Privacy

1.    Clear Loop Security – Privacy Policy

1.1. Who Are We?

We are Clear Loop Consulting Ltd., t/a Clear Loop Security, an information and cyber security consultancy and provider of managed security services, and the controller of personal data that we process. We can be contacted through the following means:

  • Email to dataprotection@clearloopsecurity.com
  • Post to our registered office address of Greetwell Place, 2 Lime Kiln Way, Lincoln, Lincolnshire, United Kingdom, LN2 4US

1.2. What Data Do We Collect?

We obtain information from prospective and actual customers and suppliers as stated below.

Purpose Data Collected Lawful Basis How Long is The Data Retained?
Service Delivery Name, job title, contact details including email address, postal address, phone number. This information is collected as part of negotiations to enter into a contract for services that we provide, and for the performance of contracts to deliver these services.

 

The lawful basis is contractual obligation.

 7 years from the date of the last commercial interaction with your organisation, or for a period mandated to us by the law.
Marketing Name, job title and email address. We may send marketing communications to you, in relation to services and information that we believe will be of interest to you.

 

The lawful basis is our legitimate interest in providing services of interest to you.

 Until you inform us that you no longer wish to receive these communications, or for a period mandated to us by the law.

Note that if you fail to provide the personal data stated above, we may not be able to provide the services that you require, or send marketing information to you for services that may be of interest.

We do not employ any automated decision-making or profiling technologies.

1.3. Who Has Access To Your Personal Data?

The personal data that we collect is accessed by Clear Loop Security personnel as part of their duties, and may be provided to sub-contractors and service providers as part of the delivery of Clear Loop Security’s services. In addition, our professional advisors such as legal representation and accountants may require access to this data for legal and business purposes.

1.4. International Transfers

To provide our services it may be necessary to transfer your personal data to service providers located in a country outside of the European Union (EU). Where this occurs, we ensure a similar degree of protection of your personal data by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed by the European Commission to provide an adequate level of protection
  • We will ensure that we put in place European Commission-approved model clauses between us any third party that processes your personal data

Further details on the above are available on request, by contacting us via the methods stated in Section 1.1

1.5. Your Rights

You have the following rights:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no valid reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

1.6. Complaints

Should you have any complaints regarding the handling of your personal data, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns directly, so please contact us in the first instance by means of one of the methods stated in Section 1.1.

The ICO can be contacted by one of these methods: