1. WHO WE ARE AND HOW YOU CAN CONTACT US
We are CloudCustom Limited (“CloudCustom”), a company based in Prestwood, United Kingdom. CloudCustom controls personal data about our business contacts and their representatives. This means that we are responsible for ensuring that the personal data is used fairly and lawfully.
CloudCustom Limited is registered in The United Kingdom under registration number 09710373, and our registered office is at 28 Nairdwood Close, Prestwood, Buckinghamshire, HP16 0QN, United Kingdom. This is also our principal place of business.
You can contact us about issues relating to personal data, including the contents of this notice, by any of the following methods:
Post: 28 Nairdwood Close, Prestwood, Buckinghamshire, HP16 0QN, United Kingdom
Telephone: 020 3900 2220
2. WHAT WE USE PERSONAL DATA FOR
This section explains the purposes for which we use personal data about our business contacts and their representatives. More detail about the types of personal data that we might use for these purposes can be found in section 3 below.
We use personal data for marketing purposes, typically in relation to current or potential clients and their representatives. This includes providing you with original insight, commentary and research on business software; information about software for uncovering relevant information from contracts and related documents; early notifications of exclusive events and webinars and updates on our products and services.
We will not make contact with you for marketing purposes through any particular channel (such as email, telephone or post) if you have told us that you don’t want to hear from us in that way. Please note that if you ask us not to contact you for marketing purposes, you might still hear from us for other reasons – for example, as part of our ordinary relationship management activity.
We use personal data for relationship management purposes. Relationship management is the ongoing maintenance of our relationship with our clients, suppliers and their representatives. This could include activities such as interactions about your use of our software, letting you know about service changes or planned maintenance activity, contacting you with billing enquiries, inviting you to events and webinars, dealing with your enquiries, or asking you about what sorts of solutions you want us to develop.
Monitoring and Improving Our Website
We use information such as how different people navigate around our website, how long they spend on particular pages and whether they download any of our content in order to help customise and improve the user experience of our website. It also allows us to tailor the website to match your interests and preferences better and helps us understand who has visited which pages to determine the most popular areas of the website. This information is also used for security and system administration and to generate aggregate non-personalised information for use by us, our business contacts, selected third parties, sponsors or advertisers (such as anonymous statistics related to the take up or use of services, or patterns of browsing).
Legal and Regulatory Purposes
We may use your personal data for legal and regulatory purposes. For example, this might include responding to complaints or enquiries from you or a regulator about how we have used your personal data.
3. WHAT KINDS OF PERSONAL DATA WE USE AND WHERE WE GET IT FROM
We obtain and use information from various different sources:
You are free to choose whether or not you give us your personal data. However, if you are signing up to one of our products or services, we might not be able to provide you with that product or service if you do not give us the information we need in order to do so.
4. WHAT OUR LEGAL GROUNDS FOR HANDLING PERSONAL DATA ARE
This section explains the basis on which we process your personal data in The UK and Europe.
Data protection law in the UK and European Economic Area (EEA) allows the use of your personal data where necessary for legitimate purposes provided that this isn’t outweighed by the impact it has on you. The law calls this the “legitimate interests” basis for processing personal data. We rely on this basis for several of our processing activities.
The legitimate interests we are pursuing are:
*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.
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.
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.
5. WHO WE SHARE THE PERSONAL DATA WITH
We may provide your information to third parties who help us use it for the purposes described in section 2. For example:
Our database of personal data may be hosted by third parties on our behalf.
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.
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.
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.
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.
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.
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.
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.
6. WHERE THE PERSONAL DATA IS STORED AND SENT
We are based in the United Kingdom, and will normally access and use your information from here.
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.
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:
Putting in place a contract with the recipient containing terms which have been approved by the authorities as providing a suitable level of protection.
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. One example is the “Privacy Shield” scheme that has been agreed between the European and US authorities.
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.
7. HOW LONG THE PERSONAL DATA KEPT FOR
We will not keep your personal data for longer than we need it.
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.
8. WHETHER THE PERSONAL DATA IS USED TO MAKE AUTOMATED DECISIONS ABOUT YOU OR TO PROFILE YOU
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.
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.
9. YOUR RIGHTS IN RESPECT OF THE PERSONAL DATA THAT WE HOLD ABOUT YOU
To enquire about exercising these rights, please use the contact details set out Section 1.
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.
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.
Restriction: In certain circumstances you can ask us to restrict in which we use your personal data.
Portability: You have the right to receive limited kinds of information in a portable format.
10. WHO YOU CAN COMPLAIN TO IF YOU ARE UNHAPPY ABOUT THE USE OF YOUR PERSONAL DATA?
If you are not happy you should make contact so that we can investigate your concerns. Please contact us using these details:
Post: 28 Nairdwood Close, Prestwood, Buckinghamshire, HP16 0QN, United Kingdom
Telephone: 020 3900 2220
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.