This policy sets out the information gathering and dissemination practices of the Clearswift Group. It relates to both our online and offline practices and we will continue to update it as we improve our services and range of products.
Clearswift Group of companies includes the following companies:
- Clearswift Systems Limited;
- Clearswift Limited;
- Clearswift Corporation;
- Clearswift (Asia/Pacific) Pty. Ltd.;
- Clearswift Kabushiki Kaisha;
- Clearswift S.A;
- Clearswift GmbH;
- Content Technologies Holdings Ltd
Clearswift is a wholly owned subsidiary of RUAG Holding AG, Switzerland.
1. Information We Collect and How We Will Use That Information
Our main goal in collecting information is to provide you with a user-friendly, customized, and efficient experience.
To become a member and subscribe to any of our email services or to be able to access some of our product information services or download software, we require that you register with us. The registration process includes the collection of certain information, which will allow us to manage our website, send you the information you require, contact you following the download of evaluation software to discuss a purchase and allow us to monitor and enforce certain contractual clauses between us and the users of our software, especially in relation to the provision of support and/or maintenance services and the licence to use our software.
European personal information is stored on servers located in data centers in Europe. We may also store regional information at our satellite offices in Australia, Japan and the US. Our various global re-sellers and distributors may also store your personal information as may be legally and/or contractually required by them. In relation to any re-sellers or distributors, you need to satisfy yourself that they are acting in accordance with any local obligations.
b) Email Communications
As with many other companies, any emails we may send to the address supplied by you, will contain tracking images that enable us to see when you open the email. We will also know if you click on any link contained in the email.
We use this information to help us improve the quality and relevance of our communications. If you do not download images in our emails, then we are not able to track when you open or read the emails we send.
You can unsubscribe from any Clearswift email communication at any time by clicking the unsubscribe link in the email sent. If you do this we will not send you any more marketing emails, however, we will keep your details on file in order to satisfy this requirement.
c) Purchase of Software or Services
During the conclusion of any transaction, we will collect certain information such as email address, geographical location, first and last name, position in company, company name, address and telephone number. We will use this information to fulfill the order with you, both in terms of software and the provision of any services, as well as making you aware of other products or services and improvements to the products or services that you originally purchased. We will retain such information for as long as is necessary in relation to managing and satisfying any contractual obligations.
d) Support and Maintenance Services
In order to fulfill our contractual commitments with our distributors/re-sellers and end users, we will collect certain information such as email address, geographical location, first and last name, position in company, company name, address, telephone number and summaries of discussions regarding product issues. This will allow us to contact the appropriate individual in response to an issue raised and to allow us to refine our products. We may also make such people aware of other products or services and improvements to the products or services that were originally purchased.
2. Data Processing Activities
- What is the purpose and legal basis of the processing?
Clearswift is required to process personal information to satisfy our contractual commitments and/or to provide information to you as may be requested from time to time.
- What are the categories of personal data?
Clearswift will typically only process contact details; although more detailed personal data may be processed where required for specific service and/or contractual requirements.
- Who will have access to personal data?
Only those who need access to your personal data for the purpose of fulfilling any commitments will have access to data. Security controls, which include but are not limited to passwords and staff vetting, are used to ensure safeguards are in place for maintaining confidentiality.
- What are the details of transfers to countries outside the EEA and what safeguards exist?
Any transfers of personal data to countries outside the European Economic Areas are undertaken where it is know that those countries and organisations involved comply with the European Commission’s standards from a security adequacy perspective.
- What retention periods are used?
Personal data is not knowingly kept for longer than is necessary or permitted.
3. Your Online Activities
If you visit any of our websites, we keep track of IP host addresses solely for security purposes. All IP host addresses for which no security issues are identified are disposed of in a timely manner. We also keep track of daily page views to monitor traffic volume so that we can plan for future growth.
For example, we use IP addresses to monitor the regions from which you navigate the Clearswift websites.
Clearswift websites use the below cookies, each with a different purpose. In each case, the cookies are used to give you a better experience and pose no privacy threat.
|Drupal (website CMS)||has_js||These cookies are used to minimize screen load time.|
|Marketo||_mkto_trk _cdrop||Munchkin tracking code helps track visits to our website through our email service provider.|
|Google.com||NID||Standard google ad cookie – used to ‘customise ads on google properties’|
|pid||This cookie created by Twitter as part of the twitter feed plugin which appears on the site|
|lidc L1e bcookie bscookie||These cookies are created by LinkedIn as part of the LinkedIn feed plugin which appears on the site|
Disabling/Enabling Cookies - You can accept or decline cookies by modifying the settings in your browser.
5. Third Parties
Except as described elsewhere in this document or as permitted or required by relevant legislation, we do not provide any personal information we have collected to third parties or other users. We may share information with our subsidiaries, affiliates or business associates (such as telemarketers, distributors and re-sellers), but only to the extent that the sharing of such information is permitted by law. If you give your consent, our business associates may provide you with details of any new products or services they offer.
We may disclose aggregate data (e.g. '45% of our users are small businesses') and survey results to third parties for the purpose of supporting our business activities.
We may disclose personal, business or trading details should we need to pursue an action against a user who violates any of our terms and conditions, copyright rights or other proprietary rights and intellectual property rights.
To be able to fulfil our contractual obligations to you we may need to transmit personal information to countries outside the European Union. The handling and processing of all personal information shall be in compliance with the relevant data processing legislation in such countries and/or in compliance with the data processing legislation in the country from which the information is transmitted.
From time to time we may purchase contact lists for marketing purposes from third parties. We use reasonable efforts to ensure that such third parties have complied with the relevant data protection legislation in relation to such lists.
We may disclose personal information within the Clearswift Group of companies, but solely for the purposes of fulfilling contractual requirements, maintaining the business and to ensure that the most appropriate individual is party to such information.
We maintain the highest standards of data privacy and security to protect your personal details and other information. We regularly review our processes and procedures to protect your personal information from unauthorised access and use, accidental loss and/or destruction. These security measures include backing up of data and encrypting usernames and passwords. Despite these measures, 'perfect security' on the internet does not exist.
To assist us in managing the company's security, the security of our online services and computer systems, we scan the content of incoming and outgoing emails, using our proprietary software, for inappropriate content.
In the event of a security breach impacting your personal information we will notify you at the earliest opportunity possible. In addition we will notify the applicable supervisory authority of a personal data breach, without undue delay and, where feasible, not later than 72 hours after having become aware of it. Any notifications will include details such as but not limited to:
- the likely consequences of the personal data breach, and
- the measures taken or proposed to be taken by Clearswift to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.
7. Access, Correction and Removal of Personal Information
Under the Data Protection Act 1998, you have a right to know what personal information we hold about you. If you would like a copy of some or all of your personal information, please email or write to us using the contact details provided. It would help us if you provide as much detail in any request to prevent us needing to follow up with clarifying questions. Please note we may make a small charge for this service.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
In the event that you wish your personal information to be removed from our web-based databases or from any other of our databases, please email or write to us using the contact details provided. However, we may not be able to remove personal information when we are legally and/or contractually bound to maintain it.
8. Other Websites
10. How to Contact Us