Privacy Policy

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1. What Data is Covered?

This policy details the obligations of CleverClogs Tutoring Limited regarding your rights under current UK and EU regulations, “General Data Protection Regulations” (GDPR). Your data will be processed, lawfully, fairly and transparently and only collected for specific, explicit and legitimate purposes and not processed further for any incompatible purposes other than the original purpose for collection.

In this Privacy notice, “ Personal data ” means any information relating to an individual who can be identified, directly or indirectly, in particular by reference to an identifier such as names, an identification number such as a National Insurance number, location data or an online identifier such as an IP address.

Personal data also refers to one or more factors specific to the physiological, genetic, mental economic, cultural or social identity of an individual.

“Special Category Data” may be collected and from which we can determine a person’s;

• Political Opinions
• Religious or philosophical beliefs
• Genetic data
• Racial or ethnic origins

2. Purposes for which we collect and process personal data.

For the performance of our professional Services;

The data we collect depends upon the services provided to you, and we only process personal data for the purpose for which it was collected.

The purposes for which we process data and the legal basis for doing so

Clients; -

• for the performance of any contract we enter in to with you or pre-contract due diligence enquiries should no contract subsequently be entered in to
• for either our or your legitimate interest
• in respect of any legal obligation we are subject to
• where you have provided your consent for us to do so
• where necessary to do so

Visitors to the CleverClogs Tutoring Ltd website - We also collect personal data about you when you visit our website.

Information which you provide to us voluntarily - for example when completing an online form to contact us, or when agreeing to subscribe to a newsletter or when registering with us to receive our services. Such voluntary information may be in the form of;

• Name
• Address
• Contact information such as mobile number, email address and other telephone numbers
• Demographic information such as postcode any preferences and interests
• Any other relevant information to enable us to offer and supply our services to you

Any information which you provide on this basis which may be sensitive is not collected or processed intentionally. Such information is provided by you on a voluntary basis and you acknowledge and agree that such information may be processed by us.

If you register on our site and/or instruct us in respect of our services, your personal data is collected and stored in our system and any data held on individuals who have not been engaged, or ceased to be engaged by us, is deleted after a period of 18 months or sooner if required by law.

If you opt out of any of our services, your basic data will remain on our opt out list.

Cookies - Data which is automatically collected when you visit our site through cookies - when you visit our site we automatically collect certain personal data from your device, if you allow us.

Through our website, in allowing cookies (which are small files) they will transfer this small file to your computer hard drive through your web browser. This enables the site (or our service provider) to recognise your browser and capture and remember certain information. Such data is;

• IP address
• Unique device identifier number
• Device type
• Browser type
• Geographical location e.g. country or city location
• and other technical information

We collect this information to improve the services supplied to you and it enables us to better understand the visitors to our site.

Further information on our cookies is available by reading our Cookie Policy.

The purposes for which we collect and/or process Your personal data as a visitor to our site; -

• To assist in administering and managing our site.
• For site security, for example to authenticate Your identity and to prevent unauthorised access to the site.
• To more personalise your visits to our site, so we may enhance your experience.
• To analyse visitor data so as to enhance our marketing and other communications.
• To understand which features of the site visitors use.
• To assist us in monitoring and enforcing all relevant regulations and applicable compliance.
• To assist us in continual risk management assessment.
• Any other purposes for which you provide us with your information.

Legal Grounds for processing personal data of visitors to the site; -

• For the effective and lawful operation of our business.
• To improve and develop our site to enhance visitor experience.
• Any matter for which we have been given your explicit consent.

If you would like to know more about cookies please go to www.allaboutcookies.org

Other purposes we may collect personal data from you can be; -

3. Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

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Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service.

• Google Analytics - Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visitors’ activity.
  For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
• Hotjar - We use Hotjar in order to better understand our users’ needs and to optimise this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymised user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.
• Smartlook - Your personal data might be collected by us or 3rd parties, such as Smartsupp.com, s.r.o., VAT ID CZ03668681.

4. Transfer of Personal Data and its Security

We take all appropriate security and legal precautions to safeguard the safety and integrity of all of your personal data that is collected and used within the company. Your personal data will only be accessed by persons within the company who have a legitimate need to do so.

Access to the confidential data we collect is limited and we have policies and procedures in place to safeguard your information from loss, misuse and improper disclosure.

All of our employees are subject to a company privacy and confidentiality policy which ensures that they are contracted to understand your confidentiality requirements and will work to the best of their ability in line with this policy.

5.Your Rights and our Complaints Procedure

You have the following rights in relation to your personal data; -

• You may access the data we hold about you.
• If you note that your data is incorrect or incomplete you have the right to have that data corrected.
• You may opt out of any of the services provided, but please note some services we may be unable to provide should you do so.
• You may request that we delete your personal data (this subject to any legal requirement where we may have to retain such data).
• You may request a copy of your personal data held; this may take up to thirty (30) days.
• You have the right to withdraw your consent to the use of any of your personal data for which you have previously given your consent to the use of.
• You have the right to complain to the Data Protection Authority, such a complaint should be directed to the authority in your country or a relevant court of competent jurisdiction. We do however have a complaints procedure and we will deal with any complaints you may have. Any such complaint should be directed to us. We will acknowledge your complaint and ensure it is investigated honestly and fairly and inform you how it will be handled.

If you have any other queries or wish to exercise any of your rights in respect of your personal data please contact us on support@cleverclogs.co. We will do our very best to deal with the matter to your satisfaction.

You may also complain directly to https://ico.org.uk/

6. Who we disclose your Personal Information to

We will disclose your personal information to the following: -

• As described in clause 2 of this policy
• If required by law.
• If we believe disclosure is appropriate to enforce any of our terms and conditions, to protect and defend our rights, property or safety.
• In compliance of any court order, proceeding or under any other legal obligation, regulatory or government requirement where we are specifically directed to do so.
• With your consent.

Third Party Recipients of Personal Data include; -

• Professional Advisors such as law firms, tax advisors or auditors all of whom are subject to privacy and confidentiality laws and regulations.
• Regulatory and other such bodies.
• Providers of identity verification services.
• The Courts, police and other relevant law enforcement agencies.
• Relevant Government departments and agencies.
• Our Service Providers.

7. How long do we retain your personal information?

We retain your personal information only as long as it is needed by us, see clause 2. Thereafter we only retain any information as long as it is required under the regulatory requirements, we are subject to.

To ensure we meet our legal liabilities we may retain some information for a significant time. Examples of the reason for this could be, to protect, defend or exercise our legal rights or for archiving and historical purposes.

8. Data Security and Breaches

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

If there is a security breach, or a suspected security breach we will inform you of the breach or suspected breach as immediately as it is known to us and report it to the appropriate regulatory body.

Once such a breach is discovered we will use all reasonable business measures to correct the breach and prevent any further breaches and recover or delete any lost information.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws (General Data Protection Regulations) in relation to your personal data. Specifically, you have the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. We ask that you update us with any changes to your personal information.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Recruitment - personal data may be collected directly from a job applicant, or indirectly via a recruitment agency when you or they correspond with us by telephone, email or online.

10. Other Legal Compliance

Children’s online privacy protection - The Company is in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act). The Company does not collect any information from any person under the age of 18 years old. The company website, its products and services are directed at people who are over the age of 16.

Because the Company values your privacy, we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We will therefore not distribute your personal information without your consent.

11. Changes to this Policy

We will, from time to time, make changes to this policy. This may be to ensure that we continue to be in line with the legal requirements and any regulatory changes made in law. We may also change our practices to better serve our and your needs. We will revise the, “last updated’” date at the top of this notice and will, if such changes are material, post a prominent notice of the changes on the website.

We request that you read this policy from time to time and keep your personal information up to date at all times.