This Policy applies as between you, the User of this Web Site and ClevaGroup Ltd the owner and provider of this Web Site. This Policy applies to our use of any and all Data collected by us in relation to your use of the Web Site and any Services or Systems therein.
Who this policy applies to
- People who visit and use our Site
- Subscribers to ClevaGroup Services
- People who contact us
- Job applicants and our current and former employees
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Cookie” – means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site.
“Cookie Law” – means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“Personal data” – means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” – means ClevaGroup Ltd a limited company registered in England under company number 05809779, whose registered address is Unit 5, Harforde Court, John Tate Road, Hertford, SG13 7NW and whose main trading address is Unit 5, Harforde Court, John Tate Road, Hertford, SG13 7NW.
People who visit and use our Site
Our Site may invite you to sign up for certain features, such as newsletters, email updates, quote requests and other general interactive features. Where you provide information for these purposes, we will use your information to provide the relevant service or feature that you have requested and to manage your preferences. We may also gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our newsletters and email subscriptions. You will have the ability to unsubscribe from any repeat communications at any time.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
Please note: If you disable cookies on our Site, some features of the Site may not be available to you.
If you perform any searches on our Site, search queries and results may be logged anonymously to help us to improve our Site and search functionality. No user-specific data is collected.
We may also collect information about visitors’ activities on our blog, for example the number of users viewing a page on the blog, to monitor and report on the effectiveness of the blog and help us improve it. Visitors may be required to enter a name and email address to view our blog and/or post comments.
Website security and performance
We may use third parties to help maintain the security and performance of our Site. To deliver this service we may need to allow the third party to process the IP addresses of Site visitors.
Subscribing to ClevaGroup
Our subscription services are provided according to our terms of service and contain features which enable Users to upload, store and process substantial amounts of personal information, for example contact records for your business, some of which may be sensitive personal information. When you provide any personal information to us in the course of using our subscription services, you do so as the “data controller” under UK Data Protection Law. We shall only process it in accordance with the terms of service and in the context of providing the Services to you and do so as the “data processor”. You and we shall both comply with prevailing UK data protection legislation at all times in this regard.
Subscriber application process
When you apply to subscribe to use our Services, the information you give us may contain some personal information, for example where the business is a sole trader and or contact details of a relevant member of staff. We will use this for its own purposes to assess your application and provide our Services to you as applicable.
In addition to the above, where you subscribe to use our Services, we will need to use some personal information in the context of our relationship pursuant to the terms outlined in our contracts.
We may record personal information provided to us by telephone, email, in person or otherwise in writing or electronically. We will only use your information for the purposes that you provided it to us and for administrative purposes, always in compliance with Data Protection Law. Email monitoring or blocking software may be used. Please be aware that you have a responsibility to ensure that any communications from you are within the bounds of the law.
Job applicants, current and former employees
When individuals apply to work for us, we will only use the information they supply to us to process their application and to monitor recruitment statistics. Where we want to disclose information to a third party, for example where we want to take up a reference or obtain a ‘disclosure’ from the Criminal Records Bureau we will not do so without informing the applicant beforehand, unless the disclosure is required by law.
Personal information about unsuccessful candidates will be held for 12 months after the recruitment exercise has been completed, it will then be destroyed or deleted. We may retain de-personalised statistical information about applicants to help inform our recruitment activities, but no individuals are identifiable from that information.
Once a person has taken up employment with us, we will compile a file relating to their employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once their employment with us has ended, we will retain the file in accordance with the requirements of our retention schedule and then delete it.
2. Information About Us
2.1 Our Site is owned and operated by ClevaGroup Ltd , a limited company registered in England under company number 05809779, whose registered address is Unit 5, Harforde Court, John Tate Road, Hertford, SG13 7NW.
2.2 Our VAT number is 918199096.
2.3 Our Information Security Manager can be contacted by email at email@example.com, by telephone on 03333 448 300 or by post at Unit 5, Harforde Court, John Tate Road, Hertford, SG13 7NW.
3. What Does this Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14)
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data We Collect
Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data.
5.2 business/company name
5.3 contact information such as email addresses and telephone numbers
5.4 your website URL
5.5 IP address
5.6 web browser type and version
5.7 operating system
5.8 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to
6. Financial transactions
7. How Do We Use Your Data
7.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times.
7.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
7.2.1 Providing and managing your access to Our Site;
7.2.2 Supplying Our products and/or services to you (please note that We require your personal data in order to enter into a contract with you);
7.2.3 Personalising and tailoring Our products and/or services for you;
7.2.4 Replying to emails from you;
7.2.5 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking the unsubscribe link at the bottom of the email;
7.2.6 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
7.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on our products and/or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
7.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
7.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected
8. How and Where We Store Your Data?
8.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
8.2 Our Site servers are and will always be located in the UK and/or the EEA. In order to effectively process credit or debit card transactions it may be necessary for the bank or card processing agency to verify your personal information for authorisation with an entity outside the EEA. Such information will not be transferred out of the EEA for any other purpose.
8.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
8.4 Steps We take to secure and protect your data include:
8.4.1 Using appropriate technical and organisational steps, and will store it on our database within a secure network.
8.4.2 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
9. What Happens If Our Business Changes hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
10. Business Reorganisation
11. Sharing your data with third parties
We contract with a number of third parties to assist us in providing our Site and Services. For example, we may use third parties to develop our Site and to provide the servers on which our Site is hosted. Wherever third parties are involved in processing personal information on our behalf, we shall ensure they do so in accordance with UK Data Protection Law. Third parties are not allowed to use your personal information for their own purposes.
12. How Can you Control Your Data?
12.1 When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
12.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
13. Your Right To Withhold Information
13.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
14. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at firstname.lastname@example.org or using the contact details below in section 13.
16. Contacting Us
17. Complaints or queries