PRIVACY POLICY. Vull Cirqle,

Dated: 09-08-2022 Vull Cirqle, located at Kingsfordweg 151, 1043 GR
Amsterdam is responsible for the processing of personal data as
reflected in this privacy statement.

1. Contact details

www.vullcirqle.com
Mansour Amini is the Data Protection Officer of Vull Cirqle he can be reached at
mansour@vullcirqle.com

2. Personal data we process

Vull Cirqle processes your personal data because you use our services and/or becauseyou provide it to us yourself.Below is an overview of the personal data we process:

• First and last name
• Gender
• Date of birth
• Birthplace
• Address details
• Phone number
• E-mail
• Ip-address
• Location information
• Data about your activities on our website
• Data about your browsing behavior across different websites (for example, because this company is part of an advertising network)
• Internet browser and device type

3. Personal data we process

Vull Cirqle processes personal data because personal data can be left on our site. We also use social media plugins.

4. Special and/or sensitive personal data we process

Vull Cirqle does not process any special and/or sensitive personal data about you.

5. Special and/or sensitive personal data we process

Our website and/or service does not intend to collect data on website visitors who are under the age of 16. Unless they have parental or guardian consent. However, we cannot verify whether a visitor is older than 16. We, therefore, recommend that parents be involved in their children's online activities in order to avoid collecting data about children without parental consent. If you believe that we have collected personal information about a minor without such consent, please contact us at hello@vullcirqle.com and we will delete this information.

6. For what purpose and on what basis we process personal data

Vull Cirqle processes your personal data for the following purposes:

• Sending our newsletter and/or promotional flyer
• Calling or emailing you if necessary to perform our services
• Informing you of changes to our services and products
• To deliver goods and services to you
• Vull Cirqle analyzes your behavior on the website in order to improve the website and tailor the offer of products and services to your preferences.
• Vull Cirqle also processes personal data if we are legally required to do so, such as data we need for our tax return.

7. Automated decision-making

Vull Cirqle takes #responsibility based on automated processing decisions about matters that can (significantly) affect individuals. These are decisions that are made by computer programs or systems, without a person (e.g. an employee of Vull Cirqle) being involved.

8. How long we keep personal data

Vull Cirqle does not retain your personal data longer than is strictly necessary to fulfill the purposes for which your data is collected. We use the following retention periods for the following (categories) of personal data:

8.1 (Category) personal data > Retention period > Reason• Personal data > 7 years > Tax audit
• Address > 7 years > Tax audit
• Customer service email > 3 months > Service purposes
• Surfing data > several months > Retargeting

8.2 Storage periods Vull Cirqle retains your (account) information for as long as you are a customer.
to use this means that your customer profile will be kept until you indicate that you no longer wish to use the services. Pursuant to applicable administrative obligations, Vull Cirqle must retain invoices containing your (personal) data, Vull Cirqle will therefore retain this data for as long as the applicable term runs.

9. Sharing personal data with third parties

Vull Cirqle does not sell your data to third parties and will only provide it if necessary for the execution of our agreement with you or to comply with a legal obligation. With companies that process your data on our behalf, we conclude a processor agreement to ensure the same level of security and confidentiality of your data. Vull Cirqle remains responsible for this processing.

10. Sharing personal data with third parties

Vull Cirqle shares your personal data with several third parties as necessary to execute the agreement and to comply with any legal obligation.
With companies that process your data on our behalf, we enter into a processing agreement to ensure the same level of security and confidentiality of your data. Vull Cirqle remains responsible for this processing. In addition, Vull Cirqle provides your personal data to other third parties.
We will only do this with your express permission.

10.1 Webhosting

Vull Cirqle purchases web hosting and e-mail services from a trusted host. This host processes personal information on behalf of Vull Cirqle and does not use your information for its own purposes. However, this party may collect metadata about the use of the services. This is not personal data. The host has taken appropriate technical and organizational measures to prevent the loss and unauthorized use of your personal data.
The host is bound to secrecy under the agreement. Vull Cirqle hosts on a VSP server. Vull Cirqle has taken appropriate technical and
organizational measures to prevent abuse, loss and corruption of data as much as possible. These security measures include at least the use of SSL encryption and a strong password policy. Regular backups are made to prevent loss of data.

10.2 E-mail and mailing lists

Vull Cirqle uses all Google Workspace services, for example, for its business e-mail traffic and document storage. This party have appropriate technical and organizational measures in place to prevent abuse, loss and corruption of your and Vull Cirqle's data as much as possible. Google Workspace do not have access to Vull Cirqle's mailbox and Vull Cirqle treats all email traffic as confidential.

10.3 Payment process

For handling (part of) the payments of invoices the platform of Mollie is used. Mollie processes your name, address, place of residence and your payment information such as your bank account number. Mollie has taken appropriate technical and organizational
measures to protect your personal data. Mollie reserves the right to use your data to further improve the service and as part of this to share (anonymized) data with third parties. All of the above guarantees regarding the protection of your personal data also apply to those parts of Mollie's services for which it engages third parties. Mollie will not retain your data longer than permitted under the statutory time limits.

10.4 Online accounting program

An online accounting program is used for our record-keeping and bookkeeping. Vull Cirqle shares your name, address and business address information and details related to your order. This data is used to administer sales invoices. For our record-keeping and accounting purposes, Vull Cirqle uses the services of this provider. Vull Cirqle shares your name, address and residence information and details related to your order. This
information is used to administer sales invoices. Your personal information is transmitted
and stored in a protected manner. This provider is committed to confidentiality and will keep your information confidential.
This provider will not use your personal data for purposes other than those described above.

11. Sharing personal data with third parties

Vull Cirqle only provides third parties and only when necessary for the performance of our agreement with you or to comply with a legal obligation.

12. Cookies, or similar techniques, that we use

Vull Cirqle uses only technical and functional cookies. And analytical cookies that do not invade your privacy. A cookie is a small text file that is stored on your computer, tablet, or smartphone the first time you visit this website. The cookies we use are necessary for the technical operation of the website and your ease of use. They ensure that the website works properly and, for example, remember your preferences. They also allow us to optimize our website. You can opt out of cookies by setting your Internet browser so that it no longer stores cookies. In addition, you can also delete any information previously stored via your browser settings.

13. View, modify or delete data

You have the right to view, correct or delete your personal data. You can do this yourself through the personal settings of your account. In addition, you have the right to withdraw your possible consent to data processing or object to the processing of your personal data by our company and you have the right to data portability. This means that you can submit a request to us to send the personal data that we hold about you in a computer file to you or another organization named by you.

If you wish to exercise your right to object and/or right to data portability or have other questions/comments about data processing, please send an itemized request tohello@vullcirqle.com.

To make sure that the request for inspection is made by you, we ask you to send a copy of your ID with the request. In this copy, black out your passport photo, MRZ (machine readable zone, the strip of numbers at the bottom of the passport), passport number and citizen Service Number (BSN). This is to protect your privacy. Vull Cirqle will respond to your request as soon as possible, but in any case within four weeks.

Vull Cirqle would also like to remind you that you have the possibility to file a complaint with the national regulator, the Authority Persoonsgegevens. This can be done via the following link:https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit- persoonsgegevens/tip-ons

14. How we secure personal data

Vull Cirqle takes the protection of your data seriously and takes appropriate measures to prevent abuse, loss, unauthorized access, unwanted disclosure, and unauthorized modification. If you have the impression that your data is not well protected or there are indications of abuse, please contact our customer service or at hello@vullcirqle.com.Vull Cirqle takes the protection of your data seriously and takes appropriate measures to prevent misuse, loss, unauthorized access, and unwanted disclosure and 18 unauthorized modification. If you have the impression that your data is not properly secured or there are indications of abuse, please contact our customer service or at hello@vullcirqle.com. Vull Cirqle has taken the following measures to secure your personal data

16.1 Data-leakAs of Jan. 1, 2016, Vull Cirqle, as a web entrepreneur, is required to report certain data breaches to the Personal Data Authority. A data breach is a security incident involving access to or destruction, alteration or release of personal data without intent. In a data breach, personal data must have been lost or unlawful processing of personal data cannot be ruled out. In the event of such a data breach, Vull Cirqle will also notify its customers by email.

15. Privacy policy changes

We reserve the right to change our privacy policy at any time. However, you will always find the most recent version on this page.