Platforms privacy notice
This policy, sets out how we may collect personal data from you, when we may collect person data from you, the type of personal data and/or sensitive personal data we may collect from you or that you provide to us, and how such data may be controlled and/or processed once you have registered to use the www.clarity.app website and/or the Clarity app (together the “Platforms”).
By providing us with your data, you warrant to us that you are over 13 years of age.
Curious Fu Limited is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.
Our full details are:
Full name of legal entity: Curious Fu Limited. 3rd Floor, 3 Fitzhardinge Street, London, W1H 6EF
Data Protection Officer Becks Armstrong
Email address: email@example.com
Postal address: 3rd Floor, 3 Fitzhardinge Street, London, W1H 6EF
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at firstname.lastname@example.org
WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
- Communication Data that includes any communication that you send to us whether that be through the contact form on our Platforms, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
- User Data that includes data about how you use our Platforms and any online services together with any data that you post for publication on our Platforms, or through other online services. We process this data to operate our Platforms and ensure relevant content is provided to you, to ensure the security of our Platforms, to maintain back- ups of our Platforms and/or databases and to enable publication and administration of our Platforms, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our Platforms and our business.
- Technical Data that includes platform data, but is not limited to, your device’s Internet Protocol (IP) address, web cookies, browser type and version, the pages of our Platforms you visit, the amount of time spent on each page of our Platforms, time zone settings, the time and date of your visit and the operating system or platform you use, information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Platforms (including date and time), any products you have viewed or searched for, page response times, download errors, use and length of visits to certain pages within the Platforms, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. Platform Data is collected by us when it is transmitted to us during or after your use of the Platforms. We process this data to analyse your use of our Platforms, and other online services, to administer and protect our business and Platforms, to deliver relevant Platforms content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our Platforms and our business and to grow our business and to decide our marketing strategy.
- Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant Platforms content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
- We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant Platforms content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
We need to collect the following sensitive data about you in order to tailor the Platforms experience to your needs:
i) Necessary Data. This is data we must collect in order to activate, and provide you with access to your app account, as well as to enable you to access and use your account across multiple devices, to enable you to delete personal data when you wish, and/or for us to fulfil any order for products or services you place through the Platforms. We may also use Necessary Data for the purpose of providing you with information about similar products and services we provide.
Necessary Data includes, but is not limited to, your name, email address, your login information, billing address and delivery address.
Necessary data will be collected by us when you fill in and submit the relevant form through the Platforms which contains that data.
ii) Optional Data. This data includes information which is not necessary for us to collect but which you actively choose to provide to us (“Optional Data”).
Optional Data includes, but is not limited to, your age, your reasons for using the Platforms or product and the symptoms you are experiencing. We may also use Optional Data for the purpose of analysing your requirements as a consumer and providing you with information about other products and services we provide which may be of interest to you.
Optional Data will be collected by us when you submit an optional form through the Platforms which contains that data.
You may be able to actively provide us, at any time in the future, with additional Optional Data if you choose to do so. We will collect and use that data in accordance with these terms.
Platform Data includes, but is not limited to, your device’s Internet Protocol (IP) address, web cookies, browser type and version, the pages of our Platforms you visit, the amount of time spent on each page of our Platforms, time zone settings, the time and date of your visit and the operating system or platform you use, information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Platforms (including date and time), any products you have viewed or searched for, page response times, download errors, length of visits to certain pages within the Platforms, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. Platform Data is collected by us when it is transmitted to us during or after your use of the Platforms. Such data may or may not be anonymised and will be used as further described in paragraph 6 below.
We require your explicit consent for processing sensitive data, so when you submit your details, we will give you a further communication asking for you to confirm your consent to this processing.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at email@example.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We carry out automated decision making and automated profiling as outlined in section 2. ii) optional data. We use the information from your self identified systems to tailor the recommended content for the platforms.
HOW WE COLLECT YOUR PERSONAL DATA
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share personal data with the parties set out below:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers
- Government bodies that require us to report processing activities.
We may share anonymized personal data with the parties set out below:
- Service providers who provide market research and fraud prevention agencies
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
- We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org
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 or 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 month. Occasionally it may 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.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
This Platform may include links to third-party Platforms, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party Platforms and are not responsible for their privacy statements. When you leave our Platforms, we encourage you to read the privacy notice of every Platform you visit.