Privacy Policy

Updated December 7, 2021

Introduction

One GS Media LLC (“Company” or “we” or “us”), respects your privacy, and we are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website (https://CircleAround.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;
In email, text, and other electronic messages between you and this Website;
Through mobile and desktop applications you download from this Website or that we make available on an app store, which provide dedicated non-browser-based interaction between you and this Website; and
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this 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, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide 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 a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@onegsmedia.com.

Additionally, California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Information We Collect About You and How We Collect It

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

By which you may be personally identified, such as name, postal address, e-mail address, and telephone number (“personal information”); and
That is about you but individually does not identify you, such as: (i) IP addresses; (ii) domain servers; (iii) computer and mobile device types; (iv) type of operating system; (v) web browsers and browser settings and plug-ins; (vi) URL traffic to, through and from the Website; (vii) geo-location information, and (viii) pages viewed and other general tracking information and cookies to enhance your experience and gather information about users and visits to the Website.

We collect this information:

Directly from you when you provide it to us;
Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and
From third parties (for example, our business partners).

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 includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our Website.
Records and copies of your correspondence (including email addresses), if you contact us;.
Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
Your responses to surveys that we might ask you to complete for research purposes
Your search queries on the Website.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

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:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website; and
Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may, or may authorize third parties to, use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). We do not honor “Do Not Track” signals.

The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns;
Store information about your preferences, allowing us to customize our Website according to your individual interests;
Speed up your searches; and
Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers.

These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. In addition, data collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such data was collected.They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

To present our Website and its contents to you;
To provide you with information or services that you request from us;
To fulfill any other purpose for which you provide it;
To provide you with notices about your account;
To carry out our obligations and enforce our rights arising under this policy or our Terms of Use or from any contracts entered into between you and us;
To notify you about changes to our Website or any services we offer or provide though it;
To allow you to participate in interactive features on our Website;
In any other way we may describe when you provide the information; and
For any other purpose with your consent.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please send an email to Technical@CircleAround.com. For more information, see Choices About How We Use and Disclose Your Information below.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates, including without limitation Girls Scouts of the United States of America.
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Website users is among the assets transferred.
To third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see Choices About How We Use and Disclose Your Information below.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To carry out our obligations and enforce our rights arising under this policy or our Terms of Use or from any contracts entered into between you and us.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.
Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email with your request to info@onegsmedia.com.
Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form) or at any other time by logging into the Website and adjusting your user preferences in your account profile or by sending us an email stating your request to info@onegsmedia.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to Company as a result of a direct request from you.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

Some of these third parties may participate in the Digital Advertising Alliance (“DAA”) AdChoices Program and may display an Advertising Option Icon for interest-based advertisements. Visit http://www.youradchoices.com to learn more. The DAA offers a tool for opting out of the collection of cross-app data on a mobile device for interest-based advertising. You can download the AppChoice app at http://youradchoices.com/appchoices.

Some of these third parties may participate in the Network Advertising Initiative (“NAI”). NAI provides a tool that allows consumers to opt out of targeted advertising delivered by NAI members’ advertising networks. Visit http://www.networkadvertising.org/choices/ to learn more.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website and visiting your account profile page.

You may also send us an email at info@onegsmedia.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. 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.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Use.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Your California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (“CCPA”) (Civil Code Sections 1798.100 to 1798.199) may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit CCPA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS.

GDPR Policy

This GDPR Policy complements our Privacy Policy and applies to persons located within the European Economic Area, Switzerland, and the United Kingdom, and those to whom the GDPR applies by operation of law (collectively, “EU Residents”). Please refer to the General Data Protection Regulation 2016/679 (“GDPR”) for a full explanation of your rights.

Legal Basis for Processing

We process your personal information on the following legal bases:

With your opt-in consent, where applicable; As necessary to perform agreements between you and the Company, including without limitation our Privacy Policy, this GDPR Policy, and our Terms of Use; To comply with any legal obligation; and In furtherance of our legitimate interests pursuant to providing the Website.

With your opt-in consent, where applicable;
As necessary to perform agreements between you and the Company, including without limitation our Privacy Policy, this GDPR Policy, and our Terms of Use;
To comply with any legal obligation; and
In furtherance of our legitimate interests pursuant to providing the Website.

Transfers

We may transfer, store, or process your personal information in the United States and any other country where we or our affiliates or service providers maintain facilities. Our Website is directed towards users who reside in the United States. By using our Website, you consent to us collecting, storing, and processing your personal information in and to the United States and any other country where we or our affiliates or service providers maintain facilities.

Individual Rights

EU Residents are entitled to the following rights under the GDPR:

You have the right to withdraw your consent at any time by emailing us at info@onegsmedia.com.
The right to access. You have the right to obtain your personal information that we store as well as information about our processing of your personal information.
The right to rectification. You have the right to request that we update your personal information if it is inaccurate or incomplete.
The right to erasure. You have the right to have your personal information erased from our systems in certain circumstances, including if the personal information is no longer necessary for the purpose for which it was collected, or if you withdraw consent and there is no other legal ground for processing.
The right to restrict processing. You have the right to restrict our processing of your personal information in certain circumstances, including if you contest the accuracy of your personal information, or if our processing is deemed unlawful and you oppose erasure of your personal information and request restriction instead.
The right to object to processing. You have the right to object to our processing of your personal information where we process it based on our legitimate interest.
The right to data portability. You have the right to receive your personal information and to transmit it to another controller where our processing is based on consent you gave us and was carried out by automated means.
The right to complain to a supervisory authority. You have the right to lodge a complaint about our collection and processing of your personal information to your Data Protection Authority.

Some of the rights are complex. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. https://gdpr-info.eu/

You may exercise any of your rights in relation to your personal data by written notice to us at: info@onegsmedia.com. We may request additional information from you to help us verify you and the applicability of the GDPR to you and to help us respond to your request.

Data Retention

Your personal information is deleted when it is no longer needed to achieve the purpose for which it was collected. Generally, we retain your personal information when you give us your opt in consent such as to sign up for our newsletter, and we retain such personal information until you withdraw your consent.

Data Security

We take commercially reasonable steps to help protect your personal information against loss, misuse and unauthorized access, or disclosure. 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.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Changes to Our Privacy Policy

We may modify or update this policy periodically. If we do so, we will provide you with notice by posting a notice of the change on the Website by sending you an email, or by any other means we reasonably deem appropriate. Any such changes will become effective immediately upon posting to the Website, and the continued use of the Website by you after any changes have been made shall constitute your acceptance of such changes.

The date the privacy policy was last revised is identified at the top of the page.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Email: info@onegsmedia.com

Address: One GS Media, 420 Fifth Avenue, New York, NY 10018