This Privacy Policy explains the practices of CIRCULATE RESOURCES LIMITED. Circulate Resources develops computer integrated systems design for circular material flows, and this policy covers the data that supports that work. We ask every visitor, client, supplier and yard partner to read it carefully before using our websites, platforms or services.
1. Introduction and Scope
CIRCULATE RESOURCES LIMITED respects the privacy of every person who interacts with our business. This policy describes the personal data we collect, the reasons we collect it, the way we store it and the choices available to the people whose data we hold. It applies to our main website, our services pages, our contact channels, our by-product marketplace platforms, our telemetry dashboards and any yard visit at our premises.
The policy applies to visitors, prospective clients, existing clients, suppliers, haulage partners, marketplace buyers and sellers, and members of the public who contact us by email, telephone or web form. It does not apply to third party websites that we may link to, because those sites operate under their own privacy rules and we cannot control their practices.
We operate within the Computer Systems Design and Related Services industry, and our work involves connecting physical recovery lines to software platforms. That combination means we handle two broad categories of information: personal data about individuals, and operational data about material flows. This policy addresses both where they overlap, and it explains the strict separation we maintain between the two.
2. Who We Are and How to Reach Us
CIRCULATE RESOURCES LIMITED is the data controller for the personal data described in this policy. Our registered address is G/F, No 6 Hung Mo Tam, Pat Heung, Yuen Long, Hong Kong (HK). Our developer and operating identity is Circulate Resources, and the same team is responsible for the systems described here.
For any question about this policy, a request to exercise a right, or a concern about how data has been handled, please write to admin@circulateresources.lol or call +12768778392 during business hours. We aim to acknowledge every privacy enquiry within five working days and to resolve substantive requests within thirty days, unless the law allows us a longer period.
Where a client engages us to operate a managed loop, the client usually remains the controller of the personal data generated at their site, and we act as a processor on their instructions. In those cases we handle personal data only as the client directs, and the client privacy notice governs the relationship with the individual.
3. Information We Collect Directly
We collect personal data that you provide to us on purpose. This includes your name, email address, telephone number, company name, job title and postal address when you complete a contact form, request a yard visit, subscribe to a review session or ask for a quotation.
When you engage us for a recovery project, we collect the details needed to deliver the work, which may include site addresses, contact names for operations and safety, delivery and collection instructions, and the identity of authorised signatories. We collect the content of messages you send us, including attachments such as specifications, photographs of material streams or sample descriptions.
If you attend our premises, we may record your name, organisation and arrival time for safety and security purposes. We do not collect more than we need, and we do not ask for special category data such as health information or political opinions. Please do not send us such data unless we specifically request it and inform you why it is required.
4. Information Collected Automatically
When you visit our website, our hosting infrastructure records technical information that helps us keep the site available and secure. This includes the internet protocol address assigned to your connection, the browser and device type you use, the pages you request, the date and time of each request, and the referring address that led you to us.
We use this information in aggregate to understand which pages are useful and which are not, to detect abusive traffic and to diagnose faults. We do not attempt to identify individuals from technical logs unless a security incident requires it, and even then we limit the review to what is necessary.
Our web forms are designed to minimise data. A field that is not needed for the stated purpose is not collected. The contact form on our website prepares an email in your own mail client rather than storing your message on our servers, which means the content of your enquiry travels through your own email provider and ours.
5. Information from Third Parties
We may receive personal data about you from third parties in the ordinary course of business. A client may give us your name as their site contact. A haulage partner may list your name as a driver or dispatcher. A marketplace participant may identify you as an authorised buyer or seller representative.
We may also receive information from public registers, credit reference services or compliance screening providers where we are required to verify the identity of a business counterparty before entering into a contract. When we receive personal data from a third party, we use it only for the purpose for which it was shared and we take reasonable steps to confirm that the source was entitled to provide it.
If you believe that a third party has shared your data with us without your knowledge, please contact admin@circulateresources.lol and we will investigate promptly and correct our records where appropriate.
6. How We Use Personal Data
We use personal data to respond to enquiries, prepare quotations, deliver recovery and telemetry projects, operate managed loops, maintain marketplace accounts, process transactions and meet our legal and accounting obligations. Each use is tied to a specific purpose that we can explain on request.
We also use contact details to send service messages, such as confirmation of a yard visit or notice of a scheduled calibration. With consent where required, we may send occasional updates about the quarterly loop rinse review or about new services. Every marketing message includes a way to opt out, and an opt out takes effect promptly.
We do not sell personal data. We do not rent contact lists. We do not use personal data to build advertising profiles for unrelated parties. Our commercial model rests on recovered material and on software that measures it, not on the trade of personal information.
7. Lawful Bases for Processing
Where the law requires a lawful basis, we rely on one or more of the following. We process data to perform a contract with you, or to take steps at your request before entering a contract, such as preparing a quotation. We process data for our legitimate interests in running a safe and efficient business, provided those interests are not overridden by your rights.
We process data to comply with legal obligations, including tax, accounting, environmental and safety requirements that apply to our yard and to the movement of recovered material. Where we send marketing communications that require consent, we rely on your consent, which you may withdraw at any time.
Where we process personal data on behalf of a client as a processor, the client is responsible for identifying the lawful basis, and we support the client in meeting that obligation through clear records and technical measures.
8. Telemetry and Industrial Data
Our recovery lines generate telemetry: mass readings, moisture levels, temperatures, throughput figures and grade classifications. This operational data describes material, not people. We treat it as business data and we keep it separate from personal data.
In limited cases, an operational record may include an operator identifier so that a batch can be traced to the person who signed off a calibration. When that happens, we minimise the identifier, restrict access to supervisors and engineers who need it, and retain it only as long as the quality record must be kept.
Where telemetry is displayed on a shared dashboard, we remove or mask personal identifiers so that personal data does not leak into a wider audience. Clients who operate their own dashboards can configure the same masking, and we provide guidance on doing so.
9. Cookies and Similar Technologies
Our website uses a minimal set of cookies and similar storage mechanisms. Strictly necessary storage keeps the site working, for example by remembering that a mobile navigation panel is open. We do not use advertising cookies on our public pages, and we do not permit third party advertising networks to track visitors across our site.
Where we use analytics, we prefer aggregate and privacy preserving measurement over individual tracking. If we introduce a tool that requires consent, we will present a clear choice and we will not load the tool before that choice is made.
You can control cookies through your browser settings. Blocking strictly necessary storage may affect how the site behaves, but it will not prevent you from reading our pages or contacting us by email or telephone.
10. Sharing Data with Processors and Partners
We share personal data with service providers who help us operate the business, including hosting providers, email providers, accountants and legal advisers. These providers act on our instructions, are bound by confidentiality terms, and may use the data only to deliver the service we have engaged them for.
We may share data with haulage and treatment partners where this is necessary to move or process material. In those cases we share only the details needed for the movement, such as a contact name and a collection address, and we require the partner to protect that data.
We may disclose personal data where the law requires it, where a regulator or court orders it, or where disclosure is necessary to protect the safety of people at our yard. We will resist any request that is excessive or unclear, and we will tell you about a request where we are legally permitted to do so.
11. Marketplace Listings and Buyer Records
Our by-product marketplace platforms allow sellers to list recovered material and buyers to express interest. A listing is about material, not about people, and a public listing never displays a personal telephone number or private email address. Communication between parties runs through platform messaging or through a shared business contact that the parties choose to disclose.
To prevent fraud and to meet compliance duties, we keep records of who transacted, which organisation they represented and what documents supported the transaction. These records are used for audit, dispute resolution and regulatory reporting, and they are retained for the period required by law or by the applicable contract.
Buyer and seller accounts may be suspended where we detect misuse, such as false grade claims or attempts to circumvent chain-of-custody requirements. Account decisions are recorded with reasons so that the handling can be reviewed.
12. International Transfers of Data
CIRCULATE RESOURCES LIMITED is based in Hong Kong, and our primary systems are hosted in jurisdictions where we or our providers operate. When personal data moves across a border, we take steps to ensure that it continues to receive an appropriate level of protection.
Those steps may include contractual clauses that bind the recipient to protect the data, a review of the recipient security practices, or a transfer to a jurisdiction that the relevant authority recognises as providing adequate protection. Where a client instructs a transfer, we follow the client lawful instructions and document them.
Because our industry includes operators in many regions, a single project may involve data from more than one country. We keep a transfer register for major systems so that we can answer questions about where data is held and how it is safeguarded.
13. Data Retention and Disposal
We keep personal data only as long as we need it for the purpose it was collected, or as long as the law requires. Enquiry records are kept for a reasonable period so that we can follow up, then deleted or archived in a form that no longer identifies individuals.
Contract and financial records are kept for the period required by tax and company law. Telemetry records are kept for the period needed to support quality claims, warranties and audit, after which they are aggregated or removed. Safety and incident records are retained for the period recommended by our insurers and regulators.
When data reaches the end of its retention period, we delete it securely or anonymise it so that it can no longer be linked to an individual. Backup copies are cycled out under the same schedule, and we verify that deletions propagate to backups within a defined window.
14. Security of Personal Data
We protect personal data with technical and organisational measures appropriate to the risk. Access is limited to staff and contractors who need it for their role, and access is reviewed when roles change. Accounts are protected by strong authentication, and administrative privileges are granted sparingly.
Data in transit is encrypted, and data at rest is protected on managed systems. We keep systems patched, we monitor for unusual activity, and we maintain an incident response process that includes containment, assessment and notification where the law requires it.
No system is perfectly secure. If a breach occurs that is likely to affect your rights, we will notify you and the relevant authority without undue delay and will explain what happened and what we are doing about it. We would rather tell you early than let a problem grow in silence.
15. Your Rights and Choices
Subject to the law in your jurisdiction, you may have the right to access the personal data we hold about you, to ask for corrections, to request deletion, to restrict or object to certain processing, and to receive a portable copy of data you provided to us.
You may also withdraw consent where processing relies on consent, and you may opt out of marketing at any time. To exercise a right, write to admin@circulateresources.lol with enough detail for us to identify your records. We may ask for proof of identity to protect against fraudulent requests, and we will not charge a fee unless the law allows and the request is manifestly unfounded or excessive.
Some rights are limited. For example, we may need to keep a record to comply with a legal duty, or we may refuse a deletion request where the data is needed to defend a legal claim. Where we refuse, we will explain the reason and the available review route.
16. Privacy for Children
Our services are designed for businesses and professionals. We do not knowingly collect personal data from children, and our website and marketplace platforms are not directed at children. If a child has provided data to us, a parent or guardian may contact admin@circulateresources.lol and we will delete the data promptly.
Where a site visit or an educational event may involve young people, we require an adult organiser to manage consent and supervision, and we limit the data we collect to what is needed for safety and attendance.
17. Changes to This Policy
We review this policy regularly and update it when our practices, our systems or the law change. The updated version is published on this page with a revised date, and material changes are highlighted in a notice on the homepage for a reasonable period.
Where a change significantly affects how we use data we already hold, we will take additional steps to inform affected individuals, which may include direct notice by email where we have a valid address. Continuing to use our services after an update means you accept the revised policy, but you always retain the rights described in this document.
18. How to Make a Complaint
If you are unhappy with how we have handled personal data, please contact us first at admin@circulateresources.lol or on +12768778392. Describe what happened, what outcome you seek and any reference numbers you hold. We will investigate, respond, and where we got something wrong we will correct it and explain what changed.
You also have the right to complain to the data protection authority in your jurisdiction, including the authority in Hong Kong where our registered address is located. We will cooperate fully with any regulator that examines our handling of a complaint.
CIRCULATE RESOURCES LIMITED, G/F, No 6 Hung Mo Tam, Pat Heung, Yuen Long, Hong Kong (HK). This policy is maintained by Circulate Resources and forms part of our commitment to fair and transparent handling of personal data across every recovered, rinsed and returned loop.