Privacy policy
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Who is responsible
Gusto King trading as Circle37, Manchester, UK, is the controller of personal information collected through this website. Our contact address is 93–95 Shudehill, Manchester, M4 4AN. For privacy questions or requests, email [email protected].
What we collect, why and our lawful bases
- Enquiries and requested reports: the name, email, optional phone number, business and website details, project message, brief or calculator inputs you provide, plus relevant correspondence. We use these to respond, prepare the requested check or quote and deliver agreed work. Our bases are steps you request before a contract, performance of a contract, and legitimate interests in handling general enquiries and running our business.
- Optional email updates: your contact details and the choice, form, page and time of your opt-in. We rely on consent; requesting a report or quote does not subscribe you. You can unsubscribe or withdraw consent at any time.
- Security and technical records: IP address, browser information, request logs and verification results used to serve the website, prevent abuse and protect enquiries. Our basis is legitimate interests in operating a secure service; we also keep records where a legal obligation requires it.
- Optional analytics and advertising: page views, traffic sources, device information, cookie identifiers and saved-enquiry events, as explained below. Our basis is consent. We do not put enquiry names, email addresses, phone numbers or message text into analytics or advertising events.
Cookies, analytics and advertising
Optional tracking stays off until you choose it. Analytics only enables Google Analytics 4 to measure visits and page use, including clicks on our phone, email and WhatsApp links and main calls to action, and which calculator steps are reached. We do not record what you type. Accept all also enables Meta pixel, Google Ads conversion measurement and Google Ads remarketing. Reject all leaves both categories off and forms remain usable. Use Cookie settings to change your choice.
With advertising consent, Google can associate advert click identifiers (GCLID, GBRAID or WBRAID) with a saved-enquiry event. Meta receives page views, technical details and saved-enquiry events to measure Facebook and Instagram advertising and support remarketing. Automatic Meta button/form collection is disabled. With the same advertising consent, our server also tells Meta when an enquiry was saved (Meta Conversions API), using your IP address, browser details and Meta's cookie identifiers, but no names, email addresses, phone numbers or message text; Google signals stay disabled. With advertising consent, Google can also use your visit to this website to show you our adverts later on Google services (remarketing); this Google advertising personalisation is switched on only if you choose Accept all. Analytics consent alone does not permit advertising tracking.
Analytics cookies include _ga and _ga_N272P4EQK8; Meta uses _fbp and, where relevant, _fbc; Google advertising cookies may begin _gcl_. Our analytics-cookie and cookie-choice lifetime is up to 180 days. Withdrawing consent stops the relevant collection and removes these tracking cookies where our code can do so. It does not erase information already received by a provider. See Google’s privacy policy and Meta’s privacy policy.
Providers and international transfers
We use Cloudflare for website delivery and security, Contabo for our enquiry system, Google Gmail for correspondence, and Brevo for email delivery and opted-in updates. Google and Meta also process consented analytics or advertising data under their own terms. Providers receive only information needed for the relevant service and may act as processors or independent controllers, depending on that service. We do not sell your personal information.
Our enquiry system is hosted on a Contabo server in the UK. Brevo states that its contact databases are hosted in the European Union. Cloudflare, Google and Meta operate internationally, so some service data may be processed outside the UK, including in the United States. UK recognition of adequate protection can cover some transfers; other restricted transfers require safeguards such as standard contractual clauses with the UK International Data Transfer Addendum.
Cloudflare’s data-processing terms include standard contractual clauses and the UK Addendum. Google’s transfer information describes its use of adequacy arrangements, the UK Extension to the EU–US Data Privacy Framework and standard contractual clauses where applicable. Brevo’s data-processing agreement forms part of its terms of service; Meta’s privacy policy explains its international processing. Contact us for information about the safeguards relevant to your data or how to obtain a copy.
Retention
Enquiries, website-check requests and calculator submissions: we normally retain these for up to 12 months after your last meaningful contact with us, then delete or anonymise them if they have not led to a customer relationship. We review these records at least quarterly; any longer retention must have a documented business or legal reason. If we work together, we keep contract, accounting and related records for as long as needed to fulfil the contract, meet legal obligations or handle legal claims. We keep opt-in and suppression records as needed to respect your choices, and review information for deletion when it is no longer required.
Our TikTok and YouTube publishing tools
Circle37 uses the TikTok Content Posting API and YouTube API Services to publish its own organic content to its own accounts only. These publishing integrations do not collect, store or sell data from TikTok or YouTube viewers. Only Circle37 connects its accounts; visitors do not need to connect a social account to use this website.
Use of YouTube API Services is subject to the YouTube Terms of Service. Google explains its handling of information in the Google Privacy Policy. TikTok use is governed by TikTok’s Terms of Service and TikTok’s Privacy Policy.
For publishing, we store our own account authorisation tokens, content and upload records needed to operate and secure the connections. The statement about viewer data above relates to these publishing integrations; this website’s separate forms and tracking are described in this policy. The account owner can revoke YouTube access through Google’s security settings and can contact us about deleting stored connection data.
Your rights
Under UK data-protection law, you may request access, rectification, erasure, restriction, portability or object to processing, subject to the applicable conditions. Where we rely on consent, you can withdraw it without affecting earlier lawful processing. Contact [email protected]. You can also complain to the Information Commissioner’s Office (ICO).
We use automated tools to prepare replies and reports, with human follow-up. We do not make decisions with legal or similarly significant effects about you solely through automated processing.