Privacy

ClearPeople Ltd is a full service digital agency and consultancy with offices in London and Spain. We aim to respect your privacy and are committed to protecting the confidentiality of your personal information. Our aim is to be as clear and open as possible about what we do and why, which is why we go in-depth below to explain what we collect, send and use your data for and what your rights are. By using our services, you agree to the use of the data that we collect in accordance with this Privacy Policy.

Our Compliance Officer is Jeffrey Cosper 
Email: theconsultagents@clearpeople.com 

We are committed to protecting your privacy

This Policy indicates the type of processes that may result in data being collected about you. Your use of this website gives us the right to collect that information.

Why we process your personal data

We process your personal data primarily on the basis of Legitimate Interest as a business but only if necessary for the purpose we collected it for. We will also process data on the basis of contractual and transactional obligation where necessary. We may process your data for;
  • Sales and marketing activities such as calls, emails and other types of communications
  • Understanding how you interact with the website and social media
  • Account activity such as, email, written and verbal communications and agreements
  • Financial activity, such as billing communications
  • To perform obligations under a contract with you or a business you may work for
  • We will only store your data, for as long as we need it to undertake any of the processes listed above.

How we collect information about you

a. About You: When you sign up for and use the website or Service, consult with our team, send us an email, post on our blog, or communicate with us in any way, you are voluntarily giving us information that we collect.

That information may include either your or your Contacts name, physical business address, email address, IP address, phone number, as well as details including occupation, location, history, and other demographic information. By giving us this information, you agree to this information being collected, used, disclosed, transferred within the United Kingdom (to our data storage centre in Ireland) and stored by us.

b. Automatically: When you browse our website or use or Service, we may collect information about your visit to our website, your usage of the Service, and your web browsing. That information may include your IP address, your operating system, your browser ID, your browsing activity, and other information about how you interacted with our website or Service. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies. Our use of cookies and other tracking technologies is discussed more below.

To ensure our prospects and clients receive the most relevant communications, we use some automated processes to send you communications. These processes (such as lead scoring and marketing based on behaviour), might indicate what the contents of a marketing email may be, or indicate to us when the best time to contact you might be.

c. IP address lookup: We use third parties to provide information about visitors to our websites. When you visit our website we will record your IP address. This address will be matched against public and proprietary IP address databases to provide us with information about your visit. This information may identify the organisation to whom the IP address is registered but not individuals. In some limited cases i.e. single person companies, it may be possible to identify personal data from publicly available ICANN data.

d. Cookies, tracking & beacons: We may use various technologies to collect and store information when you use our website or Service, and this may include using cookies and similar tracking technologies, such as pixels and web beacons, to analyse trends, administer the website, track users’ movements around the website and Service, serve targeted advertisements, and gather demographic information about our user base as a whole.

e. Cookies/tracking: Cookies allow us to provide important site functionality, so you don’t have to re-enter lots of information. They also allow us to remember what links and pages have been clicked or viewed during a session. If you have provided us with personal data, completing a contact form for example, we may associate this personal data with other information. This will allow us to identify and record what is most relevant to you. By using your browser controls, you are always in control of the cookies we store and access on your computer. More information on how to control cookies and limit personal data processing can be found at youronlinechoices.com/uk/five-top-tips. For comprehensive information on how to change your cookie settings in a wide variety of different web browsers, visit www.aboutcookies.org.

ClearPeople’s main cookies

Google Analytics Cookies: Google Analytics is a website monitoring tool that allows users to see volumes of website visitors, their source, and to analyse how the content of their website is viewed and navigated. This in turn allows optimisation of the content and pages and the marketing programs that drive traffic to the website. Google Analytics does not store any personal information about website visitors, but does use persistent cookies to identify repeat visitors. You may universally opt-out of all Google Analytics tracking used by all websites by visiting the following url – https://tools.google.com/dlpage/gaoptout

GatorLeads Cookies: GatorLeads is a tool that identifies the business or organisation that website visitors belong to, based on a reverse IP Lookup. GatorLeads also use cookies to process this identification, and personal information about individual users is stored. Cookies used by GatorLeads store information about your current web browsing session (pages viewed, time on site etc) and the dates and times of previous website visits.

This information is used by ClearPeople to profile website visitors, in order to better understand the way in which our website content is viewed by different segments. It is also used, for example, to identify the types of organisations that might be interested in attending our Best Practice Seminars.
 
Email Marketing Post-Click Tracking Cookies: These cookies are used to report on the pages that have been viewed by visitors to the site who have followed links from our email marketing campaigns. This analysis helps us to understand additional content that is viewed by the contacts in our database and therefore allows us to improve and tailor future campaigns to those contact’s specific areas of interest.

Beacons/Pixels: On our website and in our emails we use web beacons. When we send emails to Customers, we may track behaviour such as who opened the emails, who clicked the links and which pages of our website they have visited.

This allows us to measure the performance of our email campaigns and to improve our Service and website. To do this, we include single pixel, also called web beacons, in emails we send. Web beacons allow us to collect information about when you open the email, your IP address, your browser or email client type, and other similar details. We also include Web Beacons in the emails we deliver for you. We use the data from those Web Beacons to create reports about how your email campaign performed and what actions your Contacts took. Reports are also available to us when we send email to you, so we may collect and review that information.
 
Data sources: Other than the aforementioned ways of obtaining data (form fills on the website, cookies, verbal and written) we may obtain information about you from third party sources, such as public databases, data service companies, social media platforms, third party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally permitted or required to disclose such information to us.

Examples of the information we may receive from other sources include: demographic information, device information (such as IP addresses), technology usage, location, email address, contact number, technographics, and online behavioural data (such as information about your use of social media websites, page view information, and search results and links). We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products features, and services.
 
Who will see your data: Your data will only be seen and used by employees of ClearPeople. We operate a role-based access policy for personal data. What this means, is that an employee will only have access to personal data, if they need that access to do their job. We do not share the personal data of prospects or clients with any third parties.

How we use your information

We may disclose Personal Information and use personal data acquired from and provided by yourself to fulfil any of your requests and to send you appropriate and useful communications. You should be aware this includes, but not limited to, the types of communications explained in this section.

A copy of our legitimate interests ‘balancing test’ is available on request as part of our commitment to managing your information rights. Please use the details at the start of the page to request this.

We use your data for the following purposes:

a) To promote use of our products and services to you. For example, if we collect your Personal Information when you visit our website and do not sign up for any of the Service, we may send you an email inviting you to sign up or attend an event. If you use any of our Service or website and we think you might benefit from using another part of our Service we offer, we may send you an email about that. You can stop receiving our promotional emails by following the opt-out link included in every email we send.
 
In addition, we may use information we collect in order to advertise our products and/or Services to you or suggest additional features of our Services that you might consider using. In addition, we may use your Personal Information to advertise our Services to potential or other users like you. For more information on how we use cookies or other tracking technologies for these purposes, as well as how to opt out of the use of cookies, please see our Cookie Policy below.

b) To send you informational and promotional content in accordance with your marketing preferences. You can stop receiving our promotional emails by following the opt-out instructions included in every email.
  • Types of communications: By processing your Personal Information under Legitimate Interest, you will receive any specific piece(s) of information you requested, as well as allowing us to send you appropriate and useful communications. This includes but is not limited to; invitations to our industry leading events and webinars, our latest assets (whitepapers, guides, reports, infographics, videos and case studies) and promotional offers on software and services. We would also like to keep you abreast of the charity events and initiatives we partake in. At any you can unsubscribe/opt-out of our marketing by clicking the opt-out link in any emails you receive from us. The link will always be in the footer of the email. If you don’t have an email from us to hand and want to unsubscribe, you can do so now by emailing marketing@clearpeople.com and putting “Unsubscribe” in the subject header.
c) To bill and collect money owed to us by our Customers. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure debit and/or credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments.
 
d) To communicate with our Customers about their account and provide customer support.
 
e) To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
 
f) To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
 
g) To prosecute and defend a court, arbitration, or similar legal proceeding.
 
h) To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements. 

Combined Information: We may combine Personal Information with other information we collect or obtain about you (such as information we source from our third party partners), to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this Privacy Policy. When we combine Personal Information with other information in this way, we treat it as, and apply all of the safeguards in this Privacy Policy applicable to, Personal Information.

Disclosing Information

We do not disclose any personal information obtained about you from this website to third parties except when we need to do so in order to complete the transaction – e.g. when arranging for a courier company to deliver goods that you have ordered. We may also use the information to keep in contact with you and inform you of developments associated with our business. You will be given the opportunity to remove yourself from any mailing list or similar device. If at any time in the future we should wish to disclose information collected on this website to any third party, it would only be with your knowledge and consent.
We may from time to time provide information of a general nature to third parties – for example, the number of individuals visiting our website or completing a registration form, but we will not use any information that could identify those individuals.

Public Information and Third-Party Websites

a) Blog. We have public blogs on our website. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact on the information provide at the start of this page. If we are unable to remove your information, we will tell you why.
 
b) Social media platforms and widgets. Our website includes social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. We also maintain presences on social media platforms including Facebook, Twitter, and LinkedIn. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
 
c) Links to third-party websites. Our website include links to other websites, whose privacy practices may be different from ours. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

Competitions

We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our websites, software or through social media (collectively “Our Promotions”). Participation in Our Promotions is completely voluntary. Information requested for entry may include personal information such as your name, address, phone number, email address, username, and similar details. We use the information you provide to administer Our Promotions. We may also, unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Services.

Your Rights

You have certain rights given to you by law, that means you have an amount of control over your personal data that we process.
  1. Access to Your Personal Data: This right allows you to confirm that your personal data is being processed and to allow you to check if the processing is lawful.
  2. Correcting Any Mistakes: The right of rectification allows you to instruct an organisation that is processing your personal data, to rectify any mistakes.
  3. Right to be Forgotten: You have the right to instruct an organisation to erase your personal data.
  4. Stop Processing: The right to stop the processing of your personal data
  5. Moving Data: The right to data portability means that under certain circumstances you will be able to ask for your personal data to be transferred from one organisation to another.
  6. Right to Object to Direct Marketing: You have the right to object to the processing of your personal data for the purposes of direct marketing.
  7. Object to Profiling: Under certain circumstances, you are able to object to profiling and/or automated decision making.
Right to complain to the Information Commissioners Office (ICO): If you are not happy with an aspect of how ClearPeople are processing your data, you can lodge a complaint to the supervisory authority, which is the ICO. (www.ico.org.uk)

Before it gets to that situation, please make sure you contact our Compliance Officer (Jeffrey Cosper) at theconsultagents@clearpeople.com if you wish to exercise any of your rights or if you have any questions about the processing of your personal data.
 

Security and Compliance

Notice of Breach of Security

If a security breach causes an unauthorised access into our system that materially affects you or your contacts in our software, then ClearPeople will notify you as soon as possible and later report the action we took in response.

We operate in the United Kingdom

Our servers and offices are located in Ireland, so your information is not transferred to, stored, or processed outside the EU or United States. 
 

Detailed Cookie Policy

 List of Cookies we use:

Site

Full tag (cookie) name

Lifespan

Full description

Essential / Analytics/ Marketing

Intrusiveness/Justification

CommuniGator

wow.session

Session

IIS Session cookie

Essential

ZERO

Standard session cookie served by the web server.

CommuniGator

wow.anonymousid

2 year

Anonymous Visitor Id

Analytics

LOW

Does not store user data, only stores active menu node over post-back.

CommuniGator

wow.scheulde

Session

Load Balance Session Queue

Essential

ZERO

Standard session cookie served by the web server.

CommuniGator

wow.utmvalues

Session

Stores the UTM values for the session

Analytics

LOW

Does not store user data, only stores active menu node over post-back.

CommuniGator

wow.trackingdata

Session

Contains CommuniGator encrypted identifier for the session

Marketing

MEDIUM

Cookie which is only used by GatorMail integration so GatorLeads knows email contacts visiting website.

CommuniGator

wow.data

2 year

Holds the encrypted GatorMail identification

Marketing

MEDIUM

Cookie which is only used by GatorMail integration so GatorLeads knows email contacts visiting website.

CommuniGator

ASPXAUTH

Session

CommuniGator Product Authentication

Essential

ZERO

Authentication cookie served by the CommuniGator product.

CommuniGator

ASP.NET_SessionId

Session

IIS Session cookie

Essential

ZERO

Standard session cookie served by the web server.

Google Analytics

_utma

_utmb

_utmc

_utmz

The longest lasting cookie expires 2 years after your last visit to the website. Others are deleted 6 months, 30 minutes and the moment you close your browser

Google Analytics cookies do not collect personal data about our website visitors.

The data collected by Google Analytics is used to analyse how frequently the same people revisit the University website, how the website is found (from advertising or referring websites), and which pages are most frequently viewed. This information is combined with data from thousands of other users to create an overall picture of website use, and is never identified individually or personally and is not linked to any other information we store about you.

Google’s privacy policy

Opt out of Google Analytics

Analytics

LOW

3rd part cookie which does not store personal user data

Google Maps

SID, SAPISID, APISID, SSID, HSID, NID, PREF

Most of the cookies expire 10 years after your last visit to a page containing a Google Map

Various unique identifiers, except for PREF which stores your options such as preferred zoom level.

Google set a number of cookies on any page that includes a Google Map. While we have no control over the cookies set by Google, they appear to include a mixture of pieces of information to measure the number and behaviour of Google Maps users.

Google’s privacy policy

Analytics

LOW