CLEARnotes privacy notice

Last updated: Jul 2024

Introduction

Welcome to 33n Ltd’s privacy notice.

This privacy notice gives you information where 33n (hereafter “we”, “us”, or “our”) is the Controller of your Personal Data. Please see the end of this privacy notice for a statement concerning where 33n is a Processor.

This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.

33n Limited is a registered limited company (Companies House No. 11004779) in the United Kingdom.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO at dpo@33n.co.uk.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

What personal data we collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

  • Identity Data includes your first name, surname, maiden name, title and/or prefix, the company you work for, the department you work in, your title or position, and your professional registration number.
  • Contact Data includes your email address and telephone numbers.
  • Performance Data includes ratings and scores you provide about how your experience of the service/website.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website, products, and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

How your personal data is collected

Direct interactions. You may give us your Identity, Contact Data, and Performance Data when you use the website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • sign up to our services;
  • log in or otherwise verify a user account associated with access to a service provided by 33n;
  • request marketing to be sent to you;
  • enter a scores, ratings, or comments using features available on the website; or
  • otherwise give us feedback or contact us.

Automated technologies or interactions. As you interact with our website/service, we automatically collect data about your usage and device information. This includes:

  • Usage Data: information about your interactions with our website, such as pages visited, time spent on each page, clicks, and navigation paths.
  • Technical Data: information regarding the device you use to access our website, including browser type, operating system, and device type.

This personal data is collected through cookies, server logs, and other similar technologies. Additionally, we may receive similar data about you when you visit other websites that use our cookies. For more details, please refer to our cookie policy.

Third parties or publicly available sources. We will receive Technical Data from analytics providers such as Google based outside the EU and other personal data about you from public sources.

How we use your personal data

  • Where we need to perform the contract, we are about to enter into with you or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

PURPOSE/ACTIVITY TYPE OF DATA LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
To manage our relationship with you which will include:
a) Account creation and site access
b) Notifying you about changes to our terms or privacy notice
c) Asking you to leave a review or take a survey
d) Customer services		 a) Identity
b) Contact
c) Marketing and Communications		 a) Performance of a contract with you
b) Necessary to comply with a legal obligation
c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) a) Identity
b) Contact
c) Technical		 a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences a) Technical
b) Usage		 Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you a) Identity
b) Contact
c) Usage
d) Marketing and Communications
e) Technical		 a) Necessary for our legitimate interests (to develop our products/services and grow our business)
b) Consent

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Performance Technical, and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have opted in to receiving that marketing.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see cookie notice.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

  • External Third Parties such as service providers who provide IT and system administration services.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

33n uses third-party processing tools and, as a result, may make limited amounts of international transfers as part of a processing tool’s data redundancy and back-up, policies and procedures. All such transfers are governed by suitable safeguards, specifically use of Standard Contractual Clauses, which ensure your personal information is treated by those third parties in a way consistent with, and which respects, EU and UK laws on data protection.

If you require further information about this protective measure, you can request it from the DPO (dpo@33n.co.uk).

Data security

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.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your legal rights

  • Right to access: the right to a copy of the personal information we hold about you.
  • Right to correct: the right to have your personal information rectified if it is inaccurate or incomplete. If we believe that your personal data is accurate, we will let you know that we will not be amending your personal information and why.
  • Right to erasure and to restrict our use of your information: the right to request that we delete or remove your personal information from our systems. Data protection laws give exceptions to this right which, if applicable, we will explain in our response to you.
  • Right to restrict our use of your information: in some circumstances you can ‘block’ us from using your personal information or limit the way in which we can use it.
  • Right to data portability: the right to request that we move, copy or transfer your personal information.
  • Right to object: the right to object to our use of your personal information including where we use it for our legitimate interests, or where we use your personal information to carry out profiling to inform our market research and user demographics. If you raise an objection, we will stop processing your personal information unless very exceptional circumstances apply, in which case we will let you know why we’re continuing to process your personal information. We may give you the option to hear from us by email about tips, news, and relevant 33n services and exclusives. You have the right to object to our processing of your personal information in this way.
  • Withdrawal of consent: where you have provided us with consent to use your personal information, you can withdraw this at any time.

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.

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.

We try to respond to all legitimate requests within one calendar month. Occasionally it could take us longer than a calendar 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.

Where we are a Processor of your Personal Data we will operate under the terms of a Data Processing Agreement with the relevant Controller.

This is generally data you input when directly using a service and may include information we receive from you relating to the performance of the website with regard to a specific usage, as opposed to more general performance of the website, (eg scores or comments provided by you), using features available on the website.

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