Privacy policy

Version 1.0 (July 21, 2021)

Our commitment to privacy

Circular Materials is committed to your privacy and protecting it through our compliance with this privacy policy (“Privacy Policy”). Circular Materials has developed this Privacy Policy in accordance with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and other relevant privacy laws.  This Privacy Policy explains how Circular Materials (“us”, “our”, and “we”) gathers and uses your information and applies to all who use our website or other electronic services, or any individual, business-partner-specific, merchant-specific, city-specific, or other area-specific websites we offer that link to or reference this Privacy Policy (collectively, the “Site”), including in the event you receive electronic communications from us.

Please read this Privacy Policy carefully and review it periodically for the latest information about our privacy practices. By visiting and/or using the Site, you expressly consent to our collection, use and disclosure of your Personal Information in accordance with this Privacy Policy. If you do not agree with the practices described in this Privacy Policy, please do not provide us with your Personal Information or interact with the Site.


This Privacy Policy applies to all Personal Information collected, used or disclosed by Circular Materials from users of our Site (“Users”), including you.  “Personal Information” is any information in any form that identifies or can identify an individual or could be combined with other information to identify an individual.

This Privacy Policy also applies to information that is about you but individually does not identify you, as described below.


Circular Materials is responsible for the Personal Information under its possession and control.  Circular Materials shall make known, upon request, the title of the person or persons designated to oversee Circular Materials’ compliance with this Privacy Policy.

Circular Materials is responsible for Personal Information in its possession or custody, including information that has been transferred to a third party for processing. Circular Materials shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.

Circular Materials shall implement policies and practices to give effect to these principles, including:

  • Implementing procedures to protect Personal Information;
  • Establishing procedures to receive and respond to complaints and inquiries;
  • Training staff and communicating to staff information about the organization’s policies and practices; and
  • Developing information to explain the organization’s policies and procedures.

The information we collect

Personal Information that Circular Materials collects includes, but is not limited to:

  • request for additional information about our services or company, or asking us to contact you;
  • use of our services as a client or customer;
  • receipt of customer support; and
  • make any comment or contribution on our website.

The categories of Personal Information you provide may include:

  • first and last name;
  • job title and company name;
  • email address;
  • phone number
  • mailing address;
  • the category or type of organization you work for; and
  • any other identifier that permits Circular Materials to make contact with you.

Circular Materials collects non-Personal Information (“NPI”) about Users when they interact with the Site or use our services. For instance, NPI may include but is not limited to, browser name, type of computer or device, and technical information about a User’s means of connecting to the Site, such as operating system, Internet service provider utilized, and mobile network information. See the section below entitled “How does Circular Materials collect, use and share NPI?” for more information.

Please note that Personal Information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to you or any other User. Such information by itself or together cannot be tracked to a specific individual’s Personal Information.

How Circular Materials uses your personal information

Circular Materials collects Personal Information for the following purposes:

  • to fulfill your requests for information about our company and our products and services;
  • to communicate with you about your requests and inquiries;
  • to recommend or to offer you other products and services based on your inferred interests;
  • to communicate with you regarding service issues; and
  • to protect the security or integrity of our website and our business.

How does Circular Materials collect, use, and share NPI?

Circular Materials uses NPI in an ongoing effort to better understand and serve our customers and to improve the content and functionality of our Site.

In addition, Circular Materials may use Personal Information, on an aggregated de-identified basis, for research purposes to improve our Site or services.  This aggregated de-identified information does not identify any individual and therefore is considered and treated as NPI under this Privacy Policy.  For instance, Circular Materials uses NPI to monitor traffic to the Site and to collect statistical data regarding use of the Site.

No NPI by itself, or together with aggregated Personal Information, can be tracked to a specific individual’s Personal Information.


Circular Materials respects your privacy and, unless otherwise required by law, Circular Materials will not collect, use or disclose your Personal Information without your prior consent. Your consent may be expressed or implied. You may expressly give your consent in writing, verbally or through any electronic means.  In certain circumstances, your consent may be implied by your actions.  For example, providing Circular Materials with Personal Information to register is implied consent to use such information to provide you with the services.

Where appropriate, Circular Materials will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Circular Materials wants to use the information for a purpose other than those identified above).  In obtaining consent, Circular Materials will use reasonable efforts to ensure that a User is advised of the identified purposes for which Personal Information collected will be used or disclosed.

The form of consent sought by Circular Materials may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, Circular Materials shall take into account the sensitivity of the Personal Information and the reasonable expectations of Circular Materials’ Users.  Circular Materials will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. In order to withdraw consent, you must provide notice to Circular Materials in writing.

Limiting use, disclosure, and retention

As noted above, Circular Materials does not disclose your Personal Information to third parties, except as provided for in this Privacy Policy.

Only Circular Materials’ employees, agents, contractors, and service providers (and their employees and contractors) with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about you.   All such employees and contractors will be required as a condition of employment to contractually respect the confidentiality of Circular Materials Users’ Personal Information.

Circular Materials will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by Circular Materials.

Circular Materials will disclose Personal Information without your knowledge or consent if Circular Materials receives an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or another person with jurisdiction to compel disclosure of your Personal Information. If Circular Materials receives a written request from a police officer or other law enforcement agency with authority to request access to your Personal Information in the course of an actual or potential investigation into a breach of a law, Circular Materials’ policy is to provide the requested information.

Cookies and opt-out

In order to improve the Site, Circular Materials may use small files commonly known as “cookies”. A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer or mobile phone (your “device”) from the Site and is stored on your device’s browser or hard drive.  Cookies are used in analyzing trends, administering the site, tracking users’ movements around the site and gathering demographic information about our user base as a whole. Circular Materials may generate reports based on the use of these technologies on an aggregated basis.

The cookies Circular Materials uses on the Site won’t collect personally identifiable information about you and we won’t disclose information stored in cookies that we place on your device to third parties.  Circular materials use cookies as follows:

  • To provide an enhanced experience for Users;
  • To identify registered Users;
  • To monitor and analyze the performance, operation and effectiveness of the Site; and
  • To ensure the security of the Site.

You are able to disable cookies directly in your website browser. Visit for information.  If you reject cookies, you may still use the Site, but your ability to use some features or areas of our site may be limited.

How can I access my personal information?

Upon request, Circular Materials will provide you with information regarding the existence, use and disclosure of your Personal Information and you will be given access to that information.  Circular Materials will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. An individual may challenge the accuracy and completeness of the information and have it amended as appropriate.

NOTE: In certain circumstances, Circular Materials may not be able to provide access to all of your Personal Information that it holds.  Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. Circular Materials will provide the reasons for denying access upon request.


We have implemented administrative, technical and physical measures to safeguard your Personal Information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access of Personal Information. This includes:

  • utilizing access controls and firewall controls of computer servers;
  • limiting access of employees to, and the use of, Personal Information through the use of passwords and graduated levels of clearance;
  • the use of pseudonymization and encryption of Personal Information, where appropriate;
  • measures to ensure the ongoing confidentiality, integrity, availability and resilience of its systems and services; and
  • a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing of Personal Information.

Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorized access to your Personal Information and no website is completely secure. We cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will ever occur. Accordingly, you should not transmit Personal Information to us using our Site if you consider that information to be sensitive.

Inquiries; challenging compliance

An individual can make inquiries and/or address a challenge concerning compliance with this Privacy Policy to Circular Materials’ Privacy Officer.

Circular Materials will maintain procedures for addressing and responding to all inquiries or complaints about Circular Materials’ handling of Personal Information. Circular Materials shall investigate all complaints. All inquiries or complaints involving Circular Materials’ handling of Personal Information or compliance with this Privacy Policy or with PIPEDA shall be directed to Circular Materials’ Privacy Officer.

Circular Materials will respond to all such inquiries or complaints within 14 business days of receipt.  Circular Materials will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If Circular Materials finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.

For more information, please contact Circular Materials’ Privacy Office as follows:



Circular Materials
700-1 St. Clair Ave. West
Toronto, ON
M4V 1K6

Storage outside of Canada

Your Personal Information may be used or stored by us or our service providers outside of Canada. We require that our service providers safeguard your Personal Information. However, if your Personal Information is used or stored outside of Canada, it will also be subject to the laws of the country in which it is used or stored.

Children and minors

The Site is not directed to children under the age of 13 years.  Circular Materials will not knowingly collect Personal Information about a child under the age of 18.  Circular Materials does not allow minors (persons who are under the age of majority in their place of residence) to use the services provided on the Site.+


Circular Materials has the right to modify and amend this Privacy Policy from time to time in its sole discretion without prior notice to clarify our practices and to reflect new or different privacy practices, such as when we add new services, functionality or features to the Site. Any such amendment(s) will be posted on the Site and will be effective as of the date of posting.  If we make any material changes we will notify you by e-mail (sent to the e-mail address specified in your account, if any). You can determine when this Privacy Policy was last revised by referring to the version date listed above.