and process payments, and facilitate interactions with third-party service providers, such information should only be submitted directly to the individual or entity authorized to make such request related to a proper business purpose. It is always your choice as to whether to provide such personal information. If you elect not to provide the personal information, we and/or or clients may not be able to engage in a transaction with you. Sensitive personal data is considered User Submitted Data under this Privacy Policy and treated accordingly.

For highly sensitive information, such as social security number, and payment information, we restrict access to employees, agents, and others who use such information only as permitted by law and to provide you products and services.

Other Information

Any communication or material you provide or transmit to the Site that is not User Submitted Data, such as questions, comments or suggestions, will be treated as non-confidential and non-proprietary and may be used by us for any purpose and without restriction or obligation to you.

Changes to this Privacy Policy

Full Circle Tech may at any time in its sole discretion, and without notice, revise this Privacy Policy by updating this posting. You are bound by any such revisions and should therefore periodically visit this page to review the current Privacy Policy. The date of the most recent update is noted below. Your continued use of the Site after any change(s) will constitute acceptance of such change(s).

Law and Jurisdiction

This Privacy Policy is governed by the laws of the Commonwealth of Massachusetts, USA, without regard to its choice of law provisions, except where preempted by federal law. The courts of general jurisdiction located within the City of Boston, Massachusetts, USA, will have exclusive jurisdiction over any and all disputes arising out of, relating to or concerning this Privacy Policy or in matters in which this Privacy Policy is a material fact.

In the event that a court of competent jurisdiction holds any provision of this Privacy Policy to be invalid or unenforceable, then such provision shall be severable from and shall not affect the validity or enforceability of the remaining provisions.

The Site is controlled, operated and intended for use solely within the United States of America. We do not represent or warrant that the Site, any content thereon, or any use of the Site or any such content are appropriate or lawful for use outside of the United States of America. Use of the Site is void where prohibited.

Contact Us with Questions or Comments

If you have any questions about the Privacy Policy, please contact us at the address above.

Updated: May 3, 2022.

Website Terms of Use

Last Modified: November 4, 2024

Acceptance of the Terms of Use

The website located at www.fullcircletech.com (the “Website”) is owned and operated by and is a copyrighted work belonging to Full Circle Technologies, Inc. (the “Company,” “us,” “our,” and “we”). The following terms and conditions, together with any documents they expressly incorporate by reference (collectively, these “Terms of Use”), govern your access to and use of the Website, including any content, functionality and services offered on or through the Website.

Please read these Terms of Use carefully before you use the Website. By using the Website or by clicking to accept or agree to theSe Terms of Use when this option is made available to you, you accept and agree to be bound and abide by these Terms of Use and our Privacy Policy WHICH IS incorporated herein by reference. If you do not agree to these Terms of Use or the Privacy Policy, you must not access or use the Website.

This Website is available only to individuals who can form legally binding contracts under applicable law. By using this Website, you represent and warrant that you are (i) at least eighteen (18) years of age and (ii) otherwise recognized as being able to form legally binding contracts under applicable law. If you do not meet all of these requirements, you must not access or use the Website.

Changes to the Terms of Use

We may revise and update these Terms of Use from time to time in our sole discretion. All changes are effective immediately when we post them and apply to all access to and use of the Website thereafter. However, any changes to the dispute resolution provisions set forth in the section of these Terms of Use entitled “Governing Law and Jurisdiction” will not apply to any disputes for which the parties have actual notice prior to the date the change is posted on the Website.

Your continued use of the Website following the posting of revised Terms of Use means that you accept and agree to the changes. You are expected to check this page each time you access this Website so that you are aware of any changes, as they are binding on you.

Accessing the Website and Account Security

We reserve the right to withdraw or amend this Website and any service or material that we provide or make available on the Website in our sole discretion and without notice. We will not be liable if for any reason all or any part of the Website is unavailable at any time or for any period. From time to time, we may restrict access to all or certain parts of the Website.

You are responsible for:

• making all arrangements necessary for you to have access to the Website.
• ensuring that all persons who access the Website through your internet connection are aware of these Terms of Use and comply with them.

When accessing the Website, contacting us directly via telephone or email, or submitting a request to contact us, you may be asked to provide certain information about yourself, including your first and last name and your email address. It is a condition of your use of the Website that all the information you provide to us on the Website is correct, current, and complete. You agree that all information that you provide to us when using the Website is governed by our Privacy Policy and you consent to all actions we take with respect to your information consistent with our Privacy Policy.

Intellectual Property Rights

The Website and all of its contents, features, and functionality (including but not limited to all information, software, text, displays, images, video and audio, and the design, selection, and arrangement thereof), are owned by the Company, its licensors or other providers of such material and are protected by United States and international copyright, trademark, patent, trade secret and other intellectual property or proprietary rights laws.

These Terms of Use permit you to use the Website for your personal, non-commercial use only. You must not reproduce, distribute, modify, create derivative works of, publicly display, publicly perform, republish, download, store or transmit any of the material on our Website, except as follows:

• Your computer may temporarily store copies of such materials in RAM incidental to your accessing and viewing those materials.
• You may store files that are automatically cached by your Web browser for display enhancement purposes.
• You may print or download one copy of a reasonable number of pages of the Website for your own personal, non-commercial use and not for further reproduction, publication or distribution.

You must not:

• Modify copies of any materials from this Website.
• Use any illustrations, photographs, video or audio sequences or any graphics separately from the accompanying text.
• Delete or alter any copyright, trademark or other proprietary rights notices from copies of materials from this Website.

You must not access or use for any commercial purposes any part of the Website or any services or materials available through the Website.

If you print, copy, modify, download or otherwise use or provide any other person with access to any part of the Website in breach of the Terms of Use, your right to use the Website will cease immediately and you must, at our option, return or destroy any copies of the materials you have made. No right, title or interest in or to the Website or any content on the Website is transferred to you, and all rights not expressly granted are reserved by the Company. Any use of the Website not expressly permitted by these Terms of Use is a breach of these Terms of Use and may violate copyright, trademark and other laws.

Trademarks

The Company name and all related names, logos, product and service names, designs, and slogans are trademarks of the Company or its affiliates or licensors. You must not use such marks without the prior written permission of the Company. All other names, logos, product and service names, designs, and slogans on this Website are the trademarks of their respective owners.

Prohibited Uses

You may use the Website only for lawful purposes and in accordance with these Terms of Use. You agree not to use the Website:

• in any way that violates any applicable federal, state, local or international law or regulation (including, without limitation, any laws regarding the export of data or software to and from the US or other countries);
• for the purpose of exploiting, harming or attempting to exploit or harm minors in any way by exposing them to inappropriate content, asking for personally identifiable information or otherwise;
• to transmit, or procure the sending of, any advertising or promotional material, including any “junk mail,” “chain letter” or “spam” or any other similar solicitation;
• to impersonate or attempt to impersonate the Company, a Company employee, another user or any other person or entity (including, without limitation, by using e-mail addresses associated with any of the foregoing); or
• to engage in any other conduct that restricts or inhibits anyone’s use or enjoyment of the Website, or which, as determined by us, may harm the Company or users of the Website or expose them to liability.

Additionally, you agree not to:

• use the Website in any manner that could disable, overburden, damage or impair the Website or interfere with any other party’s use of the Website, including their ability to engage in real time activities through the Website;
• use any robot, spider or other automatic device, process or means to access the Website for any purpose, including monitoring or copying any of the material on the Website;
• use any manual process to monitor or copy any of the material on the Website or for any other unauthorized purpose without our prior written consent;
• use any device, software or routine that interferes with the proper working of the Website;
• introduce any viruses, trojan horses, worms, logic bombs or other material which is malicious or technologically harmful;
• attempt to gain unauthorized access to, interfere with, damage or disrupt any parts of the Website, the server on which the Website is stored, or any server, computer or database connected to the Website;
• attack the Website via a denial-of-service attack or a distributed denial-of-service attack; or
• otherwise attempt to interfere with the proper working of the Website.

Website Disclaimer

The information presented on or through the Website is made available solely for general informational purposes. All information on the Website is provided in good faith, however, we make no representations or warranties of any kind, whether express or implied, regarding the accuracy, adequacy, validity, reliability, availability, usefulness or completeness of any information on the Website. UNDER NO CIRCUMSTANCE SHALL WE HAVE ANY LIABILITY TO YOU OR TO ANYONE WHO MAY BE INFORMED OF ANY OF ITS CONTENTS FOR ANY LOSS OR DAMAGE OF ANY KIND INCURRED AS A RESULT OF THE USE OF THE WEBSITE OR RELIANCE ON ANY INFORMATION PRESENTED ON OR THROUGH THE WEBSITE. YOUR USE OF THE WEBSITE AND YOUR RELIANCE ON ANY INFORMATION POSTED OR MADE AVAILABLE ON THE WEBSITE IS SOLELY AT YOUR OWN RISK.

External Information and Links Disclaimer

The Website may contain (or you may be sent through the Website) links to other websites or content belonging to or originating from third parties or links to websites and features in banners or other advertising. All statements and/or opinions expressed in these materials, and all articles and responses to questions and other content, other than the content provided by the Company, are solely the opinions and the responsibility of the person or entity providing those materials. Such external links are not investigated, monitored or checked for accuracy, adequacy, validity, reliability, availability, usefulness or completeness by us. WE DO NOT WARRANT, ENDORSE, GUARANTEE, OR ASSUME RESPONSIBILITY FOR THE ACCURACY OR RELIABILITY OF ANY INFORMATION OFFERED BY THIRD-PARTY WEBSITES LINKED THROUGH THE WEBSITE OR ANY WEBSITE OR FEATURE LINKED IN ANY BANNER OR OTHER ADVERTISING. WE WILL NOT BE A PARTY TO OR IN ANY WAY BE RESPONSIBLE FOR MONITORING ANY TRANSACTION BETWEEN YOU AND THIRD-PARTY PROVIDERS OF PRODUCTS OR SERVICES. We are not responsible, or liable to you or any third party, for the content or accuracy of any materials provided by any third parties.

Changes to the Website

We may update the content on this Website from time to time, but its content is not necessarily complete or up-to-date. Any of the material on the Website may be out of date at any given time and we are under no obligation to update such material.

Information About You and Your Visits to the Website

All information we collect on this Website is subject to our Privacy Policy. By using the Website, you consent to all actions taken by us with respect to your information in compliance with the Privacy Policy.

Links from the Website

If the Website contains links to other websites and resources provided by third parties, these links are provided for your convenience only. This includes links contained in advertisements, including banner advertisements and sponsored links. We have no control over the contents of those websites or resources and accept no responsibility for them or for any loss or damage that may arise from your use of them. If you decide to access any of the third party websites linked to this Website, you do so entirely at your own risk and subject to the terms and conditions of use for such websites.

Geographic Restrictions

The owner of the Website is based in the Commonwealth of Massachusetts in the United States. We make no claims that the Website or any of its content is accessible or appropriate outside of the United States. Access to the Website may not be legal by certain persons or in certain countries. If you access the Website from outside the United States, you do so on your own initiative and are responsible for compliance with local laws.

Disclaimer of Warranties

You understand that we cannot and do not guarantee or warrant that files available for downloading from the internet or the Website will be free of viruses or other destructive code. You are responsible for implementing sufficient procedures and checkpoints to satisfy your particular requirements for anti-virus protection and accuracy of data input and output, and for maintaining a means external to our Website for any reconstruction of any lost data. WE ARE NOT LIABLE FOR ANY LOSS OR DAMAGE CAUSED BY A DISTRIBUTED DENIAL-OF-SERVICE ATTACK, VIRUSES OR OTHER TECHNOLOGICALLY HARMFUL MATERIAL THAT MAY INFECT YOUR COMPUTER EQUIPMENT, COMPUTER PROGRAMS, DATA OR OTHER PROPRIETARY MATERIAL DUE TO YOUR USE OF THE WEBSITE OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE OR TO YOUR DOWNLOADING OF ANY MATERIAL POSTED ON IT, OR ON ANY WEBSITE LINKED TO IT.

YOUR USE OF THE WEBSITE, ITS CONTENT AND ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE IS AT YOUR OWN RISK. THE WEBSITE, ITS CONTENT, AND ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS, WITHOUT ANY WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. NEITHER THE COMPANY NOR ANY PERSON ASSOCIATED WITH THE COMPANY MAKES ANY WARRANTY OR REPRESENTATION WITH RESPECT TO THE COMPLETENESS, SECURITY, RELIABILITY, QUALITY, ACCURACY OR AVAILABILITY OF THE WEBSITE. WITHOUT LIMITING THE FOREGOING, NEITHER THE COMPANY NOR ANYONE ASSOCIATED WITH THE COMPANY REPRESENTS OR WARRANTS THAT THE WEBSITE, ITS CONTENT OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE WILL BE ACCURATE, RELIABLE, ERROR-FREE OR UNINTERRUPTED, THAT DEFECTS WILL BE CORRECTED, THAT OUR WEBSITE OR THE SERVER THAT MAKES IT AVAILABLE ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS OR THAT THE WEBSITE OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE WILL OTHERWISE MEET YOUR NEEDS OR EXPECTATIONS.

THE COMPANY HEREBY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, STATUTORY OR OTHERWISE, INCLUDING BUT NOT LIMITED TO ANY WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT AND FITNESS FOR PARTICULAR PURPOSE.

Limitation on Liability

IN NO EVENT WILL THE COMPANY, ITS AFFILIATES OR THEIR LICENSORS, SERVICE PROVIDERS, EMPLOYEES, AGENTS, OFFICERS OR DIRECTORS BE LIABLE FOR DAMAGES OF ANY KIND, UNDER ANY LEGAL THEORY, ARISING OUT OF OR IN CONNECTION WITH YOUR USE, OR INABILITY TO USE, THE WEBSITE, ANY WEBSITES LINKED TO IT, ANY CONTENT ON THE WEBSITE OR SUCH OTHER WEBSITES OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE OR SUCH OTHER WEBSITES, INCLUDING ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO, PERSONAL INJURY, PAIN AND SUFFERING, EMOTIONAL DISTRESS, LOSS OF REVENUE, LOSS OF PROFITS, LOSS OF BUSINESS OR ANTICIPATED SAVINGS, LOSS OF USE, LOSS OF GOODWILL, LOSS OF DATA, AND WHETHER CAUSED BY TORT (INCLUDING NEGLIGENCE), BREACH OF CONTRACT OR OTHERWISE, EVEN IF FORESEEABLE.

Indemnification

You agree to defend, indemnify, and hold harmless the Company, its affiliates, licensors and service providers, and its and their respective officers, directors, employees, contractors, agents, licensors, suppliers, successors and assigns from and against any claims, liabilities, damages, judgments, awards, losses, costs, expenses or fees (including reasonable attorneys’ fees) arising out of or relating to your violation of these Terms of Use or your use of the Website, including, but not limited to, any use of the Website’s content, services, and products other than as expressly authorized in these Terms of Use or your use of any information obtained from the Website.

Governing Law and Jurisdiction

All matters relating to the Website and these Terms of Use and any dispute or claim arising therefrom or related thereto (in each case, including non-contractual disputes or claims), shall be governed by and construed in accordance with the internal laws of the Commonwealth of Massachusetts without giving effect to any choice or conflict of law provision or rule (whether of the Commonwealth of Massachusetts or any other jurisdiction).

Any legal suit, action or proceeding arising out of, or related to, these Terms of Use or the Website shall be instituted exclusively in the federal courts of the United States or the courts of the Commonwealth of Massachusetts in each case located in the City of Boston and County of Suffolk although we retain the right to bring any suit, action or proceeding against you for breach of these Terms of Use in your country of residence or any other relevant country. You waive any and all objections to the exercise of jurisdiction over you by such courts and to venue in such courts.

Limitation on Time to File Claims

ANY CAUSE OF ACTION OR CLAIM YOU MAY HAVE ARISING OUT OF OR RELATING TO THESE TERMS OF USE OR THE WEBSITE MUST BE COMMENCED WITHIN ONE (1) YEAR AFTER THE CAUSE OF ACTION ACCRUES, OTHERWISE, SUCH CAUSE OF ACTION OR CLAIM IS PERMANENTLY BARRED.

Waiver and Severability

No waiver by the Company of any term or condition set forth in these Terms of Use shall be deemed a further or continuing waiver of such term or condition or a waiver of any other term or condition and any failure of the Company to assert a right or provision under these Terms of Use shall not constitute a waiver of such right or provision.

If any provision of these Terms of Use is held by a court or other tribunal of competent jurisdiction to be invalid, illegal or unenforceable for any reason, such provision shall be eliminated or limited to the minimum extent such that the remaining provisions of the Terms of Use will continue in full force and effect.

Entire Agreement

The Terms of Use and our Privacy Policy constitute the sole and entire agreement between the Company and you with respect to the Website and supersede all prior and contemporaneous understandings, agreements, representations and warranties, both written and oral, with respect to the Website.

Digital Millennium Copyright Act (the “DMCA”)

We respect the intellectual property rights of others and ask that users of our Website do the same. In connection with our Website, we have adopted and implemented a policy respecting copyright law that provides for the removal of any infringing materials and for the termination, in appropriate circumstances, of users of our Website who are repeat infringers of intellectual property rights, including copyrights. If you believe that one of our users is, through the use of our Website, unlawfully infringing the copyright(s) in a work, and wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the U.S. Digital Millennium Copyright Act, 17 U.S.C. § 512) must be provided to our designated copyright agent:

Full Circle Technologies, Inc
11 Beacon Street Suite 340
Boston, MA 02108

Attention: DMCA Agent

Email: help@fullcircletech.com

To submit a valid notice of alleged copyright infringement, ensure you provide:

1. A signature (either electronic or physical) of the person authorized to act on behalf of the copyright owner.
2. A detailed description of the copyrighted work you believe has been infringed.
3. The specific location of the purported infringing material on our Website.
4. Your contact details, including your address, phone number, and email.
5. A statement that you have a good faith belief that the use of the material is not sanctioned by the copyright owner, its agent, or the law.
6. A declaration, made under the penalty of perjury, confirming the accuracy of the information in your notice and that you are either the copyright owner or have the authority to act on their behalf.

General Contact Information

All other feedback, comments, requests for technical support and other communications relating to the Website should be directed to: help@fullcircletech.com

Thank you for visiting the Website.

Privacy Policy

Last Modified: November 4, 2024

Introduction

Full Circle Technologies, Inc. (the “Company,” “us,” “our,” and “we“) respects your privacy and is committed to protecting it through our compliance with this privacy policy (this “Privacy Policy”).

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit our website located at www.fullcircletech.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• on this Website; and
• in e-mail, text, and other electronic messages between you and this Website.

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by the Company or any third party; or
• any third party, including through any application or content (including advertising) that may link to or be accessible from the Website.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you should refrain from accessing and using our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Website Users Under 18 Years of Age

Our Website is not intended for any users under 18 years of age. Accordingly, no one under 18 years of age may provide any personal information to or on the Website. We do not knowingly collect personal information from any users under 18 years of age. If you are under 18 years of age, you are prohibited from using the Website, providing any information on this Website or through any of its features or providing any information about yourself to us, including your name, address, telephone number, email address or any screen name or username you may use. If we learn we have collected or received personal information from any user under 18 years of age, we will delete that information. If you believe we might have any information from or about any user under 18 years of age, please contact us at help@fullcircletech.com

Information We Collect About You and How We Collect It

We collect various types of information from and about users of our Website, including:

• personally identifiable information, such as your first and last name, email address, telephone number, and other similar contact information, as well as any other non-public information about you that is associated with or linked to any of the foregoing data (sometimes referred to as “Personal Data”);
• information our servers automatically collect when you access the Website, such as your IP address, browser type, the dates and times of your visits, the pages or content you view, your interactions with the Website’s features, and other similar data, and other Anonymous Data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons.

We collect this information:

• directly from you when you provide it to us, such as when contact us via the Website, email, or phone; and
• automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses and information collected through cookies and other tracking technologies.

Information You Provide to Us.

The information we collect on or through our Website may include:

• information that you provide by filling in forms on our Website. This may include information that you provide to us when contacting us or requesting additional services; and
• records and copies of your correspondence (including e-mail addresses), if you contact us.

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• To make our Website more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP“) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
• Like many other websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, internet service provider (“ISP“), referring/exit pages, operating system, date/time stamp, and clickstream data.
• Like many websites, we use cookies to collect information. “Cookies” are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a website or mobile application. Cookies are then sent back to the originating site on each subsequent visit, or to another site that recognizes those cookies. Cookies are widely used in order to make sites work, or to work more efficiently, as well as to provide information to the owners of the platform. We use cookies to enhance the online experience of our visitors and to better understand how our site is used. Cookies may tell us, for example, whether you have visited our site before or whether you are a new visitor. This type of information is collected to make the Website more useful to you.
• We may use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user.
• We use Google Analytics to help analyze how users use the Website. Google Analytics uses Cookies to collect information such as how often users visit the Website, what pages they visit, and what other sites they used prior to coming to the Website. We use the information we get from Google Analytics only to improve the Website. Google Analytics collects only the IP address assigned to you on the date you visit the Website, rather than your name or other personally identifying information. We do not combine the information generated through the use of Google Analytics with your Personal Data. Although Google Analytics plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Website, the Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Use of Your Personal Data and Anonymous Data

In general, Personal Data you submit to us is used to respond to requests that you make. We use your Personal Data in the following ways:

• to provide improved administration of the Website;
• to improve the quality of experience when you interact with the Website;
• to send you follow-up communications when you contact us via e-mail, submit feedback, or post an event; and
• to send you administrative e-mail notifications, such as updates regarding the Website, security, or support and maintenance advisories.

We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of, and improve navigation on, the Website. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.

Website Users Outside the United States

If you are a user of the Website who resides in a country other than the United States this section applies to you:

• If you reside in the UK or any country within the European Economic Area (“EEA“):
  • The Company is the Controller (for the purposes of the General Data Protection Regulation 2016/679 (“GDPR”) and any implementing legislation or legislation having equivalent effect in the UK (together, “EU Data Protection Legislation”)) of your Personal Data.
  • The legal basis of our processing of your Personal Data as described in this Privacy Policy is our legitimate interests where those interests are not overridden by the impact on you (unless our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, please contact us at the address or phone number above.
  • We ask that you not provide us with any Special Category Personal Data (as defined in the GDPR), e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or trade union membership, or any criminal background information. If you do not consent to our processing and use of such sensitive information, you must not submit such sensitive information through the Website.
  • We may transfer your Personal Data to a country outside the UK or EEA in accordance with requirements prescribed under EU Data Protection Legislation. When we transfer your Personal Data outside the UK or EEA, we hold it subject to appropriate safeguards and controls and ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:
  • We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en(opens in a new tab).
• If you reside in Singapore:
  • You agree that your accessing or using the Website in any way constitutes your agreement that (a) we may process your Personal Data for the purposes identified in the Privacy Policy, and (b) your Personal Data may be transferred to and processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country.
  • We may transfer your Personal Data to a country or territory outside Singapore in accordance with requirements prescribed under the Singapore Personal Data Protection Act (“PDPA”) to ensure that we provide a standard of protection to Personal Data so transferred that is comparable to the protection under the PDPA. By providing your Personal Data, you consent to such transfer.

Accessing and Correcting Your Information

You may send us an e-mail at help@fullcircletech.com to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to help@fullcircletech.com

Additional Rights Related to Personal Data for Users Outside of the United States.

If you reside in the UK or EEA, you have certain, you have certain rights regarding your Personal Data and may, in certain circumstances, ask us to take the following actions in relation to such data:

• provide you with information about our processing of your Personal Data and give you access to such data;
• update or correct inaccuracies in your Personal Data;
• delete your Personal Data;
• transfer a machine-readable copy of your Personal Data to you or a third party of your choice;
• restrict the processing of your Personal Data;
• object to our reliance on our legitimate interests as the basis of our processing of your Personal Data that impacts your rights.

If you reside in Singapore, you may request to access and/or correct your Personal Data currently in our possession by writing to us. Please note that we may charge you a reasonable fee for the handling and processing of your requests to access your Personal Data.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, please contact us at: help@fullcircletech.com