Last updated: June 14, 2025

Circular Market Group (“we,” “us,” or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit www.circularmarketgroup.com (the “Website”) or engage our services. Please read this policy carefully. If you do not agree with the terms, please do not access the Website or use our services.

1. Definitions

  • Personal Data: Any information relating to an identified or identifiable natural person.
  • Processing: Any operation performed on Personal Data (collection, storage, use, disclosure, etc.).
  • You/Your: Any visitor to the Website or user of our services.

2. Data We Collect

2.1 Information You Provide

  • Contact Details: Name, email address, phone number, job title, company name when you submit an inquiry or sign up for our newsletter.
  • Service Details: Project specifications, budgets, or timelines you share when requesting a proposal or services.
  • Communications: Content of any messages, feedback, or comments you send us.

2.2 Information Collected Automatically

  • Usage Data: IP address, browser type/version, pages visited, time and date stamps, referring URLs, and device identifiers collected via cookies or similar tracking technologies.
  • Analytics: Aggregated statistics about Website performance to improve user experience.

2.3 Third-Party Sources

  • Marketing Platforms: If you subscribe via a third-party mailing list provider (e.g., Mailchimp), we receive your name and email from them.
  • Social Media: Public profile information if you interact with us on LinkedIn, Facebook, or Instagram.

3. How We Use Your Data

We process your Personal Data for the following purposes:

  1. To Provide Services: Proposals, project delivery, billing, and support.
  2. Communication: Responding to inquiries, sending updates, newsletters, and marketing communications (where you have opted in).
  3. Website Improvement: Analytics to monitor and enhance Website usability and performance.
  4. Legal Compliance: Meeting legal or regulatory obligations in the UAE or other jurisdictions.
  5. Fraud Prevention and Security: Protecting our operations and users against unauthorized access, abuse, or fraud.

4. Legal Basis for Processing

Under applicable UAE law (including the UAE Federal Decree-Law No. 45 of 2021) and, where applicable, the EU General Data Protection Regulation (GDPR), we rely on:

  • Consent: Where you have given clear consent (e.g., newsletter sign-up).
  • Contractual Necessity: To perform a contract or take steps at your request prior to entering a contract.
  • Legal Obligation: To comply with legal or regulatory requirements.
  • Legitimate Interests: For our business purposes (e.g., Website analytics, fraud prevention), balanced against your rights.

5. Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to:

  • Remember your preferences;
  • Analyze Website traffic;
  • Deliver targeted advertising (where permitted).

You can manage or disable cookies through your browser settings, but this may affect your experience on the Website.

6. Sharing and Disclosure

We may share your Personal Data with:

  • Service Providers: Vendors who help us operate the Website or provide services (hosting, analytics, payment processing).
  • Professional Advisors: Legal, accounting, or auditing firms as required.
  • Regulators or Authorities: If required by law or to protect our rights.

We never sell your Personal Data to third parties.

7. International Data Transfers

Your data may be transferred to, and processed in, countries outside the UAE, including service providers in the EU or the United States. Whenever we do so, we implement appropriate safeguards (standard contractual clauses or equivalent measures) to ensure an adequate level of protection.

8. Data Retention

  • Contact Data & Project Records: Retained for as long as necessary to fulfill the purposes outlined, or as required by applicable law (typically up to 7 years for accounting and tax).
  • Analytics Data: Aggregated and retained in anonymized form indefinitely.

9. Security

We implement technical and organizational measures—firewalls, encryption, access controls—to protect your data. However, no method of transmission over the Internet is 100% secure; we cannot guarantee absolute security.

10. Your Rights

Subject to applicable law, you have the right to:

  • Access: Request a copy of your Personal Data.
  • Rectification: Correct any inaccurate or incomplete data.
  • Erasure: Delete your data where no longer necessary.
  • Restriction: Limit or object to our processing of your data.
  • Portability: Obtain your data in a structured, machine-readable format.
  • Withdrawal of Consent: Withdraw consent where processing is based on consent.

To exercise any right, please contact us (see Section 12). We may require identity verification.

11. Children’s Privacy

Our services are intended for adults. We do not knowingly collect information from individuals under 18. If you believe we’ve collected data from a minor, please contact us to request deletion.

12. Changes to This Policy

We may update this Privacy Policy by posting the new version on this page and updating the “Last updated” date. Your continued use after changes constitutes acceptance.

13. Contact Us

For questions or to exercise your rights, contact:
Email: privacy@circularmarketgroup.com
Address: Mazyad Mall, Tower 2nd, P.O. Box 144, Dubai, UAE

Thank you for trusting Circular Market Group with your information.