Claromentis Privacy and Cookie Policy

Claromentis has created this privacy statement in order to demonstrate our firm commitment to privacy. We operate websites based in the UK, Europe, Australia, and United States of America.

These websites are owned by Claromentis Limited or its wholly owned subsidiaries. As the central administration for the websites is based in the UK we apply UK law to the privacy principles for each one. This Privacy Statement also applies to any other websites we may establish in the future, in any location, and which are not specifically named here.

2. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

3. Claromentis Ltd

These websites are owned and operated by Claromentis, a limited company registered in England under company number 03672955, whose registered address is Cardens Accountants, The Old Casino, 28 Fourth Avenue, Hove, East Sussex, BN3 2PJ, and whose main trading address is Claromentis Ltd, 6th Floor, Vantage Point, New England Road, Brighton, East Sussex, BN1 4GW.

Our Data Protection Manager is Will Emmerson, and can be contacted by email at data-protection@claromentis.com, by telephone on UK) 0800 409 6101 US) 1 (844) 238 6868 , or by post at Claromentis Ltd, 6th Floor, Vantage Point, New England Road, Brighton, East Sussex, BN1 4GW.

4. Your Rights

1) As a data subject, you have the following rights under the UK GDPR, which this Policy and our use of personal data have been designed to uphold:

• The right to be informed about our collection and use of personal data
• The right of access to the personal data we hold about you (see section 10)
• The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details in section 12)
• The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (we only hold your personal data for a limited time, as explained in section 6 but if you would like us to delete it sooner, please contact us using the details in section 12)
• The right to restrict (i.e. prevent) the processing of your personal data;
• The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation)
• The right to object to us using your personal data for particular purposes; and
• Rights with respect to automated decision making and profiling.

2) If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 12 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

3) For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What data do we collect?

6. How do we use your data?

1) All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the UK GDPR at all times. For more details on security see section 7, below.

2) Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:

• Providing and managing your access to our websites
• Personalising and tailoring your experience on our websites
• Supplying our products and services to you – please note that we require your personal data in order to enter into a contract with you
• Replying to emails from you
• Replying to messages from you that are sent via Hubspot.
• Supplying you with emails sent from HubSpot when you download a brochure/advice guide/e-book on our websites, which provides you with a link to the download and follow-up emails with content offers that are relevant to you (you may unsubscribe or opt-out at any time by clicking the “unsubscribe” link at the bottom of the email, which will allow you to unsubscribe from our HubSpot campaigns). The Sales team may also contact you directly via email and/or telephone (if provided) to see if they can help you with further information.
• Supplying you with emails sent from HubSpot when you request an instant access demo (“try our software”) for workplace.claromentis.com which provides advice on how to use the demo, information about a selection of our clients, and information about how to pursue your interest in Claromentis further (you may unsubscribe or opt-out at any time by clicking the “unsubscribe” link at the bottom of the email, which will allow you to unsubscribe from our HubSpot campaigns). The Sales team may also contact you directly via email and/or telephone (if provided) to see if they can help you with further information.
• Supplying you with emails sent from HubSpot after a period of time subsequent to your initial interest in Claromentis (downloading a brochure/advice guide/e-book or requesting an instant access demo (“try our software”)) which provides you with relevant information about Claromentis products and/or services which we think you may find interesting (you may unsubscribe or opt-out at any time by clicking the “unsubscribe” link at the bottom of the email, which will allow you to unsubscribe from our HubSpot campaigns).
• Supplying you with any other emails/newsletters that you have explicitly opted into (you may unsubscribe or opt-out at any time by clicking the “unsubscribe” link at the bottom of the email, which will allow you to unsubscribe from our HubSpot campaigns).
• Market research
• To gain feedback and opinion on the product and/or services that we provide
• We may contact customers either directly or via a third-party service to request a review based on the customer’s experience of our product and/or services.

3) With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email with information, news and offers on our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with our obligations under the UK GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

4) Third parties whose content appears on our websites may use third party cookies, as detailed below in section 9. Please refer to section 9 for more information on controlling Cookies. Please note that we do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.

5) You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it. Please refer to section 10 for details on how to do this.

6) We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

• Personal data used for Newsletters/Marketing: We’ll maintain a list of subscribers who are actively participating in our email campaigns. If the subscriber signed up over 5 years ago AND hasn’t opened any of the last 5 campaigns we will remove and delete any personal data for this subscriber.
• Personal data used to communicate with potential customers will be kept for up to 5 years after the initial enquiry or until requested otherwise (see section 10)
• We’ll store any personal data used in order to fulfil our contractual obligations for the product and/or service that we provide, for the length of the contract and for up to 5 years after the contract has been terminated.

7. How and where do we store your data?

We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.
Some or all of your data may be stored outside of the European Economic Area (“the EEA”). You are deemed to accept and agree to this by using our website and submitting information to us. If we do store data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as the EU or UK and we’ll only provide access to personal data for sub-processors based outside of the EEA so long as they are based in countries that are deemed to have “adequate protection” according to the UK GDPR article 45 of Regulation (EU) 2016/679. For any sub-processor that is based outside of the EU (for example, in the United States) but are classified by the European Commission as providing “adequate” levels of personal data protection, we will endeavour to sign a DPA with these sub-processors to ensure we have SCC’s with these service providers.

Our SaaS platform can be hosted in any one of the following regions, depending on your needs:

• London (europe-west2)
• Frankfurt (europe-west3)
• South Carolina (us-east1)

By signing our SaaS Agreement you are also agreeing to our DPA (Data Processing Agreement) which is available to view at the following link: Data Processing Agreement

Here are some of the controls that we use to comply with the UK GDPR and ensure the privacy of your data:

We thoroughly review all new sub-processors by conducting a Data Protection Impact Assessment in order to validate the compliance and controls of the sub-processor, assess the risks, and to ensure adequate protection is put in place to mitigate any risks. We update new and existing clients when there are any changes to our list of sub-processors.

Our team maintains a central register of all data so that it’s clear why we’re collecting data, what type of data is collected and how, and a description of any transfer of data.

We maintain security controls according to HIPAA and ISO 27001 standards. This includes, but is not limited to, secure hosting with Google Cloud Platform (https://cloud.google.com/security/overview/whitepaper), strong encryption, background checks for staff, regular vulnerability scanning, monitoring, firewalls, endpoint protection, incident management, and regular audits.

8. Do we share your data?

Personal information will not be released to any other third parties (such as a Claromentis Business Partner) except to progress the matter for which you provided the information in the first instance unless the release of your personal information is required by law or is pertinent to governmental or judicial investigations or proceedings.

‘Business Partners’ are defined as Distributors, Resellers, or Channel Partners of Claromentis with each one delivering varying levels of goods or services depending upon their relationship with Claromentis. If you have any concerns about a particular Business Partner, whether they are listed or not, you should contact us before you provide us with your personal information.

The Claromentis & Claromentis websites may contain links to other, external websites. Operation of these links will not cause your personal information to be transmitted to these sites. Likewise, Claromentis cannot be held responsible for the Privacy Principles of other entities.

We may sometimes contract with third parties to supply services to you on our behalf. These may include search engine facilities, analytics, advertising, and marketing. 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.

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.

We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EU/UK and under the UK GDPR.  We ensure compliance with the EU and UK GDPR by including Standard Contractual Clauses within our DPA, which you can sign here: Data Processing Agreement

Please see the list below for a summary of our key sub-processors:

9. Cookie policy

Our websites may place and access certain first party cookies on your computer or device. First party cookies are those placed directly by us and are used only by us. We use cookies to facilitate and improve your experience of our websites and to provide and improve our services. We have carefully chosen these cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using our websites, you may also receive certain third party cookies on your computer or device. Third party cookies are those placed by websites, services, and/or parties other than us. Third Party cookies are used on our websites for the reasons shown in the table below.

All cookies used by and on our websites are used in accordance with current laws under the UK GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003;

By giving your consent to the placing of cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to or block the placing of cookies (including essential cookies); however certain features of our websites may not function fully or as intended or you may not be able to access all or parts of our website. Certain features of our websites depend on cookies to function.

The following essential cookies/scripts may be placed on your computer or device:

The following first party cookies may be placed on your computer or device:

and the following third party cookies may be placed on your computer or device:

Marketing cookies/scripts

Analytics cookies/scripts

Personalisation cookies/scripts

How to manage or opt out of cookies

You can manage your cookies by loading the cookie banner here and clicking “Cookies Preference Centre”.

You can choose to delete cookies on your computer or device at any time, however you may lose any information that enables you to access our website more quickly/efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

10. Request for access / accuracy & retention of data

The Claromentis product: We provide services to organisations, rather than end users. It is therefore the organisation who is the Data Controller, according to the U GDPR. As an end user of our product and in the first instance, you can edit your profile within the Claromentis product. Some fields may not be editable if these fields are synchronised from an external Identity Provider, User Directory, or if they are restricted fields, controlled by an intranet administrator. You can contact your intranet administrator if you would like to amend/delete personal data or to have your account deactivated, if required. Please speak to the Data Protection Officer/Manager at your organisation if you have any further questions about data privacy when using the Claromentis product.

Our websites: This applies to any data held by us related to websites we control for the purposes of Sales and Marketing, Billing/Administration or Support. You have the right to access, correct, amend or delete personal data held by us (where such data is held). Under the UK GDPR, no fee is payable and we will provide any and all information in response to your request free of charge. Please contact us for more details at data-protection@claromentis.com, or by using the contact details below in section 12.

11. Your Right to Withhold Information

You may access our websites without providing any data at all. However, to use all features and functions available on our websites you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see section 9 (our cookie policy).

12. Contacting Us

If you have any questions about our websites or this privacy policy, please contact us by email at data-protection@claromentis.com, by telephone (UK) 0800 409 6101, (US) 1 (844) 238 6868, or by post at Claromentis Ltd, 6th Floor, Vantage Point, New England Road, Brighton, East Sussex, BN1 4GW. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 10, above).