GDPR - Clear Sales Message™

To comply with GDPR , this page exists to make clear the information we collect and how we process it.

If you have any queries at all please email us at this dedicated address:

Welcome to our Privacy Policy

New thinking Ltd respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you contact us through this website or purchase a service from us and will tell you about your privacy rights and how the law protects you.

This website and our services are not intended for children and we do not knowingly collect data relating to children.

About Us

Clear Sales Message is a trading name for New Thinking Ltd. We are a limited company incorporated in England and Wales under Company number 05686354.

New Thinking Ltd is the controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us by email at [email protected]

The Data We Collect About You

Personal data, or personal 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 (anonymous data).

We will only ever collect, process and store essential information required for contacting an individual within a business environment.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Dataincludes first name, maiden name, last name, marital status, title, date of birth and gender.
Contact Dataincludes billing address, delivery address, email address and telephone numbers.
Financial Dataincludes bank account and payment card details.
Transaction Dataincludes details about payments to and from you and other details of services you have purchased from us.
Technical Dataincludes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any Special Categories of Personal Dataabout you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How We Collect the Personal Data We Hold

We collect most of this personal information directly from you—in person, by telephone, email and/or via our website. However, we may also collect information:

From publicly accessible sources, e.g. Companies House;
directly from a third party, e.g. someone who has introduced you or referred you to us, or from our third party course provider (Teachable) where you sign up to one of our courses;
from publicly accessible social media platforms, e.g. Linkedin;
from cookies on our website—as you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy https://www.clearsalesmessage.com/cookie-policy/or further details;
We will also receive Identity and Contact Data from Campaign Monitor, which is our third party email software provider, if you have signed up to receive emails from us;
We may receive Contact, Financial and Transaction Data from payment providers such as Teachable / PayPal / Amazon.

What We Do with the Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

to comply with our legal and regulatory obligations;

for the performance of our contract with you or to take steps at your request before entering into a contract;

for our legitimate interests or those of a third party; or

where you have given consent.

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	Performance of a contract with you
To provide products and/or services to you including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Updating and enhancing client records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
External audits e.g. the audit of our accounts	To comply with our legal and regulatory obligations
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price
To send you weekly and ad-hoc emails to make suggestions and recommendations to you about goods or services that may be of interest to you	For our legitimate interests, i.e. to promote our business to existing and former customers

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting Out

You can unsubscribe from emails from us by emailing: [email protected]

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or experience.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://www.clearsalesmessage.com/cookie-policy/.

Who We Share Your Personal Data With

We routinely share personal information with:

third parties we use to help deliver our services to you, e.g. payment service providers.

other third parties we use to help us run our business, e.g. Campaign Monitor, Google (cloud) or our website host;

third parties approved by you, e.g. social media sites you choose to link your account to or third-party payment providers;

our insurers and brokers;

our bank, auditors and legal advisers;

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Where Your Personal Data Is Held

Information is stored in cloud based applications provided by Googleand may be held at our offices and those of our third-party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘International transfers’ [link].

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

International Transfers

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield. Google and Linkedin are part of the Privacy Shield.

If you would like further information please contact us (see ‘How to contact us’ below).

How Long We Will Use Your Personal Data For

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data. See your legal rightsbelow for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Changes To The Privacy Policy

We keep our privacy policy under regular review. This version was last updated on 4^thMarch 2019Historic versions can be obtained by contacting us.

Changes to Your Personal Data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.]

Your Rights

You have the following rights, which you can exercise free of charge:

The right of Access– The right to be provided with a copy of your personal information
The right to Rectification– The right to require us to correct any mistakes in your personal information
The right to be Forgotten– The right to require us to delete your personal information in certain situations
The right to the Restriction of Processing– The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
The right to Data Portability– The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party, in certain situations
The right to Object– The right to object:
- at any time to your personal information being processed for direct marketing (including profiling
- in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.

The right Not to be subject to automated individual decision-making- The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

email or write to us—see below: ‘How to contact us’; and

let us have enough information to identify you (g. your full name and address)

let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill);

let us know what right you want to exercise and the information to which your request relates.

NO FEE USUALLY REQUIRED

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 could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

HOW TO CONTACT US

Please contact us by email or post if you have any questions about thisPrivacy Policy or the information we hold about you.

Email: at [email protected]