Privacy

Your privacy is very important to us. We want to make your Circle of Beautiful People International (CBP Int’l) membership experience enjoyable and rewarding as much as possible and we want you to use our site and membership opportunities with complete confidence. CBP Int’l has created this Privacy Policy to demonstrate our commitment to privacy and security. This Privacy Policy governs and describes the manner in which CBP Int’l collects and discloses information from its users of the www.circleofbeautifulpeople.com website, and members of CBP Int’l membership services (the "Services"), how we use the information we collect and the choices you have concerning the collection and use of such information. Please read this Privacy Policy carefully.

CBP International’s Commitment to Data Security

CBP Int’l has security measures in place to protect the loss, misuse, and alteration of the information under our control. While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party "hackers" from illegally obtaining this information. We will never sell your information to a third party.

The Purpose of this Notice

This Privacy Notice provides mandatory information as required under Articles 13 and 14 of the European General Data Protection Regulation (GDPR) regarding the transparency of personal data processing. Definitions of certain terms within this notice are explained in the appendix.

Collection and Use of Information

As per the European Union's General Data Protection Regulations ("GDPR"), effective May 25th, 2018, we are required to clarify and apply our privacy policy to our global audience.
Here's a quick summary:
  • We're being more specific on how we use the information we collect, and how long we keep the data
  • We're being more specific about your data preferences and your data rights
  • These changes will not affect the way you use CBP Int’l
  • You do not need to take any action
If you continue using CBP Int’l on or after May 25, 2018, you are agreeing to these terms.

How We Use Your Information

We never sell your information to anyone. We use your information to:
  1. Provide CBP Int’l services to you.
  2. Allow you to sign in to your account.
  3. Allow you to connect with brand partners and sellers through CBP Int’l.
  4. Send you emails relevant to your usage, as controlled by your email preferences.
  5. Reply to your questions.
  6. Understand how you use the service and market CBP Int’l to you, including suggesting brands you may be interested in supporting.
  7. Create better tools for CBP Int’l to serve members.
  8. Conduct research and development to improve CBP Int’l and develop future products that our users may be interested in by analyzing how you use it.
  9. Prevent fraud and abuse on CBP Int’l.
Members are asked to provide certain information when they apply for membership such as name, address, telephone number, billing information (such as a credit card number). The personal information collected from members during the registration process is used to manage each Member's account (such as billing and collections).
To better understand its members, CBP Int’l will collect consumer, demographics and other publicly available information from third-parties. CBP Int’l may use this data to provide product and service offers. We will use data in aggregate to negotiate additional benefits, or develop products and offers and to better serve our members.
CBP Int’l collects information from members who use the various parts of our Services. We use this information for the purpose of providing a customized experience as necessary as you use our Services.
CBP Int’l may share identifying information (like Name and address) with affiliates or business partners for their use in delivering product and service offers to members. Affiliates or business partners are not allowed to use CBP Int’l data for any other purpose other than CBP Int’l approved programs designed to better serve members.
In instances where CBP Int’l and a partner jointly promote the Services, CBP Int’l will provide the affiliate certain personal information, as a result of the joint promotion. In this instance, the information shall not be used by the partner for any other purpose. CBP Int’l will also generate aggregate profiles from information provided during registration (such as the total number, but not the names, of members). We will use this aggregated and non-identifying information to sell advertisements that appear on the Services.
We will use registration information to contact you in a variety of ways. We ocassionally send you offers through email, phone or regular mail of CBP Int’l products and services or offers on behalf of selected affiliates.

Your Rights

You have the right to be informed, the right of access, the right to rectification, the right to erasure, the right to restrict processing, the right to data portability, the right to object and rights related to automated decision making and profiling. CBP Int’l will always fully respect your rights regarding the processing of your personal data, and has provided below the details of the person to contact if you have any concerns or questions regarding how we process your data, or if you wish to exercise any rights you have under the GDPR.

Data Protection Principles

CBP Int’l has adopted the following principles to govern its collection and processing of Personal Data:
  • Personal Data shall be processed lawfully, fairly, and in a transparent manner.
  • The Personal Data collected will only be those specifically required to fulfil service requirements on the platform. Such data will be collected directly from you and provided to CBP Int’l via online private social network profile questionnaire, purchasing applications and/or contact information forms via the website. Such data will only be processed for that purpose.
  • Personal Data shall only be retained for as long as it is required to fulfil contractual requirements, or to provide statistics to CBP Int’l.
  • Personal Data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are collected and/or processed. Personal Data shall be accurate and, where necessary, kept up to date.
  • You have the right to request from CBP Int’l access to and rectification or erasure of your personal data, to object to or request restriction of processing concerning the data, or to the right to data portability. In each case such a request must be put in writing to Section: CONTACT DETAILS.
You have the right to make a complaint directly to a supervisory authority within your own country. CBP Int’l’s Data Protection compliance is supervised by:

Deidre Madsen, Chief Information Officer
CIRCLE OF BEAUTIFUL PEOPLE INTERNATIONAL
2613 Lincoln Blvd., Suite 105
Santa Monica, CA 90405

Personal Data shall only be processed based on the legal basis explained in Section: THE DATA CONTROLLER FOR PERSONAL DATA, except where such interests are overridden by the fundamental rights and freedoms of you, which will always take precedent. If you have provided specific additional Consent to the processing, then such consent may be withdrawn at any time (but may then result in an inability to fulfil service requirements).
CBP Int’l will not use personal data for any monitoring or profiling activity or process, and will not adopt any automated decision making processes.

"Cookies" and How CBP International Uses Them

A "cookie" is a small data file that can be placed on your hard drive when you visit certain websites. CBP Int’l uses cookies to collect, store, and sometimes track information for statistical purposes to operate and improve the products and services we provide and to manage our network and property. If you have created your own Personal Start Page, we use a cookie to save your settings and to provide customized and personalized services. Additionally, be aware that if you visit non-CBP Int’l websites where you are prompted to log in or that are customized, you may be required to accept cookies. Advertisers and partners may also use their own cookies. We do not control use of these cookies and expressly disclaim responsibility for information collected through them.

Online Advertisements

CBP Int’l shares aggregated and non-identifying information about our visitors and members collected through the registration process as well as through online surveys and promotions with select advertisers. We use third-party advertising and/or marketing and PR companies to serve ads when you visit our website. These companies use information (not including your name, address, email address or telephone number) about your visits to this and other websites in order to provide advertisements on this site and other sites about goods and services that may be of interest to you.

Voluntary Surveys

We periodically conduct both business and individual surveys. We encourage members to participate in these voluntary surveys because they provide us with important information that helps us to improve the types of services we offer and how we provide them to you. Your personal information and responses will remain confidential, even if the survey is conducted by a third-party.

We take the information we receive from individuals responding to our surveys and disclose personal information or information regarding use of the Services if, for any reason, in our sole discretion, we believe that it is reasonable to do so, including: to satisfy laws, regulations or other legal requests for such information; to disclose information that is necessary to identify, contact or bring legal action against someone who may be violating our Acceptable Use Policy or other policies; to operate the Services properly; or to protect CBP Int’l, our Services, our employees or our members.

Public Forums

Any information that you disclose in public areas of our websites or the Internet may become public information. You should exercise caution when deciding to disclose personal information in these areas.

Transfers to Third Parties

To fulfil service-related arrangements for you, it will in most cases be necessary to process personal data via a third party (these will include but are not limited to concierge, curators, brand partners, airlines, hotels, car hire companies, and Visa or Passport companies). Personal Data shall only be transferred to, or processed by, third party companies where such companies are necessary for the fulfilment of the service-related arrangements.

Personal Data shall not be transferred to a country or territory outside the European Economic Area (EEA) unless the transfer is made to a country or territory recognised by the EU as having an adequate level of Data Security, or is made with your consent, or is made to satisfy the Legitimate Interest of CBP Int’l in regard to its contractual arrangements with its clients.

All internal group transfers of Personal Data shall be subject to written agreements under the Company’s Intra Group Data Transfer Agreement (IGDTA) for internal Data transfers which are based on Standard Contractual Clauses recognised by the European Data Protection Authority.

Your Acceptance of These Terms

By using this website, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our website. Your continued use of the website following the posting of changes to this policy will be deemed your acceptance of those changes.

How to Access or Modify Your Account Information

CBP Int’l offers members the opportunity to access or modify information provided during registration. Please keep track of your login information and personal password for safe keeping. For more information about our terms of service and support please refer to our Terms of Service Agreement.

Contacting CBP International Regarding the Privacy Policy

Questions about this Privacy Policy or the practices described herein should be directed to our contact page.
If you have any additional questions about this Privacy Policy or the practices described herein, you may contact:

Customer Service
Circle of Beautiful People International LLC

2613 Lincoln Boulevard, Suite 105
Santa Monica CA 90405 USA

Contact Details

For Opting Out or more information, the identity and contact detail for the Data Protection Officer within CBP Int’l is:

Deidre Madsen, Chief Information Officer
CIRCLE OF BEAUTIFUL PEOPLE INTERNATIONAL
2613 Lincoln Blvd., Suite 105
Santa Monica, CA 90405

The Data Controller for personal data

The Data Controller for the personal data processed by us is the Client Company of CBP Int’l (the employer of the natural person whose data is collected). The Data Controller will pass personal data of members (you) to CBP Int’l to manage service-related arrangements on behalf of CBP Int’l's members in connection with their membership in the platform which includes all CBP Int’l related events and activities (online or on location). CBP Int’l will subsequently use that personal data to facilitate service-related arrangements for you. It is this contract which forms the ‘Legal Basis’ for the processing of personal data carried out by CBP Int’l in these circumstances.

CBP Int’l will also become a Data Controller if it collects additional personal data directly from you. In these circumstances CBP Int’l will be acting under a ‘Legitimate Interest’ to legally process the data for the management of service-related arrangements for you and to fulfil contractual requirements. CBP Int’l also acts as a Data Controller for any personal data held regarding its own employees, and legally processes this data under its Contract of Employment with those Data Subjects.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Revisions to This Policy

Circle of Beautiful People International reserves the right to revise, amend, or modify this policy and our other policies and agreements at any time and in any manner. Any revision, amendment, or modification will be posted on our website Circle of Beautiful People.

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