Last Modified: 20 April 2025
Our Commitment
Circa Logica Group Co. (“Circa Logica Group,” “we,” “our,” or “us”) is fully committed to upholding your right to privacy and the responsible handling of personal information. This Data Privacy and Protection Policy outlines how we collect, use, manage, and protect your data across all platforms and services offered by Circa Logica Group, whether you are accessing our content from the Philippines, the United States, or any other location. We are officially registered with the National Privacy Commission (NPC) as a Data Protection Officer (DPO) and Data Processing System (DPS) holder, which demonstrates our legal compliance and commitment to safeguarding your data under the Philippine Data Privacy Act of 2012 and applicable New York State privacy regulations.
We view privacy not as a one-time compliance obligation but as an ongoing ethical duty and a core part of how we operate. Whether you are a program participant, intern, client, job seeker, or event attendee, we apply the same rigorous protection protocols to your information. This Policy applies to all users interacting with our websites, solutions, learning portals, digital platforms, email communications, customer support systems, or any third-party tools we utilize.
What personal data do we collect?
Circa Logica Group collects personal data in two main ways: directly, through your voluntary submissions, and indirectly, through automatic tracking technologies. When you engage with our services—whether through enrollment forms, registration pages, downloads, or customer support—you may be asked to provide your full name, email address, company or academic affiliation, job title, contact number, and, in some cases, other information such as uploaded resumes or valid IDs. These details are necessary to complete transactions, register you for programs, or fulfill services you requested.
We also collect non-identifying, technical data automatically when you browse our websites. This includes your device type, IP address, browser version, session time, pages visited, and activity logs. These are collected through technologies such as cookies, tracking pixels, and analytics platforms like Google Analytics, Meta Pixel, LinkedIn Insight Tag, and similar tools. Such information helps us understand how users navigate our digital platforms, which pages are most viewed, and where improvements can be made to the user experience.
For participants in our HR certification programs, internship portals, or compliance-based solutions, we may collect additional information that ensures regulatory and programmatic accuracy. This could include educational background, work experience, industry, and answers to assessment questions. Any sensitive personal information, if collected, is processed only with your explicit consent and is protected using advanced technical and administrative safeguards.
Your data may also be collected through integrations with CRM and support systems (e.g., Hubspot, Mailchimp, Jotform). These tools help us organize and personalize your journey, manage communications, track interactions, and ensure a seamless experience as you progress through our solutions. All collected data—whether personal or technical—is stored and processed securely.
Why do we collect your data?
We collect your data to provide you with the highest quality services, tailored content, and uninterrupted access to our solutions. Your personal information allows us to fulfill our commitments to you—from delivering certifications and providing learning content to enabling communication and account management. For example, your email is used to send login details, receipts, updates on program milestones, and important policy changes. Without this data, many of our services simply wouldn’t function as intended.
Beyond service delivery, your data helps us better understand your preferences, behavior, and engagement patterns. Using analytical insights from platforms such as Google Analytics and Hubspot, we can assess how users interact with our site, what content is most effective, and what gaps may exist in our offerings. These insights directly inform content development, curriculum improvements, support responsiveness, and website design enhancements.
Additionally, your data is crucial for legal and regulatory compliance. As a registered data processing entity under the National Privacy Commission, Circa Logica Group must maintain audit-ready records for training attendance, certification results, and financial transactions. For example, invoices must include accurate contact and billing details; certification records must be retained to verify a user’s status; and participant data is sometimes required by partner institutions or accrediting bodies.
We may also use your data for limited, consent-based marketing purposes. If you opt in, we may contact you to inform you of upcoming events, new programs, special promotions, or updated resources that align with your professional goals. You may unsubscribe at any time if you prefer not to receive such communications.
How do we collect and store this data?
Your data is collected either directly through your interactions with our websites and services or automatically through integrated third-party tools. Direct data collection happens when you fill out a form, register for a certification program, download a whitepaper, or participate in a survey or event. In these cases, you are providing data voluntarily, and we collect only what is essential to fulfill the stated purpose of your interaction.
Automatically collected data occurs through cookies and embedded analytics scripts, which allow us to observe general usage trends and technical details about how our platforms are being used. These tools, which include Google Analytics, Meta Pixel, Hotjar, and others, provide valuable feedback that supports website optimization, session performance analysis, and campaign measurement. For instance, knowing which content users visit most frequently helps us prioritize updates and improve relevance.
Once collected, all data is stored securely using encrypted cloud platforms and server infrastructure managed by trusted providers. Our primary storage solutions include Hostinger for email, Google Drive for document backup, and Jotform for secure form submissions. Each provider is carefully vetted and operates under strict data protection agreements that prevent unauthorized access or usage.
Internally, access to your data is strictly limited to authorized Circa Logica Group personnel who need it to perform their duties. All staff members undergo regular data privacy training, and role-based access controls are enforced to ensure sensitive information is not accessible to unauthorized parties. Our servers are routinely monitored, patched, and audited to minimize vulnerabilities.
Are cookies and tracking tools used?
Yes. Like most professional websites, Circa Logica Group uses cookies and tracking technologies to improve user experience, enhance security, and understand how users interact with our content. A cookie is a small text file stored on your browser that helps our systems recognize your device and remember your preferences. Some cookies are essential to our platform’s functionality, while others support analytics, personalization, and marketing efforts.
We use both first-party cookies—those placed by Circa Logica Group—and third-party cookies from platforms like Google Ads, Meta, and LinkedIn. These tools allow us to track performance metrics, analyze click behavior, and serve targeted ads to users who may benefit from our services. Tracking pixels may also be embedded in emails and webpages to measure engagement, such as open rates or page scroll depth.
You can manage your cookie preferences at any time by adjusting your browser settings. Most browsers allow you to accept or block specific cookies or notify you when a website attempts to set a cookie. While you are free to block non-essential cookies, doing so may limit your ability to access certain features or receive personalized experiences on our platform.
Circa Logica Group respects Do Not Track (DNT) signals, and users who wish to avoid tracking entirely may activate this setting on their browsers. We also comply with opt-out preferences set via advertising platforms such as Google Ads and Facebook Ads. For more comprehensive cookie management tips, we recommend visiting www.allaboutcookies.org.
Do we share your personal data?
Circa Logica Group does not sell your personal data to third parties. However, to deliver our services effectively, we may share your information with a carefully selected group of trusted service providers. These include cloud storage vendors, email and CRM providers, payment gateways, analytics platforms, advertising networks, and certified training partners. All such partners are contractually obligated to handle your information confidentially and only for the purposes explicitly authorized by Circa Logica Group.
For instance, when you make a payment, your transaction details are shared with PayPal, our payment processing partner, to complete and verify the transaction. Similarly, if you register for a webinar, your email may be stored in Mailchimp or Hubspot to send you reminders and materials. If you raise a support ticket, platforms such as Jotform and Google Workspace may temporarily process your request. In each case, access is granted only to fulfill specific, service-related tasks and never for unsolicited marketing or resale.
There are also limited circumstances under which we may be legally required to disclose your data. These include instances where we are compelled to comply with a subpoena, legal warrant, regulatory request, or court order, either under Philippine or New York law. In such events, we will disclose only the minimum amount of information necessary to comply with the legal obligation.
Lastly, if Circa Logica Group undergoes a corporate restructuring, merger, or asset acquisition, your data may be transferred as part of the business transaction. In such cases, we will ensure that the acquiring organization honors this policy and continues to apply equal or stronger data protection standards. We will inform users of any such transfer before it takes effect.
What are our legal bases for processing your data?
We only process your personal data when we have a clear legal basis to do so. The first and most common basis is your consent. When you register for a program, download a resource, or subscribe to a newsletter, you explicitly agree to share your personal information with us for that purpose. You may withdraw this consent at any time without affecting the legality of processing done before the withdrawal.
In other cases, we process your data under contractual necessity. If you engage us to deliver a training program, issue a certificate, or process an invoice, we need to collect and retain certain personal details to meet our obligations to you. Without this information, we would not be able to fulfill our service agreements or issue proof of learning, participation, or payment.
Another legal ground is legitimate interest. This applies to data we use to improve our systems, protect against fraud, analyze aggregate usage trends, or develop new services. For example, we may monitor website usage data to prevent unauthorized access or to optimize website loading times. We balance these legitimate interests with your rights and freedoms and take extra steps to ensure the data used for such purposes is minimally invasive and often anonymized.
e may also process your data based on legal obligations. As a registered business entity in both the Philippines and the United States, we are required to retain certain data for taxation, auditing, labor compliance, and data protection reporting. This includes maintaining records of certifications issued, financial transactions completed, and interactions with government or regulatory bodies.
What rights do you have over your personal data?
As a data subject, you are entitled to a wide range of rights under the Philippine Data Privacy Act of 2012 and relevant U.S. laws, particularly in the State of New York. These rights ensure transparency, accountability, and individual control over how your data is used. Circa Logica Group honors these rights and provides clear pathways for you to exercise them.
You have the right to access your personal data and request information about how it has been processed. If any of your data is inaccurate or outdated, you may request to rectify or update that information. You can also request a copy of your data in a portable format, especially if you wish to transfer it to another provider. In certain cases, such as marketing or profiling, you have the right to object to processing or limit how your data is used.
If you believe we have collected your data in error or no longer need it, you have the right to request deletion. We will review your request and remove your information, provided there are no overriding legal or contractual obligations requiring us to retain it. This is also known as the “right to be forgotten.” Additionally, you may withdraw your consent at any time for any processing activities where consent was the legal basis.
To exercise these rights, simply send an email to privacy@circalogicagroup.com or contact our compliance team at compliance@circalogicagroup.com. We aim to respond to all such requests within 15 business days and may ask for verification to ensure the request is legitimate and authorized.
How long do we retain your data?
Circa Logica Group only retains personal data for as long as it is necessary to fulfill the specific purposes for which it was collected, or as long as required under applicable law. This retention period varies depending on the type of data and the legal or operational requirements related to it. We apply standardized data retention schedules and review them periodically to ensure they remain appropriate.
For example, certification records—including names, email addresses, and course completion data—may be retained for up to five years to support verification requests, audit requirements, or reissuance of credentials. Financial and accounting records, such as receipts and invoices, are retained for at least seven years in compliance with tax and audit obligations. General system or account access logs are usually deleted within 30 days of disengagement unless otherwise required.
When data is no longer needed, we initiate a secure deletion process. Physical records are shredded, while digital records are deleted using irreversible data-wiping tools that comply with global standards for data disposal. If full deletion is not feasible due to technical limitations, we take steps to anonymize the data to ensure that individuals can no longer be identified.
In cases where data is retained for research, statistical, or archiving purposes, we ensure the information is de-identified and used solely for non-commercial, non-intrusive analysis. We never use retained data in a way that would conflict with the purpose for which it was originally collected, nor would we use it to profile or remarket to users who have opted out.
What happens if you are under 13?
Circa Logica Group does not knowingly collect, store, or process personal information from children under the age of 13. Our websites, programs, and services are specifically intended for individuals who are of legal age to enter into agreements or who are acting under the guidance and consent of a parent or legal guardian. We strongly encourage parents and guardians to supervise their children’s online activities and to help enforce responsible information sharing online.
If you are under 13 years old, we kindly request that you do not submit any personal data through our forms, platforms, or communication channels. Any such submission will be considered unauthorized and may be subject to removal from our records. If we become aware that we have unintentionally collected personal data from a minor without appropriate parental consent, we will take immediate steps to delete the information from our servers and notify the relevant parties.
In instances where a minor is participating in a family learning activity or organizational group training (e.g., students from a school or youth program), all data collection must be facilitated through an authorized adult representative, and appropriate consent forms must be submitted in advance. We require that such engagements be organized by the school, guardian, or responsible third party, and that all data use complies with applicable child privacy laws, including COPPA (Children’s Online Privacy Protection Act) in the U.S.
If you suspect that a child under the age of 13 has submitted personal information to Circa Logica Group without consent, please contact our privacy office immediately at privacy@circalogicagroup.com. We will act promptly to investigate and ensure corrective actions are taken, including secure data deletion and follow-up with the reporting party.
Can you opt out of communications?
Yes. We recognize and respect your right to choose how and when you want to hear from us. If you’ve previously consented to receive promotional emails, newsletters, invitations to events, or marketing campaigns, you may opt out at any time. Every marketing email we send includes an “unsubscribe” link at the bottom, which you can click to stop receiving future messages.
Alternatively, you can contact us directly at contact@circalogicagroup.com with the subject line “OPT OUT” to request removal from any or all mailing lists. Your request will be processed promptly, and we will ensure that your preferences are updated across all communication channels within our system. We also maintain an internal “do not contact” list to avoid accidental resubscriptions.
However, please note that opting out of marketing communications does not apply to transactional or operational messages. These include essential communications such as account verification emails, certification notifications, invoices, policy changes, and urgent platform updates. These messages are necessary for the ongoing provision of our services and are not considered promotional.
If you would like to stop receiving all forms of contact from us, including operational emails, you may initiate full account deletion or disengagement. Please email privacy@circalogicagroup.com with your request and we’ll assist you in removing all associated data and access as permitted by legal and contractual obligations.
How do you update or correct your information?
Keeping your personal data accurate and up to date is crucial for maintaining the integrity of our services and your experience with Circa Logica Group. You have the right—and are encouraged—to request corrections, updates, or modifications to your personal data at any time. Whether you’ve changed your email address, switched employers, updated your name, or want to correct a spelling error, we will process your request swiftly and transparently.
To update your information, simply email info@circalogicagroup.com with the subject line “UPDATE INFORMATION”. In your message, specify which details you’d like to update and provide any supporting documentation, if necessary (e.g., a new company ID or a government-issued document for a name change). We may ask for verification to confirm your identity before making significant changes to sensitive records.
We recommend reviewing your stored data periodically—especially if you’re a certificant, training participant, or long-term client—to ensure accuracy in our certification registry, mailing list, and platform credentials. If you’re an organization working with us, we encourage your HR or program contact person to notify us of any changes in your team’s contact list or data-sharing agreement to avoid delivery or compliance issues.
Circa Logica Group takes data accuracy seriously, not only to comply with legal obligations but to deliver the highest quality service to our users. Incorrect or outdated information could lead to missed updates, invalid certificates, or communication failures. That’s why we treat every update request with care and discretion.
What happens when we update this policy?
We review and revise this Data Privacy and Protection Policy regularly to ensure it stays aligned with changes in legislation, emerging technologies, operational shifts, and industry best practices. When updates are made, we revise the “Last Modified” date at the top of this document so users can quickly verify the most recent version.
If the changes are minor or purely editorial—for example, correcting spelling, updating a contact address, or clarifying existing sections—they will take effect immediately upon posting. Your continued use of our website or services following such updates constitutes your acceptance of the revised policy. For more substantial changes that affect how your data is collected, shared, or used, we will notify you directly.
Notifications of material changes may appear as banner alerts on our websites, as part of platform notifications, or in emails sent to registered users. We want to ensure that you’re always informed, and that you have a chance to review and respond to updates—especially if they involve consent-based features such as marketing preferences, cookie usage, or data sharing terms.
We encourage all users to review this Policy periodically to stay informed about how their personal information is managed. Transparency is central to our relationship with you, and we aim to maintain an open line of communication regarding all matters related to data protection. If at any time you have questions or concerns about an update, you’re welcome to contact our privacy office for clarification.
Need help or have questions?
If you have any concerns, suggestions, or questions about this Policy or the way Circa Logica Group handles personal information, we encourage you to contact us. Our Data Privacy, Protection, and Security Office is committed to resolving inquiries promptly and ensuring all communications are handled with care, confidentiality, and professionalism.
Email us at privacy@circalogicagroup.com for data-related concerns.
For policy violations, legal inquiries, or compliance matters, reach us at compliance@circalogicagroup.com.
We are fully committed to transparency, integrity, and your right to data protection.
Thank you for trusting Circa Logica Group.