PRIVACY POLICY
1. Introduction
We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us. In this document, we will explain how we collect, use and protect your personal data.
We will also explain what rights you have with regards to your personal data and how you can exercise those rights.
2. Who we are
Clearsound Productions Ltd is the data controller for the company. This means that Clearsound Productions Ltd determines how this data is going to be used and how this data is protected.
Our registered office address is:
Clearsound Productions Ltd
10 Tilemans Park
Shipston on Stour
CV36 4PR
United Kingdom
If you have questions about how we process personal data, or would like to exercise your data subject rights, please email us at hello@clearsound.co.uk.
3. Companies and websites we use
The following companies and websites are within scope for this privacy policy:
Clearsound Productions Ltd - www.clearsound.co.uk
InspHire - Current RMS - www.current-rms.com (GDPR Policy - https://www.current-rms.com/gdpr-information/)
Xero Accounting - www.xero.com/uk (GDPR Policy - https://www.xero.com/uk/campaigns/xero-and-gdpr/)
Unless specifically stated, we consider these websites to be UK based websites; see section 6 below for more information on non-EU data processing.
This policy also covers any additional personal data collected in the following online web applications:
Wix Website - www.wix.com (GDPR Policy - Web Link)
Mailchimp - www.mailchimp.com (GDPR Policy - Web Link)
Teamtrack - www.teamtrack.uk - privacy policy
It includes personal data that is collected through our websites, by telephone, through LiveChat and through any related social media applications.
4. Collection of personal data
We collect personal data from you for one or more of the following purposes:
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To provide you with information that you have requested or which we think may be relevant to a subject in which you have demonstrated an interest;
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To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of products and/or services;
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To fulfil a contract that we have entered into with you or with the entity that you represent;
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To ensure the security and safe operation of our websites and underlying business infrastructure, and
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To manage any communication between you and us.
The table in Section 5 below provides more detail about the data that we collect for each of these purposes, the lawful basis for doing so, and the period for which we will retain each type of data.
Technical information
In addition, and in order to ensure that each visitor to any of our websites can use and navigate the site effectively, we collect the following:
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Technical information, including the Internet Protocol (IP) address used to connect your device to the Internet;
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Your login information, browser type and version, time zone setting, browser plug-in types and versions;
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Operating system and platform;
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Information about your visit, including the Uniform Resource Locators (URL) clickstream to, through, and from our site.
Our cookies policy is in line with that outlined by our website provide Wix and can be viewed here which describes in detail how we use cookies.
In Section 8 below, we identify your rights in respect of the personal data that we collect and describe how you can exercise those rights.
5. Lawful basis for the processing of personal data
The table below describes the various forms of personal data we collect and the lawful basis for processing this data. Our business architecture, accounting and systems infrastructure and compliance organisation means that all personal data is processed on common, Group-wide platforms. We have processes in place to make sure that only those people in our organisation who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties and, where this happens, this is also identified below.
When we process on the lawful basis of legitimate interest, we apply the following test to determine whether it is appropriate:
The purpose test – is there a legitimate interest behind the processing?
Necessity test – is the processing necessary for that purpose?
Balancing test – is the legitimate interest overridden, or not, by the individual’s interests, rights or freedoms?
6. Use made of the information
We may use information held about you for various reasons, for example:
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To carry out our obligations arising from any contracts entered into between you and us
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To comply with any legal and /or statutory obligation in terms of relevant municipal laws
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To ensure that content from our site is presented in the most effective manner for you and for your computer
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To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes
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To allow you to participate in interactive features of our service(s), when you choose to do so
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To notify you about changes to our products and/or service(s)
If you are an existing customer, we may contact you by email, telephone, printed media or in other manners with information about goods and services similar to those which were the subject of a previous sale to you.
Clearsound Productions does not share the personal information of its customers or suppliers and/or their employees with any third parties for the purposes of further marketing by those third parties.
The information we collect from you depends on what activities you are carrying out on our site(s), whether you are logged in or not and whether you are placing an order. For example, we may collect, process, maintain and store some, all, or any combination of the following personally identifiable information about you:
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Contact Name (First and family names)
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Company Name, registration number and tax related numbers
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Postal and / or physical address
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Payment details (which may include credit card or banking account information)
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Contact telephone number(s)
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Contact email address(es)
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Contact person(s) names
Examples of instances when such information may be collected, processed, maintained or stored are when you:
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Provide the information by completing online forms on our site: This includes information provided at the time of registering to use our site, purchasing our products, completing the “Contact Us” form. We may also ask you for information when you report a problem with our site
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Contact us: we may keep a record of that correspondence
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Complete surveys that we use for research purposes or to enhance our services: There will however be no obligation on your part to respond to them
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Complete transactions through our site and for the fulfilment of your orders
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Visit our site(s) and access resources we may collect data with the use of cookies.
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Trade with us, including requests for offers, quotes, etc. In such cases the collection of personal data will also potentially be necessary to complete the trade contract
Clearsound Productions Ltd also relies on collecting data to further its legitimate interests as a basis of lawfulness of processing.
For Clearsound Productions Ltd a legitimate interest is when we have a business or commercial reason to use your information. Even in these circumstances the legitimate interest must not unfairly go against your rights in terms of the GDPR. Generally, we will rely on legitimate business interest when collecting the following, or any combination of the following, categories of personal information:
7. Storage of personal data
Clearsound Productions Ltd is a UK organisation whose offices are in the UK.
EU GDPR does not apply in the UK after the end of the Brexit transition period on 31 December 2020.
However the UK’s DPA 2018 has already enacted the EU GDPR’s requirements into UK law and, with effect from 1 January 2021, the DPPEC (Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit)) Regulations 2019 amended the DPA 2018 and merged it with the requirements of the EU GDPR to form a new, UK-specific data protection regime that works in a UK context after Brexit as part of the DPA 2018.
This new regime is known as the ‘UK GDPR’.
UK organisations should therefore align their GDPR documentation with the requirements of the UK GDPR. In particular, Article 30 records, privacy notices, DPIAs (data protection impact assessments), DSARs (data subject access requests) and documentation covering international data flows must all reflect the UK’s independent jurisdiction and the specific scope and wording of the UK GDPR.
Any UK organisation that offers goods or services to, or monitors the behaviour of, EU residents will also have to comply with the EU GDPR, and will reflect this in its process documentation.
Any data that you provide to us is normally stored, processed and maintained in the UK. While it is not normal practice for Clearsound Productions Ltd to do so, data may be transferred to, and stored at, a destination outside the UK. In such cases we shall ensure that only countries, and / or third-party processors that are compliant with the UK regulations are used by using means prescribed by the UK – GDPR.
Similarly, data may also be processed by staff operating outside the UK who work for us or our associated service provider(s). Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We request that you do not share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect any personal data you give us, we cannot guarantee the security of your data transmitted from your terminal to our site.
We also take appropriate steps, such as encrypted passwords and recovering passwords via email without direct passwords details, to verify your identity before granting access to your personal profile.
8. Security measures
We have what we believe are appropriate security controls in place to protect personal data. Risk assessment, including assessing risks to the rights and freedoms of data subjects, is at the heart of our security measures. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.
9. Your rights as a data subject
In terms of the UK- GDPR you have the following rights:
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To be provided with details regarding the type of personal information being collected, processed and maintained
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Rectification of incorrect personal information that has been collected and stored by Clearsound Productions Ltd
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Subject to competing rights and legal obligations of Clearsound Productions Ltd, partial or complete erasure of your personal information because:
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Clearsound Productions Ltd no longer needs the personal information for the purposes that it has collected
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You wish to withdraw the consent that you gave for the personal information to be processes
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If the processing is based on furthering our legitimate interest you may object to such processing. This objection will be weighed against our rights and legal obligations to further process the personal information.
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The processing is unlawful
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Restrict the processing of personal information because:
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Of inaccuracies in the personal information
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The processing is unlawful
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Clearsound Productions Ltd no longer needs the personal information for the purposes that it has been collected
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If the processing is based on furthering our legitimate interest you may object to such processing. This objection will be weighed against our rights and legal obligations to further process the personal information.
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If the processing is based on furthering Clearsound Productions Ltd legitimate interest you may request that such processing be ceased. This objection will be weighed against our rights and legal obligations to further process the personal information
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Where the processing of personal information is based on furthering Clearsound Productions Ltd legitimate interest, to download such personal information in digital format
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Where the processing of personal information is based on consent, to withdraw such consent
You can exercise your right to prevent such processing by checking the relevant boxes on the online forms that we use to collect your personal data. You can also exercise the right at any time by contacting us directly.
Where we have shared your personal information in line with the provisions with this privacy policy, we shall take reasonable steps to inform all parties with whom we have shared the information of any request to have such personal information deleted.
Any of our websites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The GDPR gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request will be dealt with free of charge.
Changes to our privacy policy
You will be notified of any changes that we may make to our Privacy Policy in the future.
10. Contact us
Any comments, questions or suggestions about this privacy policy or our handling of your personal data should be emailed to hello@clearsound.co.uk
Alternatively, you can contact us at our HQ using the following postal address or telephone numbers:
GDPR Compliance Manager
Clearsound Productions Ltd
10 Tilemans Park
Shipston on Stour
CV36 4PR
United Kingdom
Telephone: 01608 66506
11. Complaints
Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.
Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority within the European Union. For the United Kingdom, this is the Information Commissioner’s Office (ICO), who is also our lead supervisory authority. Its contact information can be found at https://ico.org.uk/global/contact-us/.