This Policy sets out the obligations of Heavencircle (“the Company”) regarding data protection and the rights of it service users (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

We respect the privacy of every person who registers with Heavencircle or visits Heavencircle’s website and/or uses the services made available by us (the “Heavencircle Service”) We are committed to ensuring a safe online experience
.
1 – PURPOSE OF THIS NOTICE

This privacy notice explains our approach to any personal information that you might supply to us (or that might be collected from you) in connection with your use of the Heavencircle Service and sets out your rights in respect of Heavencircle' processing of your personal information.

This privacy notice will inform you how you can verify which of your personal information is collected by us through the Heavencircle' Service and how you can request that we delete, update or transfer it.

This privacy notice is intended to assist you in making informed decisions when using the Heavencircle' Service. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Terms of Use.

Please also note that this privacy notice only applies to the use of personal information collected by us from your use of the Heavencircle Service or during your communications with us. It does not apply to personal information collected during your communications with third parties (including any retail partners associated with Heavencircle).

2 – WHO ARE WE AND WHAT DO WE DO?

The Heavencircle Service is operated by Elysium Productions Limited (“EP”) whose principal activities include operating a private members club and associated website. Please be aware that when you create a profile on Heavencircle, your profile will be publicly available to Members.

Heavencircle is operated by EP (“us”, “we”, or “our”). We are registered in England and Wales under company number 11893735 and our registered office is at 91 - 93 Buckingham Palace Road, Victoria, London SW1W 0RP

3 – HOW TO CONTACT US?

If you have any questions about this privacy notice or want to exercise your rights, please contact us by:

• sending an email to [email protected] or
• writing to us at Elysium Productions Limited, 91 - 93 Buckingham Palace Road, Victoria, London SW1W 0RP, UK

4 – WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE DO IT?

Our primary goal in collecting personal information from you is to give you a customized experience while allowing us to provide services and features that most likely meet your needs. In order to do so personal information may be collected from you in the following ways:

• Information you voluntarily provide to us.

We collect and maintain personal information that you voluntarily submit to us during your use of the Heavencircle Service (e.g. when registering with the website, subscribing to Membership, during the course of your interactions and communications with any other members, through any email exchanges with us or as part of any customer support interactions).

In particular, in order to sign up and create an account we require the following personal information from you:

• name;
• e-mail address;
• date of birth
• gender; and
• password

In order to subscribe to paid Membership, our payment processor requires the following and other information from you (we do not collect or store payment information). You should check with your payment processor what information they collect and store:

• name;
• password;
• payment method;
• debit or credit card details or PayPal account information; and
• billing address.

Through your use of the Heavencircle Service we may also ask you for the following additional personal information:

• your image/photo;
• description of yourself / your body;
• sexual preferences / interests;
• profession;
• city / county; and
• current relationship status.

You have the flexibility to provide us with as little or as much of this information as possible. However, the more information you provide, the more you will get out of the Heavencircle Service.

If you contact us, we may collect additional information from you such as a telephone number.

• Information we collect through your use of the Heavencircle Service.

We may collect through our use of cookies, pixels, beacons, log files and other technologies personal information regarding your mobile device, computer hardware and software used to access the Heavencircle Service. This may include the following:

• IP address of device(s) used;
• browser type;
• operating system and device type;
• approximate location (e.g. London);
• access times and dates;
• onsite navigation/clicks;
• profile views/likes;
• transaction history and
• referring website addresses.

We may also collect personal information regarding your use of and activity on the Heavencircle Service.
This personal information allows us to deliver more helpful information, services and tools. Please see our cookie policy for further information.

• Information we collect from third parties.

We may also combine personal information that we collect through your use of the Heavencircle Service with personal information that: a) you have provided to third parties and in respect of which you have given the third party permission to share with Heavencircle; and/or b) we have obtained from a public

5 – HOW DO WE USE YOUR PERSONAL INFORMATION?

We collect and use your personal information to operate the Heavencircle Service efficiently and to deliver you the very best service. In particular, we may use your personal information for the following purposes:

• Provision of the Heavencircle Service.

We use your information to identify you and your account and to provide you with the features of the Service related to your membership and the information submitted and collected.

What is our legal basis?

It is necessary for us to use your personal information to provide the Heavencircle Service to you and perform our obligations in accordance with the contract that we have with you. It is also in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you.

We may use your information for customer profiling to ensure that we personalize the most suitable services for you. It is necessary for us to profile you as it is in our legitimate interests to provide the very best service we can to you.

• Service administration.

We may use your personal information to:

• develop and improve the Heavencircle Service;
• send you administrative e-mails about the Heavencircle Service; and
• contact you to answer any queries you may have.

It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you.

• Internal record keeping and legal compliance.

We may use your personal information for internal record-keeping purposes and to check you comply with the Membership Rules and Terms of Use.

It is in our legitimate interest to ensure that we keep our records up-to-date in order to monitor who uses theHeavencircle Service, to comply with our legal obligations and to monitor your compliance with the Terms of Use.

• Marketing by us.

We may send you information about our services or products that we think may be of interest to you.

Your consent.

• Sharing information with third-party processors.

We may share your personal information with third-party processors in order to provide the Heavencircle Service and associated products and services to you. These are suppliers of ours who for example provide us with site hosting or other technology services.

It is in our legitimate interest to share your personal information in such a way to ensure that we provide the very best service we can to you. Where we share your sensitive personal data, we shall be relying on your consent to do so.

• Sharing information with professional advisors & potential purchasers.

We may share your personal information with professional advisers or regulatory authorities:
(i) – to enable them to process your personal information on our behalf in a manner consistent with this privacy notice;
(ii) – to comply with our legal obligations;
(iii) – to enforce our legal rights; or
(iv) – protect rights of third parties.

Your personal information may also be shared with prospective buyers if we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

It is in our legitimate interest to share your personal information with such third parties to enable them to process your information on our behalf, to comply with and/or enforce our legal rights and obligations, to protect the rights of third parties and to facilitate business transitions. Where we share your sensitive personal data, we shall be relying on your consent to do so.

Any other purposes for which we wish to use your personal information will be notified to you either by updating our privacy notice or otherwise from time to time including the legal basis of such use.

6 – HOW DO WE OBTAIN YOUR CONSENT?

Where use of your personal information by us requires your consent, you can provide such consent:

• at the time we collect your personal information following the instructions provided, for example at the point of application for membership; or
• by informing Heavencircle by e-mail, post or phone using the contact details set out in this privacy notice.

7 – USE OF COOKIES

The Heavencircle Service may use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. See our page on cookies to find out more about the cookies we use and how to manage and delete cookies.

8 – THIRD-PARTY LINKS AND SERVICES

The Heavencircle Service may contain links to third-party websites and services. Please remember that when you use a link to go from Heavencircle to another website or you request a service from a third party, this privacy notice no longer applies.

Your browsing and interaction on any other website, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies.

We do not monitor, control, or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third-party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

This privacy notice applies solely to personal information collected by us through the Heavencircle Service and does not apply to these third-party websites and third-party service providers.

9 – TRANSFERS OUTSIDE THE EEA

We may transfer your personal data outside the EEA to in connection with our business or for legal reasons. We will ensure that the transfer is lawful and that there are appropriate security arrangements.

The European Commission has decided that a country provides an adequate level of protection in relation to data that is transferred there and/or we have entered into an agreement ensuring appropriate and suitable safeguards. This is in standard terms adopted by the Information Commissioner and approved by the Commission.

10 – HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We do not keep your personal data for any specific period but will not keep it for longer than is necessary for our purposes.
In considering how long to keep it, we will take into account its relevance to our business and our legal and regulatory obligations.

11 – CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

• unauthorized access;
• improper use or disclosure;
• unauthorized modification; and
• unlawful destruction or accidental loss.

All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of the Heavencircle Service.

12 – HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS?

You have the following rights in relation to the personal information we hold about you:

• Your right of access.

If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

• Your right to rectification.

If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to erasure.

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to restrict processing.

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to data portability.

You have the right, in certain circumstances, to obtain the personal information you’ve provided us with (in a structured, commonly used machine-readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.

• Your right to object.

You can ask us to stop processing your personal information, and we will do so if we’re:

– relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;
– processing your personal information for direct marketing; or
– processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest.

• Your rights in relation to automated decision-making and profiling.

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling is necessary for entering into, or the performance of, a contract between you and Heavencircle.

• Your right to withdraw consent.

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

• Your right to lodge a complaint with the supervisory authority.

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

13 – CHANGE TO THIS PRIVACY NOTICE

We may make changes to this privacy notice from time to time.
To ensure that you are always aware of how we use your personal information we will update this privacy notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We may notify you by e-mail of any significant changes. However, we encourage you to review this privacy notice periodically to be informed of howHeavencircle uses your personal information.

Last Updated – 9th May 2021