Last updated 18/05/2018
This notice sets out the basis which Inclarity collects personally identifiable information (‘Personal Data’), how we process this data, and how to contact us to discuss this data.
We collect and receive Personal Data from you via a) your use of our public websites and portals www.inclarity.co.uk, oms.inclarity.co.uk, smt.inclarity.co.uk, recording.inclarity.co.uk, wallboard.inclarity.co.uk (‘Sites’) and/or b) your use of our telecommunications products and services (‘Services’).
Inclarity Communications Limited is a UK limited company and is the data controller for processing of Personal Data for the Sites and Services. Inclarity Communications Ltd. is also a UK registered telecommunications provider, with certain regulatory obligations. If you wish to contact us relating to our processing your personal data, our contact details are set out below.
Inclarity’s general commitments to privacy are such that:
- We will only collect, keep, use and share Personal Data needed for the specific business purposes that are explained below, or if we are legally obliged to do so.
- We will be as clear and as transparent as we can with you regarding what Personal Data we collect and how it will be processed.
- For as long as we hold your Personal Data, we will take appropriate measures to secure it, and will provide you with the means to keep it up to date.
- We will not hold your Personal Data for longer than is necessary for the purposes that we initially collected and processed it.
Inclarity reserves the right to make changes to this notice, as required to by law, or as may be necessary to accommodate changes to Inclarity’s future business practices.
CUSTOMERS & RESELLERS
We collect the following data from or about you as an Inclarity customer or reseller, which may include Personal Data:
- Data collected directly from your business as a mandatory step of the service ordering process, including: a contact name, a contact telephone number, a contact email address, a postal address, and bank details for Direct Debit payment purposes.
- Data volunteered by your business – or inputted directly by you via our Sites – for the purpose of setup, delivery and configuration of Services, including: site contact name, site contact telephone number, site contact email address, site postal address, telephone subscriber number, telephone subscriber name, telephone subscriber email address, and telephone Subscriber alternative number, and any contact data uploaded into your Private or Shared Contacts.
Note that while is mandatory to provide Inclarity with contact, billing and site information for your organisation, it is entirely up to your organisation as to what Personal Data (if any) it provides to meet these business requirements.
We use the data collected from your business for the following legal reasons:
- because it is necessary to fulfil a contract that we have in place with you;
- where the processing is necessary for compliance with our legal obligations; or
- for our legitimate business interests.
Our contract with you as your telecommunication service provider means that we will need to process your data to:
- Deliver, support and maintain the Services that you have ordered.
- Bill you for the Services that you have ordered.
- Contact you with important updates concerning the status, features, and ongoing development of your active Services.
- Contact you with surveys or feedback requests.
- Contact you regarding any breach of Inclarity’s Terms & Conditions of business, Service Level Agreement or Acceptable Use Policy.
When you join Inclarity we will also invite you to give your consent to receive marketing communications from us by email.
When your contract with Inclarity is terminated, Inclarity reserves the right to hold your data for a period of no longer than 6 months in case we need to contact you concerning any matters relating to the cessation of your services and the payment of your final bill.
As a visitor of any of the pages on our website, through the receipt of a cookie from Google Analytics, we will record the fact that you have visited that page as an anonymised impression against that page. We do not collect any other data or attempt to identify you as part of this interaction.
Some of the pages on the Inclarity website may be related to emails you have received from us, where the email includes a link to the page with the intent of providing you with more information on the subject of the mail. Your click is entirely voluntary, but if made will result in us recording – through the use of a cookie – the fact that you clicked to view the page. We do not collect any other data or attempt to identify you as part of this interaction.
Some of the pages on the Inclarity website include forms that can be filled in by you voluntarily to request more interaction with Inclarity. In each case, the web page containing the form will clearly state how the data volunteered by you will be used.
Also see our statement on Cookies below.
We count the aggregated impressions of our web pages to measure website performance, the success of our email notices, and to compare monthly and annual trends.
Typically an interaction triggered by your voluntary web form submission will be to provide you with the information about our Services that you have specifically requested, and if you do not subsequently agree to any further interaction, your details will be deleted.
Your use of any of our Sites is not dependent on cookies, and there is no mandatory requirement for you to accept cookies.
Analytics/ Performance Cookies
As noted above, upon receipt of an email from Inclarity which contains a link to an Inclarity web page, if you voluntarily click on the link we will record your visit, based on a tracking cookie which is downloaded by your browser as part of this interaction. You may refuse or disable this cookie by updating the appropriate settings in your browser.
Also as noted above, Google Analytics, a web analytics service provided by Google, Inc. (“Google”) places cookies on your computer each time you visit our Sites, to enable Google to provide us with activity reports relating to the Sites. Google uses this data only to provide us with information on how users use the Sites and does not associate your IP address with any other data held by Google. The information generated by Google cookies about your use of the platform (including your IP address) will be transmitted to and stored by Google on servers in the United States. You may refuse or disable these cookies by selecting the appropriate settings on your browser or by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB.
Inclarity will not sell your information. We will also not share your information with any third party, except as stated in this Privacy Notice, or as required to operate our Sites, supply you with Services, to administer your account, or otherwise as required to or permitted by law.
We use third party data processors to collect, export, process and store data on our behalf, which may include Personal Data. The processors we are currently using include:
- For call reporting: Akixi, http://www.akixi.com/privacy-policy/
- For call recording
- For billing and invoicing: PRD, http://www.p-rd.com/
- For UK emergency services and directory services: British Telecom https://www.productsandservices.bt.com/privacy-policy/
- For payment processing:
- For web site hosting, management, and analysis:
- Word Press, https://automattic.com/privacy/
- AWS, located in the UK and the USA (Privacy Shield Certified), https://aws.amazon.com/privacy/
- Now Communications, https://www.nowcomms.com/privacy-compliance-statement/
- Big Group, https://www.biggroup.co.uk/privacy
- Google Analytics, located in the USA (Privacy Shield Certified), https://www.google.com/policies/privacy/
- Autopilot, located in the USA (Privacy Shield Certified), https://autopilothq.com/privacypolicy.html
- Lead Forensics, https://www.leadforensics.com/privacy-and-cookies/
- For web chat services: Natterly, https://www.natterly.com/privacy-policy
- For online surveys: Survey Monkey, located in the USA (Privacy Shield Certified), https://www.surveymonkey.com/mp/policy/privacy-policy/
YOUR PERSONAL RIGHTS
Your rights in relation to your personal information include:
- the right to request access to your personal information (a “subject access request”);
- correct any mistakes on our records;
- erase or restrict your personal information where they are no longer needed for the purpose for which they were obtained or used;
- object to our use of personal information based on legitimate business interests, including for profiling and marketing;
- (where we rely on your consent to process your personal information) the right to withdraw consent to the processing of your personal information, and
- In certain circumstances, receive a machine-readable copy of your personal information.
It is free to make a request to us to exercise your rights. However, we may charge a reasonable fee if your request is clearly unfounded, excessive or repetitive. We will handle any request to exercise your rights in accordance with the relevant data protection laws.
To exercise any of these rights please email us at firstname.lastname@example.org.
To assist us in dealing promptly with your request, please make it clear what right you would like to exercise and provide us with the following information:
- Your full name (first name and surname)
- Your contact details for further correspondence (either email or postal address)
- Details of the type of personal information you are seeking
To honour your request Inclarity may also require you to provide proof of your identity.
You also have the right to make a complaint about how we process your personal data or respond to you following a request to exercise any of your personal data rights. Your complaint should be directed to the UK data protection supervisory authority: the Information Commissioner’s Office (ICO). We would request that, if you are not satisfied with a response from us, you first give us the opportunity to resolve the matter to your satisfaction before making any complaint to the ICO.