1.1 ClearWELL (“ClearWELL”, we", "us" and "our") are committed to safeguarding the privacy of our website visitors and service users.
1.2 We are data controller for the purposes of this policy and with respect to the personal data of our website visitors and service users.
1.3 We may update this policy from time to time by publishing a new version on our website. We will notify you of changes to this policy by email or through a prominent notice on our website.
1.4 It is important that you read this policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you so that you were fully aware of how and why we are using your information. This policy supplements the other notices and is not intended to override them.
2.1 We may process data about your use of our website and services. Such data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.2 We may process information that you provide to us for the purpose of subscribing to our mailing list. This personal information may be processed for the purposes of sending you the relevant news and/or newsletters. The legal basis for this processing is consent. We use a third-party provider, Mailchimp, to deliver our newsletter. Mailchimp gathers statistics around e-mail opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see Mailchimp’s privacy notice. To view the data stored about you, edit this data or delete this data from the database, you can click on the link contained in the footer of any direct email communication sent to you from us via Mailchimp. Alternatively contact us using the contact details below.
2.3 We may process information contained in or relating to any communication that you send to us, including when using a contact form. The data may include the communication content, your name, e-mail address, and where provided, your company, address and position and any metadata associated with the communication. The data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users and, where relevant, consent.
2.4 We will only use your personal information for the purposes for which we collected it as detailed above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so, or we will seek your consent if required.
2.5 Unless you are notified otherwise, we will not use profiling, or automated decision making in any form, to make important decisions that will affect you.
3.1 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data, the purposes for which we processed the personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
4.1 Please be aware that the transmission of information via the internet is not always completely secure. Although we will do our best to protect your personal data, we cannot guarantee the complete security of your data transmitted to us electronically; any transmission is at your own risk. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data to the best of our abilities. To do so, we will store any personal data on secure servers and encrypt data where appropriate (for example passwords).
5.1 Under certain circumstances, you have the following rights under data protection law:
(a) the right to access your personal information enabling you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
(b) the right to rectification enabling you to have any inaccurate personal data about you rectified and to have any incomplete personal data about you completed;
(c) the right to erasure enabling you to ask us to delete or remove personal information where there is no good reason for us continuing to process it;
(d) the right to restrict processing enabling you to ask us to suspend the processing of personal information about you;
(e) the right to object to processing where we are relying on a legitimate interest (or a legitimate interest of a third party) and there is something about your particular situation which makes you want to object to processing on this ground;
(f) the right to data portability enabling you to ask for your data to be transferred to another party;
(g) the right to complain to a supervisory authority being the Information Commissioner’s Office in the UK; and
(h) the right to withdraw your consent to our processing your personal information if we rely on consent to do so.
If you wish to discuss or exercise any of these rights, please refer to the contact details below.
6.1 Our website includes hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties. We encourage you to review all privacy policies of third parties.
7.1 The information you provide to us will be treated by us as confidential. We may disclose your information to other third parties who act for us for the purposes set out in this notice or for purposes approved by you, including group companies and Mailchimp (as detailed above).
7.2 We do not transfer your personal information outside of the European Economic Area.
8.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via the browser you are using.
12.2 Blocking all cookies will have a negative impact upon the usability of many websites and you may not be able to use all the features on our website.
13.1 This website is owned and operated by ClearWELL.
13.2 Our principal place of business is at Wellheads Crescent, Dyce, Aberdeen, AB21 7GA.
13.3 You can contact us: by post, to the postal address given above; using our website contact form; by telephone, on the contact number published on our website from time to time; or by email at firstname.lastname@example.org