PRIVACY POLICY

GENERAL INFORMATION

CloudClevr Holdings Ltd operates this website. CloudClevr Holdings Ltd comprises a group of separate Operating Companies (OpCos) as follows:
• CloudClevr Ltd
• CloudClevr IT Ltd
• 4Sight Communications Ltd
• NGC Networks Group Ltd

For simplicity, this privacy policy covers every aspect of privacy for CloudClevr Holdings Ltd; however, because of the differences in business delivery, not every OpCo will need every stated requirement.

This privacy policy tells you what you may expect us to do with your personal information, including:
• How we obtain personal information.
• What categories of personal information we process.
• What purposes we are processing personal information for.
• What the lawful bases for the processing of personal information are, including our legitimate interests.
• How long we store personal information for.
• Whether there are other recipients of personal information; and
• Whether we intend to transfer personal information to another country.

CONTACT DETAILS

This website provides a method for contacting CloudClevr Holdings Ltd on the home page – see https://cloudclevr.com/
The address of CloudClevr Holdings Ltd is Bridgeway House, Bridgeway, Stratford-Upon-Avon, Warwickshire, England, CV37 6YX.

DATA PROTECTION OFFICER’S CONTACT DETAILS

Our Data Protection Officer (DPO) is Selby Spicer.
You can contact our DPO at [email protected] or via the postal address above. Please mark the envelope Data Protection Officer.

HOW DO WE OBTAIN PERSONAL INFORMATION?
Most of the personal information we process is provided to us directly by one of the following methods:
• By you subscribing to newsletters and email notifications.
• By you filling in the ‘Contact us’ section of this website, or any form to receive further information, or by otherwise communicating with us to request further information, or communicating with us for another reason such as making an enquiry or complaint, applying for a job etc.
• By you registering to use any of our sites that require such registration.
• By you entering into a contract with us.
• By you subscribing to/using our products and services.
• By you requesting further products or services.
• By you signing in / out when visiting our offices.
• We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

Additional sources of personal information include:
• Social media advertising.
• Usage of our websites – note that by accessing or using this website, you are consenting to the collection and processing of your personal information in accordance with this Privacy Policy. If you do not consent to this, please do not access, or use this website.
• Bought-in marketing lists.
• From your employer, in the course of us carrying out our obligations arising from a contract entered into with the same.
• An employee of ours giving details of emergency contacts or referees.
• CCTV or similar systems at our premises.

CHANGES TO THE WAYS HOW WE OBTAIN PERSONAL INFORMATION

In the event that we need to obtain personal information in relation to you from any other source than those described above, we shall notify you of this.

WHAT CATEGORIES OF PERSONAL INFORMATION DO WE PROCESS?

Personal information is information which you can be identified from (and does not include any anonymised forms of information).
We may process the following categories of personal information in relation to you:
• Name/s (first name, last name).
• Gender and/or marital status (from your title).
• Marital status (from your title).
• CCTV and similar images (which are not biometric data).
• Contact details (address, email address, phone number, mobile number, job title and place of work).
• Financial information (results of credit checks, banking details, payment details, financial account details, credit card details).
• Technical information (authentication details, IP addresses, device ID data, location data)
• Site/service usage data (traffic data, location data, weblogs and other communication data, referral source, length of visit, page views, website navigation paths, information about the timing, frequency, and pattern of use).
• Products and services supplied.
• Marketing preferences.

Additional personal information may be processed in relation to you if you are or have been employed by CloudClevr Holdings Ltd or one of its OpCos:
• Age / Date of Birth.
• Attendance records.
• Employment and career history.
• Health and safety records.
• ID documentation, such as passport, national insurance number, ID card, and driving licence details.
• Income/salary.
• Loans and benefits.
• Pension details.
• Performance appraisals.
• Records of DBS and other such screening/checks.
• Recruitment.
• Termination details.
• Training records.

PURPOSES OF PROCESSING

In general, personal information will be processed for the following purposes:
• to provide you with email notifications and newsletters to which you have subscribed.
• to engage in communication with you and for record-keeping, where you have filled out a contact form or contacted us by another method to request information – or where you have contacted us for other reasons such as making an enquiry or complaint, applying for a job etc.
• for marketing purposes to provide information to you on products or services you have shown interest in or which we believe may interest you – or to engage you in research, where you have consented to be contacted for such purposes.
• to carry out our obligations arising from any contracts entered into, including (but not limited to) the provision of our products and services, the provision of support services etc.
• to manage customer relationships.
• to allow you to participate in interactive features of our products and services, where these are available.
• to analyse the usage of our products, services, and website/s to make improvements to them and also to notify you about changes to them.
• where necessary, for the establishment, exercise, or defence of legal claims.
• for security and fire safety reasons when visiting our offices.

We have described above that one of the general purposes for which your personal information shall be processed is for marketing purposes. We wish to make you aware that you have the right to object or to opt out of any direct marketing by contacting us to unsubscribe on your behalf at [email protected] or, where provided, unsubscribing using links within marketing emails.
If we want to use your personal information for any other purpose, we will ask you for consent and will use your personal information only upon receiving your consent and then only for the purpose(s) for which consent has been granted, unless we are required to do otherwise by law.

Please note that if you do not allow us to collect or process required personal information or withdraw consent to process the same for the required purposes, we may not be able to carry out our obligations arising from any contracts entered into. This may mean, for example, that you may not be able to use our products and services.

LAWFUL BASES OF PROCESSING

We have described above the purposes for which we may process your personal information. These purposes will at all times be justified by UK data protection law.
The lawful bases upon which we can process your personal information are:
• where we have your consent to use your personal information for a specific purpose i.e.
o to provide you with email notifications and newsletters.
o to engage in communication with you and for record-keeping.
o to provide information to you on products or services.
o to engage you in research.
• where it is necessary to enter into a legal contract with you or to perform obligations under a legal contract with you; and/or to take steps to enter into such a legal contract, at your request.
o participation in interactive features of our products and services.
• where it is necessary to enable us to comply with a legal obligation.
• where it is necessary to ensure our legitimate interests or the legitimate interests of a third party (provided that your interests and rights do not override those interests). Our legitimate interests include, but may not be limited to:
o the proper management of our customer relationships.
o the improvement of our products, services, and sites.
o the protection and assertion of our legal rights, your legal rights, and the legal rights of others.
o the health and safety of our employees and of visitors to our premises.
• where we need to protect your own vital interests (or the vital interests of another person).
• where it is needed in the public interest (or where we are acting in our official functions), provided that the task or function has a clear basis in law.
Lawful bases specifically applicable to marketing:
• We will only ever use your personal information to send you marketing directly where we have your explicit consent (which will be obtained in a format separate to this Privacy Policy).

HOW LONG WE STORE PERSONAL INFORMATION FOR

Your personal information will only be kept for the period of time which is necessary for us to fulfil the purposes set out in this Privacy Policy. We may need to retain certain information for longer periods for reasons such as record-keeping / reporting under applicable law or for other legitimate reasons like enforcement of legal rights, fraud prevention etc.

SHARING PERSONAL INFORMATION

We may disclose your personal information to any of our employees, partner organisations and OpCos of the CloudClevr Holdings Ltd group of companies as far as is reasonably necessary for the purposes as set out in this Privacy Policy.

We may also disclose your personal information:
• to the extent that we are required to do so by law.
• in connection with any legal proceedings or prospective legal proceedings; including if we sell or buy any business/assets, in which case we may disclose your personal information to the seller or buyer of such businesses or assets.
• to establish, exercise or defend our legal rights; or to enforce or apply our terms of use or terms and conditions of other agreements; or to protect our rights, property, or safety including those of our customers, or others (including providing information to others for fraud prevention and reducing credit risk).
Except as provided for in this Privacy Policy, we will not disclose your information to third parties unless we have your specific consent to do so. We will notify you should this position change.
WHERE WE STORE YOUR PERSONAL INFORMATION
The personal information that we collect from you may be transferred to and stored at, a destination in the European Economic Area (“EEA”). If we need to transfer or store personal information to a destination outside of the EEA, we will follow applicable Information Commissioner’s Office (ICO) guidelines and ensure the destination country is covered by an ‘adequacy decision’ – meaning it is considered to meet the required standards in the way it treats personal information, or that an appropriate safeguard or exception is met.

YOUR DATA PROTECTION RIGHTS

Under data protection law, you have rights we need to make you aware of. This includes fair processing of information and transparency over how we use your use personal information. The rights available to you depend on our reason for processing your personal information.

YOUR RIGHT OF ACCESS

You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process.

YOUR RIGHT TO 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. This right always applies.

YOUR RIGHT TO ERASURE

You have the right to ask us to erase your personal information in certain circumstances.

YOUR RIGHT TO RESTRICTION OF PROCESSING

You have the right to ask us to restrict the processing of your information in certain circumstances.

YOUR RIGHT TO DATA PORTABILITY

In certain circumstances, you have the right to receive personal information you have provided to a controller in a structured, commonly used, and machine-readable format and to request that it be transmitted to another controller.

YOUR RIGHT TO OBJECT

You have the right to object to the processing of your personal information in certain circumstances. You have an absolute right to stop your personal information from being used for direct marketing.

RIGHTS RELATED TO AUTOMATED DECISION MAKING

In certain circumstances, you have the right to object to decisions being taken by automated means (including profiling) which produce legal effects concerning you or similarly significantly affect you. CloudClevr Holdings Ltd does not conduct any automated processing or profiling of personal information.

RIGHT TO WITHDRAW CONSENT

In any circumstance where we rely upon your consent for processing your personal information, you may withdraw this consent at any time.

RIGHT TO COMPLAIN

If you have queries or concerns about the way we process your personal information, do not hesitate to get in touch with us at [email protected].
If you remain dissatisfied, you have the right to make a complaint about the way we process your personal information to the supervisory authority. The supervisory authority in the United Kingdom is the Information Commissioner (ICO).

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on your rights under the UK General Data Protection Regulations.

If you would like to exercise any of these rights don’t hesitate to get in touch with Selby Spicer, Group Data Protection Officer at [email protected].
Note that we may charge a reasonable fee when a request to exercise one or more of these rights is deemed to be manifestly unfounded or excessive, particularly if it is repetitive or if it is a further request for additional copies of information previously supplied. In the case of complex or numerous requests, the response time may be extended, and an explanation will be provided.

CHANGES TO THIS PRIVACY POLICY

This privacy policy was last updated on 4th April 2024. Effective date TBC
We may change this Privacy Policy without notice. Any changes we may make to this Privacy Policy in the future will be posted on this page. We therefore recommend that you periodically review this page.

CHILDREN’S INFORMATION

We do not provide products and services directly to children (anybody under the age of 18) or proactively collect their personal information. Neither is this website intended for children. If we have reason to believe that we hold personal information of a person under that age, we will delete that information.

KEEPING PERSONAL INFORMATION SECURE

We will ensure the safety and security of your personal information and have measures in place to do so. We will also use technological and organisational measures to keep your personal information secure. These measures include, but may not be limited to:
• Storing information on secure servers
• Having procedures in place to deal with any information security breach, which shall be reported and dealt with under data protection laws and regulations. You will be notified of any suspected breach concerning your personal information.

You acknowledge, however, that the transmission of unencrypted (or inadequately encrypted) information over the Internet is inherently insecure, and we cannot guarantee the absolute security of information sent to us over the Internet. You are responsible for keeping any passwords you use for accessing our sites and services confidential and you should ensure that any such password is not susceptible to being guessed, whether by a person or a computer program.

LINKS TO OTHER WEBSITES

Our websites may, from time to time, contain links to and details of third-party websites. Please note that such websites are not governed by this Privacy Policy, and we have no control over them, therefore we cannot be held responsible or liable for the protection and privacy of any information once you have used these links to leave our sites. We advise you to exercise caution and refer to the Privacy Policy applicable to the website in question.

COOKIES

Cookies are small text files that are placed on your computer when you visit our (or other) websites. They are generally used to make websites work or work more efficiently/securely. To find out more about cookies generally visit www.aboutcookies.org or www.allaboutcookies.org.
As we have already stated elsewhere in this Policy, we obtain usage data to analyse and improve our sites and services.
This information is generally acquired via Google/Google Analytics. For more information, visit Google’s Privacy & Terms site https://policies.google.com/privacy?hl=en-GB&fg=1 .
Our OpCo NGC Networks has a separate Cookie Policy.

Most web browsers allow some control of most cookies through browser settings and most browsers allow you to refuse to accept cookies and/or to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can obtain information about managing cookies via these links:
Chrome – https://support.google.com/chrome/answer/95647?hl=en%20(Chrome);
Firefox – https://support.mozilla.org/en-US/products/firefox/protect-your-privacy/cookies
Edge – How to Manage and Clear Your Cache and Cookies | Edge Learning Center (microsoft.com)
Opera- https://help.opera.com/en/latest/security-and-privacy/
Safari – Clear cookies in Safari on Mac – Apple Support (IN)
If you are using any other web browser, please visit your browser’s official support documents.

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you may not be able to use all the features on

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