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:
This website and our services are not intended for children and we do not knowingly collect data relating to children.
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.
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;
- 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.
|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:
(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
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can unsubscribe from emails from us by emailing: firstname.lastname@example.org
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.
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].
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.
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 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.
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.]
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
Email: at email@example.com