Privacy Policy

Last Updated: 12th January 2025

Cleracomms (“We,” “Us,” “Our”) is committed to protecting Your personal data and respecting Your privacy. This Privacy Policy explains how We collect, use, and protect Your personal data when You use Our website and services (“Service”). It also outlines Your rights under applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR).

By using Our Service, You agree to the practices described in this Privacy Policy. If You do not agree with this policy, please refrain from using Our Service.

If You have any questions or concerns about this policy or how We handle Your personal data, You can contact Us at [email protected]

Interpretation and Definitions

Interpretation

Words in this Privacy Policy with initial capital letters have specific meanings as defined below. These definitions apply whether the words appear in singular or plural form.

Definitions

Account — A unique account created for You to access parts of the Website or to use Our Services.

Company — Refers to Lewis Gray T/A Cleracomms, 44 The Butts, Westbury, Wiltshire, BA13 3EX. For the purposes of the UK GDPR, the Company acts as the Data Controller.

Cookies — Small files placed on Your Device by a website, containing information about Your browsing activity or preferences.

Country — Refers to the United Kingdom.

Data Controller — The legal entity (in this case, the Company) that determines the purposes and means of processing Personal Data under the UK GDPR.

Device — Any device capable of accessing the Website, such as a computer, smartphone, or tablet.

Personal Data — Any information relating to an identified or identifiable individual, including, but not limited to, a name, identification number, location data, online identifier, or factors specific to physical, physiological, genetic, mental, economic, cultural, or social identity.

Service — Refers to the business activities, offerings, and professional services provided by the Company. These may include communication, consulting, design, technical support, and other services as agreed upon between You and the Company.

Service Providers — Third-party organisations or individuals engaged by the Company to facilitate or provide elements of the Services, analyse their use, or assist in other related activities. These providers act as Data Processors under the UK GDPR.

Usage Data — Information collected automatically through the use of the Website or Services. This may include details such as Your Device’s Internet Protocol (IP) address, browser type, browser version, the pages You visit on the Website, the time and date of Your visit, the time spent on those pages, unique device identifiers, diagnostic data, and information about how You interact with Our Services, including the type of Device used and its configuration.

Website — Refers to Cleracomms’ website, accessible from https://cleracomms.com

You — Refers to the individual accessing or using the Service, or the legal entity on behalf of which such an individual accesses the Service. Under the UK GDPR, You may also be referred to as the Data Subject.

Collecting and Using Your Personal Data

We collect and use Your Personal Data to provide, improve, and maintain Our Website and Services. This section explains the types of data We collect, how We use it, and why.

Personal Data

While using Our Website or Services, We may ask You to provide certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email Address.
• First Name and Last Name.
• Phone Number.
• Postal Address, including Country, City, County, and Postal code.
• Bank account information, where necessary, to process payments for products and/or services.

To facilitate payments or verify Your identity for certain transactions, We may also request:

• Date of Birth.
• Passport or National ID card.
• Bank Statement.
• Proof of Address or other documents linking You to an address.

Usage Data

We automatically collect Usage Data when You use Our Website or Services. This data may include:

• Your Device’s Internet Protocol (IP) address, browser type, and browser version.
• The pages of Our Website You visit, the time and date of Your visit, and the time spent on those pages.
• Diagnostic data, such as error reports or performance metrics.
• Device-specific details, including operating system, unique device identifiers, and configurations.

Cookies and Tracking Technologies

We use Cookies and similar tracking technologies to monitor activity on Our Website and Services, enhance Your user experience, and collect information about how You interact with Us.

Cookies are small files placed on Your Device that may include an anonymous unique identifier. The types of tracking technologies We use include Cookies, Flash Cookies, and Web Beacons.

Browser Cookies

These are small text files stored on Your Device when You visit Our Website. Browser Cookies can be “Persistent” or “Session” Cookies:

• Persistent Cookies — Remain on Your Device even after You close Your browser and are used to remember Your preferences or activities for future visits.
• Session Cookies — Are temporary and deleted as soon as You close Your browser.

Flash Cookies

Certain features of Our Services may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or activity on Our Website. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies.

To learn more about disabling or deleting Flash Cookies, visit: https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_.

Web Beacons

Certain sections of Our Website and emails may contain small electronic files known as Web Beacons (also referred to as clear gifs, pixel tags, or single-pixel gifs). Web Beacons allow Us, for example, to:

• Count users who have visited specific pages.
• Track whether emails have been opened.
• Monitor the popularity of certain content.
• Verify the integrity of Our systems and servers.

Categories of Cookies We Use

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are critical to provide the Website and its features, such as user authentication and fraud prevention. Without these Cookies, the services You request cannot be delivered.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies track whether You have accepted the use of Cookies on Our Website.

Functionality Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies store Your preferences (e.g., login details, language settings) to provide a more personalised experience and prevent You from re-entering information repeatedly.

Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies track traffic and usage patterns on Our Website, allowing Us to understand visitor behaviour. The data collected may include pseudonymous identifiers linked to Your Device. We may also use these Cookies to test new features or pages and evaluate user responses.

Managing Cookies

When You first visit Our Website, You will see a cookie banner that informs You about Our use of Cookies and provides the option to manage Your preferences. You can accept all Cookies, decline non-essential Cookies, or customise Your choices.

You can also manage Cookies at any time by adjusting Your browser settings to refuse or delete certain Cookies. Please note that disabling Cookies through Your browser or declining them via the cookie banner may impact the functionality of some features on Our Website and Services.

Use of Your Personal Data

The Company may use Your Personal Data for the following purposes:

To Provide and Maintain Our Website and Services

• Ensuring functionality, availability, and accessibility.
• Monitoring usage patterns to improve performance.

To Manage Your Account

• Handling Your registration as a user of the Website or Services.
• Providing access to features available to registered users.

For the Performance of a Contract

• Developing, fulfilling, and managing purchase contracts for products, items, or services You have requested.

To Contact You

• Communicating via email, phone calls, SMS, or other electronic means regarding updates, functionalities, security issues, or service-related information.
• Sending push notifications or messages via mobile applications, if applicable.

To Send Marketing and Promotional Content

• Providing You with news, special offers, and general information about similar goods, services, or events unless You opt out.

To Manage Your Requests

• Attending to and resolving Your enquiries, requests, or complaints.

For Business Transfers

• Evaluating or conducting a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of Our assets. Personal Data may be part of the assets transferred.

For Data Analysis and Service Improvement

• Analysing usage trends to enhance the quality of Our Website, Services, and marketing efforts.
• Determining the effectiveness of promotional campaigns.

For Other Legitimate Business Purposes

• Using data for compatible purposes, such as research or operational improvements, where legally permissible.

Sharing Your Personal Data

We may share Your Personal Data in the following situations:

• With Service Providers — To facilitate service delivery, payment processing, and customer support.
• For Business Transfers — During mergers, acquisitions, or other business transitions.
• With Affiliates — Including parent companies, subsidiaries, or joint ventures, under the condition that they honour this Privacy Policy.
• With Business Partners — To offer products, services, or promotions in collaboration with trusted partners.
• With Other Users — When You share information in public areas of the Website, it may become publicly visible.
• With Your Consent — For any additional purposes with Your explicit approval.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy. The specific retention periods depend on:

• Legal and Regulatory Obligations — Retention required to comply with laws, such as tax, accounting, or other statutory requirements.
• Contractual Commitments — Data retained to fulfil the terms of a contract between You and the Company.
• Legitimate Business Purposes — Retention to address disputes, enforce agreements, or ensure the security of Our operations.

After the relevant retention period expires, Your Personal Data will either be securely deleted or anonymised so it can no longer be associated with You.

Retention of Usage Data

Usage Data is retained for a shorter period, unless it is used to:

• Improve the functionality of Our Website and Services.
• Strengthen security measures.
• Comply with legal obligations requiring longer retention.

Transfer of Your Personal Data

Your information, including Personal Data, may be processed at the Company’s operating offices and other locations where the parties involved in data processing are based. This may include transfers to and storage on systems outside Your country, region, or jurisdiction, where data protection laws may differ.

International Transfers

When transferring Personal Data outside the United Kingdom or European Economic Area (EEA), the Company ensures that adequate safeguards are in place to protect Your information.

These measures may include:

• Standard Contractual Clauses (SCCs) — Approved by the UK Information Commissioner’s Office or European Commission for cross-border data transfers.
• Adequacy Decisions — Transfers to countries deemed by authorities to provide an adequate level of data protection.

By using Our Website or Services and providing Your Personal Data, You acknowledge and agree to these transfers.

Our Commitment to Secure Transfers

The Company will take all reasonable steps to ensure Your data is treated securely and in compliance with this Privacy Policy. Transfers will not occur unless adequate protections, including data security and privacy safeguards, are implemented.

Disclosure of Your Personal Data

We may disclose Your Personal Data under the following circumstances:

Business Transactions

If the Company is involved in a merger, acquisition, restructuring, or sale of assets, Your Personal Data may be transferred as part of that transaction. We will notify You before any transfer occurs and Your data becomes subject to a different Privacy Policy.

Legal and Regulatory Obligations

We may disclose Your Personal Data if required to do so by law or in response to valid requests from public authorities, such as courts, law enforcement agencies, or regulatory bodies.

To Protect Rights and Prevent Harm

We may disclose Your Personal Data in good faith when such action is necessary to:

• Comply with legal obligations or respond to legal claims.
• Protect and defend the rights, property, or safety of the Company, its users, or the public.
• Prevent, investigate, or address suspected fraud, security breaches, or other misconduct.
• Mitigate legal liability.

Tracking Technologies and Cookies

Certain information, including Usage Data, may be shared with third-party providers through Cookies and similar technologies, as described in the “Cookies and Tracking Technologies” section of this Privacy Policy.

Security of Your Personal Data

We are committed to protecting Your Personal Data and take commercially reasonable measures to safeguard it. These measures include:

• Using encryption to protect data during transmission.
• Implementing access controls to restrict data access to authorised personnel only.
• Regularly monitoring Our systems for vulnerabilities and conducting risk assessments.

However, no method of transmission over the Internet or electronic storage is 100% secure. While We strive to use industry-standard practices to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process, and transfer information about Your activity on Our Website and Services in accordance with their respective privacy policies.

Affinity Suite

• Affinity Suite provides tools for graphic design, photo editing, and publishing.
• Privacy Policy: https://affinity.serif.com/privacy

Apple

• Apple provides devices and related services used for accessing and storing data.
• Privacy Policy: https://www.apple.com/legal/privacy

Canva

• Canva is a visual design platform used to create graphics and marketing materials.
• Privacy Policy: https://www.canva.com/policies/privacy-policy

ChatGPT (OpenAI)

• ChatGPT is an AI-based tool used for generating content and answering questions.
• Privacy Policy: https://openai.com/privacy

Facebook

• Facebook is a social media platform used for advertising and marketing purposes, including audience targeting and engagement tracking.
• Privacy Policy: https://www.facebook.com/policy.php

Fireflies AI

• Fireflies AI is a tool for transcribing meetings and generating notes.
• Privacy Policy: https://fireflies.ai/privacy

FreeAgent

• FreeAgent is an accounting software used to manage invoices, payments, and financial records.
• Privacy Policy: https://www.freeagent.com/privacy/

GoHighLevel

• GoHighLevel is a Client Relationship Management (CRM) system used for managing client communications and relationships.
• Privacy Policy: https://www.gohighlevel.com/privacy-policy

Google Analytics

• Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of Our Website and Services, and may share it with other Google services.
• Privacy Policy: https://policies.google.com/privacy

Google Workspace

• Google Workspace includes email, document management, and cloud storage tools used for productivity and collaboration.
• Privacy Policy: https://policies.google.com/privacy

LinkedIn

• LinkedIn is a professional networking platform used for advertising, marketing, and client engagement.
• Privacy Policy: https://www.linkedin.com/legal/privacy-policy

Mailgun

• Mailgun is an email marketing and transactional email service used to send and manage email communications.
• Privacy Policy: https://www.mailgun.com/legal/privacy-policy/

Make.com

• Make.com is an automation platform that connects and streamlines workflows across different applications.
• Privacy Policy: https://www.make.com/en/privacy-notice

Proton

• Proton is a secure email service used for business communication and productivity.
• Privacy Policy: https://proton.me/legal/privacy

Remote HelpDesk

• Remote HelpDesk provides IT support services for resolving technical issues.
• Privacy Policy: https://www.remotedesktop.com/privacy_policy.htm

Rev

• Rev provides transcription and captioning services to enhance accessibility.
• Privacy Policy: https://www.rev.com/legal/privacy

Signal

• Signal is a secure communication platform used for private messaging.
• Privacy Policy: https://signal.org/legal/

WhatsApp

• WhatsApp is a messaging service used for secure communication with clients.
• Privacy Policy: https://www.whatsapp.com/legal/privacy-policy

Processing Payments

We use third-party payment processors to securely process payments made for Our products or Services. These payment processors handle Your payment information in accordance with their privacy policies and adhere to industry standards such as PCI-DSS (Payment Card Industry Data Security Standard) for secure processing.

GoCardless

• GoCardless facilitates direct debit payments and subscription billing.
• Privacy Policy: https://gocardless.com/privacy

Stripe

• Stripe is a payment processing platform for handling online transactions.
• Privacy Policy: https://stripe.com/privacy

We do not store or collect Your payment card details. Any payment information You provide is processed directly by these providers.

GDPR Privacy

Legal Basis for Processing Personal Data

We may process Your Personal Data under the following legal bases:

• Consent — You have provided explicit consent for processing Your Personal Data for one or more specific purposes.
• Performance of a Contract — Processing is necessary to fulfil a contract with You or to take pre-contractual steps at Your request.
• Legal Obligations — Processing is necessary for compliance with a legal obligation to which the Company is subject.
• Vital Interests — Processing is necessary to protect Your vital interests or those of another natural person.
• Public Interest — Processing is related to a task carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate Interests — Processing is necessary for purposes related to the legitimate interests pursued by the Company or a third party, provided that these do not override Your rights and freedoms.

If You have questions about the legal basis for processing specific data, or if the provision of Personal Data is a statutory or contractual requirement, please contact Us for clarification.

Your Rights under GDPR

The Company is committed to protecting Your rights under GDPR. You have the right to:

• Access Your Personal Data — Request a copy of the information We hold about You and verify how it is processed.
• Correct Inaccurate Data — Request corrections to any incomplete or inaccurate data We hold.
• Object to Processing — Object to processing based on legitimate interests, including for direct marketing purposes.
• Request Erasure (“Right to be Forgotten”) — Request deletion of Your Personal Data when it is no longer necessary for the purposes it was collected, or if You withdraw Your consent.
• Request Data Portability — Request that Your Personal Data be transferred to You or another service provider in a structured, machine-readable format.
• Withdraw Consent — Withdraw consent where processing is based on Your consent. Note that withdrawal does not affect the lawfulness of prior processing.

Exercising Your GDPR Data Protection Rights

To exercise any of these rights, contact Us at [email protected].

We may require verification of Your identity before fulfilling Your request. If You are not satisfied with Our response, You have the right to lodge a complaint with a Data Protection Authority, such as the UK Information Commissioner’s Office (ICO).

Children’s Privacy

Our Website and Services are not intended for individuals under the age of 13. We do not knowingly collect Personal Data from anyone under 13 without parental consent.

If You are a parent or guardian and become aware that Your child has provided Us with Personal Data, please contact Us at [email protected]. Upon verification, We will take steps to delete the data.

If Your country requires parental consent for processing Personal Data, We may request such consent before collecting or using the information.

Links to Other Websites

Our Website may include links to external websites that are not operated by the Company. We strongly encourage You to review the Privacy Policy of any third-party site You visit, as We are not responsible for their content, privacy practices, or services.

Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in Our practices, services, or legal obligations.

Any changes will be posted on this page, with the “Last Updated” date revised. For significant updates, We will notify You via email and/or a prominent notice on Our Website before the changes take effect.

We recommend reviewing this Privacy Policy regularly to stay informed about how We protect Your Personal Data.

Contact Us

If You have any questions, concerns, or requests regarding this Privacy Policy, please contact Us at: [email protected]