- 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. Details of the Cookies used by Our Site are set out in section 13, below;|
|“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 Clear Thinking IT, a limited company registered in England under company number 05989705, whose registered address is Clear Thinking IT, Unit 7a Radford Crescent, Billericay, CM12 0DU.|
- Information About Us
2.1 Our Site is owned and operated by Clear Thinking IT, a limited company registered in England under company number 05989705, whose registered address is Clear Thinking IT, Unit 7a Radford Crescent, Billericay, CM12 0DU.
2.2 Our Data Protection Officer can be contacted by email at firstname.lastname@example.org, or by post at ATTN: Data Protection Officer, Clear Thinking IT, Mayflower House, 128a High Street, Billericay, Essex, CM12 9XE.
- What are Cookies?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device and to target the content displayed to the user’s interests.
5.2 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for analysing usage of our website to continually improve services. For more details, please refer to section 6, above, and to section 13.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
5.3 All Cookies used by and on Our Site are used in accordance with current Cookie Law.
5.4 Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
5.5 The following first party Cookies may be placed on your computer or device:
Name of Cookie
5.6 Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
5.7 The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
5.8 The analytics service(s) used by Our Site use(s) the following Cookies:
|Name of Cookie||First / Third Party||Provider||Purpose|
|_ga||Third Party||Google-analytics.com||This is a Google Analytics HTTP cookie that registers a unique ID that is used to generate statistical data on how you use the website. It is retained for 2 years.|
|_gat||Third Party||Google-analytics.com||This is a Google Analytics HTTP Session cookie used to throttle request rate which is removed when you quit your browser.|
|_gid||Third Party||Google-analytics.com||This is a Google Analytics HTTP Session cookie used to generate statistical data on how you use the website which is removed when you quit your browser.|
|Collect||Third Party||Google-analytics.com||This is a Google Analytics Pixel Session cookie used to send data to Google Analytics about the visitor’s device and behavior which is removed when you quit your browser.|
|_gd#||Third Party||Google-analytics.com||This is a Google Analytics HTTP Session cookie used to generate statistical data on how you use the website which is removed when you quit your browser.|
|Impression.php/#||Third Party||Facebook.com||Used by Facebook to register impressions on pages with the Facebook login button.|
|Safe_image.php||Third Party||Facebook.com||Used by Facebook to register impressions on pages with the Facebook login button.|
5.9 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
5.10 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
5.11 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings
- Your Rights
6.1 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:
6.1.1 The right to be informed about Our collection and use of personal data;
6.1.2 The right of access to the personal data We hold about you (see section 12);
6.1.3 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);
6.1.4 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);
6.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
6.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
6.1.6 The right to object to Us using your personal data for particular purposes; and
6.1.8 Rights with respect to automated decision making and profiling.
6.2 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.
6.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
7.0 What Data Do We Collect?
7.2 business/company name
7.3 contact information such as email addresses and telephone numbers;
7.4 IP address;
7.5 web browser type and version;
7.6 operating system;
7.7 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
8.0 How Do We Use Your Data?
8.1 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. For more details on security see section 7, below.
8.2 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:
8.2.1 Replying to emails and contact requests from you;
8.2.2 Analysing your use of Our Site to enable Us to continually improve Our Site and your user experience;
8.3 We will not 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.
8.4 Third parties (including www.facebook.com) whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
8.5 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
8.6 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. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
8.7 Personal Data collected via the Contact Page will be kept for a maximum period of 2 years.
9.0 How and Where Do We Store Your Data?
9.1 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.
9.2 Your data will only be stored in the UK.
9.3 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.
10.0 Do We Share Your Data?
10.1 Subject to section 8.2, We will not share any of your data with any third parties for any purposes.
10.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
11.0 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 email@example.com, or using the contact details below in section 14.
- Contacting Us
If you have any questions about Our Site or this Policy, please contact Us by email at firstname.lastname@example.org, or by post at Clear Thinking IT, Mayflower House,
128a High Street, Billericay, Essex, CM12 9XE. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 12, above).
- Changes to Our Policy
We may change this Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.