1. Important notice
You have the right to object to us processing your personal data for our legitimate business interests or for direct marketing purposes (including any related profiling).
2. Data Protection Rights for You
You have the following rights under GDPR:
• You have the right to be informed on the personal data Clear Pathway processes on you and how they use it.
• You have right of access to the personal data Clear Pathway processes on you.
• You have the right to rectification of your personal data.
• You have the right to erasure of your personal data in certain circumstances.
• You have the right to restrict processing of your personal data.
• You have the right to data Portability in certain circumstances
• You have the right to object to the processing of your personal data that was based on public or legitimate interest.
• You have the right not to be subjected to automated decision making and profiling.
• You have the right to withdraw consent at any time.
3. Personal Data we may collect and why
Personal data is any information which identifies you personally whether directly (for example, your name) or indirectly (for example, information about your use of our products and services).
We may collect the following data about you:
• Contact details: your name, email address, and telephone number so that we can contact you in response to an enquiry you make, or in relation to the products and services that we have from time to time agreed to provide to you;
• Correspondence: we collect any additional personal data you may provide to us from time to time if you contact us by email, letter or telephone.
4. How we use your personal data
We use your personal data for the following purposes:
To provide you with the products and services you have requested
We use your personal data to accept you as a new or returning customer to provide you with the products and services you have requested in accordance with the Trading Terms or Terms of Trading.
To send you service communications, including in relation to changes to our Trading Terms or Terms of Trading
We use the contact details you have provided to us so that we can communicate with you about the products and services that we provide, including to let you know about major changes to those products and services or to the Trading Terms or Terms of Trading between us or to any related information.
Direct marketing (including by third parties)
If you have provided your consent or we otherwise have the right to do so, we may use your contact details to send you direct marketing and keep you informed of promotional offers by email, SMS, post or telephone relating to our products and services.
You can unsubscribe from our direct marketing at any time by clicking the “Unsubscribe” link in any of our emails or by contacting us.
Our trusted business partners would also like to use your name, email address, postal address and telephone number to inform you of similar products, services and promotional offers. We will only share your personal data with our partners where you have provided us with your consent to do so. You can unsubscribe at any time by clicking the “Unsubscribe” link in any of their emails or by contacting us.
To track your usage of our website, communications, products and services
To provide and improve customer support
We use your personal data to be able to provide and improve the customer support we provide to you (for example, where you have questions about our products and services).
To maintain our records and improve data accuracy
Like any business, we process personal data in the course of maintaining and administering our internal records. This includes processing your personal data to ensure that the information we hold about you is kept up to date and accurate.
To respond to enquiries, complaints and disputes
We use the personal data we hold about you to help us respond to any enquiries or complaints you have made, or deal with any dispute which may arise in the course of us providing our products and services to you, in the most effective manner.
To investigate, detect and prevent fraud and comply with our legal obligations
In certain circumstances, we use your personal data only to the extent required in order to enable us to comply with our legal obligations, including for fraud detection, investigation and prevention purposes. This may require us to provide your personal data to law enforcement agencies if they request it.
5. Access and Update your Personal Data
Individuals can establish what personal data is held by Clear Pathway by making a “Subject Access Request” under General Data Protection Regulation (GDPR). If we do hold information about you, we will give you the following information:
• Clear Pathway will give you a description of it.
• Clear Pathway will tell you the reason for holding the information.
• Clear Pathway will tell you who it could be disclosed to and why.
• Clear Pathway will let you have a copy of the information.
In order to make an access request to Clear Pathway for any information that we hold, please contact Gary Brown on 07765 402145 or email clearpathwayconsultants.co.uk.
Any information we hold about you at Clear Pathway you can ask for it to be corrected, updated, amended or you can ask for it to be removed.
6. Legal grounds for processing
Data protection law requires us to only process your personal data if we satisfy one or more legal grounds. These are set out in data protection law and we rely on a number of different grounds for the processing we carry out.
These are as follows:
In certain circumstances, we process your personal data after obtaining your consent to do so for the purposes of:
• sending you marketing communications about our products and services;
• sharing your name, email address, postal address and telephone number with our trusted business partners so that they may market to you about their own similar products and services;
• conducting marketing research;
• obtaining your credit score so that we can establish the best possible payment terms we are able to offer to you.
Necessary for the performance of a contract and to comply with our legal obligations
It is necessary for us to process your basic contact details, payment details and information about the business you represent for the performance of the Trading Terms or Terms of Trading between us. In particular, we rely on this legal ground to:
• provide you with the products and services;
• communicate with you about the products and services that we provide to you, including to let you know about major changes to those products and services or to the Trading Terms or Terms of Trading between us or to any related information;
• provide and improve customer support; and
• notify you about changes to our service
If you choose not to give some or all of the aforementioned information to us, this may affect our ability to provide our products and services to you.
In certain circumstances, we also use your personal data only to the extent required in order to enable us to comply with our legal obligations, including to detect, investigate and prevent fraud.
Necessary for the purposes of our legitimate business interests or those of a third party
It is sometimes necessary to collect and use your personal data for the purposes of our legitimate interests as a business, which are to:
• provide you with products and services that are as useful and beneficial as possible, including by personalising our contact with you and making sure we tell you about all the offers that are relevant to you;
• better understand our customer base so that we can improve our products and services and marketing activities (which could also benefit you);
• comply with our contractual obligations to third parties;
• develop and improve our Site to enhance the customer experience;
• train our staff so that we can provide you with a better customer service;
• respond to any enquiries or complaints you have made, or deal with any dispute which may arise in the course of us providing our products and services to you; and
• to ensure that content from our Site is presented in the most effective manner for you and for your computer;
• ensure effective operational management and internal administration of our business, document retention, compliance with regulatory guidance and exercise or defence of legal claims.
Where we think there is a risk that one of your interests or fundamental rights and freedoms may be affected we will not process your personal data unless there is another legal ground for us to do so (either that we have obtained your consent to the processing or it is necessary for us to perform our contract with you or to comply with our legal obligations).
7. Who we share your personal data with
We may provide your personal data to our suppliers and service providers, including other companies in our group, who provide certain business services for us and act as “processors” of your personal data on our behalf. In addition, we may disclose your personal data if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to protect the rights, property, or safety, of our business, our customers or others. This includes, in specific cases, exchanging information with other organisations for the purposes of fraud protection.
8. How long we keep your personal data for
We retain your personal data for no longer than is necessary for the purposes(s) for which it was provided. What this means in practice will vary between different types of data. When determining the relevant retention periods, we take into account factors including:
• legal obligation(s) under applicable law to retain data for a certain period of time;
• statute of limitations under applicable law;
• potential or actual disputes; and guidelines issued by relevant data protection authorities
Otherwise, we securely erase your personal data from our systems when it is no longer needed.
9. Opting Out
You may opt out of receiving promotional communications from Clear Pathway by using the unsubscribe option within each email, or emailing us to have your contact information removed from our marketing, mailing, email or database.
Any opt out requests are usually processed immediately, please allow 10 business days for a removal request to be processed. Even after you opt out from receiving promotional messages from us, you may continue to receive transactional messages from us regarding Clear Pathway services.
10. How to contact us
If you would like to exercise your data protection rights or if you are unhappy with how we have handled your personal data, please feel free to contact us by using the details set out on our Site.
If you’re not satisfied with our response to any enquiries or complaint or believe our processing of your personal data does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) by:
• writing to: Information Commissioner’s Officer, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF;
• calling: 0303 123 1113; or
• submitting a message through the ICO’s website at: ico.org.uk
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