1. Introduction

Thank you for visiting Clear Ring. We are a call tracking and analytics provider whose software gives website owners (Our Clients) the ability to track and record calls (optional), form submissions, measure and understand their online and offline marketing campaigns to optimise the effectiveness of their marketing, improve customer service and sales performance. This information allows a website owner which is a customer of Clear Ring to improve the overall service that they provide to their website visitors.

This privacy policy informs how Clear Ring collects and processes your personal data when you visit websites of our Clients who use our software and services. If you are a user of Clear Ring’s website or a user of our Client’s website, and you would like information about how we process your data, please click here for a link to our ‘Privacy policy for Clear Ring website and Clear Ring Clients

2. About us and the services we provide

Clear Ring is a company registered in England and Wales (Company No* 12866676), with registered office at 17 Boundary street, Liverpool, United Kingdom, L5 9UB.

We have appointed a data protection officer (DPO) responsible for overseeing any questions relating to this privacy notice. If you have any questions about this notice or how we process your data, please contact us using the contact details below in the ‘Contact Us’ section.

3. Information collected and how we use such information

Personal data or information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymised data). For users of a Clear Ring Client website, Clear Ring acts as a service provider to the client, providing Clear Ring Services.

Clear Ring tracks the online activity of a visitor to the Client’s website enabling the Client to analyse the website visitor’s journey through to the Client’s website. To do this we use cookies (via our Client’s websites) to collect certain information from your device regarding your use of our Client’s website.

The information we may collect on our Client’s behalf (via their website) could include your telephone number, IP address and information relating to your operating configuration (e.g., screen resolution) and cookie IDs. We may also process recordings of calls made to our Clients upon our Client’s request.

The collection of such information is to enable Clients to analyse a website visitor’s journey through the Client website and analyse the effectiveness of the Client’s marketing strategies. Please be aware that our Client determines the purpose for which such information is used and is responsible for establishing the legal basis for process such data. Clear ring processes such information on the instruction and behalf of the Client.

Clear Ring will only process your personal information for the purpose of providing our Services to our to our Client, and as required under applicable laws. You should refer to the Client’s privacy policy to find out how they use your personal data.

We may collect, use and share aggregated data such as statistical or demographic data for any purpose (Aggregated Data). Aggregated Data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly disclose your identity. For example, we may aggregate information about the number of users using a website or specific website features. If we merge or link Aggregated Data with your personal such that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

4. What basis do we have for processing your personal data

We will process your personal data where we have a lawful basis for doing so. In general, our lawful basis will be:

(i) That the processing is necessary for the purposes of pursuing our legitimate interests or the legitimate interests of our Clients (as explained above);

(ii) That the processing is necessary for compliance with our legal obligations.

We may also process personal data with your consent.

5. Disclosure of your personal data

We will never sell your data to third parties.

We may share your personal data with:

  • Our suppliers and service providers who we use in connection with and for the purposes of providing the Services, including for example providers of cloud storage, data centres and telecommunication providers. We require our suppliers to respect the security of your personal data and treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data to the extent required to provide the Services.
  • Our legal and other professional advisors, our insurers and insurance brokers;
  • Government agencies, regulators, and other authorities.
  • In some cases, we may choose to buy or sell business assets. In these types of transactions, user information is typically one of the transferred business assets. If Clear Ring, or substantially all its assets, were acquired, user information is likely to be one of the assets that is transferred or acquired by a third party, and the acquirer may continue to use your personal data for the purposes set out in this policy.

5.1 Release of your information for legal purposes
We may disclose personal data about you:

  • when required to do so in order to comply with any applicable laws, regulations or enforceable governmental or public authority request;
  • where such disclosure is reasonably necessary to (i) enforce applicable terms of service, including investigation of potential breaches; (ii) detect, prevent, or otherwise address fraud, security or technical issues; (iii) respond to user support requests; or (iv) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organisations for fraud protection and spam/malware prevention.

6. Right to access, edit, and remove your information

The European Union’s General Data Protection Regulation (GDPR) provides you with rights in relation to your personal data in certain circumstances:

  • The right to request access to personal data we hold about you.
  • You may have the right in accordance with applicable data protection law to have personal data we hold about you rectified or restricted.
  • You may, in some circumstances, have the right to have personal data we hold about you deleted (although note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request).
  • In some circumstances, you may have the right to receive or ask for your personal data to be transferred to a third party.
  • You have the right to object to how we process your personal data in certain circumstances.
  • Where we are processing personal data relating to you with your consent to do so, you may withdraw your consent at any time (this will not affect the lawfulness of any processing carried out before you withdraw your consent).

When you request access to personal information that we hold about you, we may ask you to verify your identity before providing such information to you or making any requested changes. We may also contact you to ask you for further information in relation to your request. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

If you wish to exercise any of the rights set out above in respect of our processing of your personal data, please contact us at hello@clearring.co.uk. If you wish to access, or correct, amend, or delete inaccurate data held by one of our Clients, or no longer want to be contacted by one of our Client, please direct your enquiry to the relevant Client because the Client is the data controller.

You may have the right to lodge a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance and we shall endeavour to resolve your complaint.

7. Security Measures

We use an extensive range of technical and organisational measures to protect the security of our website and Clear Ring Services. Our data storage facilities have comprehensive detection and protection systems. Further details on our security and privacy measures are available on request.

8. International Transfer

Clear Ring stores and processes personal data on servers based in the European Union. We do not hold or transfer any data outside of the European Economic Area

9. Children and Special Categories of Personal Data

We do not knowingly collect, seek to collect, or anticipate collecting any personal data from children or any data considered to be ‘special categories of data’ (data about your race or ethnicity, religious or philosophical beliefs, sexual orientation, sex life, trade union membership, political opinions, health data and genetic or biometric data

10. Cookies

Use of cookies by Clear Ring

Cookies are small data files placed on your computer by the websites you visit and can be used to help recognise you when you return to a website. Cookies can be used to, among other things, measure activity, personalise your experience, or remember your viewing preferences. For some of these purposes, cookies may be tied to personal data.

Use of cookies on our Client’s websites

Clear Ring Services use first-party cookies to analyse a user’s session across multiple pages on a Customer’s website. These cookies do not track the same user across unrelated domains and Clear Ring does not attempt to identify the same person across disparate, unrelated domains.
Please see our cookies policy for more information about cookies.

Blocking Cookies

You can set your browser to reject cookies, or to alert you when websites set or access cookies. You can also manually delete individual or all of the cookies on your computer by following your browser’s help file directions.

11. Retention of data

We will only retain your personal data for as long as necessary to provide the Services to our Client or for the purposes of satisfying any legal or reporting requirements.

12. Links to third party websites

Our website may include links to and from third-party websites. Please be aware that these websites have their own privacy policies if you follow a link to any of these websites. We do not accept any responsibility or liability for these policies. You should check these policies before submitting any personal data to their websites.

13. Changes

We reserve the right to amend this Privacy policy and may change it from time to time. When there are changes to this Privacy Policy, we will update this page. The date on the bottom will always indicate when we last made changes.

14. Contact Us

If you have any questions or concerns regarding the way in which we process personal data, please contact us hello@clearring.co.uk or via postal mail at:

Clear Ring Ltd
17 Boundary Street
Liverpool, UK
L5 9UB

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