Last updated: August 2025
Circulox Pte Ltd, together with its subsidiaries and affiliates (collectively, "Circulox," "we," or "us"), is committed to safeguarding your privacy and protecting your personal data meaning any information that can identify you as an individual.
This Privacy Policy explains how we collect, use, and protect personal data in the course of our business activities, which include legal advisory, regulatory consulting, client engagements, and hosting events, as well as through our websites, applications, and communications that link to this Privacy Policy. As the data controller for these activities, we are committed to handling your personal data responsibly, transparently, and in accordance with applicable data protection laws. For additional information regarding the terms governing your use of our Sites, please refer to our Terms of Use.
Circulox collects personal data in the course of its business activities, including in connection with some client services. This information falls into two categories: User‑Provided Information and Automatically Collected Information.
This is the information you provide to us directly, which may include personal details such as your name, mailing address, email address, and telephone number, along with identification information and documents submitted for regulatory or KYC purposes. It may also include background information necessary for providing our services or onboarding you as a client, as well as any details you share through communications, inquiries, event registrations, or subscription requests.
When you interact with our Sites or services, we automatically collect certain information, which may include information such as your IP address, device identifiers, browser type, and operating system. This also includes data on the pages you visit, your search history, referring and exit URLs, and timestamps of your interactions with our Sites. Additionally, we use cookies, web beacons, pixels, and similar technologies to analyze site performance and enhance user experience. We may collect aggregated analytics about how you interact with our Sites or engage with our digital content. Circulox may also obtain personal data from third parties, including public databases, regulatory sources, or social media platforms where such data is lawfully shared with us, and we may combine this information with data we already hold to improve client onboarding, compliance processes, and service delivery.
Circulox uses your personal data to fulfill your requests for information, process your participation in our services and events, personalize the content that you view or receive on the Sites, evaluate and improve our services, distribute newsletters and regulatory updates, and comply with legal or regulatory requirements. We may also process personal data for recruitment, fraud prevention, compliance monitoring, and to support business operations such as analytics and reporting. In some situations, the collection of personal data is required for the proper operation of the Sites or to provide services to our clients. We may combine or analyze personal data to better understand client needs and to offer services that are most relevant to you. We may retain your personal data and use it to communicate with you in the future where legally permissible.
Circulox and its service providers may use first and third‑party cookies and tracking technologies to operate our Sites, analyze performance, and improve user experience. Circulox and its service providers may also collect information about whether you open or engage with any communications we send to you. Our Sites do not track your activity across third‑party websites for targeted advertising.
If you access our services via mobile applications, Circulox may use third‑party service providers to analyze user activity to monitor usage, fix errors, and improve performance. For example, we may receive reports on aggregate usage patterns, device types, and app interactions. Some applications may also generate a unique identifier to personalize your experience and maintain security. We do not share your mobile viewing history or trends with external third parties outside of our affiliates or service providers.
Our processing of your personal data is based in part on our legitimate interests in promoting and protecting Circulox, building and maintaining client relationships, and providing our services; in part on your consent, for example, when you register for events or subscribe to newsletters; and in part on our obligations to comply with applicable legal or regulatory requirements.
Personal data collected by Circulox in the course of business activities or on the Sites may be transferred from time to time to our subsidiaries, affiliates, and third‑party service providers located worldwide. These transfers may occur to countries that do not have the same level of data protection as your home country. Where required, Circulox implements appropriate legal mechanisms, including the EU Standard Contractual Clauses or equivalent, to ensure adequate protection of your personal data. By using our Sites and providing personal data, you consent to such trans‑border transfers and hosting of your data.
Circulox will not intentionally disclose your personal data to third parties without your consent except as permitted by law. We may provide access to third‑party service providers who assist in our operations, including hosting, compliance, analytics, recruitment, or communications. We may also disclose personal data when required by law, to respond to government or law enforcement requests, to protect the rights or safety of individuals, to prevent fraud, to enforce our Terms of Use, to support compliance and auditing functions, or in connection with a merger, sale, or corporate reorganization.
Any information you disclose publicly on our Sites, including forums or discussion boards, may be collected and used by others. Circulox is not responsible for the actions of third parties who collect such publicly disclosed information.
Our Sites may provide links to third‑party websites for your convenience. These links do not constitute an endorsement, and Circulox is not responsible for the content, security, or privacy practices of these third‑party websites. Your use of such sites will be subject to their respective terms and privacy policies.
The Sites may allow you to link or log in using social media accounts, such as LinkedIn, X (Twitter), Facebook, or YouTube. By doing so, you permit us to access information available in your public profile, such as name, email address, and profile picture, in accordance with the respective social network's terms. You can manage what data is shared through the privacy settings of your social media account. If you wish to disconnect a linked account, you must adjust the settings within that social platform.
Circulox employs industry standard measures to protect personal data from loss, misuse, unauthorized access, or disclosure. Access to personal data is restricted to authorized personnel and trusted service providers, all of whom are bound to maintain confidentiality. However, no data transmission or storage system can be guaranteed to be fully secure.
Circulox retains personal data for as long as necessary to fulfill the purposes for which it was collected and to meet legal, regulatory, or operational requirements. In certain cases, we may retain data longer for recordkeeping, compliance, or dispute resolution purposes. If you request deletion of your personal data, we will make reasonable efforts to delete it in its entirety, subject to applicable law.
Our Sites and services are not directed to children under 16, and Circulox does not knowingly collect personal data from minors.
Subject to applicable law, you may have the right to request access, correction, or deletion of your personal data, and in some cases to request that we cease processing it. You may also request a copy of your data where legally permissible. To exercise your rights, please contact us at info@circulox.org. We will take steps to verify your identity and respond in accordance with applicable law. Depending on your jurisdiction, you may also have the right to file a complaint with a data protection authority.
By using the Sites, you consent to the collection and processing of your personal data as described in this Privacy Policy. Circulox reserves the right to modify this Privacy Policy from time to time. If material changes are made that increase our rights to use your data, we will notify you via email or prominent notice on the Sites, and seek additional consent if required.
If you have any questions regarding this Privacy Policy please reach out to info@circulox.org