Interpretation and Definitions
Interpretation
The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
Company: referred to as either "the Company","We", "Us" or "Our" in this Policy, refers to ClearRoute Limited, WeWork - 26, Hatton Garden, EC1N 8BR.
Cookies: small files that are placed on your computer, mobile device or any other device by a website, containing details of your browsing history on that website among its many uses.
Data Controller: for the purposes of the UK GDPR (UK General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
Device: any device that can access the Service such as a computer, a mobile phone or a digital tablet.
Personal Data: any information that relates to an identified or identifiable individual. For the purposes of UK GDPR, Personal Data means any information relating to You such as a name, email address, telephone number, job title, employer or company name, IP address, device identifiers, online identifiers including cookie IDs and social media handles, location data, or one or more factors specific to the economic, cultural or social identity of that individual.
Service: refers to the Website.
Service Provider: any natural or legal person who processes data on behalf of the Company. For the purpose of the UK GDPR, Service Providers are considered Data Processors.
Usage Data: data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (forexample, the duration of a page visit).
Website: ClearRoute, accessible from clearroute.io or clearroute.co.uk.
You: the individual accessing or using the Service, or the company or other legal entity on behalf of which such individual is accessing or using the Service. Under UK GDPR, You may be referred to as the Data Subject or the User.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data: this is the information you provide when you use the Contact section of our site to send a message, ask a question or subscribe to our email mailing list. This may include your name, email address, telephone number, job title, company name, social media handles, and any other information you choose to share with us.
Usage Data: Usage Data is collected automatically when using the Service. Usage Data may include information such as your Device's IP address, online identifiers including cookie IDs, location data, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on our Service and store certain information. Tracking technologies used are beacons, tags, scripts, pixels, session recording tools and similar technologies to collect and track information and to improve and analyse our Service.
This website uses a cookie control system, allowing you to give explicit permission or to deny the saving of cookies on your computer or device. Users who wish to deny the use of cookies should use the cookie control system upon their first visit or adjust their browser security settings to block cookies from this website and its external vendors.
Persistent Cookies(Administered by Third Parties): These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor through a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or functionality of the Website.
Web Beacons: Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company to count users who have visited those pages or opened an email, and for other related website statistics.
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your device when you go offline, while Session Cookies are deleted as soon as you close your web browser.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To contact You by email, telephone or SMS regarding updates or informative communications related to our services, including security updates, when necessary orreasonable.
- To provide You with news, special offers and general information about other goods, services and events which we offer, unless You have opted not to receive such information.
- To manage Your requests: to attend and manage Your requests to Us.
- For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of Our assets, in which Personal Data held by Us may be among the assets transferred.
- For other purposes: such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share Your personal information in the following situations:
- With Service Providers: We may share Your personal information with Service Providers to monitor and analyse the use of our Service and to contact You.
- For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
- To comply with a legal obligation: We may disclose your personal information if we are under a duty to do so by law or in response to valid requests by public authorities.
- To prevent fraud or protect rights: We may disclose personal information if we believe that such action is necessary to prevent fraud or cyber crime, or to protect the rights, property or personal safety of any person.
With Your consent: We may disclose Your personal information for any other purpose with Your explicit consent.
We do not sell your personal data to third parties.
Email Marketing, Events and Digital Campaigns
We operate an email mailing list used to inform subscribers about ClearRoute's services, insights, and events.
We may also collect personal data at industry events including through badge scanning, business cards and sign-up sheets, and through digital campaigns including social media lead generation and paid advertising, webinars and virtual events, and gated content such as downloadable reports and whitepapers. In all cases:
- We clearly identify ClearRoute Limited as the party collecting your data at the point of collection.
- We explain specifically what your data will be used for before you provide it.
- Consent to be added to our mailing list and consent to direct sales outreach are always collected separately - these are not bundled together.
- Attendance at an event or scanning of a badge does not constitute consent to marketing. Where we capture data at events, an explicit separate consent step is always offered and obtained.
We use Salesforce Marketing Cloud for email marketing and engagement tracking (opens, clicks, unsubscribes), and Salesforce CRM for managing contact information, communication history and sales opportunities.
Data from both platforms is transferred to the United States under Salesforce's Data Processing Addendum (DPA), which supports the UK International Data Transfer Agreement (UK IDTA) as a lawful transfer mechanism under UK GDPR Chapter V. All data across both platforms is retained for 730 days.
Our email marketing messages may contain tracking technologies such as tracked links or web beacons that record engagement data including open rates and click activity.
You can unsubscribe from our mailing list at any time by clicking the unsubscribe link in any marketing email, or by contacting us at Privacy@clearroute.io. We will process your request promptly and you will not be re-added without your explicit consent.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
Specific retention periods:
- Contact form enquiries: retained for 730 days
- Marketing consent records: retained for the duration of the marketing relationship.
- Website usage and analytics data: retained for 730 days.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. Information submitted by you may be transferred to our other offices and/or to the third-party Service Providers referenced in this Privacy Policy, which may be situated outside the United Kingdom.
Where we transfer your information outside the United Kingdom, we will take all steps required by UK GDPR to ensure that your privacy rights continue to be protected, including where applicable the use of UK International Data Transfer Agreements (IDTAs) or transfers to countries covered by UK adequacy regulations.
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Other Legal Requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of users of the Service or the public
Protect against legal liability
Security of Your Personal Data
We place great importance on the security of all personally identifiable information associated with our users. We have appropriate technical and organisational security measures inplace to protect against the loss, misuse and alteration of personal information under our control. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts toprevent it.
You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via the Site whilst it is in transit over the internet and any such submission is at your own risk.
Analytics
We may use third-party Service providers to monitor and analyse the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services.
Data collected via Google Analytics is transferred to the United States. This transfer is conducted under Google's Data Processing Terms, which incorporate the UK International Data Transfer Agreement (UK IDTA) as the lawful transfer mechanism under UK GDPR Chapter V. Analytics data is retained for 14 months.
You can opt out of Google Analytics by declining analytics cookies in our cookie banner when you first visit the site, or by changing your preferences via the cookie control system at any time. As a fallback you can also install the Google Analytics opt-out browser add-on. For more information visit: https://policies.google.com/privacy
UK GDPR Privacy
Legal Basis for Processing Personal Data under UK GDPR
We may process Personal Data under the following conditions:
Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
Performance of a contract: processing personal data is necessary to take steps at your request before entering into a contract (for example, respondingto your enquiry) or to perform a contract to which you are a party.
Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company, where those interests are not over ridden by your rights. Specifically, we rely on legitimate interests for: business development and marketing to existing and prospective business contacts; managing our relationships with clients, suppliers and partners; recruitment and candidate engagement; ensuring the security of our website, networks and information; and analysing and improving our website and services.
Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
Your Rights under UK GDPR
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
- the right to receive a copy of the Personal Data we hold about you. Please contact us at Request access to Your Personal Data: the right to receive a copyof the Personal Data we hold about you. Please contact us at Privacy@clearroute.io to make a request.
- You have the right to have any incomplete or inaccurate information we hold about You corrected.Request correction: You have the rightto have any incomplete or inaccurate information we hold about You corrected.
- This right exists where we are relying on a legitimate interest as the legal basis for processing, or where we are processing Your Personal Data for direct marketing purposes.Object to processing: This rightexists where we are relying on a legitimate interest as the legal basis forprocessing, or where we are processing Your Personal Data for direct marketingpurposes.
- You have the right toask Us to delete or remove Personal Data when there is no good reason for Us to continue processYou have the right to ask Us to delete or remove Personal Data when there is no good reason for Us tocontinue processing it.
- We will provide to You, or to a third party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format, where applicable.Request the transfer of Your Personal Data: We will provide to You, or to a third party You havechosen, Your Personal Data in a structured, commonly used, machine-readableformat, where applicable.
- You have the right to ask us to restrict the processing of your personal data in certain circumstances, for example while we verify the accuracy of data you have contested or while we consider an objection you have raised.Request restriction of processing: You have the right to askus to restrict the processing of your personal data in certain circumstances,for example while we verify the accuracy of data you have contested or while weconsider an objection you have raised.
- You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you. ClearRoute does not currently carry out solely automated decision-making of this kind.Rights related to automated decision-making: You have the right not tobe subject to a decision based solely on automated processing, includingprofiling, that produces legal effects concerning you or similarlysignificantly affects you. ClearRoute does not currently carry out solelyautomated decision-making of this kind.
- You have the right to withdraw Your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.Withdraw Your consent: You have theright to withdraw Your consent at any time. Withdrawal does not affect thelawfulness of processing carried out before withdrawal.
Exercising Your UK GDPR Rights
You may exercise your rights by contacting us at Privacy@clearroute.io. Please note that we may ask You to verify Your identity before responding to such requests. We will respond as soon as possible and within one month of receipt. Requests are handled free of charge unless they are manifestly unfounded or excessive.
You have the right tocomplain to the Information Commissioner's Office (ICO) about our collectionand use of Your Personal Data. You can contact the ICO at www.ico.org.uk.
Data Protection Complaints
If you are unhappy with how we have collected, used or handled your personal data, we encourage you to raise this with usdirectly in the first instance. You do not need to use formal legal language —simply explain your concern and we will investigate it. We accept complaintssubmitted by any means, including by email, post or via social media.
To submit a complaint, please contact us at privacy@clearroute.io or write to us at WeWork, 26 Hatton Garden, EC1N 8BR.
On receiving your complaint, we will acknowledge it within 30 days and let you know who is handling it. We will thenreview the circumstances, gathering information from relevant teams or systems where necessary, and keep you informed of progress if the matter takes longer to resolve. We will provide you with a written response explaining our findings and, where appropriate, any steps we are taking to address the issue.
If you remain dissatisfied with our response,you have the right to escalate your complaint to the Information Commissioner'sOffice (ICO), the UK's independent supervisory authority for data protection.The ICO generally expects individuals to raise concerns with the organisation directly before it will investigate. You can contact the ICO at www.ico.org.uk or by calling 0303 123 1113.
We keep a record of all data protection complaints we receive, including when they were acknowledged, the steps taken during our review, and the outcome. These records are retained in line with our data retention policy
Third Party Links
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Changesto this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice on our Service, prior to the change becoming effective, and update the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
ContactUs
If you have any questions about this Privacy Policy, You can contact us at Privacy@clearroute.io
