Privacy Notice

Policy Updated November 2020

1. Overview

1.1 This Privacy Notice applies when you visit or use our website. Further Privacy Policy statements and documents may apply offline and these are available, if relevant, on request

1.2 This site is owned by Inclarity Communications Ltd whose Registered office is situated at 1 Lyric Square, Lyric Square, London W6 0NB

1.3 Our Company registration number is 07193672. We are the ‘data controller’ of any personal information you provide to us

1.4 We are registered as a Data controller with the Information Commissioners Office our registration number is: ZA 801527

1.5 We have appointed a Data Manager who is Mr Rashesh Rao (rashesh.rao@inclarity.co.uk)

1.6 You can contact our Data Manager at our postal address given above or via email at privacy@inclarity.co.uk if you have any queries regarding this policy

1.7 As a Data Controller, we will take all the necessary steps to comply with the GDPR and Data Protection Act 2018 and relevant subordinate legislation when handling any personal data which you may provide to us

This includes ensuring that data is:

1.7.1 Fairly and lawfully processed

1.7.2 Processed for limited purposes

1.7.3 Adequate, relevant and not excessive

1.7.4 Accurate and Secure

1.7.5 Not kept longer than necessary

1.7.6 Processed in accordance with your rights

1.7.7 Not transferred to countries outside the UK without safeguards

1.8 We are committed to protecting and respecting your privacy when visiting our website and providing us with your personal information and this privacy policy statement summarises what personal details we may collect from you before, during or after you use our site and what we will do with them

1.9 Use of Third Party Computer Applications for Video conferencing: Where we engage with you Online using a Video Conferencing Application the following will apply:

1.9.1 All participants in Video conferencing will be given specific log in details

1.9.2 We operate in accordance with our Video Conferencing Privacy policy

1.9.3 We as Data Controller will manage the Personal Data shared by participants and restrict or control access as necessary for the security of other participants and to prevent cyber security issues such as Phishing

1.9.4 Password access will be controlled by the Moderator and individual passwords issued where an increased risk is perceived such as large groups or public access

1.9.5 A full Legitimate Interest Assessment Test and Privacy Policy on Video Conferencing is held within our Offline Company Compliance Documents

1.10 Please Note: This Online Privacy information is a precis of our detailed written policies which are held at our business premises. Please contact our Data Manager if you require further information regarding our data protection compliance procedures

1.11 We will review and update this Privacy Policy from time to time and all changes will be posted to this page

2. Our Privacy Notice and Data Protection policies:

2.1 We are committed to protecting your personal privacy and, in accordance with relevant data protection laws, we uphold strict security procedures for the collection, storage, use and disclosure of your personal information

2.2 We have described below the personal information we may gather about you, the purposes for which we will hold it and the limited categories of people to whom we may disclose it

3. What information do we collect and how may we use it?

3.1 During your visit to our site, we will only collect personal information that you choose to provide. If, for example, you contact us with an enquiry or request us to provide you with further information

3.2 If you share other people’s data with us, for example if you order on behalf of another Company, you will need to check that Company consents to you providing their information and you are responsible for the transmission to us of the information

3.3 We may process data about you from various sources and use it to contact you if it is in our Legitimate Interests to do so and we have completed the necessary formalities required under the data protection legislation and guidelines

3.4 In all cases, the purpose of our contacting you will be made clear and you will be provided with information with which to contact us if you would like us to stop processing your data

4. We may use the information held about you in the following ways:

4.1 To administer any account you have with us

4.2 To perform our contractual obligations to you

4.3 To respond to your queries and requests

4.4 To communicate with you

4.5 To ensure that the content of our site is presented in the most effective manner

4.6 To provide you with the information, products and services requested from us

4.7 To provide you with helpful information about our products or services

4.8 To make improvements to the service we provide you

4.9 We also reserve the right to disclose your personal information where we are required to do so by law, such as to assist in any disputes, claims or investigations relating to your account or contracts with us and to detect and prevent fraudulent transactions

4.10 E-mail correspondence with us via our website and email addresses accessible through or obtained from this site may be recorded and/or monitored

5. How do we store and protect your data?

5.1 We take the security of your information seriously and we will endeavour to ensure that the personal information you submit to us is kept private and secure

5.2 Data we receive and process is held by us in secure electronic devices and separate back up devices and servers

5.3 Personal Data may also be held in encrypted 3rd party ‘Cloud’ Servers

5.4 Further encrypted back ups of data may be held securely in offsite locations which are also subject to physical security at their location

5.5 We will not sell, rent or otherwise disclose the personal information you provide to us through the site to third parties (other than as listed below) unless we are required to do so by law

6. Third parties who provide services on our behalf

6.1 We may share your personal information with certain third parties who provide services on our behalf

6.2 Such 3rd Parties only have access to the personal information they need to perform those services

6.3 Such 3rd parties are bound by contractual arrangements with Ourselves in accordance with Data Protection legislation and are required to keep your personal information secure and confidential. They may only use it as permitted by us in accordance with our Privacy Policies

6.4 If you have contracted with us we will share data only to the extent necessary for the performance of the contract, otherwise we will obtain specific consent from you before sharing your data

6.5 The third parties who provide services on our behalf fall into the following categories:

6.5.1 Our partners providing logistics and external service support

6.5.2 Our business partners or advisors for the purposes of completing or investigating a transaction with you

6.5.3 Marketing agencies appointed to provide services to us

6.5.4 The service providers operating this site on our behalf

6.5.5 Accountants, auditors, law firms, payment processors, information technology support providers

6.5.6 Advertising services, analytics services, Computer Application and content providers

7. How long do we store your data?

7.1 We will not keep your data for longer than is necessary for the relevant purposes set out in this Privacy Notice or our Company Compliance Policy

7.2 Where you have purchased a product or service from us, we will hold your relevant personal details to enable us to administer the contract and provide such after-sales services as may be required

8. Your rights

8.1 Under the General Data Protection Regulation (GDPR) and The Data Protection Act 2018 (DPA) you have a number of rights with regard to your personal data

8.2 You have the right to request from us access to and rectification or erasure of your personal data; the right to restrict processing; the right to object to processing as well as in certain circumstances the right to data portability as below

8.3 In the event that you provide your data directly to us for the purpose of a contract, or in circumstances where you have to provided your data by consent, you have the right to be provided with your data in a structured, machine-readable format. This is known as Data Portability

8.4 Following a request relating to Data Portability we will transmit the relevant personal data to the data subject or their nominated data controller where it is possible and technically feasible for us to do so

8.5 Please note we will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

8.6 Automated decision making and profiling means making decisions without human intervention, usually with the use of a computer program or software. We do not use automated decision making software

8.7 To exercise any of your rights contact our Data Manager using the details given above

9. Lawful bases for data processing

9.1 We hold and process your data by lawfully allowed means, these include:

9.1.1 Your Consent: Consent is usually given by yourself when you contact us via this Website or personally when we discuss products or advice with you

9.1.2 Contractual obligations: This occurs when you purchase products or services from us

9.1.3 Legal Obligation: When the processing is necessary for us to comply with the Law

9.1.4 Vital Interests: When the processing is necessary to protect someone’s life

9.1.5 Public Task: When the processing is necessary for us to perform a task in the public interest or for an official function and the task or function has a clear basis in Law

9.1.6 Legitimate Interests: When the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests

N.B. Legitimate Interests can only be used following the application of the prescribed three part Legitimate Interests Assessment Test and then only when a positive outcome is indicated by the conclusions of the test. All Legitimate Interests Assessment Tests must be documented, recorded and retained

10. Children’s data

10.1 Our site is not directed at children and should not be accessed by them. We will not knowingly collect information from minors without their parent’s or guardian’s consent

11. Third Party Websites

11.1 From time to time our site may contain links to and from the websites of our suppliers or other third party sites

11.2 If you visit any of these sites you should confirm they have their own privacy policies and you should check these before submitting any personal data on their site. We cannot accept any responsibility or liability for the policies on any other Websites

12 Data Access

12.1 You have rights of access to the data we hold about you. Should you wish to exercise these rights please contact our Data Manager whose details are given above

12.2 There is no charge for the Data Access service. As soon as we are satisfied as to your identity, we will send you, as soon as possible and in any case within one Month, the Personal Data we hold relating to you, which we are legally obliged to provide

12.3 Please contact us if you believe that any personal data or information which we hold about you is incorrect or incomplete. Any information or data which is found to be incorrect will be corrected as soon as practicable

12.4 Please contact us if you wish to have your personal data removed entirely from our systems. As soon as we are satisfied as to your identity and the data is not required to be kept for any other lawful reason or purpose it will be removed from our systems forthwith

12.5 If you so wish, your Data is provided to you electronically in a commonly used format such as email

12.6 If you are unhappy with any of the responses given to you by us you may complain about us to the Regulator at the Information Commissioners Office on 0303 123 1113 or through their website www.ico.org.uk

13. Business Transfer or Sale

13.1 In the event our business, or part of it, is taken over, bought or merged with another business we may need to disclose any personal data we are holding about you to the other Company so they can continue to provide services to you in accordance with this Privacy Policy

13.2 It may be necessary to transfer your data to a Company that is negotiating with us for the purchase of our business but only where it is necessary to evaluate the business purchase transaction. In this case your data would be kept safe and destroyed by the third party if the sale or merger did not go ahead

14. Changes to this policy

14.1 There may be developments in how we use your data according to changes in the Law

14.2 We reserve the right to make changes to this Data Protection and Privacy Policy at any time without notice and it is your responsibility to revisit this page from time to time to re-read this policy including any and each time you visit our website

14.3 Any revised terms shall take effect as at the date of posting

14.4 If you don’t find your concern addressed here, feel free to contact us by e-mailing our Data Manager; Mr Rashesh Rao (rashesh.rao@inclarity.co.uk)

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