privacy

 

Circle Instruments Ltd

Company Number 12966211

16 October 2026

Website Privacy Policy

1 INTRODUCTION

1.1 Important information and who we are

Welcome to Circle Instruments Ltd’s Privacy and Data Protection Policy (“Privacy Policy”).

At Circle Instruments Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include: Customers

Suppliers Business contacts

Employees/Staff Members

Third parties connected to your customers

and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2 Who is Your Data Controller

Circle Instruments Ltd is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us on email at hello @ circleinstruments . com

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);

Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;

Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;

Obtain the prior specific or general authorisation of the Controller before engaging another Processor;

Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;

Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;

Maintain a record of all categories of processing activities carried out on behalf of a Controller;

Cooperate, on request, with the supervisory authority in the performance of its tasks;

Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and

Notify the Controller without undue delay after becoming aware of a Personal Data Breach;

2 LEGAL BASIS FOR DATA COLLECTION

2.1 Types of Data / Privacy Policy Scope

“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.

Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.

Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

“Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.

“Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.

“Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.

“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.


3 HOW WE USE YOUR PERSONAL DATA

3.1 Our Uses

We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.

Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.

Activity

When a customer signs up

Type of data

Profile/Identity Data

Contact Data

Marketing and Communications Data

Customer Support Data


Legal Justification

Consent

Contractual Obligations

Legal Compliance

Legitimate Interest


Lawful basis for processing data

We need to collect this data to build a list of prospects to contact when our products are ready and keep them updated with progress and future deals.

3.2 Marketing and Content Updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3 Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.






4 YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 How Does Circle Instruments Ltd Protect Customers' Personal Data?

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems, including We implement certain security measures to ensure the security of your Personal Data on our systems, including adopting a secure protocol and encrypting our databases.. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Circle Instruments Ltd to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

4.2 Opting Out Of Marketing Promotions

You can ask us to stop sending you marketing messages at any time by We use Mailchimp, all emails have an opt-out button.

Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

4.3 How to Request your Data and the Process for Obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.






5 YOUR DATA AND THIRD PARTIES

5.1 Will We Share Your Data With Third Parties?

We may also share Personal Data with interested parties in the event that Circle Instruments Ltd anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.

If Circle Instruments Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.






6 HOW LONG WILL WE RETAIN YOUR DATA FOR?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.






7 INTERNATIONAL TRANSFER OF DATA

Some of the services we use are based outside the UK. Our website host, Squarespace, and our mailing-list service, Mailchimp, are US companies and may process your data in the US. They do so under the safeguards UK data protection law requires, such as the UK-US data bridge or standard contractual clauses, as set out in their data processing terms. Plausible Analytics, which counts visits to our website, processes and stores its data in the EU.






8 NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY

We keep our Privacy Policy under review and will place any updates on this webpage. This version is dated 16 October 2026. Continued access or use of Circle Instruments Ltd will constitute your express acceptance of any modifications to this Privacy Policy.






9 INTERPRETATION

All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.).

Our staff are not authorised to contract on behalf of Circle Instruments Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Circle Instruments Ltd address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Circle Instruments Ltd rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Circle Instruments Ltd legal department.






10 COOKIES, ANALYTICS AND WHAT THIS WEBSITE COLLECTS

We're a small company, and we'd rather you knew exactly what happens when you visit circleinstruments.com. We don't use Google Analytics, advertising trackers or anything that follows you around the web. Here's what does happen, and what you can switch off.

10.1 Counting visits, without cookies

We count visits so we can understand where our visitors are, which pages they read and what interests them, and so we can make the website better. That's the only reason.

We use Plausible Analytics, a European service that processes the data for us and for no other purpose. For each page you view, it records:

  • the page, and the page you came from (such as a search engine or Instagram)

  • roughly where you are: country, region and city, worked out from your IP address

  • your browser, operating system and type of device (phone, tablet or computer)

  • a few actions on the site, such as signing up to the mailing list or pressing Play on a film, without any of your details

Plausible uses no cookies and stores nothing on your device. We never store your IP address. It's used for a moment to work out your city, and to make a visitor code that changes every 24 hours, so you can't be recognised on another day. We only ever see totals, such as "12 visitors from Austin this week", never a record of you. The data is held in the EU.

  • If you're in the EU, the EEA or anywhere else in Europe, we count your visit only if you say yes.

  • Everywhere else, including the UK, we count your visit unless you tell us not to. UK law allows this for statistics that improve a website, as long as we tell you and make saying no easy. Press Don't count me on the notice, or Privacy choices at the foot of any page, and we stop.

  • If your browser sends a Global Privacy Control signal, we don't count you at all.

We tell which applies from your browser's time-zone setting. That's read on your device and isn't sent to us. If we can't tell, we ask.

Our legal basis for using your IP address this way is our legitimate interest in understanding where interest in our instruments comes from, and in improving our website. For visitors we ask first, it is your consent.

10.2 What our website host does

Our website runs on Squarespace. We've switched off Squarespace's own analytics cookies. To run the site, it still uses:

  • crumb (a cookie): security, it stops forged form submissions. It lasts until you close your browser.

  • test (stored on your device): checks your browser can store information. It's kept by your browser.

Squarespace also counts page views for its own statistics, with code that runs in your browser but sets no cookie. As part of hosting the site, it also receives basic technical and performance information. Like any visit to any website, these carry your IP address and browser details. We can't switch this off on Squarespace. We've switched off Squarespace's visitor activity log, so we don't see visitors' IP addresses. Squarespace is a US company.

If your browser still holds any of four older analytics cookies, _ga and _ga_1NVTV21MVQ (Google Analytics) or ss_cvr and ss_cvt (Squarespace), our site deletes them when you visit. We use neither of these.

Until 15 November 2026: if you visited between 15 October 2026 and 16 October 2026, while we used Squarespace's cookie banner, your browser may still hold the two cookies that recorded your choice, ss_performanceCookiesAllowed and ss_marketingCookiesAllowed. They expire 30 days after you chose.

10.3 Films from YouTube and clips from Instagram

Our films are hosted on YouTube (Google), and some clips on Instagram (Meta). Nothing loads from YouTube or Instagram until you press Play. When you do:

  • your device connects to YouTube or Instagram. They receive your IP address, browser details, which film or clip you watched, and that you watched it on our website. They may also receive cookies they've already placed in your browser

  • YouTube's player stores some settings on your device. We use YouTube's privacy-enhanced mode. When we tested it, pressing Play set no cookies. Instagram may use cookies

  • what YouTube and Instagram do with this is covered by their own policies: Google's privacy policy and Meta's privacy policy

  • we don't receive any information about you from them

Not pressing Play is always fine. The rest of the page works just the same. The still pictures for our films come from our own website host.

10.4 Our map

The map on our Contact page is a picture, served from our own website host. Open in Google Maps takes you to Google's site, under Google's privacy policy.

10.5 Forms

The mailing-list form on our Contact page sends your name, email address and country to Mailchimp, which sends our newsletter. It sets no cookies on our website. To stop spam, Squarespace may check form submissions with Google reCAPTCHA, which would load only when you use the form and may read Google cookies already in your browser.

10.6 Payments

When you pay for an instrument, our buttons take you to Stripe's own checkout page. Stripe sets its cookies there, on Stripe's site, under Stripe's privacy policy. Our site sets none for Stripe.

10.7 Your choices

  • Privacy choices, at the foot of every page, shows whether you're counted, and lets you change it at any time.

  • If you press a button on our notice, we remember your answer on your device, in one item called ci-consent. It holds only your answer, the date, and the version of the notice you answered. We ask again after 12 months, or sooner if we change the notice. If you never press a button, no answer is stored.

  • You can also delete cookies and stored data in your browser's settings at any time.

  • Questions: hello@circleinstruments.com

Last updated: 16 October 2026