Privacy Policy

This privacy policy applies between you, the User of this Webtool and Circular Concierge Ltd, the owner and provider of this Webtool. Circular Concierge Ltd takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Webtool. This privacy policy should be read alongside, and in addition to, our Terms and Conditions, which can be found in the footer.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

Data: collectively all information that you submit to Circular Concierge Ltd via the Webtool. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

Cookies: a small text file placed on your computer by this Webtool when you visit certain parts of the Webtool and/or when you use certain features of the Webtool. Details of the cookies used by this Webtool are set out in the clause below (Cookies);

Data Protection Laws: any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation;

GDPR: the UK General Data Protection Regulation;

Circular Concierge Ltd: we or us, Circular Concierge Ltd, a company incorporated in England and Wales with registered number 12946664 whose registered office is at 30 Greyhound Road, London, N17 6XW;

UK & EU Cookie Law: the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 & the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2018

User or you: any third party that accesses the Webtool and is not either (i) employed by Circular Concierge Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Circular Concierge Ltd and accessing the Webtool in connection with the provision of such services; and

Webtool: the webtool that you are currently using, [www.theseam.uk], and any sub-domains of this site unless expressly excluded by their own terms and conditions.

2. In this privacy policy, unless the context requires a different interpretation

the singular includes the plural and vice versa;
references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
a reference to a person includes firms, companies, government entities, trusts and partnerships;
"including" is understood to mean "including without limitation";
reference to any statutory provision includes any modification or amendment of it;
the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

3. This privacy policy applies only to the actions of Circular Concierge Ltd and Users with respect to this Webtool. It does not extend to any webtools that can be accessed from this Webtool including, but not limited to, any links we may provide to social media webtools.

4. For purposes of the applicable Data Protection Laws, Circular Concierge Ltd is the "data controller". This means that Circular Concierge Ltd determines the purposes for which, and the manner in which, your Data is processed.

Data collected

5. We may collect the following Data, which includes personal Data, from you

name;
gender;
profession;
contact Information such as email addresses and telephone numbers;
financial information such as credit / debit card numbers;
operating system (automatically collected);
a list of URLs starting with a referring site, your activity on this Webtool, and the site you exit to (automatically collected);in each case, in accordance with this privacy policy.

How we collect data

6. We collect Data in the following ways:

data is given to us by you ; and
data is collected automatically.

Data that is given to us by you

7. Circular Concierge Ltd will collect your Data in a number of ways, for example:

when you contact us through the Webtool, by telephone, post, e-mail or through any other means;
when you register with us and set up an account to receive our products/services;
when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
when you enter a competition or promotion through a social media channel;
when you make payments to us, through this Webtool or otherwise;
when you elect to receive marketing communications from us;
when you use our services;
in each case, in accordance with this privacy policy.

We collect Data in the following ways:

data is given to us by you; and
data is collected automatically.

Data that is collected automatically

8. To the extent that you access the Webtool, we’ll collect your Data automatically, for example:

we automatically collect some information about your visit to the Webtool. This information helps us to make improvements to Webtool content and navigation, and includes your IP address, the date, times and frequency with which you access the Webtool and the way you use and interact with its content.
we’ll collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Webtool, see the section below, headed "Cookies".

Our use of data

9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Webtool. Specifically, Data may be used by us for the following reasons:

internal record keeping;
improvement of our products / services;
transmission by email of marketing materials that may be of interest to you;
contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Webtool;
in each case, in accordance with this privacy policy.

10. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

11. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

12. For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:

soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.
for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we will provide.
if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.
When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

13. Legal Basis for Processing

We process your personal data based on one or more of the following legal grounds under the UK General Data Protection Regulation (UK GDPR):

Contractual Necessity – where processing is necessary for the performance of a contract with you, or to take steps at your request before entering into a contract. Examples include:
1. Creating and managing your account
2. Processing bookings and payments
3. Providing customer service and support
Legitimate Interests – where we have a legitimate interest in using your data and this interest is not overridden by your rights and freedoms. Examples include:
1. Improving and securing our Webtool and services
2. Preventing fraud or misuse
3. Understanding how users interact with our platform
Consent – where you have provided clear and informed consent for specific purposes. Examples include:
1. Receiving marketing communications
2. Participating in surveys or promotions

You can withdraw your consent at any time by contacting us at support@cicon.app.

Legal Obligations – where we are required to process your data to comply with legal or regulatory obligations. Examples include:
1. Retaining payment records for tax and accounting
2. Complying with lawful requests from public authorities

14. We may use your Data to show you Circular Concierge Ltd adverts and other content on other webtools. If you do not want us to use your data to show you Circular Concierge Ltd adverts and other content on other webtools, please turn off the relevant cookies (please refer to the section headed "Cookies" below).

Who we share Data with

15. We may share your Data with the following groups of people for the following reasons:

any of our group companies or brand partners - To ensure the proper administration of your webtool and business;
our employees, agents and/or professional advisors - To obtain advice from professional advisers;
third party service providers who provide services to us which require the processing of personal data - To help third party service providers in receipt of any shared data to perform functions on our behalf to help ensure the webtool runs smoothly;
D-third party payment providers who process payments made over the Webtool - To enable third party payment providers to process user payments and refunds;

Data Processing Agreements with Third Parties

16. In accordance with Article 28 of the GDPR, we have ensured appropriate safeguards are in place when third parties process personal data on our behalf. We utilize third-party providers such as Stripe, Twilio, AWS, and Royal Mail to process personal data. These providers incorporate GDPR-compliant Data Processing Agreements (DPAs) into their service terms, which automatically apply when we use their services to process personal data.

These DPAs satisfy the requirements of Article 28(3) of the GDPR by establishing appropriate technical and organizational measures, ensuring data is processed according to documented instructions, and providing sufficient guarantees for the security of personal data. Information about each provider's data processing practices and DPAs can be found at:

These agreements ensure that our third-party processors maintain appropriate technical and organizational measures to protect your data and process it only according to our instructions and applicable data protection laws.

Keeping Data secure

17. We use technical and organisational measures to safeguard your Data, for example

access to your account is controlled by a password and a user name that is unique to you.
we store your Data on secure servers.
payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology.

18. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: support@cicon.app.

In the event of a personal data breach, Circular Concierge Ltd will:

Assess the nature and severity of the breach, including the type of data affected and the risk to individuals’ rights and freedoms;
Where legally required, notify affected users via email within 72 hours of becoming aware of the breach;
Notify the UK Information Commissioner’s Office (ICO) without undue delay and, where feasible, within 72 hours in accordance with Article 33 of the GDPR;
Keep a record of any personal data breaches, whether or not they are reportable;
Take appropriate remedial actions to mitigate any harm caused and to reduce the risk of future incidents.

19. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Our use of data

Data Retention

20. Circular Concierge Ltd maintains specific data retention periods in accordance with the "storage limitation" principle (GDPR Article 5(1)(e)) that balance your privacy rights with our business needs and legal obligations. We retain your Data for the following durations:

Account information: We retain your account information for as long as your account remains active, plus 24 months after your last login or interaction. This enables us to offer seamless service if you return and helps us understand usage patterns to improve our offerings.
Booking and transaction data: We retain booking and transaction information for up to 6 years from the end of the financial year in which a transaction occurred. This duration reflects our legal obligations under UK tax and accounting laws. It also supports fraud prevention, security, and the handling of potential disputes or refunds.
Payment information: We do not store full card details. Where necessary (e.g., for recurring services), payment data is stored securely by our payment processor in accordance with PCI-DSS standards and retained until the service is terminated or consent is withdrawn.
Communication records: We retain customer service communications (e.g., support emails or chat transcripts) for 12 months to improve service quality and for internal training.
Marketing preferences and data: We retain marketing consent and preferences for 24 months from your last interaction (e.g., clicking an email, visiting the site). You may withdraw consent at any time via the unsubscribe link or by contacting us.
Website usage and analytics data: We retain anonymized usage and analytics data for 13 months to understand how visitors interact with our Webtool and improve user experience. This data does not identify individual users.

21. After these retention periods expire, your personal data will be either:

Anonymized so that it can no longer be associated with you, or
Permanently deleted or destroyed in a secure manner, or
Archived with restricted access if required to meet legal obligations.

22. Exceptions to these periods may apply where:

Retention is required to comply with legal or regulatory obligations
There is an active dispute, investigation, or legal claim
You have explicitly asked us to retain data (e.g., for ongoing service use)
Data is required for archiving in the public interest or scientific research purposes under Article 89(1) of the GDPR

23. Your Rights: You may request the deletion of your personal data at any time ("right to erasure" under GDPR Article 17), unless we are required to retain it for legal or regulatory reasons. To do so, please contact us at support@cicon.app

24. Backups and archives: Even after deletion from our active systems, your data may remain in encrypted backups for a limited time (up to 90 days) for business continuity or legal compliance purposes. We restrict access to this data and do not process it unless strictly required.

Withdrawing Consent

25. You have the right to withdraw your consent to the processing of your personal data at any time. To do so, please contact us by email at support@cicon.app.

Withdrawing consent will not affect the lawfulness of any processing carried out before your withdrawal.
Withdrawal of consent may impact our ability to deliver certain services, especially where processing is necessary to perform a contract or provide personalised features.
In some cases, we may continue to process certain data where we have a legal obligation to retain it, such as for tax, fraud prevention, or regulatory purposes.
If you request to withdraw consent, we will respond without undue delay and within one month of receipt, in accordance with GDPR Article 7(3). You may also request the erasure of your data or object to specific processing activities (see "Your Rights" below).

Your rights

26. You have the following rights in relation to your Data

Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
Right to erase - the right to request that we delete or remove your Data from our systems.
Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
Right to data portability - the right to request that we move, copy or transfer your Data.
Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

27. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: support@cicon.app.

28. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their webtool at https://ico.org.uk/.

29. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Links to other webtools

30. This Webtool may, from time to time, provide links to other webtools. We have no control over such webtools and are not responsible for the content of these webtools. This privacy policy does not extend to your use of such webtools. You are advised to read the privacy policy or statement of other webtools prior to using them.

Changes of business ownership and control

31. Circular Concierge Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Circular Concierge Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

32. We may also disclose Data to a prospective purchaser of our business or any part of it.

33. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

34. This Webtool may place and access certain Cookies on your computer. Circular Concierge Ltd uses Cookies to improve your experience of using the Webtool and to improve our range of services. Circular Concierge Ltd has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

35. All Cookies used by this Webtool are used in accordance with current UK and EU Cookie Law.

36. Before the Webtool places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Circular Concierge Ltd to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Webtool may not function fully or as intended.

37. This Webtool may place the following Cookies:

Strictly necessary cookies

These are cookies that are required for the operation of our webtool. They include, for example, cookies that enable you to log into secure areas of our webtool, use a shopping cart or make use of e-billing services.

Analytical / performance cookies

They allow us to recognise and count the number of visitors and to see how visitors move around our webtool when they are using it. This helps us to improve the way our webtool works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies

These are used to recognise you when you return to our webtool. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies

These cookies record your visit to our webtool, the pages you have visited and the links you have followed. We will use this information to make our webtool and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

38. You can find a list of Cookies that we use in the Cookies Schedule.

39. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser.

40. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Webtool more quickly and efficiently including, but not limited to, personalisation settings.

41. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

42. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

General

43. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

44. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

45. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

46. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

47. Circular Concierge Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Webtool and you are deemed to have accepted the terms of the privacy policy on your first use of the Webtool following the alterations. You may contact Circular Concierge Ltd by email at support@cicon.app.