Privacy Policy

CLAUSE

1. Important information and who we are

2. The types of personal data we collect about you

3. How is your personal data collected?

4. How we use your personal data

5. Disclosures of your personal data

6. International transfers

7. Data security

8. How long we keep your information

9. Your legal rights

10. Contact details

11. Complaints

12. Changes to the privacy policy and your duty to inform us of changes

13. Third-party links

1. Important information and who we are

We are Clearline Digital Ltd incorporated and registered in England and Wales with company number 12831815 and our registered office is at 45 Strothers Way, Cramlington, England, NE23 8AN.

This privacy policy gives you information about how we, as data controller, collect and use your personal data through your use of this website, including any data you may provide through forms on this website or that we may collect via the use of cookies or similar tracking mechanism.

This website is not intended for children and we do not knowingly collect data relating to children.

2. The types of personal data we collect about you

Personal data refers to any information that can be used to identify an individual.

We may collect, use, store and transfer different types of personal data, which we have grouped as follows:

• Identity Data – includes your first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data – includes your billing address, delivery address, email address and telephone number.
• Financial Data – includes your bank account and payment card details.
• Transaction Data – includes details about payments to and from you, and information about the products and services you have purchased from us.
• Technical Data – includes your IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, platform, device ID and other technology used to access this website.
• Profile Data – includes your username and password, purchase history, your interests, preferences, feedback and responses to any surveys or forms.
• Usage Data – includes information on how you interact with our website, including pages visited, actions taken, and features used.

Marketing and Communications Data – includes your preferences for receiving marketing from us and third parties, and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic information. This type of data does not directly (or indirectly) identify you. For example, we may use aggregated Usage Data to understand how users interact with our website, which helps us improve our content, design and services.

3. How is your personal data collected?

We collect your personal information when you browse our website or when you provide information by engaging with us, for example by completing our contact form.

We also collect information automatically when you browse our website, including technical information (such as your IP address) and information about your activities on our website (such as which pages you visit, the duration of your visit, etc).

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the unsubscribe links within any marketing communication sent to you or by contacting us by email.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.

• Service Providers. We provide access to or disclose your information to third parties that perform services on our behalf, such as billing, payment processing, advertising, web and other analytics, data storage and processing, customer support, security, fraud prevention, and other services.
• Affiliates. We provide access to or disclose your information to our affiliates for the purposes described in this Policy.
• For Legal Reasons of the Protection of Us and Others. We will disclose the information we collect about you if required by law or legal process or if we believe in good faith that disclosure is reasonably necessary to: (i) enforce any applicable terms of use, this Policy, or other contracts with you, including investigation of potential violations thereof; (ii) respond to claims that any content violates the rights of third parties; and/or (iii) protect the rights, property or personal safety of us, our customers and/or others. This includes exchanging information with other companies and organisations for fraud protection, spam/malware prevention, and similar purposes.
• Business Transfers. We may disclose your information to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• Other Unaffiliated Third Parties. We may disclose your information to other unaffiliated third parties such as third parties we collaborate with in connection with integration, co-marketing and other co-ordinated efforts.
• Your Consent. If you consent to our disclosure of your information, we will disclose your information consistent with your consent.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We do not transfer your personal data outside the UK.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. How long we keep your information

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

If you opt out of email marketing, we maintain your email on our suppression list to comply with your request. We may delete or de-identify your information sooner if we receive a verifiable deletion request, subject to exemptions under applicable laws. We may retain cached or archived copies for your information.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.

You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see opting out of marketing in paragraph 4 for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

• If you want us to establish the data’s accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us. See Contact details (paragraph 10).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us via email at services@clearlinedigital.com, so we can try to resolve your issue.

11. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. Your continued use of the services after any changes to this Policy in effect constitutes your acceptance of the revisions to the Policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

13. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Dated: May 2024