Clear Path Analysis Limited ("We", “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Notice (“Notice”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us when you use our website at www.clearpathanalysis.com (“Website”) or any of our services, or where we enter into any other business relationship with you. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.
For the purpose of the General Data Protection Regulation (“GDPR”) the Data Controller is Clear Path Analysis Limited.
YOUR PERSONAL INFORMATION
Information we collect from you
We collect and process some or all of the following types of information from you in the course of your use of the Website, our provision of our services, or otherwise conducting any business relationship with you:
The provision of name, email address, place of work, position, telephone number and enquiry details are required from you to submit and enable Us to respond to your enquiry. Your name and email address, phone number, place of work, position, industry details, location and details regarding how you heard about Us are required from you to subscribe to our services. The provision of your name, email address, place of work, position, telephone number, industry details, location and details regarding how you heard about Us is required from you when downloading material, participating in surveys or registering for events or requesting to be notified when such material and events registration is available. We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.
Information We Collect From Other Sources
We may also obtain personal data such as your name, organisation, job title and other information that you make public on social media, such as LinkedIn.
USES MADE OF YOUR INFORMATION
Provision of data to our content sponsor
Clear Path Analysis hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below.
Clear Path Analysis has a “free to view” business model. Our services are paid for by content sponsor (“Sponsors”) in exchange for Clear Path Analysis providing them with access to information about who reads their content. Once personal data is transferred to our Sponsor they become a data controller of this personal data. They use it to measure the response that their articles are receiving, as a form of market research. They may also use it to provide Clear Path Analysis users with information about their products and services.
Details of each Sponsor to which your personal data will be transferred is clearly stated within the summary of the content that you are able to view before you access the applicable Content. Sponsor may be located within or outside the EEA – their location will also be clearly indicated. For full details of how this Sponsor will use your personal data, you should review the Sponsor’s own Privacy Notice.
We have always been completely transparent about the provision of users’ personal data to our Sponsor, and until 25th May 2018 have relied on legitimate interest to collect and process our users’ information in this way.
From 25th May 2018, although we believe that we continue to have a legitimate interest in providing your information to the Sponsor whose content you access, and that the Sponsor continue to have a legitimate interest in receiving this personal data, we have decided to give you more control by asking for your express consent to this processing when you register. Users who register after 25th May 2018 will therefore be required to opt in or out of this use. Users who registered prior to 25th May 2018 will not be asked to expressly consent to the use but may opt out at any time by amending the settings in their profile or by contacting Us at the contact details set out below.
Clear Path Analysis’s own use of your personal data
We use information held about you in accordance with the following “legal bases” and for the following purposes:
We may use information held about you to promote our products and services that may be of interest to you. We rely on a number of legal bases for this type of processing, as follows:
In any case, if you would prefer that we do not use your data to market or promote our products and services to you, please either (i) tick the relevant box on the form through which We collect your data (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) contact Us at the contact details set out below.
DISCLOSURE OF YOUR INFORMATION
We routinely disclose your personal data to third parties as follows:
We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).
We may also disclose your personal data to third parties:
Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.
STORING YOUR PERSONAL DATA
We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. Where We process payment transactions, these will be encrypted using SSL technology. Where We have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.
Keeping your personal data up to date
If your personal details change you may update them by accessing the ‘My Subscription’ page, or by contacting Us using the contact details below. If you have any questions about how We use data collected which relates to you, please contact Us by accessing the ‘My Subscription’ page, or by contacting Us using the contact details below.
We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.
How long we keep your personal data
If you contact us using our website contact form, requesting general information about our services, we will hold personal data you choose to provide or that we may collect from you for 3 years from our last point of contact, unless you register as a user, sponsor or supplier.
If you subscribe to our services, we will hold personal data you choose to provide or that we may collect from you for 3 years from our last point of contact.
If you are engaged by one of our sponsors or suppliers we will hold you contact information for we will hold your contact details for the period that sponsor or supplier is registered with us and for 3 years after.
Data such as IP addresses, traffic data, location data, weblogs and other communication data will be retained for 3 years from the date of collection.
Where we store your personal data
All information We hold about you is stored on our secure servers.
The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services.
Such countries outside the EEA do not have the same data protection laws as the United Kingdom and EEA and we have therefore ensured that any of our suppliers who may transfer your personal data outside the EEA has put in place appropriate measures to protect your data, either by being a member of the US-EU Privacy Shield, or by entering into a European Commission approved contract (as permitted under Article 46(5) of the General Data Protection Regulation).
We will not otherwise transfer your personal data outside the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries. If you would like further information, please contact Us (see ‘Contact’ below)
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
HOW TO COMPLAIN
We hope that We can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
We reserve the right to modify this Notice at any time. Any changes We may make to our Notice in the future will be notified and made available to you using the Website. Your continued use of the services and the Website shall be deemed your acceptance of the varied Privacy Notice.
We may collect information about your mobile phone, computer or other device from which you access the Website including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
For the same reason, We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable Us:
All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to firstname.lastname@example.org.