Last updated: January 25, 2022
1. Categories of Your Personal Data We collect and process
a) Automatically collected data
- How did You find Us – this includes Your URL data.
- Location data – this includes the geographic area where You use Your computer and/or mobile devices (as indicated by an Internet Protocol (IP) address or similar identifier) when interacting with our Website.
- Device information – this includes data from Your computer and/or mobile device, such as the type of hardware and software You are using (for example, Your operating system and browser type).
- Usage data – this includes the way You interact with Our Website – We log Your taps on certain areas of the interface and pages, content You interact with, the time and duration of Your sessions, etc.
b) Data You give Us
- “Request a Demo” and “Contact Us” forms – when You use “Contact Us” and “Request a Demo” forms or other request forms, available on Our Website, to send Us Your request, We will ask You to give Us Your name, email, mobile phone, Your role (business owner, HR, etc.) and the name of a legal entity You are representing. We need this information to respond to Your request and provide You with information about Our services.
c) Data collected from the other sources
2. Why We need Your Personal Data
We collect and process only the data which is needed for certain purposes and according to the legal grounds provided by the law.
We may process Your Personal Data or in order to take steps at the request of the data subject (You) prior to entering into a contract. (legal basis: GDPR (General Data Protection Regulation) Article 6-1-(b)).
We will ask You to provide Us Your name, email, mobile phone, Company name and Your role (business owner, HR, etc.) during the submission of the “Request a Demo” form.
We will use Your name, and email to provide You with the reply to Your request in cases, when You send Us the requests through the “Request a Demo” form at the Website.
We will also use Your telephone number to reach You out for the Demo schedule and communicate on the related details.
Also We need Your role and Company name in order to provide You with the relevant and appropriate information depending on Your potential status – corporate client or supplier.
We will ask You to provide Your name and email address when You send Us the requests through the “Contact Us” form at the Website.
We will use Your name and email address to provide You with the response to Your request.
The processing based on Our legitimate interest
We may process Your Personal Data based on Our legitimate interest (legal basis: GDPR Article 6-1-(f)).
We use Automatically collected data for analytical purposes, so that We can understand what categories of users are the most interested in Our services and develop or improve Our services, and improve usability of Our Website, taking into account such information. All of these reasons constitute Our legitimate interest.
Please note that such processing of Your Personal Data will not harm any of Your rights and interests and We will not use Your Data for any other purposes.
If We process Your Personal Data on the basis of Our legitimate interest, We will consider and balance any potential impact on You and Your rights under data protection and any other relevant law.
The processing based on Your consent
In certain specific situations We may process Your Personal Data based on Your consent (legal basis: GDPR Article 6-1-(a)).
During the submission of Personal Data using the “Request a Demo” and “Contact Us” forms You may give Us Your consent on using Your Personal Data to send You emails with newsletters and other marketing materials regarding Clearmove products, services, and events. You can withdraw this consent anytime using the “Contact Us” form, unsubscribe button in the emails, or simply contact Us via email firstname.lastname@example.org.
3. How We collect Your Personal Data
We receive data directly from You when You submit the “Request a Demo” and “Contact Us” forms through the Website.
Certain categories of data as described above are collected automatically during Your usage of the Website.
We may collect information about You from publicly available resources (for example, Linkedin) and/or the other third parties, only in case they are legally allowed to share such information with Us.
4. Withdrawing Your consent
If We collect and process Your Personal Data under Your consent as a legal basis, You can withdraw Your consent at any time. In order to do this You can use the “Contact Us” form, unsubscribe button in the emails We send You, or by simply contacting Us via email email@example.com.
In case of withdrawal We will stop processing Your Personal Data subject to such consent. But in case We are required to retain Your Personal Data for legal reasons Your Personal Data will be restricted from further processing and only retained for the term required by law.
Please note that withdrawing Your consent will not affect the lawfulness of any processing activities We conducted prior to Your withdrawal. And We still can process Your Personal Information on legal grounds other than consent.
5. How We use and share Your Personal Data
We disclose Your Personal Data to the third parties when We are obliged by law or other applicable legislation.
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose information about You to government or law enforcement officials only if it is necessary or appropriate to respond to claims and legal process, at the request of governmental authorities or other third parties conducting an investigation, to protect the property and rights of Us or a third party, to protect the safety of the public or any person, or to prevent or stop activity We may consider to be illegal, fraudulent or unethical. We are entitled to share Your Personal Data for such purposes under the clause 6.1.c) of GDPR.
We will share some categories of Your Personal Data (which will include Your name and email) with the marketing automation services (such as MailChimp), when We make automated mailing. The list with Our Sub-processors is available here – Our sub-processors.
We may share Your Personal Data with Our affiliates – related to Us legal entities, which are ruled by the same management as We and/or have the same owners.
Please note that Your Personal Data is also being processed by Our hosting provider Amazon Web Services (AWS).
6. How We store Your Personal Data
Your Personal Data is hosted on servers provided by Amazon Web Services. The AWS infrastructure puts strong safeguards in place to protect Your Personal Data. All data is stored in highly secure AWS data centres.
The following is a partial list of assurance programs with which AWS complies:
- SOC 1/ISAE 3402, SOC 2, SOC 3
- FISMA, DIACAP, and FedRAMP
- PCI DSS Level 1
- ISO 9001, ISO 27001, ISO 27017, ISO 27018.
7. How We protect Your Personal Data
To protect Your Personal Data from unauthorized access, unlawful processing or disclosure, accidental loss, modification or destruction, We use appropriate technical and organizational measures.
We implemented encryption during the processing of Your Personal Data to ensure security.
Transfers of Your data are encrypted via SSL. SSL is an industry standard which establishes an encrypted link between a web server and a browser. We also use HTTPS strict transport security to add an additional layer of protection.
We use the industry standard AES-256 encryption algorithm to encrypt Your Personal Data stored in the database. This means that Your Personal Data is encrypted before and after accessing the database and never lies there in plain text.
We also apply pseudonymisation with unique identification keys during processing Your Personal Data, as required under GDPR, Article 4(5).
We work with Your Personal Data under the principle of strict access role distribution. The list of those, who have access to Your Personal Data is strictly limited and grounds on a need-to-know basis.
8. Retention period
However, if We are required by law or any mandatory regulation to retain Your Personal Data longer or if We need Personal Data to assert or defend against legal claims, We will retain Your Personal Data until the end of the relevant retention period or until the claims in question have been settled.
9. Your rights
You have the following privacy rights related to Your Personal Data processing:
- Right to be informed
This right means that You can get the information from Us of how We use Your Personal Data.
- Right to access
This right entitles You to verify the Personal Data held by Us, get informed on the ways it is used and the purposes of the processing.
- Right to rectification
You can edit Your Personal Data submitted to Us.
- Right to erasure, “right to be forgotten”
This right means that You can request the removal of Your Personal Data, We hold and process, but please pay attention that We can delete Your Personal Data only if there is no legal or regulatory obligation to retain it.
- Right to restriction of processing
This right means that You can ask Us to stop processing Your Personal Data.
- Right to object and right to withdraw consent
You can refuse to receive newsletters and other marketing materials on Your email. In order to do it You can use the “Contact Us” form, unsubscribe button in the emails, or simply contact Us via email firstname.lastname@example.org.
- Right of data portability
This right means that You can ask Us to transmit Your Personal Data to another data controller.
11. Contact details