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Data Privacy Policy

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We understand that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, (“Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.

We are bound to GDPR and ICO.

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Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Site. If you do not accept and agree with this Privacy Policy, you must stop using our Site immediately.

 

1. VALUES

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 Thank you for trusting us with some information about you.  We take that trust seriously and we want you to know how we use your information and why. If you have queries about how we use your data, or comments or questions about this Policy, please do email us.  The email address to use is set out in section 2 below.

 

2. WHO ARE WE?​

  

Name: Claire Rolfe

Trading Name: CLR Solutions Virtual Assistant 

Email address for official notices: claire@clrsolutions.co.uk 

Data Protection Officer: Claire Rolfe

 

3. WORDS WITH SPECIFIC MEANINGS
 

In this Policy, there are words and phrases that have a specific meaning or that we are using in a special way.  They are:
 

“personal data” - any information about an identifiable living human being.
“process” - we “process” your personal data when we do anything with it, which might include:  collecting, recording, organising, storing, adapting, altering, retrieving, using, combining, disclosing, or deleting it.
“special category data” - personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life or sexual orientation, health, genetic or biometric data.

 

4. WHAT THIS POLICY DESCRIBES
 

This policy describes how we will collect and use personal data about you.
We process information about:

 

“Prospects” - potential customers or referrers;   
“Customers” - who have bought goods or services from us;
“Suppliers”, “Associates” - suppliers or potential suppliers of goods or services to us;

5. WHERE DO WE COLLECT THE DATA FROM?

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Most of the personal information we process is provided to us directly by you for one of the following reasons:

 

– We may collect data about you by you providing the data directly to us (for example by filling in forms on our website, corresponding with us by phone, mail, email, social media or otherwise, by you posting details and documents to us or by you granting us access to shared online/electronic
resources such as accounting software or online storage).
– We may also collect data relating to your tax affairs (for example PAYE coding notices, tax calculation statements, and other correspondence) by it being sent to us by post or in electronic format by HMRC in cases where you have authorised HMRC to liaise directly with us as your tax agent.
– To comply with legal obligations to which we are subject, to obtain evidence of your identity and address, we may receive data from third party agencies which may include residency and identity checks and ‘risk’ factors such as politically exposed persons and those on sanctions lists, and from publicly availably sources such as Companies House.

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6. WHAT INFORMATION DO WE COLLECT, AND WHY?
 

a. Prospect
Most of the information we process comes from you.  We process it so we can reply to you, and when you contact us again we know what you asked before, what you were sent, and what you told us. We will comply with our obligations and safeguard your rights under the GDPR at all times.

 Typically, we are collecting your name, contact details, how we came across you, and background information from you or published by you on social media or freely accessible on the internet, on why you might be interested in our products or services or a relevant contact for our business.

 If you sign up to a newsletter list, you will be sent what you asked for.   We operate a ‘signup form’ and you will need to confirm your subscription before anything is sent.   You can unsubscribe at any time by clicking the unsubscribe button on any email. 

You are not automatically subscribed to any other lists, but may be invited to join an appropriate one.
If we email you individually using our own email system, or respond to an email sent to us at any of our business email addresses, a copy of that email will also be stored.

 If you make an enquiry via our website, we will keep details of that enquiry and response for our data retention period of 7 years.

 We do not routinely keep special category data unless it was supplied or made publicly available by you.
 

b. Customer
Once you contact us, we will collect information from you for future communications.

 This will include the information we collect from Prospects (above).  We may collect some or all of the following personal data (this may vary according to your relationship with us):

Full names, previous or other names, current and previous addresses, telephone numbers, email addresses, date of birth, business name, job title, profession, payment information, national insurance number, tax reference number and financial details.

This is so we can provide what we have contracted to do, and keep proper records of our business relationship.

We process your data to support the delivery the goods and services you have bought.  We keep records of the goods/services provided to you, and information you give us, so we can support you when needed and advise you of any additional services you may need.
 

Financial and credit card details
We do not receive or store your credit card details. Credit card/debit and Paypal payments are handled by an external secure processor in accordance with their data security policies.   
We receive limited information from our processor for us to tie up your payment.   


c. Supplier and Associates
We collect information on potential and actual suppliers and associates.   This is mostly provided by you, but we do add to it the same kind of data we use for Prospects (see above).

 

If you become a supplier or associate we keep a copy of the contract between us and your bank details so we can pay you.  We also keep a record of invoices/payments for accounting purposes.
We keep a record of the work you undertook for us/our clients along with any comments, reviews or suggestions about that work including complaints (if any) and their resolution.
This information is all needed to manage our customer relationships and our supply chain.

 

7. WHAT DO WE DO WITH THE DATA?

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Our purpose for collecting your contact details is so we can provide you with a service and let you know more about CLR Solutions' work.

We collect analytics information so we can provide a personalised service, monitor the impact of our work and improve future contact.

The lawful basis we rely on for processing your contact details and interest preferences is your consent under article 6(1)(a) of the UK GDPR.

The lawful basis we rely on for the processing of analytics information is article 6(1)(e) – public task.

 

8. NEWSLETTERS AND AUTOMATED EMAILS
 

We monitor who opens what in our newsletter lists, and pre-set sequences of information we send you.  We do this, so we can see if content is popular and generate more of it, or if it is not read.
There may be sub-routines that trigger if you click on links or articles.  These are designed to offer you more information about things you are interested in.
You can unsubscribe from these sequences at any time.
From time to time, we contact individual email newsletter subscribers but it is extremely rare.  This would normally be if something odd were going on and we wanted to check you could see and use the content or find out what was causing a problem.

 

9. DATA SHARING – 3RD PARTIES
 

We do not sell or exchange your personal data with organisations who may want to sell you something or use your data for research or other direct marketing purposes.
 

a. Platforms
We keep a list of the software platforms we use to run our business.  If you would like a list of all the platforms we use, please email us (at the email address in section 2, above).

We may compile statistics about the use of our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

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b. People
We use our own team for any support and do not regularly outsource work. We may sometimes contract with third parties to supply services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In certain circumstances, We may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.

 

c. Links to other websites

Where we provide links to websites of other organisations, this privacy notice does not cover how that organisation processes your personal information. This Privacy policy applies solely to information collected by CLR Solutions through this site and the service offered. Therefore this Privacy policy does not apply to your use of a third-party website accessed by selecting a link on this site or via our service. We encourage you to read the Privacy notices on the other websites you visit.

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10. WHERE IS YOUR DATA LOCATED?
 

Like most small businesses, we do not have any tailor-made software – we use mainstream packages for everything from our customer records, to email, to accounting.
This means that some of your data may be held in the EEA, and some may be held in services in the USA (with suitable data privacy shields) or elsewhere.  We have picked mainstream suppliers with appropriate security standards.

 

11. RETENTION PERIODS
 

Your information will be kept for the length of time set out in our retention period of 7 years. We need to keep customer information long enough to satisfy HMRC and our insurers.  We keep information on prospective customers long enough to make our sales enquiry system effective.
 

If you subscribed to a newsletter or updates list, you will remain on the list(s) you joined until you unsubscribe from that list.   
 

12. YOUR RIGHTS


If you are a resident of the EEA or the UK, you have the following data protection rights:

  • You have the right to know what information we are collecting on you, and to amend it if it is inaccurate.
    If you feel for any reason we have information we should not be keeping, or it is out of date or otherwise wrong, please let us know and we will take appropriate action.  
    Most of the information we hold is not based on your individual consent but is based on our needing the information to run our business and provide our products and services.
    If you want to know what information we have about you (if any) email us at the email address set out above and give us your name, email address(es) and we will happily do a search and let you know what information we hold on you and how we are using it/have used it.

  • You have a “right to erasure” - but that does have some legal limits to it.  If you want us to remove information about you, let us know.  If you have been a customer, we may not be able to remove all data as we will have to ensure that we can continue to comply with legal, accounting, taxation and our insurer’s requirements. CLR Solutions will confirm receipt of the request from the data subject to erase their data with a realistic erasure completion time frame. Under Article 12.3 of the GDPR, we have 30 days to provide information on the action you have asked for. This timeframe can be extended up to 60 days depending on the complexity of the request.

  • You have the right to data portability and have the right to ask that we transfer data you have given us to another organisation or give it to you.

  • You have the right to ask to restrict the processing of information and object to processing of information.

  • You have the right to opt out of marketing communications we send you at any time. You can exercise this right by clicking on the 'Unsubscribe' link at the bottom of the email we send you.

  • You can request access to information by emailing the address set out above (see Section 2).

 

13. CHANGES TO OUR PRIVACY POLICY


We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

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14. COMPLAINTS
 

If you have a complaint about the way we are handling your information or how we have responded to a request for information or removal, you can take this up in the first instance by emailing us at the email address set out above (see section 2).
If we can’t sort it out, the relevant supervisory authority for us is the Information Commissioner for the UK.  You can contact their helpline on 0303 123 1113.

Policy Date: March 2022

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