Privacy Policy

This policy aims to support your right to be informed, and covers how we process the data of individuals who are clients or prospects.

Identity and contact details

Please click here to find out more about The Data Comparison Company Limited, we trade as ClearCrypt. Our postal address is Unit 11, Riverside Park, Farnham, GU9, United Kingdom 7UG. You can contact us by email using dataprivacy@clear-crypt.com

Our supervisory authority under the UK’s General Data Protection Regulation (GDPR) is the Information Commissioner’s Office (ICO). We are based in the United Kingdom.

To contact the individual in charge of Data Protection in our company please use the email address dataprivacy@clear-crypt.com

What data we process

We process data which allows us to contact individuals at the organisations which are our intended customers. This includes name, job title, email address and telephone numbers. We also process data to support our analysis of the efficiency of our marketing tools and platforms, and to support the services that we offer. This can include IP addresses, information on the use of our website and application platform, and cookies (see separate section on cookies). We offer our services to corporate employees, and not to individual consumers. 

Customers

ClearCrypt captures information on individuals in customers and prospective customers who have engaged with us either directly or through our website or contacted us using email or telephone. We use a reason of ‘Contract’ to process this data as we are taking steps towards providing services to these individuals when we capture and process this data. 

ClearCrypt captures information on customers that we are in the process of providing services for so that we can effectively manage and communicate with them as we deliver our services. We use ‘Contract’ to process this data. 

We may capture special category information on these customers if they come to physical events, where we may capture information on specific dietary or access needs. We use a legal basis of explicit “Employment, social security and social protection law” to capture this special category information. 

Prospects

ClearCrypt captures information on individuals who we believe could have a need for our services. We can either capture this data directly from the individuals in the process of selling to them, or we can licence this data from reputable data providers. 

We use this data for direct marketing to the individuals who are corporate employees of the organisations that we target. We process this data using ‘Legitimate Interests’. We have conducted our gating and balancing tests to determine whether our legitimate interests do not outweigh the rights and freedoms of the individuals we are targeting. We do not process special category data on these individuals. 

Where regulations mandate that that we must obtain consent from individuals, for example if the data subject is a ‘corporate subscriber’ in a country where electronic privacy rules mean that we must use consent, and we intend to use email to communicate, then we will use the lawful basis of Consent to process data to promote our services. This lawful basis of consent can include the use of a ‘soft opt-in’ where the individuals we are targeting have bought from us within the past 2 years. We do not process special category data on these individuals. 

Any recipient or categories of recipients of the personal data

ClearCrypt passes data on to other data controllers for the following purposes:

  • As the data controller of data, we may provide access to data processors that process data on our behalf, who will only process the data according to the written instructions in the Data Processing Agreements in place with them.
  • We share data with organisations with which we have a legal obligation to share data.

Details of transfers to third country and safeguards

We will not transfer your data to countries outside the UK to destinations that are not considered ‘adequate’ by relevant legislation without additional safeguards. 

Retention period or criteria used to determine the retention period

  • We will retain information on customers for 7 years after the latest engagement as we will need to retain this information for financial purposes.
  • We will retain information that we use on prospective customers for the purposes of direct marketing for 3 years after the latest interaction with the individual where we use legitimate interests as a lawful basis for processing the data.
  • We will retain information that we use on prospective customers for the purposes of direct marketing for 3 years after the latest interaction with the individual where we use consent as a lawful basis for processing the data.

If these data retention timescales clash with legal or contractual obligations then these other obligations will override the retention timescales outlined. 

All records are disposed of securely when deleted. 

How we look after data

We take reasonable technical and procedural precautions to prevent the loss, misuse or unauthorised alteration of personal data. 

We store the personal data that we collect securely. 

We do not publish the details of the safeguards we use to protect the personal data that we control as this could reduce the effectiveness of those safeguards.

Cookies

Cookies are text files placed on your computer to collect information about which pages you visit, and how long for. This information is used to track use of the website and to compile statistical reports on website activity. 

When you visit our website you will be presented with a choice which will allow you to decide whether cookies are used or not. In a few cases some of our website features may not function if you choose not to allow cookies on our website. 

Personal data may be shared with third parties to enable us to conduct web analytics to monitor use of our website. 

Where you enter data in a form to request a demonstration of the ClearCrypt product, or ask for a free trial of the product, the Monday.com forms that we use create cookies on your device so that the system can track the transfer of data between the different servers that are processing the request. 

We also use Google Analytics and you can opt out of Google Analytics by using this link: https://tools.google.com/dlpage/gaoptout?hl+en=GB

Other websites

This privacy policy only applies to data under our control. The policy does not cover other organisations, even if we publish the link to their websites on our web pages. 

Your rights

ClearCrypt recognises the rights of individuals as defined in the UK and EU’s GDPR. 

We will always seek to uphold those rights and the links provided will enable you to communicate with us to exercise those rights, where relevant.

ClearCrypt recognises your right to lodge a complaint with a supervisory authority. You can access the ICO’s website from this link.

You can access a list of contact details for the EEA’s supervisory authorities using this link.