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Public Privacy Notice
How Clearup Solutions uses your Personal Data
Introduction
Clearup Solutions respects your
privacy and is committed to protecting your personal data. This
privacy notice (notice) will inform you as to how we look after
your personal data when you contact us or visit this website
(regardless of where you visit it from) and tell you about your
privacy rights and how the law protects you.
This notice is provided in a
layered format so you can click through to the specific areas set
out below.
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WHAT IS PERSONAL DATA?
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THE PERSONAL DATA WE COLLECT ABOUT YOU
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HOW WE COLLECT YOUR PERSONAL DATA
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HOW WE USE YOUR PERSONAL DATA
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MARKETING
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DISCLOSURE OF PERSONAL DATA
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TRANSFERS OUTSIDE THE EEA
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KEEPING PERSONAL DATA SECURE
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DATA RETENTION
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YOUR RIGHTS
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COOKIES
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COMPLAINTS
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UPDATING THIS NOTICE
Purpose of this notice
You can request a copy of the details Clearup Solutions holds by
emailing Catherine Maylin, at catherine@clearupsolutions.co.uk.
This notice is issued on behalf of the Clearup Solutions so when we
mention "Clearup Solutions", "we", "us" or "our" in this notice, we
are referring to the relevant company, Clearup Solutions who are
responsible for processing your data.
This notice aims to give you information on how Clearup
Solutions collects and processes your personal data when you
contact or access us or through your use of this website, including
any personal data you may provide when you sign up to any
newsletters, take out our services, or any other communications you
have with us for example when you call, email or contact us via
social media.
This website is not intended for children and we do not
knowingly collect data relating to children.
It is important that you read this notice together with any
other privacy notice or fair processing notice we may provide on
specific occasions when we are collecting or processing personal
data about you so that you are fully aware of how and why we are
using your data. This notice supplements the other notices and is
not intended to override them.
Controller
This notice applies to the processing of personal data by
Clearup Solutions.
We have appointed Adrien Smith as the person who has
responsibility for advising us on our data protection obligations.
If you have any questions about this notice, including any requests
to exercise your legal rights, you can contact us using the
following details:
Clearup Solutions ltd
SVS House, Oliver Grove, London SE25 6EJ
adrien@clearupsolutions.co.uk
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 this
website, we encourage you to read the privacy notice of every
website you visit.
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WHAT IS PERSONAL DATA?
Personal data is any information that tells us something about
you. This could include information such as name, contact details,
date of birth and passport details. It does not include data where
the identity has been removed (anonymous data).
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THE PERSONAL DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of
personal data about you when you make contact with us through this
website, social media, applying for a vacancy, or any other means
of contacting us. We have grouped together the different types of
personal data as follows:
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Identity Data includes first name, maiden name, last name,
username or similar identifier, marital status, title, date of
birth and photographs.
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Contact Data includes email address and telephone numbers.
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Financial Data includes bank account details.
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Transaction Data includes details about payments to and from
you.
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Technical Data includes internet protocol (IP) address, your
login data, browser type and version, time zone setting and
location, browser plug-in types and versions, operating system and
platform and other technology on the devices you use to access this
website.
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Profile Data includes your username and password, your
interests, preferences, feedback and survey responses.
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Usage Data includes information about how you use this
website.
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Marketing and Communications Data includes your preferences in
receiving marketing from us and our third parties and your
communication preferences.
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Wireless Data - includes for example device names, MAC addresses
(i.e. unique device identifiers) and the date and time that the
user connects to Clearup Solutions wireless networks. Information
relating to the websites visited is not usually collected, unless
the website is deemed to be malicious, or inappropriate by our
security appliances used by Clearup Solutions.
We also collect, use and share Aggregated Data such as
statistical or demographic data for any purpose. Aggregated Data
may be derived from your personal data but is not considered
personal data in law as this data does not directly or indirectly
reveal your identity. For example, we may aggregate your Usage Data
to calculate the percentage of users accessing a specific website
feature. However, if we combine or connect Aggregated Data with
your personal data so that it can directly or indirectly identify
you, we treat the combined data as personal data which will be used
in accordance with this notice.
Special categories of personal data
Some information is classified as "special" personal data under
data protection legislation. This includes details about your race
or ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership,
information about your health and genetic and biometric
data.
In very limited circumstances, we may collect special personal
data about you. We will however, only collect or disclosure this
special personal data where it is necessary to protect your vital
interests (for example, if you are unwell at our premises, we may
need to pass your personal data to medical professionals in order
to seek assistance).
We do not collect any information about criminal convictions and
offences.
If you include any special personal data when you contact us on
the telephone, by email, through this website or any other means of
communication, it is your responsibility to make sure you are happy
for us to use that personal data in accordance with this notice.
You should be aware that this personal data is more sensitive and
is more heavily protected by data protection legislation, so you
should avoid including this kind of data if possible.
If you fail to provide personal data
Where we need to collect personal data by law, or under the
terms of a contract we have with you and you fail to provide that
data when requested, we may not be able to perform the contract we
have or are trying to enter into with you. In this case, we may
have to cancel the contract you have with us but we will notify you
if this is the case at the time.
3 HOW
WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you
including through:
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Direct interactions - You may give us your Identity, Contact,
Financial and Transaction Data by filling in forms or by
corresponding with us by post, phone, email or otherwise. This
includes personal data you provide when you:
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become a client of Clearup Solutions ;
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make contact with us through email, telephone, post or through
social media regarding a query, feedback or complaint;
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visit this website;
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subscribe to any of our e-newsletters or request marketing to be
sent to you.
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Automated technologies or interactions - As you interact with
this website, we may automatically collect Usage Data about how you
use this website and Technical Data about your equipment, browsing
actions and patterns. We collect this personal data by using
cookies, server logs and other similar technologies.
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Third parties or publicly available sources - We may receive
personal data about you from various third parties and public
sources as set out below:
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Technical Data from analytics providers such as Google based
outside the EU;
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Identity, Contact and Marketing and Communications Data from
marketing platforms such as Mail Chimp based outside the EU;
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Identity, Contact, Profile and Marketing and Communications Data
from survey providers such as Survey Monkey based outside the
EU;
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Identity Contact and Profile Data from social media platforms
such as Facebook, LinkedIn, Instagram, Vimeo and Twitter based
outside the EU;
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Identity, Contact, Profile, Financial and Transaction Data from
share registration service providers such as Equiniti based outside
of the EU;
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Identity and Contact Data from publicly availably sources such
as Companies House and the Electoral Register based inside the
EU.
4 HOW WE
USE YOUR PERSONAL DATA
Under data protection legislation we are only permitted to use
your personal data if we have a legal basis for doing so as set out
in the data protection legislation.
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:
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Where we need information to perform a contract we are about to
enter into or have entered into with you;
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Where we need to comply with a legal or regulatory obligation;
or
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Where it is necessary for our legitimate interests (or those of
a third party) and your interests and fundamental rights do not
override those interests.
Generally, we do not rely on consent as a legal basis for
processing your personal data other than in relation to sending you
marketing communications via email. You have the right to withdraw
consent to marketing at any time by contacting us.
Please refer to the Section below regarding the purposes for
which we will use your personal data to find out more about the
types of legal basis that we will rely on to process your personal
data.
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 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
legal basis depending on the specific purpose for which we are
using your data. Please contact us using the contact details above
if you need details about the specific legal basis we are relying
on to process your personal data where more than one ground has
been set out in the table below.
Purpose/Activity
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Type of data
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Lawful basis for processing
including basis of legitimate interest
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To register you as a new
client.
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(a) Identity; and (b)
Contact.
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Performance of a contract with
you.
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To manage our relationship with
you which will include:
(a)
Responding to your queries;
and
(b)
Notifying you about changes to our
terms and conditions or privacy notice.
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(a)
Identity;
(b)
Contact;
(c)
Profile; and
(d)
Marketing and
Communications.
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(a)
Performance of a contract with
you;
(b)
Necessary to comply with a legal
obligation; and
(c)
Necessary for our legitimate
interests (to keep our records updated and to study how clients use
our services).
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To deliver relevant website
content and advertisements to you and measure or understand the
effectiveness of the advertising we serve to you.
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(a)
Identity;
(b)
Contact;
(c)
Profile;
(d)
Usage;
(e)
Marketing and
Communications; and
(f)
Technical
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Necessary for our legitimate
interests (to study how clients use this website and services, to
develop them, to grow our business and to inform our marketing
strategy).
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To process financial
transactions including:
(a)
Manage payments, fees and charges;
and
(b)
Collect and recover money owed to
us.
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(a)
Identity;
(b)
Contact; (c) Financial; and
(d) Transaction.
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(a)
Performance of a contract with you;
and
(b)
Necessary for our legitimate
interests (to recover debts due to us).
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To assess your suitability to
become a supplier to us.
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(a)
Identity;
(b)
Contact; (c) Financial; and
(d) Transaction.
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(a)
Performance of a contract with you;
and
(b)
Necessary for our legitimate
interests (to develop and grow our business
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To promote our business
including:
(a)
sending our e-newsletter and other
marketing subscriptions;
(b)
events hosted by us;
(c)
events hosted on our
behalf.
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(a)
Identity;
(b)
Contact; and
(c)
Marketing and
Communications.
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Necessary for our legitimate
interests (to develop and grow our business understanding of
clients and to inform our marketing strategy).
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To enable you to complete a
survey.
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(a)
Identity;
(b)
Contact;
(c)
Profile;
(d)
Usage; and
(e)
Marketing and
Communications.
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Necessary for our legitimate
interests (to study how clients use our products/services, to
develop them and grow our business).
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To administer and protect our
business and this website (including troubleshooting, data
analysis, testing, system maintenance, support, reporting and
hosting of data)
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(a) Identity; (b) Contact; and
(c) Technical.
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(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); and
(b)
Necessary to comply with a legal
obligation.
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To use data analytics to improve
this website, services, marketing, client relationships and
experiences.
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(a) Technical; and (b)
Usage.
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Necessary for our legitimate
interests (to define types of clients for our services, to keep
this website updated and relevant, to develop our business and to
inform our marketing strategy).
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To make suggestions and
recommendations to you about services that may be of interest to
you.
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(a)
Identity;
(b)
Contact;
(c)
Technical; (d) Usage;
and
(e) Profile.
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Necessary for our legitimate
interests (to develop our services and grow our
business).
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Change of
purpose
We will only use your personal
data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and
that reason is compatible with the original purpose. If you wish to
obtain an explanation as to how the processing for the new purpose
is compatible with the original purpose, please contact us using
the contact details above.
If we need to use your personal
data for an unrelated purpose, we will notify you and we will
explain the legal basis which allows us to do so.
Please note that we may process
your personal data without your knowledge or consent, in compliance
with the above rules, where this is required or permitted by
law.
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MARKETING
Direct marketing
We strive to provide you with
choices regarding certain personal data uses, particularly around
marketing. We will provide you with a clear choice to opt into
receiving any of our newsletters or other marketing communications
when you first make contact with us.
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 (we call this marketing).
You will receive marketing
communications from us if you have requested information from us or
take p our services and, in each case, you have not opted out of
receiving that marketing.
Third-party
marketing
We do not share your personal
data with any company outside of Clearup Solutions for marketing
purposes.
Opting out
You can ask us to stop sending
you our newsletter, marketing messages or other marketing materials
at any time by unsubscribing from the mailing list, using the link
provided in the newsletter email, or by using the contact details
above.
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DISCLOSURES OF PERSONAL
DATA
We sometimes need to share your
data with third parties for the purposes as set out in the table in
Section 4.
Where we share your personal
data with third parties we ensure that we have appropriate measures
in place to safeguard your personal data and to ensure that it is
solely used for legitimate purposes in line with this notice. We
will always make sure that those third parties protect your
personal data in the same way that we do.
We need to share your personal
data with third parties who provide services to us to enable them
to provide their services such as IT, payment and system
administration services. We may also need to share your personal
data with our professional advisers including lawyers, bankers,
auditors and insurers based who provide consultancy, banking,
legal, insurance and accounting services.
Our websites are managed by
various developers. As part of the service provided by these
developers, they will help to maintain the security and the
performance of our websites by: (i) encrypting data in transit and
protecting user connections; (ii) using third party scanning
services to scan against known web attacks; (iii) investigating
site errors; and (iv) providing secure hosting
services.
We will not usually disclose
your personal data other than as set out above. However, there may
be circumstances where we need to share personal data other than as
anticipated above. These include:
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Where we are legally required to disclose the information, for
example because a court orders us to do so;
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Where the disclosure of the personal data is required for the
purposes of the prevention and detection of crime. This includes
sharing the personal data with tax authorities and law enforcement
agencies;
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Where we need to disclose the personal data for the purpose of
or in connection with any investigation of an alleged crime,
legal proceedings, or for the purpose of obtaining legal advice, or
the disclosure is otherwise necessary for the purposes of
establishing, exercising or defending legal rights; and
As stated above in Section 2 (Special categories of personal
data), we may in very limited circumstances collect special
personal data about you but we will only disclosure this special
personal data where it is necessary to protect your vital interests
(for example if you are unwell at our premises, we may need to pass
your personal data to medical professionals in order to seek
assistance).
7 TRANSFERS
OUTSIDE OF THE EEA
When personal data is transferred to countries outside of the UK
and the European Economic Area (EEA) those countries may not offer
an equivalent level of protection for personal data to the laws in
the UK. We will not transfer your personal data outside the
(EEA).
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We will only transfer your personal data to countries that have
been deemed to provide an adequate level of protection for personal
data by the European Commission;
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Where we use certain service providers, we may use specific
contracts approved by the European Commission which give personal
data the same protection it has in Europe; or
Please contact us using the contact details above if you want
further information on the specific mechanism used by us when
transferring your personal data.
8 KEEPING
PERSONAL DATA SECURE
We know that you provide your personal data in good faith and
expect it to be looked after. We take the security of your personal
data seriously and 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.
We have also taken steps internally in order to ensure that our
systems adequately protect your personal data. This includes for
example:
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HTTPS / SSL encryption of data between the user's browser and
server;
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use of updated and patched software;
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storing highly confidential information in encrypted form;
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using firewalled IT systems to prohibit unauthorised access
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restricted access controls on files and servers containing
personal data;
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physical security including locked rooms
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DATA RETENTION
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.
Details of retention periods for different aspects of your
personal data are available in our retention policy. You can
request details of these retention periods by contacting Adrien
Smith using the contact details above.
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YOUR RIGHTS
You have rights in respect of your personal data and this
Section explains a bit more about those rights that are applicable
to what we do with your personal data and when you can exercise
them. If you would like more information about any of your rights,
please contact us using the contact details above.
You have a number of rights in relation to your personal data,
these include the right to:
Be informed about how we use your personal data;
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Obtain access to your personal data that we hold;
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Request that your personal data is corrected if you believe it
is incorrect, incomplete or inaccurate;
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Request that we erase your personal data in the following
circumstances:
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If we are continuing to process personal data beyond the period
when it is necessary to do so for the purpose for which it was
originally collected;
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If we are relying on consent as the legal basis for processing
and you withdraw consent;
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If we are relying on legitimate interest as the legal basis for
processing and you object to this processing and there is no
overriding compelling ground which enables us to continue with the
processing;
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If the personal data has been processed unlawfully (i.e. in
breach of the requirements of the data protection legislation)
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If it is necessary to delete the personal data to comply with a
legal obligation,
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Ask us to restrict our data processing activities where you
consider that:
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Personal data is inaccurate;
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Our processing of your personal data is unlawful;
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Where we no longer need the personal data but you require us to
keep it to enable you to establish, exercise or defend a legal
claim;
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Where you have raised an objection to our use of your personal
data,
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Request a copy of certain personal data that you have provided
to us in a commonly used electronic format. This right relates to
personal data that you have provided to us that we need in order to
perform our agreement with you and personal data where we are
relying on consent to process your personal data;
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Object to our processing of your personal data where we are
relying on legitimate interests or exercise of a public interest
task to make the processing lawful. If you raise an objection we
will carry out an assessment to determine whether we have an
overriding legitimate ground which entitles us to continue to
process your personal data; or
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Withdraw consent where we are relying on consent to process your
personal data. You can withdraw consent to our processing the
personal data at any time;
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Not be subject to automated decisions which produce legal
effects or which could have a similarly significant effect on
you.
If you would like to exercise any of your rights or find out
more information, please contact us using the contact details
above. 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 may 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 may 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.
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COOKIES
You can set your browser to refuse all or some browser cookies,
or to alert you when websites set or access cookies. If you disable
or refuse cookies, please note that some parts of this website may
become inaccessible or not function properly.
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COMPLAINTS
You have the right to make a complaint at any time to the
Information Commissioner's Office. We would, however, appreciate
the chance to deal with your concerns before you approach the
Information Commissioner's Officer so please contact us in the
first instance using the contact details above.
You are important to us, and so is protecting your personal
data. We have high standards when it comes to collecting and using
personal data. For this reason, we take any complaints we receive
from you about our use of your personal data very seriously and
request that you bring any issues to our attention.
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UPDATING THIS NOTICE
We keep our notice under regular review in order to ensure that
it properly reflects our use of personal data. This notice was last
updated on 24th May 2018 and historic versions can be
obtained by contacting us.
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.
Clearup Solutions Limited
May 2018
24 hours a day - 7 days a week Emergency Response
0845 094 2921
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