CleanCloud respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data, tell you about your privacy rights and how the law protects you when:
We may collect and process the following data about you:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new Customer or User||(a) Identity (b) Contact||Performance of a contract with you|
|To provide the Services to you including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Profile||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) >(c) Necessary for the legitimate interests of others (preventing fraud)|
|To administer and protect our business, the Site, App, Platform and Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Financial (d) Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with our legal obligations|
|To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||Necessary for our legitimate interests (to study how Customers and Users use the Services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our Site, App, Platform Services, marketing, customer relationships and experiences||(a) Technical (b) Usage||Necessary for our legitimate interests (to define types of Customers and Users for the Site, App, Platform and Services, to keep our Site, App and Platform updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about Services or events that may be of interest to you||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications||Necessary for our legitimate interests (to develop the Services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services and offers may be relevant for you and send to you through our marketing messages.
You will receive marketing messages from us if you have requested information from us or purchased Services from us and you have not opted out of receiving that marketing.
Our Site 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 Site, we encourage you to read the privacy notice of every website you visit.
You can always opt-out of receiving marketing or promotional emails from us, and all future marketing and promotional communications will also contain a simple way to opt out of receiving such further communications from us. We will get your express consent before we share your personal data with any third party for marketing purposes.
We may share your information with selected third parties including:
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA“) for our own administration purposes. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. Whenever we transfer your data outside the EEA, we ensure that a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you as this is no longer personal information.
As a data subject you have certain legal rights subject to certain exceptions under the applicable Data Protection legislation including:
You can exercise any of your rights at any time by contacting us at firstname.lastname@example.org You also have the right to make a complaint to the Information Commissioner’s Office.
Any changes we may make to our policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our policy.
If you have any questions or suggestions about our Policy, do not hesitate to contact us at [CleanCloud Ltd (UK Company Number: 09357458) Name or title of data privacy manager: Simon Fattuhi Email addresses: email@example.com Postal address: Karma Yoga House, Unit 2, Hoxton Square, London, N1 6HW Telephone number: +44 (0)20 8629 1097].