*CloudCustom is a data-drive business development company. To grow and generate profits, CloudCustom needs to market its services to existing clients and potential clients. Generating profits enables CloudCustom to contribute to the economy by paying taxes in the countries in which it operates, pay its staff and reward them for the great work they do and reward its investors for having the confidence to invest.

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To achieve these aims CloudCustom has a legitimate interest to process personal data to identify clients and potential clients, who are in job roles that are likely to use our services and communicate this to them, either by phone, email or post. To establish Legitimate Interest as a lawful basis for processing personal data for these purposes, a Legitimate Interest Assessment was conducted.

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Other Grounds

In some circumstances, we may have other grounds to process personal data. These are set out in the following table, along with examples of the circumstances in which they might apply.

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5. WHO WE SHARE THE PERSONAL DATA WITH

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Service Providers

We may provide your information to third parties who help us use it for the purposes described in section 2. For example:

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Our database of personal data may be hosted by third parties on our behalf.

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• We use a third party email broadcasting service in order to send you service and marketing emails.

• We use market research companies to help us identify prospects and better understand our clients.

• Some of our marketing activity relies on us sending personal data to third parties who then analyse or enhance it and return the results to us.

• We may use a printing company to produce and send personalised direct mail.

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These service providers will not be allowed to use your information for their own purposes or on behalf of other organisations, unless you agree otherwise.

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Online Advertising Platforms

We may use third party advertising platform providers such as Google to serve advertisements to you. These third parties may use information about your visits to these and other websites in order to provide you with advertising about products and services that may be of interest to you.

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Sometimes we may provide information associated with you to third parties who operate other websites (such as social media platforms) so that we can show you relevant advertisements while you are using those websites. This information will be protected so that you can only be identified if the third party already knows you – the information we provide only tells them that you are a user of our websites.

 

You can configure your advertising preferences on social media such as Facebook, Twitter, Instagram or Pinterest by accessing your settings or preference options on the relevant platform. If you no longer want to receive personalised advertising on any website you visit, you can usually opt out directly through the privacy policy of the particular website you are accessing. Please note that this will not block ads that are displayed on the websites you visit; it will simply stop you receiving advertising that has been tailored to your interests. This opt-out relies on a cookie, so if you wipe all your cookies then that website will no longer know that you have opted out. The same applies if you use a different internet browser, or use a new computer to access the internet. You can also opt out of such advertising by visiting the IAB opt-out platform at www.youronlinechoices.com, but please note that this and other platforms only allow you to opt out of interest-based advertising delivered by registered members.

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Business Transfers

If we sell our business to a third party, or go through a corporate reorganisation, we will transfer personal data to the company that acquires the business.

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Regulators

We may sometimes need to pass personal data to a regulator such as the Information Commissioner’s Office in the UK or the local supervisory authority in other EU countries.

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Sharing of Anonymised Data with Third Parties

We may share anonymised information with other third parties, but only where the information cannot realistically be identified as relating to you.

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6. WHERE THE PERSONAL DATA IS STORED AND SENT

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Within Europe

We are based in the United Kingdom, and will normally access and use your information from here.

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Elsewhere

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• Where we use cloud-based technology or a data centre or backup facility overseas. For example, our email marketing database and customer relationship management database (which will hold your information) are currently hosted by a service provider in the United States. People in other countries may also need to access that database for purposes such as technical support or system development and testing.

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While countries within the European Union all ensure a high standard of data protection law, some parts of the world may not provide the same level of legal protection in relation to personal data. As a result, when we do send personal data overseas, we will make sure that suitable safeguards are in place to protect the information. For example, these safeguards might include:

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• Putting in place a contract with the recipient containing terms which have been approved by the authorities as providing a suitable level of protection e.g. An International Data Transfer Agreement (IDTA), Standard Contract Clauses (SCCs) with UK Addendum and supplementary measures, as appropriate.

• Sending the information to an organisation which is a member of a scheme which has been approved by the authorities as providing a suitable level of protection.

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If your information has been sent overseas like this, you can obtain further information about the safeguards used by contacting us using the details set out in section 1 above.

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7. HOW LONG THE PERSONAL DATA KEPT FOR

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We will not keep your personal data for longer than we need it.

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If you are a representative of one of our clients or potential clients, this means that we will normally keep your data while you or your employer has an ongoing relationship with us or if you have demonstrated an interest in our services within the past two years. You can request us to delete it earlier as explained in Section 9.

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8. WHETHER THE PERSONAL DATA IS USED TO MAKE AUTOMATED DECISIONS ABOUT YOU OR TO PROFILE YOU

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We use certain profiling techniques in order to help us to understand our clients and potential clients. This in turn helps us to understand which people might be interested in which of our services.

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We do not use automated decision-making or profiling to make any decisions that will significantly affect you. For example, we do not use it to set the prices that we charge for our services.

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9. YOUR RIGHTS IN RESPECT OF THE PERSONAL DATA THAT WE HOLD ABOUT YOU

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To enquire about exercising these rights, please use the contact details set out Section 1.

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Access: You have a right to find out what personal data we hold about you and certain other information such as how we are using it.

 

Withdrawal of Consent: When we rely on your consent to use your data (see Section 4 above), you have the right to withdraw that consent at any time. You can do this by contacting us, or (in the case of emails that are sent on the basis of consent) by clicking the “unsubscribe” link.

 

Objection to Direct Marketing: You have the right to object to use using your personal data for direct marketing purposes. If you do this we will stop using it for these purposes.

 

Rectification: If you believe that the information that we hold about you is inaccurate or out of date, you have a right to ask us to correct it.

 

Objection to legitimate interests: If you disagree with us relying on the legitimate interests ground for using your personal data (see Section 4 above), you can object to us doing so. We will the reassess the extent to which we can continue to use the data in light of your particular circumstances. In the case of emails that are sent on the basis of legitimate interests (see Section 4 above), you can do this by clicking on the ‘unsubscribe’ link.

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Erasure: In certain circumstances you can ask us to delete your personal data from our systems. However this usually won’t apply to all of your data because we might have good reason for needing to keep some of it. For example, so that we do not subsequently contact you if we receive your details again in the future.

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Restriction: In certain circumstances you can ask us to restrict in which we use your personal data.

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Portability: You have the right to receive limited kinds of information in a portable format.

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10. WHO YOU CAN COMPLAIN TO IF YOU ARE UNHAPPY ABOUT THE USE OF YOUR PERSONAL DATA?

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If you are not happy you should make contact so that we can investigate your concerns. Please contact us using these details:

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Post: 28 Nairdwood Close, Prestwood, Buckinghamshire, HP16 0QN, United Kingdom

Email: info@cloudcustom.co.uk

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If you are based within the United Kingdom, you also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), which is the body that regulates the handling of personal data in The UK. You can do this online through the ICO’s website at www.ico.org.uk, by telephone on 0303 123 1113, or by writing to them at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.