Privacy Notice

Reference	GDPR.PN.5.3
Issue No	4
Issue Date	29/05/2020

1. Scope
At Clekt we are committed to protecting and respecting your privacy.

This privacy notice explains when and why we collect personal information about people who visit our website, how we use it, the conditions in which you share your information and how we keep it secure.

This privacy notice may change from time to time in line with our privacy policy so please check the page occasionally to ensure that you are happy with any changes. By using the website, you are bound by this policy.

2. Responsibilities

• 2.1. Clekt is committed to abiding by GDPR and PECR regulations when it comes to protecting your privacy and personal information. As a controller of your data, our responsibilities are clearly set out by the GDPR and assigns Clekt with responsibility to decide what your personal information is used for, and the ways in which it is processed.
  GDPR – (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/)
  PECR – https://ico.org.uk/for-organisations/guide-to-pecr/what-are-pecr/
• 2.2. Clekt is responsible for maintaining and updating our Privacy Notice to reflect changes to regulations or legislation relating to processing personal data.
• 2.3. PECR guidelines provide a regulatory framework that guides how we contact you via electronic means.
• 2.4. Under GDPR, Clekt is the data owner and is responsible for ensuring that this notice is made available, you can contact us via infosecurity@clekt.co.uk

3. The purpose of processing of your data

Personal data:	Source:
What information is being collected?	Personal information collected through the contact form: including First name, Last name, Work Email, Telephone and Company. We may obtain other information about your computer, which includes your IP address, browser type and operating system. This data is accumulated to assist the system administrator as to the activity of the site. This data does not provide any personally identifiable information about you.
How is it collected?	Personal information is collected when you choose to contact us to find out more about the services that we offer. By completing the contact form, you are providing us with consent under legitimate interest, to use the data to provide you with more information on the services that we offer. We also collect data, using cookies and other tracking technology, to understand how our visitors navigate through our site so that we can adjust the site to enhance the experience.
Why is it being collected?	Your personal information is being collected so that we can respond to your information request and provide you with a service. Other information is collected to understand the traffic through our website. This is not personally identifiable information about you.
How will it be used?	The personal information that you provide will only be used for keeping in touch and responding to requests you make via the contact form.
Who it will be shared with	Personally, identifiable information will not be shared with any 3rd party, unless required by law or order of the court, to fulfil legal obligations, to enforce terms and conditions, or to protect the property, rights of the safety of Clekt limited users, our services or others. Our data processors will have access to your data in accordance with our policy framework.
The legal basis for processing	The legal basis for processing the personally identifiable information is through legitimate interest. A legitimate interest assessment has been completed.

4. Consent
When filling out the contact form you are consenting under legitimate interest for us to contact you regarding your request.

By consenting to this privacy notice at the point of sending your contact information you are giving us permission to process your personal data specifically for the purposes identified.

For presale activities, we will keep your data for up to two years, including email and telephone numbers.

5. Disclosure
By agreeing to our terms and condition of data collection you are agreeing to permit your data to be processed by our approved third-party partners. These parties will receive your personal data for the following purpose as part of the processing activities:

• 5.1. When you contact us to make requests for follow up actions, this correspondence will be recorded in our email service, the privacy policy can be found at https://privacy.microsoft.com/en-gb/privacystatement
• 5.2. When you contact us to make requests for follow up actions the correspondents will also be recorded on our Hubspot CRM, Hubspot allows us to track the legal reason for tracking your data. In the case that it is from your interest in the website, it shall be noted as ‘legitimate interest’. You will be able to opt-out of emails at any point and Hubspot will notify us of that.
• 5.3. With an organisation, we are running a joint event with, where you have opted in to register for the event.
• 5.4. With our external web developers and designers to assist us in improving the functionality of the site.
• 5.5. With any actual or prospective buyer of our business or assets.
• 5.6. As required by law or order of the court, to fulfil legal obligations, to enforce terms and conditions, or to protect the property, rights of the safety of Clekt limited users, our services or others.

6. Your rights as a data subject

• • 6.1. At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
    • 6.1.1. The right of access – you have the right to request a copy of the information that we hold about you.
    • 6.1.2. Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
    • 6.1.3. Right to be forgotten – in certain circumstances, you can ask for the data we hold about you to be erased from our records.
    • 6.1.4. Right to the restriction of processing – where certain conditions apply to have a right to restrict the processing.
    • 6.1.5. The right of portability – you have the right to have the data we hold about you transferred to another organisation.
    • 6.1.6. Right to object – you have the right to object to certain types of processing such as direct marketing.
    • 6.1.7. Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
    • 6.1.8. Right to judicial review: if Clekt refuses your request for rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in below.

Requests may also be validly made by means of social media (Twitter, LinkedIn or Instagram); please refer to the Subject access code of practice https://ico.org.uk/media/for-organisations/documents/2014223/subject-access-code-of-practice.pdffor guidance on this. We will respond to your subject access request within one month of receiving the request.

This procedure was approved by the Security Officer on 29/05/2020 and is issued on a version-controlled basis under her signature. The privacy notice is subject to change so please ensure you check regularly.