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This is the privacy notice of Clear Trace. In this document, "we,'' "our", or "us" refer to Clear Trace. Our company number, if applicable, will be in the footer of this website.
Our registered office is at
Health Innovation One,
This privacy notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you ("personal information") and information that could not. In the context of the law and this notice, "process" means to collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.
We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information.
We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
We may collect, use, store and transfer different kinds of personal data about you. We have collated these into groups as follows:
Your identity includes information such as first name, last name, title, date of birth, and other identifiers that you may have provided at some time.
Your contact information includes information such as billing address, delivery address, email address, telephone numbers and any other information you have given to us for the purpose of communication or meeting.
Your financial data may include information such as your bank account and payment card details.
Transaction data includes details about payments or communications to and from you and information about products and services you have purchased from us.
Technical data includes your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity.
For example, we may aggregate profile data to assess interest in a product or service.
However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information and it will be used in accordance with this privacy notice..
The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
We process this information on the basis there is a contract/business agreement between us, or that you have requested we use the information before we enter into a legal contract.
We shall continue to process this information until the contract/business agreement between us ends or is terminated by either party under the terms of the contract.
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you with more information about our business, including job opportunities, our products and services, you provide your consent to us to process information that may be personal information.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at email@example.com. However, if you do so, you may not be able to use our website or our services further.
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
For example, we may process your data on this basis for the purposes of:
Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
Only if our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people then the following applies.
In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.
We do not specifically use this information except to allow it to be displayed or shared.
We do store it, and we reserve a right to use it in the future in any way we decide.
Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting our DPO (1.)
Our website is a publishing medium.
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
We store information about your debit or credit card or other means of payment when you first provide it to us.
We store this payment information at your request in order to make repeat purchasing of services or products easier, or to make payment plans easier for you.
[We also store it to help us prevent fraud.]
We take the following measures to protect your payment information:
We automatically delete your payment information when a credit or debit card expires.
10 . Job application and employment
If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
This is information given to us by you in your capacity as an affiliate of us or as a business partner.
It allows us to recognise visitors that you have referred to us, and to credit to you commission due for such referrals. It also includes information that allows us to transfer commission to you.
The information is not used for any other purpose.
We undertake to preserve the confidentiality of the information and of the terms of our relationship.
We expect any affiliate or partner to agree to reciprocate this policy.
Use of information we collect through automated systems when you visit our website
Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data could possibly be used to identify you personally, even if you are not signed in to our website. all this information is handled by Clear Trace. who can be contacted via https://www.cleartrace.co.uk/contact
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
Disclosure and sharing of your information
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
No such information is personally identifiable to you.
Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.
We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.
19 Credit reference
To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
Our website is hosted in the UK.
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly data obtained within the UK or any other country could be processed outside the European Union.
For example, some of the software our website uses may have been developed in the United States of America or in Australia.
Control over your own information
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
At any time you may review or update personally identifiable information that we hold about you, by contacting us. To obtain a copy of any information that is not provided on our website you should contact us to make that request.
After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
If you wish us to remove personally identifiable information from our website, you should contact us to make your request.
This may limit the service we can provide to you.
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
We do not sell products or provide services for purchase by children, nor do we market to children.
If you are under 18, you may use our website only with consent from a parent or guardian
We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.
Such child users and visitors will inevitably visit other parts of the site and will be subject to whatever on-site marketing they find, wherever they visit.
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser's URL bar or toolbar.
If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
However, ultimately it is your choice as to whether you wish to use our website.
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
The Danish Data Protection Agency has adopted Standard Contractual Clauses (SCCs) which have been approved by the European Data Protection Board (EDPB). We have updated our detailed guidance on contracts and liabilities between controllers and processors to reflect this.
We have published detailed guidance on special category data and updated the Guide page on special category data. We have also published a template appropriate policy document. This is required by many of the DPA 2018 schedule 1 conditions for processing.
In addition, we have published a template Part 3 appropriate policy document. We have updated the conditions for sensitive processing and principles pages in the Guide to Law Enforcement Processing to provide further guidance on the Part 3 appropriate policy document.
We have published guidance on manifestly unfounded and excessive requests under the Guide to Law Enforcement Processing.
We have updated our position on how to calculate the time limit for responding to requests (in relation to Individual rights) following a determination made in a Court of Justice of the European Union (CJEU) case which has been adopted by the European Data Protection Board (EDPB). We have also added guidance on the meaning of ‘manifestly unfounded or excessive’. The following pages have been updated:
The European Data Protection Board (EDPB) published Guidelines 2/2019 on the processing of personal data under Article 6(1)(b) GDPR in the context of the provision of online services to data subjects for consultation. The consultation closed on 24 May.
The European Data Protection Board (EDPB) has adopted:
The EDPB has also published the following Guidelines for consultation:
Comments should be sent to EDPB@edpb.europa.eu.
We've also updated our guidance on the Right to be Informed.
We have published our Guide to Data Protection, combining our existing guidance on the GDPR and law enforcement regimes with new guidance explaining some basic concepts, how the DPA 2018 works, and which regime applies.
We have expanded our guidance on scope and key definitions in the guide to law enforcement processing.
We have published detailed guidance on encryption.
We have expanded our guidance on Exemptions.
We have expanded our guidance on International transfers.
The European Data Protection Board (EDPB) has published draft guidelines on certification and identifying certification criteria in accordance with Articles 42 and 43 of the Regulation 2016/679 for consultation. The consultation will end on 12 July.
We have published detailed guidance on children and the GDPR.
We have published detailed guidance on determining what is personal data.
We have published detailed guidance on the right to be informed.
We have published detailed guidance on Data Protection Impact Assessments (DPIAs).
We have published detailed guidance on consent.
We have expanded the page on the right to data portability.
We have expanded the page on Accountability and governance.
We have expanded the page on Security.
We have updated all of the lawful basis pages to include a link to the lawful basis interactive guidance tool.
We have published detailed guidance on DPIAs for consultation. The consultation will end on 13 April 2018. We have also updated the guide page on DPIAs to include the guide level content from the detailed guidance.
We have published detailed guidance on legitimate interests.
We have expanded the pages on:
The consultation period for the Article 29 Working party guidelines on consent has now ended and comments are being reviewed. The latest timetable is for the guidelines to be finalised for adoption on 10-11 April.
The consultation period for the Article 29 Working Party guidelines on transparency has now ended.
Following the consultation period, the Article 29 Working Party has adopted final guidelines on Automated individual decision-making and Profiling and personal data breach notification. These have been added to the Guide.
We have published our Guide to the data protection fee.
We have published more detailed guidance on documentation.
We have expanded the page on personal data breaches.
We have published detailed guidance on Children and the GDPR for public consultation. The consultation closes on 28 February 2018.
The sections on Lawful basis for processing and Rights related to automated individual decision making including profiling contain new expanded guidance. We have updated the section on Documentation with additional guidance and documentation templates. We have also added new sections on legitimate interests, special category data and criminal offence data, and updated the section on consent.
The Article 29 Working Party has published the following guidance, which is now included in the Guide.
It is inviting comments on these guidelines until 23 January 2018.
The consultation for the Article 29 Working Party guidelines on breach notification and automated decision-making and profiling ended on 28 November. We are reviewing the comments received together with other members of the Article 29 Working Party and expect the guidelines to be finalised in early 2018.
The Article 29 Working Party has published guidelines on imposing administrative fines.
We have replaced the Overview of the GDPR with the Guide to the GDPR. The Guide currently contains similar content to the Overview, but we have expanded the sections on Consent and Contracts and Liabilities on the basis of the guidance on these topics which we have previously published for consultation.
The Guide to the GDPR is not yet a finished product; it is a framework on which we will build upcoming GDPR guidance and it reflects how future GDPR guidance will be presented. We will be publishing more detailed guidance on some topics and we will link to these from the Guide. We will do the same for guidelines from the Article 29 Working Party.
The Article 29 Working Party has published the following guidance, which is now included in our overview.
The Article 29 Working Party has also adopted guidelines on administrative fines and these are expected to be published soon.
In the Rights related to automated decision making and profiling we have updated the next steps for the ICO.
In the Key areas to consider we have updated the next steps in regard to the ICO’s consent guidance.
The deadline for responses to our draft GDPR guidance on contracts and liabilities for controllers and processors has now passed. We are analysing the feedback and this will feed into the final version.
We have put out for consultation our draft GDPR guidance on contracts and liabilities for controllers and processors.
In the Key areas to consider we have updated the next steps in regard to the ICO’s consent guidance and the Article 29 Working Party’s Europe-wide consent guidelines.
The Article 29 Working Party’s consultation on their guidelines on high risk processing and data protection impact assessments closed on 23 May. We await the adoption of the final version.
We have updated our GDPR 12 steps to take now document.
We have added a Getting ready for GDPR checklist to our self-assessment toolkit.
We have published our profiling discussion paper for feedback.
We have published our draft consent guidance for public consultation.
Article 29 have published the following guidance, which is now included in our overview: