Privacy policy
About This Privacy Policy
Clue Computing Co. Ltd (Clue Software) has produced this privacy policy to set out the ways we gather, use and manage personal data.
This privacy policy is designed to inform you and help you understand how we collect and use your personal data in the following circumstances:
- when you visit our website https://clue.them-sparks.co.uk (the Website);
- sign up for a newsletter; or
- purchase a product or service.
We keep our privacy policy under regular review and reserve the right to amend or modify this privacy policy at any time, including in response to changes in applicable data protection and privacy legislation.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy applies to the extent we act as a data controller. Separate documentation will apply when we act as a data processor on behalf of our customers.
Whilst this policy includes all information that Clue Software collects, not all information will be relevant to all circumstances. Specific scenarios are detailed within the ‘What the information is used for’ section of this policy.
For the purpose of the General Data Protection Regulation, UK GDPR and UK DPA18, the data controller is Clue Computing Co. Ltd. If you have any questions about this privacy policy or about our processing of your personal data, please contact the Data Protection Officer (DPO) using the following contact details:
Our Contact Details:
Clue Computing Co. Ltd, Clue House, Central Trading Estate, Petherton Road, Hengrove, Bristol, BS14 9BZ.
Telephone: 01275 890130
Email: [email protected]
What Type of Information we Have and how we use it
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.
It is important that the personal data we hold about you is accurate and up-to-date. Please keep us informed if your personal data changes during your relationship with us.
We only collect, use and store your information where we have a lawful basis to do so. We currently collect and process the following types of personal data about you:
- Name
- Title
- Job title
- Business address, email address and telephone numbers
- Technical data, including your internet protocol address, browser type and version
- Information about how you use our Website, products and services and respond to campaigns we run
- Your preferences in receiving marketing from us and our third parties and your communication preferences
How we get Information and why we Have it
Information is provided by you to Clue Software to fulfil several business needs. Specifically, these are:
Information collected from you
Where we have collected information directly from you it will usually be obvious what this is, as you will have given it to us. However, we use different methods to collect personal data from and about you including:
- Through direct interactions, including where you:
- subscribe to our marketing;
- correspond with us by post, phone, email or otherwise;
- fill in forms on our Website;
- complete a survey; or
- give us feedback or contact us.
- Through automated technologies or interactions. As you interact with our Website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this data using cookies and other similar technologies.
Information collected from others
Clue Software use some third party data providers like lead generation companies. A list can be provided if required by contacting the DPO.
Other people may provide us with information about you. For example, someone else in your organisation might provide us with your contact details, or someone outside your organisation might refer you to us and give us information about you that way.
What the information is used for
We have identified four lawful bases which we use to collect and process data.
Explanations of each of these are provided below, and beneath the title of each section regarding what the information is used for we have listed the lawful basis which is applicable to that purpose.
‘Contract’ – the information is needed to perform the contract we are about to enter into or have entered into with you (including where necessary to manage your account, product or service)
‘Legal obligation’ – where we need to comply with a legal obligation or we are required by law to process your information e.g. to verify your identity
‘Legitimate interest’ – where it is necessary for our legitimate interests (or those of a third party) and on balance, your interests and fundamental rights do not override our legitimate interests
‘Consent´- in some cases we may obtain your consent to use information in a particular way or where the law requires consent to be obtained
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 upon to do so. We have also identified what our legitimate interests are where appropriate.
| Purpose/Activity | Type of personal data | Lawful basis for processing |
| To respond to enquiries you make via our website |
|
Necessary for our legitimate interests (to communicate with your business, understand your requirements and provide quotes for work) |
| To manage our relationship with your organisation, including processing orders, payments and requests for information, managing invoices and disputes and notifying you of changes to our services, terms or privacy policy |
|
Necessary for our legitimate interests (to fulfil our contractual obligations towards your organisation as a customer and exercise our rights under that contract) |
| Send you marketing communications that may be of interest to you about our services. These may include information about product updates, newsletters, events, webinars |
|
Necessary for our legitimate interests (to promote our services and our business) |
| To use data analytics to improve our website, products/services, marketing, relationships and experiences |
|
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) |
How we Store Your Information
Your information is securely stored on Clue Software systems, based within the UK or EU at a third-party data centres and protected by appropriate security measures including stringent access controls with access provided on a Need-to-Know basis. Personal data is managed in accordance with our data protection policy and supporting procedures.
Clue Software systems are managed in part on our behalf by BOM IT Solutions (www.bomitsolutions.co.uk) within their data centre at Clue House, Central Trading Estate, Petherton Road, Hengrove, Bristol, BS14 9BZ.
Clue Software also make use of Microsoft cloud systems to support business operations. Personal data may therefore be stored in Microsoft data centres, all of which provide protective measures and comply with data protection regulation.
Clue Software make use of a CRM to store and process personal data of business contacts this data centre is based in the EU, all of which provide protective measures and comply with data protection regulations.
Clue Software regularly review all retained personal information to ensure that it is still necessary for Clue Software to hold this information. Specific retention periods are dependent on the type of information held and the purpose for collecting and holding this information. If you would like to know how long your data is kept please contact the DPO.
Who we share your information with
As well as the third parties set out above, we may share your personal data with other people or organisations for the purposes set out above, as follows:
- Service providers that help us to run and maintain our business and our Website and provide IT and administration services, such as hosting providers, customer relationship management providers, accounting providers and other IT service providers;
- Professional advisers, including lawyers, bankers, auditors and insurers who provide professional services to us;
- HM Revenue and Customers, regulators and other authorities, who require reporting of processing activities in certain circumstances; and
- Third parties to whom we may choose to sell, transfer or merge parts of our business or 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 policy.
We’ll treat the information we hold as confidential and may share information with the above who are also required to keep your information confidential, safe and secure.
Transfers of your personal data
The personal data that we collect from you will not ordinarily be transferred to, or stored at, a destination outside of the United Kingdom or the European Economic Area (EEA).
However, if we do need to transfer your personal data outside of the UK or the EEA we will take all steps reasonably necessary to ensure that any such transfer is made securely and that there is adequate protection in place in order to protect your personal data.
Please contact us if you wish to find out more; if we ever transfer your Personal Data outside the UK or the EEA you can ask us for a copy of the relevant safeguards implemented in relation to the transfer.
How long we will keep information about you
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 keep your personal data for longer 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.
We will also retain data in an anonymous form for statistical and analytical purposes after this date, without further notice to you.
If you require further information relating to the timescales in which we hold your information please contact our DPO using the details at the bottom of this page.
Your Data Protection Rights
You have a number of rights in relation to your personal data, these include the right to:
- Be informed – You have the right to be informed about how we use your personal data;
- Access personal data – You have the right to ask us for copies of your personal information;
- Rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete;
- Erasure – You have the right to ask us to erase your personal information in certain circumstances;
- Restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances;
- Object to processing – You have the right to object to the processing of your personal data in certain circumstances;
- Data Portability – You have the right to request a copy of certain personal data that you have provided to us in a commonly used electronic format and to ask us to transfer it to a third party in certain circumstances.
Clue Software will not charge a fee to deal with such a request in most normal circumstances, that is, if the request is not unfounded, not excessive, and not repetitive. The request must be acknowledged, and information provided within one month of the request. We may need to extend this if your request is complex or if you make numerous requests at the same time, Clue Software will keep you up to date throughout the process.
Please contact us at [email protected] if you wish to make a request.
How to Complain or report any issues
If you are unhappy with any way we are using your personal information, you should first contact us so we can understand your issue and try and resolve it. You can contact the DPO on the details set out below.
Clue Computing Co. Ltd, Clue House, Central Trading Estate, Petherton Road, Hengrove, Bristol, BS14 9BZ.
Telephone: 01275 890130
Email: [email protected]
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Policy last update 17th May 2023