Legal & Compliance

Privacy & Terms

Effective April 3, 2026  ·  Circular Momentum, Lakeside CA  ·  pete@circmo.com

circmo.com — Legal Document

Privacy Policy

Effective April 3, 2026  ·  Last Updated April 3, 2026
1

Who We Are

Duplais Group LLC, doing business as Circular Momentum ("we," "us," or "our"), operates circmo.com (the "Site"). We are a B2B growth consultancy serving the IT Asset Disposition (ITAD) and IT reseller industries.

Duplais Group LLC dba Circular Momentum  ·  10212 Holden Trails Rd, Lakeside, CA 92040  ·  pete@circmo.com

This Privacy Policy explains what personal and business data we collect, how we use it, who we share it with, and what rights you have.

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Scope of This Policy

This Policy applies to all visitors, prospects, and clients who interact with the Site, including through:

  • Contact forms and email opt-ins
  • ITAD Exit Assessment and Acquisition Assessment tools
  • The ITAD Value Builder tool
  • Newsletter or content subscriptions
  • Direct email correspondence initiated through the Site
  • Any additional interactive tools, calculators, scorecards, or diagnostic resources made available through the Site from time to time

This Site is directed exclusively at business professionals and organizations. We do not knowingly collect data from individuals under 18, and we do not market to consumers.

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Data We Collect

3.1 Information You Provide Directly

Data Type Examples Source
Contact Information Name, email, phone, job title Contact forms, opt-ins
Company Information Company name, size, revenue range, service lines, geography Assessment tools, forms
Assessment Responses ITAD program maturity, M&A readiness indicators, valuation inputs Exit Assessment, Value Builder
Communications Messages sent via contact form or email Contact form, email

3.2 Information Collected Automatically

Data Type Examples Tool
Usage Data Pages visited, time on site, referral URLs, browser and device type Google Analytics
IP Address Approximate location derived from IP (anonymized) Google Analytics, server logs
Cookie Data Session and persistent analytics cookies Google Analytics, HubSpot
CRM Tracking Email opens, link clicks, form submission timestamps HubSpot

3.3 Information From Third Parties

We use Apollo.io to identify and contact business professionals in the ITAD and IT reseller industries. Data sourced through Apollo may include publicly available professional contact information — name, company, title, and business email — used solely for relevant B2B outreach.

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How We Use Your Data

  • Delivering our services — responding to inquiries, delivering assessment results, and fulfilling consulting engagements
  • Sales and marketing outreach — sending relevant content and service offers via email (Smartlead) and phone
  • CRM and pipeline management — tracking prospect and client interactions in HubSpot
  • Analytics and optimization — understanding Site usage to improve content and experience via Google Analytics
  • Legal compliance — retaining records as required by applicable law

We do not sell your personal data to third parties, and we do not use your data for automated decision-making that produces legal effects.

5

Legal Basis for Processing (GDPR)

If you are located in the EU or EEA, we process your personal data under the following lawful bases:

Processing Activity Lawful Basis
Responding to your inquiry or assessment submission Legitimate Interests (Art. 6(1)(f)) — pursuing a business relationship you initiated
Sending marketing emails to existing contacts Legitimate Interests (Art. 6(1)(f)) — B2B marketing to relevant industry professionals
Newsletter and content subscription Consent (Art. 6(1)(a)) — where you have explicitly opted in
Analytics and Site performance tracking Legitimate Interests (Art. 6(1)(f)) — improving the Site and our services
Compliance with legal obligations Legal Obligation (Art. 6(1)(c))

Where we rely on Consent, you may withdraw it at any time by contacting pete@circmo.com or clicking unsubscribe in any marketing email.

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Cookies

Cookie Type Purpose Provider
Essential / Functional Required for the Site to operate WordPress
Analytics Visitor behavior and usage patterns Google Analytics
Marketing / CRM Form submissions and email interaction tracking HubSpot

You can control cookies through your browser settings. EU and EEA visitors should note that a cookie consent banner is implemented on this Site to comply with the ePrivacy Directive before analytics and marketing cookies are set.

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Third-Party Services & Data Processors

Provider Purpose Data Shared Privacy Policy
Google Analytics Website analytics Anonymized usage data, IP policies.google.com/privacy
HubSpot CRM, email tracking, forms Name, email, company, interactions legal.hubspot.com/privacy-policy
Smartlead Outbound email sequences Business email, name, company smartlead.ai/privacy-policy
Apollo.io Prospect data and outreach Publicly available professional info apollo.io/privacy-policy
Riverside.fm Podcast recording Guest contact info (show participants only) riverside.fm/privacy

We do not share your data with third parties for their own marketing purposes.

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International Data Transfers

Circular Momentum is based in the United States. Data from EU, EEA, or UK visitors is transferred to and processed in the US. We rely on Standard Contractual Clauses (SCCs), adequacy decisions, and the EU-U.S. Data Privacy Framework where applicable through our processors. Questions about international transfers may be directed to pete@circmo.com.

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Data Retention

  • Prospect and contact data: Up to 3 years from last meaningful engagement
  • Assessment data: 2 years from submission date, or the duration of an active engagement plus 2 years
  • Email correspondence: 3 years from last communication
  • Analytics data: Per Google Analytics defaults, up to 14 months for user-level data
  • Financial and contract records: 7 years as required by applicable law
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Your Rights

EU and EEA Residents (GDPR)

You have the rights of Access, Rectification, Erasure, Restriction, Data Portability, Objection (including to direct marketing), and Withdrawal of Consent. To exercise any right, email pete@circmo.com with the subject line "GDPR Data Request." We will respond within 30 days. You also have the right to lodge a complaint with your national supervisory authority.

California Residents (CCPA/CPRA)

You have the rights to Know, Delete, Correct, and Opt-Out of Sale or Sharing of personal information. We do not sell or share personal information for cross-context behavioral advertising. You will not be discriminated against for exercising your rights.

B2B Context Note: The CCPA includes a partial exemption for personal information collected in a business-to-business context. Much of the data we collect qualifies under this exemption. We honor the rights above regardless.

To submit a California privacy request, email pete@circmo.com with "California Privacy Request" in the subject line. We will verify your identity and respond within 45 days.

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Data Security

We implement TLS/SSL encryption for data in transit, access controls limiting data to authorized personnel, and use security-certified SaaS providers. No transmission over the internet is 100% secure. If you believe your data has been compromised, contact pete@circmo.com immediately.

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Links to Third-Party Sites

The Site may link to third-party websites. We are not responsible for their privacy practices. We encourage you to review their policies before submitting any data.

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Changes to This Policy

We may update this Policy from time to time, revising the "Last Updated" date at the top of this page. For material changes we will make reasonable efforts to notify affected contacts directly. Continued use of the Site after any update constitutes acceptance of the revised Policy.

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Contact Us

Duplais Group LLC dba Circular Momentum — Privacy
10212 Holden Trails Rd, Lakeside, CA 92040
Email: pete@circmo.com
Website: https://circmo.com
circmo.com — Legal Document

Terms of Service

Effective April 3, 2026  ·  Last Updated April 3, 2026
1

Acceptance of Terms

These Terms of Service ("Terms") govern your access to and use of circmo.com (the "Site") and all services offered by Duplais Group LLC, doing business as Circular Momentum ("we," "us," or "our"), including consulting services, assessment tools, and content resources.

By accessing the Site, submitting any form, using any tool, or engaging our services, you agree to be bound by these Terms. If you do not agree, do not use the Site or our services. If you are accepting on behalf of a business entity, you represent that you have authority to bind that entity.

2

Who May Use the Site

The Site is intended for business professionals and organizations in the ITAD, IT reseller, data center technology, and adjacent industries. It is not directed at consumers acting in a personal capacity. You must be at least 18 years of age to use the Site.

3

Services Offered

  • General Retainer and Success-Based Business Consulting — ongoing advisory, go-to-market strategy, operational guidance, and performance-based engagements for ITAD and IT reseller companies
  • M&A Advisory Services — strategic advisory for ITAD and IT reseller companies considering acquisition or exit transactions
  • Exit and Acquisition Assessment Tools — online diagnostics that capture business data and generate preliminary strategic insights
  • ITAD Value Builder — a valuation assessment tool helping operators understand drivers of business value
  • Outsourced Lead Generation Services — multi-channel outbound programs for ITAD and IT reseller clients
  • Content Resources — articles, podcast transcripts, and thought leadership available through the Site
  • Additional Tools and Resources — any calculators, scorecards, assessments, benchmarking tools, or other interactive resources made available through the Site from time to time

Detailed terms for paid engagements are governed by separate written agreements. In the event of conflict between these Terms and a signed engagement agreement, the engagement agreement controls.

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Assessment Tools — Important Disclaimers

The ITAD Exit Assessment, Acquisition Assessment, and ITAD Value Builder are provided for informational and preliminary strategic purposes only. Results generated by these tools:

  • Are not a formal business valuation, appraisal, or professional opinion of value
  • Are not financial, legal, tax, or investment advice
  • Are based solely on information you provide and do not constitute due diligence
  • Should not be relied upon as the sole basis for any business, financial, or M&A decision
Circular Momentum strongly recommends engaging qualified financial advisors, legal counsel, and certified appraisers before making any decisions based on assessment output.

By submitting data through any assessment tool, you acknowledge and accept these limitations.

5

Business Data You Submit

When you submit business data through assessment tools or contact forms, you represent and warrant that you are authorized to share that information, it is accurate to the best of your knowledge, and sharing it does not violate any confidentiality obligation or applicable law.

We treat all business data submitted through assessment tools as confidential and will not share identifiable data with third parties for commercial purposes without your consent, except as required by law or as described in our Privacy Policy.

Data submitted through the Site does not create a confidentiality, advisory, or fiduciary relationship between you and Circular Momentum unless and until a separate written engagement agreement is executed and in effect.
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Intellectual Property

All content on the Site — including articles, transcripts, assessments, frameworks, tools, branding, and proprietary methodologies including the E3 Lifecycle Optimization framework and any proprietary scoring models — is the exclusive property of Circular Momentum or its licensed contributors, protected by applicable copyright, trademark, and other intellectual property laws.

You are granted a limited, non-exclusive, non-transferable license to access and use the Site for your internal business evaluation purposes. You may not:

  • Reproduce, redistribute, or republish Site content without prior written permission
  • Scrape or extract data from the Site by automated means
  • Represent our tools, frameworks, or methodologies as your own
  • Use our content for competitive intelligence, resale, or commercial purposes without a written license
7

User Conduct

You agree not to use the Site to submit false or fraudulent information, attempt unauthorized access to Site systems, introduce malware or disruptive code, violate any applicable law, or harass or impersonate Circular Momentum personnel. We reserve the right to deny access to any party who violates these Terms.

8

Email and Marketing Communications

By submitting your contact information through the Site, you acknowledge that Circular Momentum may contact you regarding our services, relevant industry content, and business opportunities. All marketing emails include an unsubscribe mechanism. You may opt out at any time by clicking unsubscribe in any email or by emailing pete@circmo.com with "Unsubscribe" in the subject line. Transactional communications related to an active engagement may continue after a marketing opt-out.

9

Third-Party Links and Services

The Site may contain links to third-party websites provided for convenience only. Circular Momentum does not endorse or accept responsibility for any third-party content, products, or services. Your use of third-party sites is governed by their respective terms and privacy policies.

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Disclaimer of Warranties

THE SITE AND ALL CONTENT, TOOLS, AND RESOURCES PROVIDED THROUGH IT ARE OFFERED ON AN "AS IS" AND "AS AVAILABLE" BASIS WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED. CIRCULAR MOMENTUM EXPRESSLY DISCLAIMS ALL WARRANTIES, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND ACCURACY OR RELIABILITY OF ANY CONTENT OR ASSESSMENT OUTPUT. No content on the Site constitutes professional advisory services unless explicitly provided under a signed engagement agreement.

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Limitation of Liability

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, CIRCULAR MOMENTUM SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES ARISING OUT OF YOUR USE OF THE SITE OR ANY ASSESSMENT TOOL, INCLUDING LOSS OF PROFITS, BUSINESS OPPORTUNITIES, OR DATA.

IN NO EVENT SHALL OUR TOTAL LIABILITY TO YOU FOR ANY CLAIM RELATED TO THE SITE EXCEED THE TOTAL AMOUNT YOU HAVE PAID TO CIRCULAR MOMENTUM IN THE THREE (3) MONTHS IMMEDIATELY PRECEDING THE CLAIM. Some jurisdictions do not allow certain damage limitations; in such cases our liability is limited to the greatest extent permitted by law.

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Indemnification

You agree to indemnify, defend, and hold harmless Circular Momentum and its officers, directors, employees, and agents from and against any claims, liabilities, damages, losses, and expenses including reasonable attorneys' fees arising out of your use of the Site, your violation of these Terms, or your submission of false or unauthorized information through the Site.

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Governing Law and Dispute Resolution

These Terms are governed by the laws of the State of California, without regard to conflict of law provisions. Disputes shall first be submitted to good-faith negotiation. If unresolved within 30 days, disputes shall be resolved by binding arbitration administered by JAMS under its Streamlined Arbitration Rules, conducted in San Diego, California, on an individual basis. You waive any right to participate in a class action. Either party may seek injunctive relief in a court of competent jurisdiction in San Diego County to protect intellectual property rights or prevent irreparable harm.

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Changes to These Terms

We may update these Terms from time to time. Updated Terms will be posted on this page with a revised "Last Updated" date. Your continued use of the Site after any change constitutes acceptance of the revised Terms.

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Severability and Entire Agreement

If any provision of these Terms is found unenforceable, it will be modified to the minimum extent necessary and the remaining provisions will continue in full force. These Terms, together with our Privacy Policy and any executed engagement agreement, constitute the entire agreement between you and Circular Momentum regarding use of the Site.

16

Contact

Duplais Group LLC dba Circular Momentum — Legal
10212 Holden Trails Rd, Lakeside, CA 92040
Email: pete@circmo.com
Website: https://circmo.com