Last Updated: April 5, 2019
Respecting Your Privacy
— User Submitted Data is information you personally elect to provide, such as your name and address, whether by means of typing the information into a permit or application form, providing information in a telephone call, or otherwise;
— Browser Derived Data is information we collect from your use of the Site – for example, the fact that you are accessing the Site using a smartphone; and
— Third-party Data is information we may obtain about you from third-party sources (if any).
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 Company and its 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 online or offline.
We may disclose User Submitted Data to:
- 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).
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.
- 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 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
- 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.
Remarketing and Retargeting
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.
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. Please contact your community or Full Circle Tech if you believe your communications with, or information provided to, Full Circle Tech or our clients and partners have been compromised or used or disclosed in violation of this policy.
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
Boston, MA 02108
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, political participation, health information, criminal background, or similar information.
For highly sensitive information, such as social security number, date of birth, 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.
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.
Law and Jurisdiction
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
Full Circle Technologies
617-722-0100 | firstname.lastname@example.org
Updated: April 5, 2019.