Last updated: January 2020
- The Data Protection Principles that we follow
- Personal Data We Collect and Why We Collect It
- How We Use and Share Your Personal Data
- Access to Your Personal Data and Choices
- Security of Your Personal Data
- Retention of Your Personal Data
- International Transfers
- Questions and How Contact Us
2. DATA PROTECTION PRINCIPLES
We will comply with all laws that apply to how we process your personal data. Data protection laws say that the personal data we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
3. INFORMATION WE COLLECT AND WHY WE COLLECT IT
Clarus collects certain information to enable you to take full advantage of our offerings when you register at our Site, order products or services either through the Site or our call center, communicate with our customer service representatives, participate in our contests, surveys, promotions, or activities, or otherwise communicate with us. If you choose, you can visit the Site without providing us with any information about yourself.
We seek to limit the collection and use of customer information required to deliver service to our customers. We may use this information to advise our customers about our products, services and other opportunities, and to administer our business, where we have your consent or are otherwise permitted to do so by law.
Personal Information You Provide To Us When You Become a Customer. Types of personal information we collect when you become a customer and provide it to us includes:
- Billing address
- Shipping address
- Email address
- Telephone number
- Demographic information about you
- Credit card, debit card and bank account numbers (which we will use solely for payment purposes)
Information We Collect Automatically. As is with most websites, we collect certain information automatically as you use our Site, such as
- IP address
- Browser type and language
- Computer or device type
- Unique device identifiers for mobile devices or tablets
- Operating system version
- The website from where you navigated to our Site and domain server
- Time and date of using, accessing, or otherwise interacting with our Site
- The pages on our Site that you view
- Referencing and exit pages and URLs
- The name of your Internet service provider (ISP)
- Universally unique ID
- Accounting identifier
- MAC address
- Hardware and processor information
Information from Cookies and Similar Technology
Information from Third-Party Analytics
We use or may use third-party analytics services, such as Google Analytics or Facebook Pixels, to evaluate your use of the website, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information related to the Site. Google Analytics is a web analytics service provided by Google, Inc., (“Google”). By using the Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above. For more information regarding Google Analytics please visit Google’s website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.
The Site also uses or may use the Conversion Tracking or Custom Audience Pixel service of Facebook Inc. (“Facebook”). For more information regarding Facebook Conversion Tracking, please visit Facebook’s website, and pages that describe Facebook Conversion Tracking and Custom Audience Pixels, such as https://www.facebook.com/about/privacy/ and https://www.facebook.com/ads/website_custom_audiences/, where you can also revoke permission for this service.
Information from Other Sources
We do not respond if your browser sends a “do not track” signal or similar mechanism to indicate you do not wish to be tracked or receive interest-based ads.
Advertising and Marketing
No Information from Children or Teens Under Age 13
The Site is not directed to, and we do not knowingly collect any personal data from, children or teenagers under the age of 13. If you are under the age of 13, please do not attempt to register with us at this Site or provide any personal information about yourself to us. If you are under the age of 13, you may only use this Site under the supervision of your parents or guardians.
Third-Party Sites and Social Media
Certain features and functionality of the Site are based on your location. In order to provide these features and functionalities we may automatically collect geolocational information from your mobile device, wireless carrier, and/or certain third-party service providers.
4. HOW WE USE AND SHARE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to do so. We will process your personal data:
To Provide Products, Services, and Information. As described above, we collect information from you so that we can provide products and services that you purchase from us, and to provide information that you request from us. We use your personal information to contact you about your orders, process credit card / debit card transactions, rack your order and ship our products to you. We may provide information retailers, credit and companies, banks to third party vendors and with third party service providers that help us process orders and fulfill and deliver products and services that you purchase from us.
We may provide you with information about our products and services where permitted by law or with your consent.
We may use your information to track your use of the Site.
Where you must provide personal data to us to perform a contract or take an action, we may not be able to perform the agreement or take that action without use of such data.
If you make purchases through the Site or otherwise with us, your credit card or debit card information (such as card type and expiration date) and other financial data that we need to process your payment may be collected and stored by the payment processors with which we work. We may also collect some limited information, such as your postal code, mobile number, and details of your transaction history, all of which are necessary to provide the monitoring services or products. In addition, the payment processors generally provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information they have stored, including recurring payments if you become a subscriber, and your card’s type, expiration date, and certain digits of your card number.
We use third parties to assist with providing our products and services to you host our Site, send out email updates about the Site, provide marketing and advertising services for us, remove repetitive information from our user lists, and process payments. These service providers will have access to your personal information in order to provide these services, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to help us provide the service.
Your Consent. We may use and share your personal data (including with companies, organizations or individuals outside of Clarus) when we have your consent to do so.
Legal obligations. We may use your personal data where we need to comply with a legal obligation.
Legitimate interests. We may process your personal data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. These interests may include:
- Where we reasonably need to access, use, preserve or disclose information as reasonably necessary to:
- Meet any applicable law, regulation, subpoena, legal process or governmental request.
- Enforce applicable Terms of Sale and Terms of Service, including investigation of potential violations.
- Detect, prevent, or otherwise address fraud, security or technical issues.
- Protect against harm to the rights, property or safety of Clarus, our users, customers or the public as required or permitted by law.
Sweepstakes and Contests
In order to administer our contests, sweepstakes, rewards and other promotional programs that you have consented to take part in, we may share your information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.
Other uses. We may also use your personal data in the following situations:
- Where we need to protect your interests (or someone else’s interests).
- Where needed in the public interest.
Use within the Clarus Group. We may share your personal data with our affiliates and group companies, including Clarus Glassboards LLC. Clarus uses the IT and other systems of the Clarus Group (including systems located in the USA) and may transfer your personal data in order to do this.
5. RIGHTS OF ACCESS, CORRECTION, ERASURE AND RECTIFICATION OF YOUR PERSONAL DATA AND CHOICES
If you have questions about personal information, we have about you or wish to amend or update any of your information you can contact us or call us at 020398 19280 / firstname.lastname@example.org.
You can close your online account by calling us at 020398 19280 / email@example.com. If you close your account, we will no longer use your online account information or share it with third parties. We may, however, retain a copy of the information for a period of time reasonably necessary for archival purposes, and to avoid identity theft or fraud.
If you have any questions about this privacy notice or how we handle your personal data, please contact 020398 19280 / firstname.lastname@example.org.
We will only use your personal data for marketing in accordance with applicable law. You may opt out of receiving future marketing communications from us by logging into your account and editing your profile. You may also opt out of receiving commercial e-mail from us by following the instructions in each e-mail.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. You can find out more about your rights in relation to your personal data at www.ico.org.uk.
Please note that you have rights to object to processing of your personal data for marketing and certain activities that are in our legitimate interests. You have a right to obtain a copy of your personal data and in certain situations to obtain correction, erasure and restriction of processing of your personal data.
You have a right of data portability.
Where processing is based on your consent you have a right to withdraw this consent at any time.
You may access these rights be notice to 020398 19280 / email@example.com.
6. SECURITY OF YOUR PERSONAL DATA
We use commercially reasonable physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that e-mails and other communications you send to us through our Site are not encrypted, and we strongly advise you not to communicate any confidential information through these means.
7. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will keep your personal data for the time during which your account is open (or, if you do not have an account, for a reasonable period) or, if longer, the period required by law.
To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. At all times we will comply with our data retention policy.
In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a customer we will retain and securely destroy your personal information in accordance with our data retention policy and applicable law.
9. INTERNATIONAL TRANSFERS
We may transfer your personal data to countries outside the EEA, including to countries that do not provide a level of protection for personal data considered adequate by the EU. In particular, Clarus uses IT and other systems of the Clarus Group, including systems located in the USA.
All such transfers will be made in accordance with the EU US Privacy Shield, the EU Commission standard contractual clauses or as otherwise permitted by law. At the date of this policy we are in the process of implementing standard contractual clauses.
10. QUESTIONS AND HOW CONTACT US
79 Clerkenwell Road
London EC1R 5AR
Attention: Privacy Department