Privacy Policy

Version 1.0. Last updated 14 July 2026.

1. Who we are

CIRCULARITY SERVICES LIMITED (trading as Reloop, "we", "us") is the data controller responsible for your personal data. This policy explains what we collect, why, and the rights you have under the EU/UK General Data Protection Regulation (GDPR).

2. What this policy covers

This policy covers our public website — including the contact and newsletter forms — and the Reloop platform used by residents and partners. Our Terms & Conditions and Cookie Policy form part of this policy.

3. Personal data we collect

Information you give us:

  • Contact form: your name, email address, optional phone number, and the message you send us.
  • Newsletter: your email address (and name, if you provide it).
  • Account & service data (if you hold a Reloop account): name, email, a securely hashed password, your building and unit, optional phone number, and the activity tied to your account (bookings, collection signups, donations, e-waste recycling, feedback).

Information we collect automatically:

  • Essential technical data: limited sign-in and security events, and strictly necessary cookies needed to run the service.
  • Analytics data (only with your consent): if you accept analytics cookies, Google Analytics collects usage data such as pages viewed, device and browser type, approximate location derived from a truncated IP address, and a randomly generated identifier. See our Cookie Policy.

4. Why we use your data & our legal basis

  • Responding to your enquiry (contact form) — our legitimate interest in answering you, or taking steps at your request before entering a contract.
  • Sending our newsletter — your consent, which you can withdraw at any time via the unsubscribe link.
  • Providing the Reloop service to account holders — performance of our contract with you, and our legitimate interest in running the service.
  • Analytics — your consent (analytics cookies only load once you accept them).
  • Security, fraud prevention and legal compliance — our legitimate interests and our legal obligations.

5. Who we share it with

We do not sell your personal data. We share it only with service providers who process it on our behalf under data-processing agreements, and only as needed to run the service:

  • Email delivery — Twilio SendGrid, to send transactional and contact-form emails.
  • SMS delivery — Twilio, where you provide a phone number for notifications.
  • Hosting & storage — Amazon Web Services (EU / Ireland region), which hosts the application, database, and uploaded files.
  • Analytics — Google (Google Analytics), only where you have consented.
  • Your property developer or building manager — limited to operational data needed to run the service and aggregated, non-identifying impact reports.
  • Authorities — where we are required to by law.

6. International transfers

Our hosting and database are located in the EU (Ireland). Some providers — for example Twilio (including SendGrid) and Google — may process data outside the European Economic Area, including in the United States. Where they do, transfers are protected by appropriate safeguards such as the European Commission's Standard Contractual Clauses.

(To be confirmed with counsel: the exact transfer mechanism relied on for each provider.)

7. How long we keep it

  • Contact enquiries: kept for as long as needed to deal with your enquiry and for a reasonable period afterwards.
  • Newsletter: until you unsubscribe.
  • Account & activity data: while your account is active and as long as needed to meet legal obligations or resolve disputes; then deleted or anonymised.
  • Analytics: retained in line with our Google Analytics configuration (by default, up to 14 months).

8. Your rights

Under the GDPR you have the right to:

  • Access the personal data we hold about you.
  • Have inaccurate data corrected or incomplete data completed.
  • Request erasure of your data (the "right to be forgotten").
  • Restrict or object to certain processing.
  • Receive your data in a portable format.
  • Withdraw consent at any time, without affecting prior lawful processing.

To exercise any of these rights, email us at privacy@reloop.ie. We will respond within one month. You also have the right to lodge a complaint with the Data Protection Commission (Ireland) at www.dataprotection.ie.

9. Security

We use industry-standard measures to protect your data, including encryption in transit, password hashing, and access controls. No system is perfectly secure; please tell us immediately if you suspect your account has been compromised.

10. Children

The Reloop service is intended for adults aged 18 or over. We do not knowingly collect personal data from children.

11. Changes to this policy

We may update this policy from time to time. We will post the updated version here and, where changes are material, take reasonable steps to let you know.

12. Contact

Questions or requests about this policy or your data can be sent to privacy@reloop.ie.