Privacy Policy

PRIVACY POLICY — CIRALLE (CANADA)
Last updated: 16 September 2025

  1. WHO WE ARE
    Ciralle is a brand of MPM-Group VOF (The Netherlands) (“Ciralle”, “we”, “us”, “our”). We sell apparel online to customers in Canada (excluding Québec for now). We are committed to protecting your privacy and handling personal information in a transparent and secure way.

  2. SCOPE OF THIS POLICY
    This Privacy Policy explains what personal information we collect when you use our website (ciralle.com), shop with us, or interact with our communications; how we use and share it; and the choices and rights you have. This Policy is designed to meet Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA). It does not apply to third-party websites or services that we do not control.

  3. WHAT WE COLLECT
    We collect the minimum information needed for the purposes below:
    • Identification & contact: name, shipping/billing address, email, phone.
    • Order & payment details: items purchased, order totals, chosen payment method, transaction identifiers (we do not store full card numbers).
    • Device & usage data: IP address, device/browser type, pages viewed, clicks, referring/exit pages, approximate location (country/region), timestamps.
    • Cookies & similar technologies: identifiers that help us remember your preferences, measure site performance, and deliver/measure ads.
    • Communications: messages you send us (e.g., email), reviews, survey responses, support requests.
    • Social/UGC: content you tag or submit to us about our products.
    • Age note: our store is intended for customers 18+.

  4. HOW WE USE PERSONAL INFORMATION (PURPOSES)
    • Provide our services: process and deliver your orders, handle returns/warranties, provide customer support.
    • Payments: take and manage payments, prevent fraud, issue refunds.
    • Site operations & improvement: run, secure, and improve our website, troubleshoot, analytics, and performance reporting.
    • Marketing & personalisation: send newsletters/promotions with your consent; measure, optimise, and report on ad performance (e.g., Google Ads).
    • Legal & compliance: tax/customs, recordkeeping, responding to lawful requests, enforcing our Terms, and protecting our rights and customers.

  5. CONSENT & OTHER ALLOWABLE USES
    We generally rely on your consent (express or implied) to collect, use, and disclose personal information. You can withdraw consent at any time (it won’t affect prior processing). We may also process information without consent where allowed by law (e.g., fraud prevention, legal claims, security, required disclosures).

  6. COOKIES & SIMILAR TECHNOLOGIES
    We use:
    • Strictly necessary cookies (core site functions).
    • Performance/analytics cookies (e.g., Google Analytics) to understand and improve site use.
    • Advertising cookies (e.g., Google Ads) to deliver and measure relevant ads and to understand purchases resulting from ads.
    Your options: you can manage cookies via our cookie banner (where available) and your browser settings. Blocking cookies may affect site functionality.

  7. ADVERTISING & MEASUREMENT PARTNERS
    We may share limited information with advertising/measurement partners (e.g., Google) to measure ad performance and improve our campaigns (for example, that a purchase occurred and basic order metadata). Partners may set their own cookies or read device identifiers to provide services to us and to you, subject to their privacy policies. You can opt out of promotional emails (Section 12) and manage ad personalisation via your browser/device settings.

  8. PAYMENT, COMMERCE & INFRASTRUCTURE PROVIDERS
    We use reputable providers to operate our store and process payments. These providers act as our service providers (processors) and are contractually bound to protect personal information:
    Shopify (store platform/checkout/hosting and related tools).
    Payment processors available in our checkout (e.g., Shopify Payments, card networks, Apple Pay, Google Pay, PayPal Express).
    Operational vendors (email service, customer support tools, anti-fraud, logistics, fulfilment/carriers).
    We only disclose what is necessary for each purpose and require safeguards and confidentiality.

  9. INTERNATIONAL TRANSFERS
    We operate from the Netherlands and use service providers located outside Canada (including the EU, US, and Asia). Your information may therefore be processed in other countries and subject to their laws. We take reasonable measures (contractual, technical, and organisational) to protect your information and we keep using providers with appropriate safeguards.

  10. RETENTION
    We keep personal information only as long as reasonably necessary for the purposes above, including to meet legal, accounting, or reporting requirements. Typical retention:
    • Orders, invoices & tax records: up to 7 years (or longer if required).
    • Customer support & correspondence: up to 2 years after resolution.
    • Marketing preferences & consent records: until you withdraw consent or your account/email becomes inactive for a reasonable period.
    When information is no longer needed, we securely delete or anonymise it.

  11. SECURITY
    We use reasonable administrative, technical, and physical safeguards appropriate to the sensitivity of the information (e.g., encryption in transit, access controls, least-privilege, monitoring). No method of transmission or storage is 100% secure; we continuously improve our safeguards.

  12. MARKETING COMMUNICATIONS (CASL)
    We send marketing emails only with your consent and include our identity and a working unsubscribe link in every message. You can unsubscribe at any time via the link or by emailing us at info@ciralle.com. Transactional emails (e.g., order confirmations) will still be sent.

  13. YOUR RIGHTS & CHOICES
    Subject to legal limits, you have the right to:
    Access the personal information we hold about you.
    Correct inaccurate or incomplete information.
    Withdraw consent to marketing or other processing where consent is the basis.
    Ask questions or make a complaint about our privacy practices.
    To exercise your rights, email info@ciralle.com. We may need to verify your identity before responding.

  14. CHILDREN
    We do not knowingly collect information from children. Our store is intended for individuals 18 years or older. If you believe a minor has provided information, contact us to request deletion.

  15. DISCLOSURES REQUIRED BY LAW & BUSINESS TRANSFERS
    We may disclose information if required by law, court order, or to protect our rights, customers, or the public. If we are involved in a merger, acquisition, financing, or sale of assets, information may be transferred under confidentiality and continued protection.

  16. CHANGES TO THIS POLICY
    We may update this Policy from time to time. The “Last updated” date shows the latest revision. Material changes will be highlighted on our website or by direct notice where appropriate.

  17. CONTACT & COMPLAINTS
    Questions, requests, or complaints about privacy?
    Email: info@ciralle.com

OPENING HOURS

Monday to Friday: 9:00 a.m. – 5:00 p.m.
Saturday and Sunday: Closed

CONTACT INFORMATION

Email address: info@ciralle.com
Phone: +31 6 11848773

BUSINESS INFORMATION

Company name: MPM-GROUP
Website name: Ciralle
Address: Jansplein 49-3, 6811GD Arnhem, Netherlands (No return address)
VAT number: NL867068267B01
KvK number: 95273107