Version: 1.5
Last updated: May 3rd 2023
1. Introduction
At ClearVoyage ApS (‘ClearVoyage’, ‘us’, ‘we’, ‘our’), we are committed to protecting the privacy of our customers and users of our web applications (‘Products’). This Privacy Policy states our policy and practices regarding the collection and use of information on ClearVoyage’s Products.
We want to provide a safe and secure user experience. We will ensure that the information you submit to us, or which we collect, via our Products (and in limited circumstances through written correspondence (including e-mail)), is only used for the purposes set out in this Privacy Policy.
Through this Privacy Policy we aim to inform you about the types of personal data we collect, the purposes for which we use the data and the ways in which the data is handled. We also aim to satisfy the obligation of transparency under the EU General Data Protection Regulation 2016/679 (‘GDPR’) and national laws implementing GDPR.
For the purpose of this Privacy Policy the controller of personal data is ClearVoyage, and our contact details are set out in the ‘Contact Us’ section at the end of this Privacy Policy.
2. The Information we collect
We may collect and process the following information about you when you sign up to use the Products:
Name
Username [Email address]
In general, you can visit the ClearVoyage or our Products’ external websites without identifying yourself or revealing any personal information. However, you may also choose to contact us and in doing so provide us with certain information such as your name, email address, telephone number, or similar information.
We may also collect and process the following when you use the Products:
Usage data – which includes information about how you use our Products and services; and
Statistical data about your actions and patterns in using the Products. This means information about your computer and your use of our services, which may include (where available) your IP address, unique mobile device identifier (UDID), International Mobile Equipment ID (IMEI), Android ID, device MAC address, browser information, operating system, timestamps, the pages that you request, applications downloaded, traffic data, location data, weblogs and other communication data, and the resources that you access.
3. How we use your personal information
You can be assured that information you provide voluntarily will only be used in connection with your business relationship with ClearVoyage. We will hold, use and disclose your personally identifiable information for our legitimate business purposes including:
to provide our services to you;
to maintain our business relationship, where you are a user of our Products;
to deal with your enquiries and complaints;
to keep our website and systems secure and prevent fraud;
where relevant, to meet legal, regulatory or compliance needs; and
to better understand your needs.
We will not use or share the personally identifiable information provided to us in ways unrelated to the uses described in this statement. More information about how we may share your information can be found at section 4.
4. The Legal Basis for Processing your Personal Information
Under GDPR, the main grounds that we rely upon in order to process personal information of users of our Products are the following:
(a) Necessary for entering into, or performing, a contract – in order to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data;
(b) Necessary for compliance with a legal obligation – we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency;
(c) Necessary for the purposes of legitimate interests – either we, or a third party, will need to process your personal data for the purposes of our (or a third party’s) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include optimising our Products and customer experience, responding to requests and enquiries from you or a third party, informing you about our services and ensuring that our operations are conducted in an appropriate and efficient manner;
(d) Consent – in some circumstances, we may ask for your consent to process your personal data in a particular way.
5. How we share your personal information
We may disclose your personally identifiable information with other parties. Details of those parties are set out below along with the reasons for sharing it.
1. Third Parties
We may share your personal information with trusted third parties where we have retained them to provide services, such as third party cloud hosting services.
We require minimum standards of confidentiality and data protection from such third parties. To the extent that any personal information is provided to third parties outside the EEA, or who will access the information from outside the EEA, we will ensure that approved safeguards are in place, such as the approved standard contractual clauses or the EU/US Privacy Shield.
2. Regulatory and Law Enforcement Agencies
We may disclose your personal information if required by applicable law, regulation or as part of a legal process. If we receive a request from a regulatory body or law enforcement agency, and if permitted under GDPR and other laws, we may disclose certain personal information to such bodies or agencies.
3. New business owners
If we or our business merges with or is acquired by another business or company, we will share your personal information with the new owners of the business or company and their advisors. If this happens, we will notify users and customers of such event.
4. How long we will hold your information
We will retain your personal information for the time necessary to provide the services we perform for you, or stated by the purposes outlined in this Privacy Policy, and you can always request that we stop processing or delete your personal information. The next section sets out more information on your rights.
6. Your rights on information we hold about you
You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.
Right of Access
You have the right at any time to ask us for a copy of the personal information about you that we hold. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
Right of Correction or Completion
If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. You can let us know by contacting us using the details set out in the ‘Contact Us’ section below.
Right of Erasure
In certain circumstances, you have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.
Right to object to or restrict processing
In certain circumstances, you have the right to object to our processing of your personal information by contacting us using the details set out in the ‘Contact Us’ section below. For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests.
You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.
Right of Data Portability
In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that information to you or directly to a third party organisation.
While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation’s systems. We are also unable to comply with requests that relate to personal information of others without their consent.
You can exercise any of the above rights by contacting us using any of the methods in the ‘Contact Us’ section below.
Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.
To the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. You can do this by contacting us using the details in the ‘Contact Us’ section below.
7. Aggregate Information about ClearVoyage users
We gather information and statistics collectively about all users of our Products, for example:
which areas of the Products users access most frequently; and/or
which services users access the most.
We only use such data in the aggregate form. This information helps us determine what is most beneficial for our users and how we can continually improve our Products and services to create a better overall experience for our users.
Complaints
If you are unhappy about our use of your personal information, you can contact us using the details in the ‘Contact Us’ section below. You are also entitled to lodge a complaint with the UK Information Commissioner’s Office using any of the below contact methods:
Telephone: 0303 123 11113
Website: https://ico.org.uk/concerns/
Post:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Changes to our Privacy Policy
Our Privacy Policy is subject to change from time to time and, if we update it, we will post these changes on this page so that you will be aware of how we use your information.
Contact us
f you have any enquires or if you would like to contact us about our processing of your personal information, including to exercise your rights as outlined above, please contact us by any of the methods below. When you contact us, we will ask you to verify your identity.
Contact name: Alexander Donger
Email: info@clearvoyage.com
Post: At our registered office, as set out below
Our registered office is at:
ClearVoyage ApS
Kay Fiskers Pl. 10
2300 Copenhagen S
Denmark