Effective Date: June 8, 2026
Last Updated: June 22, 2026This Cookie Policy explains how Circular Retail Group (“Company,” “we,” “us,” or “our”) uses cookies and similar technologies on our website and digital services, and how users can manage their preferences.This Policy is intended to comply with the General Data Protection Regulation (EU 2016/679) (“GDPR”), the California Consumer Privacy Act as amended by the CPRA (“CCPA/CPRA”), and applicable U.S. privacy laws.
1. WHAT ARE COOKIES
Cookies are small text files placed on your device when you visit a website. They are widely used to ensure websites function properly, improve performance, and provide analytical insights.Cookies may be:Session cookies (deleted when the browser closes)Persistent cookies (stored until expiration or deletion)First-party cookies (set by our website)Third-party cookies (set by external providers)We may also use similar technologies such as pixels, tags, and local storage.
2. TYPES OF COOKIES WE USE
2.1 Strictly Necessary CookiesThese cookies are essential for the website to function and cannot be disabled.They are used for:Website securityPage navigationForm submission functionalityLoad balancing and system stabilityLegal basis (GDPR): Legitimate interest / Contract necessity
Consent required: No
2.2 Performance & Analytics CookiesThese cookies help us understand how users interact with the website.They are used for:Website traffic analysisPage performance trackingUser behavior insights (aggregated)Service improvementLegal basis (GDPR): Consent
Consent required: Yes (opt-in in EEA)
2.3 Functional CookiesThese cookies enable enhanced functionality and personalization.They are used for:Remembering user preferencesImproving user experienceSaving session or form inputsLegal basis (GDPR): Consent / Legitimate interest
Consent required: Yes (where applicable)
2.4 Marketing Cookies (If Enabled)These cookies are used to measure the effectiveness of campaigns and outreach.They may:Track engagement with marketing contentMeasure campaign performanceSupport aggregated audience insightsWe do not use cookies for intrusive profiling or behavioral advertising.Legal basis (GDPR): Consent
Consent required: Yes (opt-in)
3. HOW WE USE COOKIE DATA
We use cookies to:Operate and secure our websiteImprove website performance and usabilityAnalyze aggregated traffic and usage patternsSupport business development and service optimizationMaintain system integrity and prevent fraudWe do not sell personal data.
4. LEGAL BASIS FOR COOKIES (GDPR)Where GDPR applies, cookies are processed under:Article 6(1)(a): Consent (non-essential cookies)Article 6(1)(f): Legitimate interests (strictly necessary cookies and limited analytics)Article 6(1)(b): Contract necessity (service-related functionality)Non-essential cookies are only activated after explicit user consent.
5. COOKIE CONSENT & CONTROL
5.1 Consent MechanismUsers are presented with a cookie banner upon first visit that allows them to:Accept all cookiesReject non-essential cookiesCustomize cookie preferencesConsent is:Freely givenSpecificInformedUnambiguousRevocable at any time
5.2 Cookie Preference ManagementUsers may update preferences at any time via:Website cookie settings panelBrowser settingsCookie consent tool (if implemented)Disabling cookies may impact site functionality.
6. THIRD-PARTY COOKIES
We may use third-party services that set cookies, including:Analytics providersHosting and infrastructure providersCRM or customer engagement toolsEmbedded content providers (if applicable)These third parties may independently process data under their own privacy policies.We are not responsible for third-party cookie practices.
7. DATA RETENTION (COOKIE STORAGE PERIODS)
Cookie retention varies depending on type:
7.1 Strictly Necessary CookiesSession-based or short-term persistenceDeleted when no longer required for system function
7.2 Analytics CookiesTypically retained between 12–24 months, depending on configuration
7.3 Functional CookiesRetained until browser deletion or up to 12 months
7.4 Marketing Cookies (if used)Retained up to 12 months, subject to consent renewalUsers may delete cookies at any time through browser settings.
8. INTERNATIONAL DATA TRANSFERS
Where data collected via cookies is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards, including:Standard Contractual Clauses (SCCs) approved by the European CommissionVendor security and compliance assessmentsReasonable technical and organizational protections
9. CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)
If you are a California resident, you have the following rights:
9.1 Right to KnowYou may request information about:Categories of personal data collected via cookiesSources of dataPurposes of collectionThird parties involved
9.2 Right to DeleteYou may request deletion of personal data collected via cookies, subject to legal exceptions.
9.3 Right to CorrectYou may request correction of inaccurate personal data.
9.4 Right to Opt-OutYou have the right to opt out of:Sale of personal information (not applicable)Sharing of personal information for cross-context behavioral advertising (not applicable)We do not sell or share personal data.
9.5 Right to Non-DiscriminationWe will not discriminate against you for exercising your privacy rights.
10. DO NOT SELL OR SHARE NOTICE (CALIFORNIA)
We do not sell or share personal information as defined under the CCPA/CPRA.A “Do Not Sell or Share My Personal Information” link may be provided in the website footer for transparency and compliance alignment.
11. GDPR RIGHTS (EU/EEA USERS)
If you are located in the European Economic Area, you have the right to:Access your personal dataRequest correction or deletionRestrict or object to processingWithdraw consent at any timeLodge a complaint with a supervisory authority
12. SECURITY OF COOKIE DATA
We implement appropriate technical and organizational safeguards, including:Secure transmission protocols (TLS)Access control limitationsSystem monitoring and loggingVendor compliance review where applicable
13. CHANGES TO THIS COOKIE POLICY
We may update this Cookie Policy periodically. Updates will be posted on this page with a revised “Last Updated” date.Continued use of the website constitutes acceptance of updates.
14. CONTACT INFORMATIONFor questions regarding this Cookie Policy or data protection rights:Circular Retail Group — Privacy Office
Email: administrator@circularretailgroup.com
Website: www.circularretailgroup.com