cleartarn Privacy and Security Policy

cleartarn Ltd (‘we/us’) takes your privacy and data security very seriously when using the Membership system (‘the system’). This policy outlines our approach to protecting your data and your privacy and the privacy of members of any organisation you create or belong to on the system.

When we refer to "personal information or data" in this policy, we mean information, which identifies you or your members as individuals, or is capable of doing so. We may hold and use data about you and your members in your capacity as a consumer, a business customer, as an individual acting on behalf of a business customer, or in any other capacity.

What we will not do:

1. We will not share your personal information with any other organisation unless we are required to do so by law or instruction from a body legally authorised to make such an instruction.

2. We do not store your credit card information.

3. As the system is aimed at group membership you may receive emails generated from any organisation you are a member of on the system. You can select in your profile not to receive emails from the organisation.

4. We cannot guarantee that any organisation that you belong to using the system will guarantee the privacy of your personal information. Should you feel that they are sharing your information with others without your permission you should first raise the matter directly with that organisation. If you are not satisfied with their response then you may raise the matter with us. We will investigate any complaint and report to you our findings and any actions at our sole discretion that we intend to take.

5. We will not contact you by post or telephone unless we believe there is some urgent matter relating to the security of your information or usage of the system. However, we would only do this in the event that we are unable to contact you by email or you have requested us to do so. Our preferred method of contact is by email.

6. We will not use the contents of any documents or files you upload, logbooks or private events for any purposes whatsoever.

7. Cookies will not be used to do anything other than detect browser and device types you are using in order to improve the session you have entered.

8. We will not collect any other information from any device you access the system from.

9. We will not access your personal data for any purposes other than to maintain or improve the system, to re-instate a deleted record at you request, to contact you or for other purposes outlined in the policy and our Terms and Conditions.

10. We cannot advise whether storage or access of personal information in the form provided by the system is lawful in any location outside of the European Economic Area (EEA) and you should ensure that you and your organisation comply with any applicable laws.

What we will do:

1. We will protect your personal information in the same way we would expect our own personal information to be protected.

2. We will comply with the Data Protection Act.

3. We may record usage statistics which are made anonymous before being used for any marketing or publicity purposes and to assist advertisers who might advertise on our website.

4. We will use secure servers hosted by reputable providers with https connections to protect your data. These servers are currently located in Europe and in the USA and the servers maintain comprehensive data backup and re-instatement provision.

5. If we transfer personal data outside the European Economic Area (EEA) we will take steps to ensure that your data will be given adequate protection as required by the Data Protection Act.

6. We may use your personal information to contact you if you or one of your organisation’s members abuses or attempts to illegally obtain information from our system or uses the system to cause offence or nuisance to others. In such cases we also reserve the right in our sole discretion to suspend to the services to you or your organisation without notice.

7. We will send you email information regarding the system, enhancements and information from other groups or organisation which we feel may be of interest to you. We may also contact you to ask about your experiences of using the system and to identify potential improvements in our service. You can select in your profile not to receive these emails.

8. We will send you email information from third parties which we feel may be of interest to you. These emails will be produced and sent from the system. We will not provide your details to any third parties to send these emails, but we may send these emails on behalf of other organisations. You can select in your profile not to receive these emails.

9. We may record and keep information relating to any abuse of the service and provide any information to the police where consider it appropriate.

10. We will store your password in encrypted form. We do not have software to decrypt your password.

11. We may provide information, in response to properly made requests, for the purposes of the prevention and detection of crime, and the apprehension or prosecution of offenders. Any information we provide will be in accordance with the Data Protection Act.

12. We also provide information when required to do so by law, for example under a court order, or in response to properly made demands, under powers contained in legislation.

What you agree to do:

1. Safeguard your password and immediately change it should you feel that it may be known to others.

2. Log off the system as soon as you have completed your session to prevent others from accessing your personal data or the personal data of anyone else on the system who you have permission to access.

3. If using a public computer you should select Private Browsing before you access the system.

4. If you have rights as a Site Administrator, ensure that the permissions that you grant to your organisation’s members are appropriate to their need to access the system.

5. Not to use the system for any illegal or unlawful purposes and to respect the copyright and intellectual property of third parties and not use the site to store or transfer information which would be in breach of any third parties rights.

6. If you access the system from outside of the U.K. you must ensure that you do not breach the Data Protection rights of any individual resident in the U.K. or European Economic Area (EEA) You should also have due regard for any local laws an regulations which might govern the use of the system

7. Report any concerns you have about data security to us.

8. You agree not use or permit the system to be used by your organisation's members to send email which could be classified as spam and nor will you register people as members of your organisation who are not actually members or have not explicitly agreed to have their details kept on the system.

9. You agree not use or permit the system to be used by your organisation's members to harass or cyber bully any other person or to say defamatory things about any organisation or person, living or dead.

10. You agree not use or permit the system to be used by your organisation's members to promote or advocate any illegal act or to display any information or make any comments which other users of the system might reasonably find offensive.

About personal information:

1. The time period for which we keep information will be no longer than is necessary for the purposes for which the data was collected or for which it is to be further processed.

2. If you wish to obtain a full subject access request under the Data Protection Act then send your request in writing by email using our contact details. You will be asked for a payment of £10 as permitted under the Data Protection Act. You will also need to provide the following information so that we can process your request:

• Your full name
• Your email address
• The organisation or organisations to which you belong

3. Once we have all the relevant information we will process your request within the 40 day time limit allowed under the terms of the Data Protection Act.

4. If the information we hold about you is incorrect please contact us and we will amend it accordingly.

5. Should you require information which organisations which use the system hold about you then you should make a formal request of those organisations as we are not permitted to access or provide that information to you.

General

1. We reserve the right to amend this policy at any time and without notice.

cleartarn Privacy and Security Policy – 1 May 2012