Privacy policy and terms of use
CLEARDOX LLC PRIVACY NOTICE
About this Notice
For all of us at ClearDox LLC (“ClearDox”, “we” or “us”), the protection of personal data is of paramount importance and we go to great lengths to ensure that we collect and use personal data lawfully and only for specific purposes.
This Notice applies to personal data which we process about job applicants and past employees, individual contractors, personnel of current and prospective customers, suppliers, partners and other organisations who we work with as part of our business operations, visitors to our website and users of our services (each of which we refer to in this Notice as “data subject” or “you”).
In this Notice we explain the things which we think are important for you to know about the personal data we collect from you, such as who we are, how we use your data, how we protect your data and who we may share your data with. We also explain the rights you have in relation to your personal data which we hold. Finally, there’s a bit about cookies – what they are and how to get rid of them if you don’t want them. If you have any questions relating to how we handle your personal data, please write or email us at the contact address set out below.
This Notice does not cover the links within our website linking to other websites. We encourage you to read the privacy statements of the other websites you visit.
About us
ClearDox is a limited liability company established in Delaware in the United States. Our registered address in the State of Delaware is Corporation Trust Center, 1209 Orange Street, in the City of Wilmington, Delaware 19801 and our primary business address is 58 Commerce Road, Stamford, Connecticut 06902, US.
If you are in the United Kingdom or the European Economic Area and we process your personal data either in connection with offering you goods or services or monitoring your behaviour then the General Data Protection Regulations (sometimes referred to as the “GDPR”) will apply to these processing activities. If that is the case, we will be a data controller in relation to your personal data because we decide what your personal data can be used for and how the personal data is processed. Our controller registration number is ZB614400. Where the GDPR does not apply to particular processing activities described in this Privacy Notice, we will not be a data controller and the rights and obligations set out in the GDPR will not apply, although we still include an explanation of how we use your personal data for your information as part of our commitment to transparency and best practice.
Where we process personal data on behalf of another company or organisation, we will be doing so as a data processor and our processing will be governed by a contract which we will have with the data controller who will have a separate privacy notice which will apply.
If you would like to contact us in relation to this Notice or your personal data, or if you would like this Privacy Notice in another format (for example audio, large print, braille) please contact our Data Protection Lead via email at dataprivacy@cleardox.com or by post to our address as set out above.
ClearDox encourages the identification and escalation of issues that may negatively impact the operations and reputation of the company; the wellbeing of its employees and customers on which ClearDox undertakes its commercial activities. Please click here to access the ClearDox anonymous reporting submission form.
About your personal data
The personal data we collect, the purpose(s) we use it for and the lawful basis on we hold it will vary depending on the category of the person it relates to. To help explain this, we have set out these separate categories as follows:
A. Job Applicants
What personal data we collect
We may receive your personal data where you apply to us for a position as employee, intern or contractor, whether you apply directly through our website or indirectly through a recruitment agency.
The personal data we collect will typically include identification information such as your name, home address, telephone number, email address, details relating to your past employment and education and could include age, ethnic origin and gender. At certain stages of the application it will be necessary for us to collect and use more personal data as we explain below. We do not collect more information than we need to use for this stated purpose and you do not have to provide the information we request however it may affect your application if you do not provide it.
If we make you a conditional offer, we will ask you for information so that we can carry our checks including proof of your identity, proof of your qualifications and a criminal records declaration. We will need to contact your references and we may ask you to complete a questionnaire about your health. If we make you a final offer, we will also ask you for your bank details and emergency contact details.
How we get your personal data
Most of the personal information we process is provided to us directly by you for one of the reasons set out below. We also receive personal information indirectly, from the following sources in the following scenarios: Individuals and organisations you have listed as references, recruitment consultants, LinkedIn, in each case for the same purposes.
How we use your personal data
We use your personal data for our recruitment purposes only, to contact you to progress your application and to assess your suitability for the role you applied for. We may from time to time refer to your personal data to assess your suitability for positions which may arise in our organisation. We may also use your personal data to monitor our compliance with equality and diversity legislation.
The lawful basis for our collection and use of the personal data
By submitting an application to us for employment or engagement as a contractor, you consent to our processing of your personal data for the purposes set out above and we rely on your consent as the lawful basis for our collection and use of your personal data. You may withdraw your consent at any time by contacting us in writing at our address set out in this Notice.
Who we may disclose your personal data to
We do use third party data processors to perform some parts of our recruitment operations. Where we do so, we have data processor contracts in place with them to ensure your personal data is safeguarded at all times and to ensure that they do not disclose your personal data to anyone else. We currently use a sub-processor Access UK Limited to process our employment records and we may share your personal data with them strictly for the purpose of processing your application.
How long we keep your personal data
If you are successful, we will keep your personal data for the duration of your employment and for a period of time after your employment ends. This period of time will vary depending on the category of data, any minimum data retention periods required by law and whether it is necessary for us to continue to hold your personal data. We will periodically review your personal data and will not hold it for longer than necessary.
If you are unsuccessful, we will keep your personal data for 6 months from the date we determine that you are not successful or for a longer period if we have your consent to retain your personal data for future employment opportunities.
We securely store your personal details on our servers in the United States. Our processor securely stores your personal data on their servers in the United Kingdom.
International data transfers
When you make an application to us, your information is received and processed by us in the United States. We may transfer your personal data to our sub-processor in the United Kingdom.
B. Customer Personnel
What personal data we collect
We may collect your personal data when you correspond with us either as an individual customer or on behalf of the company or organisation that you work for.
The personal data we collect will typically include your name, the name and address of the company you work for (if applicable), your business telephone number, your mobile telephone number and your email address. The personal data may also include onboarding information such as proof of identity to satisfy ‘Know Your Customer’ or other legal, regulatory or due diligence requirements.
How we get your personal data
Most of the personal information we process is provided to us directly by you for one of the reasons set out below. We may also receive personal information about you indirectly, from other people within your organisation, in each case for the same purposes.
How we use your personal data
We will use your personal data only to correspond with you in the course of business conducted between us and you as the customer or the customer’s representative. This may include notifying you about existing services which we provide to your organisation or informing you about new services which we think your organisation may be interested in.
The lawful basis for our collection and use of the personal data
Our processing of this personal data is necessary for the purposes of our legitimate interests in carrying out business with your organisation and to correspond with you.
Who we may disclose your personal data to
We do use third party customer relationship management systems to manage our relationship with our customers and we may share your personal details with our processors for that purpose. Where we do so, we have data processor contracts in place with them to ensure your personal data is safeguarded at all times and to ensure that they do not disclose your personal data to anyone else. Our current CRM provider is HubSpot Inc in the United States and full information about how they process personal data on our behalf can be found in HubSpot’s Data Processing Agreement available on HubSpot’s website.
We also use a third party organisation Aumni Techworks LLP in India to provide personnel to ensure that the services we provide to the organisation that you represent are provided to optimal standards. We may share your personal data with Aumni Techworks LLP for the purpose of providing support services to your organisation.
How long we keep your personal data
Where your personal data is embedded in customer records such as correspondence or invoices, we will keep your personal data for at least the minimum period of time we are required by law to retain such records and for such additional time as it is necessary for us to continue to hold them.
Where your personal data is not embedded in customer records, we will delete your data when we become aware that you no longer work for the customer organisation or when the organisation you work for ceases to be a customer (whichever is earlier) except where we are required by applicable law to continue to hold your data.
International data transfers
Your information is received and processed by us in the United States. We may also transfer your personal data to our processor in India as detailed above.
C. Supplier Personnel
What personal data we collect
We may collect your personal data when you correspond with us as the supplier or as representative of the supplier.
The personal data we collect will typically include your name, where applicable the name and address of the company you work for, your business telephone number, your mobile telephone number and your email address. The personal data may also include onboarding information such as proof of identity to satisfy legal, regulatory or due diligence requirements.
How we get your personal data
Most of the personal information we process is provided to us directly by you for one of the reasons set out below. We may also receive personal information about you indirectly, from other people within your organisation, in each case for the same purposes.
How we use your personal data
We will use your personal data only to correspond with you in the course of business conducted between us and you as the supplier or the supplier’s representative. This may include contacting you in connection with existing services which you or your organisation provides to us, for billing and payment and in response to your enquiries.
The lawful basis for our collection and use of the personal data
Our processing of this personal data is necessary for the purposes of our legitimate interests in carrying out business with the organisation which you work for or represent and to correspond with you.
Who we may disclose your personal data to
We may share your personal data with other personnel within your organisation. We do not share your personal data with any third parties. We may disclose your personal data to other companies within our group of companies where these group companies perform administrative functions on our behalf (such as accounting, legal or compliance services) or where our group companies may have an interest in receiving goods or services from the organisation you represent.
How long we keep your personal data
Where your personal data is embedded in supplier records such as correspondence or invoices, we will keep your personal data for at least the minimum period of time we are required by law to retain such records and for such additional time as it is necessary for us to continue to hold them.
Where your personal data is not embedded in supplier records, we will delete your data when we become aware that you no longer work for the supplier organisation or when the organisation you work for ceases to be a supplier (whichever is earlier) except where we are required by applicable law to continue to hold your data.
International data transfers
Your information is received and processed by us in the United States.
D. Personnel from prospective customers
What personal data we collect
We may collect your personal data in connection with marketing events, sales opportunities or in response to requests for information which you have made to us.
The personal data we collect will typically include your name, where applicable the name and address of the company you work for, your business telephone number, your mobile telephone number and your email address.
How we get your personal data
We may receive personal information directly from you where you provide this to us when you contact us through our website, for example by requesting a product demonstration or when you provide your contact details such as a business card to us at a trade event, conference or seminar.
We may also receive personal information about you indirectly, from other people within your organisation, from event organisers or from third party data providers, in each case for the purposes set out below.
How we use your personal data
We will use your personal data only to correspond with you in connection with our provision of services to the organisation you work for or represent. For example, we may use your email address to send marketing communications relating to our products and services we think may be of interest to the organisation you work for. You may unsubscribe from our marketing emails by clicking on the unsubscribe link located at the bottom of our emails or by contacting us at hello@cleardox.com.
The lawful basis for our collection and use of the personal data
Our processing of this personal data is necessary for the purposes of our legitimate interests in offering products and/or services to the organisation which you work for or represent and to correspond with you.
Who we may disclose your personal data to
We do use third party customer relationship management systems to manage our relationship with representatives of prospective customers who might be interested in our services and we may share your personal details with our processors for that purpose. Where we do so, we have data processor contracts in place with them to ensure your personal data is safeguarded at all times and to ensure that they do not disclose your personal data to anyone else. Our current CRM provider is HubSpot Inc in the United States and full information about how they process personal data on our behalf can be found in HubSpot’s Data Processing Agreement available on HubSpot’s website.
We also use a third party organisation Aumni Techworks LLP in India to provide personnel to assist us with our marketing and business development. We may share your personal data with Aumni Techworks LLP for the purpose of sending marketing emails offering our services which we think your organisation might be interested in.
How long we keep your personal data
We will store your personal data for as long as is reasonably necessary for communicating with you in connection with our provision of services to the organisation you work for or represent.
Where your information is no longer needed, we will ensure that it is disposed of in a secure manner. In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax or accounting requirements.
We review our retention periods at least annually.
We also conduct ‘weeding’ in relation to the personal data we hold as part of our routine housekeeping where we delete personal data that has become redundant or obsolete. Examples include where we have not received a response from you after a certain number of communications or where we have received ‘undelivered’ notifications in respect of email communications sent to you. We will also delete your personal data where you have requested that we do not send you marketing emails, however we may keep your name in an ‘unsubscribe’ list so that we know not contact you in the future.
International data transfers
Your information is received and processed by us in the United States. We may transfer your personal data to our processor in India as described above.
E. Visitors to our website
What personal data we collect
When you visit our website, we may collect your personal information where you submit a form containing your personal data or where the website helps you send an email to us. Where you represent a prospective customer, please refer to Section D (Personnel from prospective customers) which will govern our processing of your personal data.
The personal data we collect may include your name, your email address and the information contained in any communication with you.
How we get your personal data
We get your personal data directly from you and use it only for the purpose set out below.
How we use your personal data
We will use your personal data only for the purpose of communicating with you in response to your enquiries.
The lawful basis for our collection and use of the personal data
By contacting us through our website, you consent to our processing of your personal data for the purposes set out above and we rely on your consent as the lawful basis for our collection and use of your personal data. You may withdraw your consent at any time by contacting us in writing at our address set out in this Notice.
Who we may disclose your personal data to
The permitted recipients of your personal data will depend on whether you are a job applicant or whether you represent a prospective or existing customer or supplier. Please see the relevant section A, B or C above for further information.
How long we keep your personal data
The duration for which we hold your personal data will depend on whether you are a job applicant or whether you represent a prospective or existing customer or supplier. Please see the relevant section A, B or C above for further information.
International data transfers
Your information is received and processed by us in the United States. Depending on whether you are a job applicant or whether you represent a prospective or existing customer we may transfer your information to our processors outside the United States as detailed in the relevant sections above.
HOW WE PROTECT AND STORE YOUR INFORMATION
Security and our safekeeping of your data
We will periodically evaluate your personal data which we hold to determine whether we should continue to hold it. We have implemented all appropriate technical, organisational and security procedures to protect your personal data from unauthorised access or from accidental loss or corruption. These measures include restricting physical access to our premises where personal data is held and using access controls and firewalls to prevent unauthorised access to our systems. We recommend that you also take steps to safeguard your personal data against the risk of unauthorised access or accidental loss or corruption by backing up your personal data. Where we provide you with password-restricted access to our website or to certain functionality on our website and/or services, it is your responsibility to use a strong password and to keep it private.
Who we may disclose your personal data to
Except as set out above and save for the following exceptions, we will not disclose your personal information to any third party.
- We may disclose your personal data to ClearDox group companies where this is necessary for legal or administrative purposes.
- We will disclose your personal data to law enforcement agencies or regulatory bodies if we are required to do so by law.
- We may disclose your personal details to a third party in connection with the sale or merger of our business.
- We may employ other companies to provide services for us, including for example, processing of payments where these services are necessary in order for us to be able to provide our services to you. These companies have access to the personal information needed to perform their functions and not for any other purposes and are bound by confidentiality agreements not to disclose any information for any other purpose.
We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable laws and are carefully managed to protect your privacy rights and interests. To this end we will ensure transfers to other ClearDox group companies will be covered by an agreement entered into by members of the ClearDox group (an intra‑group agreement) which contractually obligates each member to ensure that personal information receives an adequate and consistent level of protection. Where we transfer your personal information to third parties, we will obtain contractual commitments from such parties to protect your personal information.
If at any time we wish to disclose your personal data in circumstances other than those above, we will always obtain your express consent before doing so.
Except as detailed above, we securely store your personal details on our servers in the United States.
How long we keep your personal data
Unless we provide for a specific duration in the categories set out above, we will keep your personal data for as long as is necessary for the purposes set out in this Notice after which time we will either securely delete your personal data or remove all personal identifiers from the data so that it has become anonymous. In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax or accounting requirements. This Privacy Notice shall continue to govern our use of your data for as long as we hold the data.
International data transfers
Except as detailed above, personal data is securely stored and processed on our servers in the United States and is not transferred outside the United States.
Cookies
What is a cookie? A cookie is a text string of information that a website transfers to the cookie file of the browser on your device so that the website can remember who you are. A cookie will typically contain the name of the domain from which the cookie has come, the "lifetime" of the cookie, and a value, usually a randomly generated unique number.
We may use cookies to record information about how you access our website for statistics solely for us and to the extent that these cookies contain personally identifying data, this will be limited to IP addresses only. You can choose not to accept cookies by setting the preferences on your internet browser. If you do not accept cookies from us, this may impair or prevent some or all of the services which we provide to you. We also give you the option of disabling all cookies other than those which are categorised as “Necessary” for the functioning of the website.
To find out more about cookies, what they are used for and how to remove them, please visit the Interactive Advertising Bureau Europe’s website at http://www.allaboutcookies.org/cookies/
Our website is hosted by Hubspot Inc. which provides comprehensive information on all of the cookies which are used within our website. You can find the most up-to-date list of cookies at the following web address: https://knowledge.hubspot.com/privacy-and-consent/what-cookies-does-hubspot-set-in-a-visitor-s-browser
You do not have to accept any cookies which are not necessary and we provide you with the option to decline optional cookies so that you will not be tracked when visiting our site. If you choose not to accept optional cookies, a single cookie will be used in your browser to remember your preference not to be tracked.
Your rights in relation to your personal data
As a data subject, the law provides you with certain rights in relation to your personal data which we hold. You have the right to request the following:
(1) Access to your personal data and information about why we hold it and who we can disclose it to;
(2) Correction of your personal data if it is inaccurate, incomplete or out of date;
(3) Deletion of your personal data (for example where you withdraw consent to our processing of your personal data or if you object to our processing and we have no overriding legitimate interest to continue to process your data);
(4) Stopping the processing of your personal data for certain purposes such as direct marketing;
(5) To receive your personal data in a commonly used machine-readable format or have this data sent to your designated recipient; and
(6) To object to automatic decision making and profiling based on your personal data.
Where we rely on your consent to process your personal data, you have the right to withdraw your consent at any time.
To request a copy of your personal data or to make any other request outlined above, please contact our Privacy Manager by email or by post at the contact details given at the start of this Notice. To safeguard the personal data we hold, we need to confirm your identity before we can take action following a request made under this section.
Contacting the Regulator
If you are not happy with how we have processed your personal data or how we have responded to a request you have made to us, you have the right to make a complaint to the applicable regulator which is charged with regulating data protection and use of personal data. For the United Kingdom, the applicable regulator is the Information Commissioner’s Office (or ‘ICO’) whose contact details are as follows:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: www.ico.org.uk.
Revisions to this Privacy Notice
We may change this Notice from time to time. If we make any material changes we will endeavour to place a notice on our website in advance of the changes. This Notice was last updated on 30th May 2024.