Claromentis Privacy and Cookie Policy -

1. Introduction

Claromentis has created this privacy statement in order to demonstrate our firm commitment to privacy. We operate websites based in the UK, Australia, and United States of America.

These websites are owned by Claromentis Limited or its wholly owned subsidiaries. As the central administration for the websites is based in the UK we apply EU/UK law to the privacy principles for each one. This Privacy Statement also applies to any other websites we may establish in the future, in any location, and which are not specifically named here.

2. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

“websites”	www.claromentis.com, discover.claromentis.com, workplace.claromentis.com
“cookie(s)”	This is a small text file that is placed on your computer or device by the browser when you visit certain parts of our websites and/or when you use certain features of our websites. Details of the Cookies used by websites are set out below.
GDPR	EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”). The GDPR is a legal framework that sets guidelines for the collection and processing of personal information of individuals within the European Union (EU).
“personal data”	Any data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us on these websites. This definition shall, where applicable, incorporate the definitions provided in the GDPR.
“we/us/our”	Claromentis Ltd – see section 3 for further details

3. Claromentis Ltd

These websites are owned and operated by Claromentis, a limited company registered in England under company number 03672955, whose registered address is Hampton House, High Street, East Grinstead, West Sussex, RH19 3AW, and whose main trading address is Claromentis Ltd, 6th Floor, Vantage Point, New England Road, Brighton, East Sussex, BN1 4GW.

Our Data Protection Manager is Will Emmerson, and can be contacted by email at data-protection@claromentis.com, by telephone on UK) 0800 409 6101 US) 1 (844) 238 6868 , or by post at Claromentis Ltd, 6th Floor, Vantage Point, New England Road, Brighton, East Sussex, BN1 4GW.

4. Your Rights

1) As a data subject, you have the following rights under the GDPR, which this Policy and our use of personal data have been designed to uphold:

The right to be informed about our collection and use of personal data
The right of access to the personal data we hold about you (see section 10)
The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details in section 12)
The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (we only hold your personal data for a limited time, as explained in section 6 but if you would like us to delete it sooner, please contact us using the details in section 12)
The right to restrict (i.e. prevent) the processing of your personal data;
The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation)
The right to object to us using your personal data for particular purposes; and
Rights with respect to automated decision making and profiling.

2) If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 12 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

3) For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What data do we collect

Cookie(s)	Please see section 9 for further information on the use cookies on this site
Quote requests	We collect basic company and personal data so that we can provide accurate quotes for the products and services we provide
Personalised demo	In order to arrange a personalised demo with a member of our team, we ask for a few personal contact details in order to fulfil this request
Brochure/advice guide/e-book downloads	We collect basic personal data so that we can provide you with a link to the downloads and information about Claromentis
Instant access demo (“try our software) – workplace.claromentis.com	We’ll ask for certain contact details in order to provision an account for this system
Contact form	If you’d like to get in contact with us, the contact form require basic personal information that will allow us to email you back
Support portal – discover.claromentis.com	Our support portal will collect personal data that will allow us to process support tickets, change requests, upgrades that allow us to fulfil each contract with our clients. We’ll also collect statistics and feedback that allows us to improve the products and services that we provides.
HubSpot	We use HubSpot to gain insight into website user activity, such as page views, workflows, traffic sources, etc in order to provide tailored content that’s relevant to our visitors’ needs. For more information, please visit HubSpot’s privacy policy. We also use HubSpot’s instant messaging app, where you can ask questions and speak directly to a member of our Sales team. Basic personal information is required that will allow us to reply to your messages and email you back.

6. How do we use your data?

1) All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.

2) Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:

Providing and managing your access to our websites
Personalising and tailoring your experience on our websites
Supplying our products and services to you – please note that we require your personal data in order to enter into a contract with you
Replying to emails from you
Replying to messages from you that are sent via Hubspot.
Supplying you with emails sent from HubSpot when you download a brochure/advice guide/e-book on our websites, which provides you with a link to the download and follow-up emails with content offers that are relevant to you (you may unsubscribe or opt-out at any time by clicking the “unsubscribe” link at the bottom of the email, which will allow you to unsubscribe from our HubSpot campaigns). The Sales team may also contact you directly via email and/or telephone (if provided) to see if they can help you with further information.
Supplying you with emails sent from HubSpot when you request an instant access demo (“try our software”) for workplace.claromentis.com which provides advice on how to use the demo, information about a selection of our clients, and information about how to pursue your interest in Claromentis further (you may unsubscribe or opt-out at any time by clicking the “unsubscribe” link at the bottom of the email, which will allow you to unsubscribe from our HubSpot campaigns). The Sales team may also contact you directly via email and/or telephone (if provided) to see if they can help you with further information.
Supplying you with emails sent from HubSpot after a period of time subsequent to your initial interest in Claromentis (downloading a brochure/advice guide/e-book or requesting an instant access demo (“try our software”)) which provides you with relevant information about Claromentis products and/or services which we think you may find interesting (you may unsubscribe or opt-out at any time by clicking the “unsubscribe” link at the bottom of the email, which will allow you to unsubscribe from our HubSpot campaigns).
Supplying you with any other emails/newsletters that you have explicitly opted into (you may unsubscribe or opt-out at any time by clicking the “unsubscribe” link at the bottom of the email, which will allow you to unsubscribe from our HubSpot campaigns).
Market research
To gain feedback and opinion on the product and/or services that we provide

3) With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email with information, news and offers on our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

4) Third parties whose content appears on our websites may use third party cookies, as detailed below in section 9. Please refer to section 9 for more information on controlling Cookies. Please note that we do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.

5) You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it. Please refer to section 10 for details on how to do this.

6) We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

Personal data used for Newsletters/Marketing: We’ll maintain a list of subscribers who are actively participating in our email campaigns. If the subscriber signed up over 5 years ago AND hasn’t opened any of the last 5 campaigns we will remove and delete any personal data for this subscriber.
Personal data used to communicate with potential customers will be kept for up to 5 years after the initial enquiry or until requested otherwise (see section 10)
We’ll store any personal data used in order to fulfil our contractual obligations for the product and/or service that we provide, for the length of the contract and for up to 5 years after the contract has been terminated.

7. How and where do we store your data?

We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.

Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using our website and submitting information to us. If we do store data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR. Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through our websites.

We’ll only provide access to personal data for sub-processors based outside of the EEA so long as they are based in countries that are deemed to have ‘adequate protection’ according to the GDPR article 45 of Regulation (EU) 2016/679.
Any personal data we store on our own cloud servers is based in the Google Cloud data center in the US. Google Cloud is protected by the EU privacy shield and adhere to an extensive and industry leading set of certifications, compliances and security procedures. For a full list, please refer to https://cloud.google.com/security/compliance/
Each of our websites uses world-class encryption for data in transit, in use and at rest
We regularly update our infrastructure to ensure that any security vulnerabilities are quickly rectified, so that optimal protection is always in place
If a security breach causes an unauthorised intrusion or loss of personal data that we hold, we’ll contact the affected parties as soon as possible

8. Do we share your data?

Personal information will not be released to any other third parties (such as a Claromentis Business Partner) except to progress the matter for which you provided the information in the first instance unless the release of your personal information is required by law or is pertinent to governmental or judicial investigations or proceedings.

‘Business Partners’ are defined as Distributors, Resellers, or Channel Partners of Claromentis with each one delivering varying levels of goods or services depending upon their relationship with Claromentis. If you have any concerns about a particular Business Partner, whether they are listed or not, you should contact us before you provide us with your personal information.

The Claromentis & Claromentis websites may contain links to other, external websites. Operation of these links will not cause your personal information to be transmitted to these sites. Likewise, Claromentis cannot be held responsible for the Privacy Principles of other entities.

We may sometimes contract with third parties to supply services to you on our behalf. These may include search engine facilities, analytics, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.

We may compile statistics about the use of our site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EU/UK and under the GDPR. We also ensure that each of these sub-processors has signed up to the EU Privacy Shield.

Please see the list below for a summary of our key sub-processors and a link to a confirmation of their Privacy Shield participation:

Google	Our cloud infrastructure is built on the Google Cloud IaaS named Google Compute Engine. We use this to host our SaaS software and the websites that support this.	https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI
HubSpot	We manage marketing email and newsletter campaigns through HubSpot.	https://www.privacyshield.gov/participant?id=a2zt0000000TN8pAAG&status=Active
SendGrid	SendGrid is used on our SaaS infrastructure in order to send out email notifications (an email relay service) from the clients digital workplace to the end user(s). For example, a simple notification about a new document upload would be sent out using this service.	https://www.privacyshield.gov/participant?id=a2zt0000000TRktAAG
Basecamp	This is used for the management of the initial project launch only, for communication between the Claromentis Service Delivery team and the client.	https://www.privacyshield.gov/participant?id=a2zt0000000TP1OAAW

9. Cookie policy

Our websites may place and access certain first party cookies on your computer or device. First party cookies are those placed directly by us and are used only by us. We use cookies to facilitate and improve your experience of our websites and to provide and improve our services. We have carefully chosen these cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using our websites, you may also receive certain third party cookies on your computer or device. Third party cookies are those placed by websites, services, and/or parties other than us. Third Party cookies are used on our websites for the reasons shown in the table below.

All cookies used by and on our websites are used in accordance with current laws under GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003;

By giving your consent to the placing of cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to or block the placing of cookies (including essential cookies); however certain features of our websites may not function fully or as intended or you may not be able to access all or parts of our website. Certain features of our websites depend on cookies to function.

The following first party cookies may be placed on your computer or device:

Name of Cookie	Purpose
popup	Employee Engagement e-book pop-up.
downloaded	Remembers if you have downloaded the Employee Engagement e-book.
PHPSESSID	Used by WordPress to maintain user session variables, such as logged in status and UX.

and the following third party cookies may be placed on your computer or device:

Name of Cookie	Provider	Purpose
__ar_v4	AdRoll remarketing	To serve Claromentis branded adverts on attributed websites.
_ga, _gid, _gat, gwcc	Google	Tracks the activity carried out on https://www.claromentis.com.
1P_JAR, APISID, APISID, CONSENT, CONSENT, DSID, HSID, HSID, IDE, LOGIN_INFO, NID, PREF, SAPISID, SAPISID, SID, SID, SIDCC, SSID, SSID, VISITOR_INFO1_LIVE, YSC, __utmx, __utmxx	YouTube	Cookies set by Google when a YouTube video is present.
_hjIncludedInSample, __hssrc, __hstc, _ga, hubspotutk, intercom-lou-c5ke8zbr, mp_hj_mixpanel, optimizelyBuckets, optimizelyEndUserId, optimizelySegments	HotJar	Measures clicks across https://www.claromentis.com.
hubspotutk, __hssc, __hssrc, __hstc, hsfirstvisit, hs_ab_test, messagesUtk, hs-messages-is-open, hs-messages-hide-welcome-message, __hluid, __cfduid	HubSpot	Captures website user activity on https://www.claromentis.com and https://www.discover.claromentis.com.

How to manage or opt out of cookies

Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. You may also opt out of cookies by clicking here: http://preferences.truste.com/, or if you are located in the EU, by clicking here: http://www.youronlinechoices.eu/.

You can choose to delete cookies on your computer or device at any time, however you may lose any information that enables you to access our website more quickly/efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

10. Request for access / accuracy & retention of data

You have the right to access, correct, amend or delete personal data held by us (where such data is held). Under the GDPR, no fee is payable and we will provide any and all information in response to your request free of charge. Please contact us for more details at data-protection@claromentis.com, or using the contact details below in section 12.

11. Your Right to Withhold Information

You may access our websites without providing any data at all. However, to use all features and functions available on our websites you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see section 9 (our cookie policy).

12. Contacting Us

If you have any questions about our websites or this privacy policy, please contact us by email at data-protection@claromentis.com, by telephone (UK) 0800 409 6101, (US) 1 (844) 238 6868, or by post at Claromentis Ltd, 6th Floor, Vantage Point, New England Road, Brighton, East Sussex, BN1 4GW. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 10, above).

Last updated 22nd July 2019.