Important information and who we are
This website is not intended for children and we do not knowingly collect data relating to children.
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.
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 contact us at any time to verify, confirm, update or modify your information, contacting us via writing to Claro Wellbeing, The Leather Market, 4G.01, Weston St, Bermondsey, London SE1 3ER or emailing email@example.com.
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 or pseudonymised data).
We may collect, use, process and transfer different categories of personal data about you which we have grouped together as follows:
“Identity Data” which includes first name, last name, username or similar identifier, (including family name, nickname, maiden name, etc);
“Contact Data” which includes address (current and previous), email address and telephone numbers.s, social media handles;
“Financial Data” which includes view-only access to your bank transactions and payment card details for app subscription;
“Technical Data” which includes internet protocol (IP) address, your login data, browser type and version, time zone setting, location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our services;
“Profile Data” which includes your username and encrypted password, your interests, preferences, feedback and survey responses;
“Usage Data” which includes information about how you use our website, products and services;
“Marketing and Communications Data” which includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose.
We also collect, use and share “Aggregated Data” for statistical, demographic and marketing purposes, including, but not limited to, data that allow us to improve your user experience, for product and personalization purposes.
We do not collect any “Special Categories of Personal Data” about 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) for marketing or product purposes. Nor do we collect any information about criminal convictions and offences. Occasionally we may conduct general market research about finances and consumers and as part of this research we may ask you questions relating to “Special Categories of Personal Data”. This information is fully anonymous and never forms part of our marketing or product data and is stored and processed by our data partner Dynata.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested or limit access thereto, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Claro products or services). In this case, we will give you the opportunity to provide the missing data but if we do not hear from you we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity Data, Contact Data and Financial Data by filling in forms or by corresponding with us online, via our website or our app or via post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- subscribe to our mailing or waiting list;
- create an account on our website or our app;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
(b) advertising networks such as Google, Facebook, Awin, LinkedIn, Twitter based outside the EU; and
(c) search information providers such as Google based outside the EU.
How we use your 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:
Where we have obtained your consent to use your Personal Data;
Where we need to comply with a legal obligation;
Where we need to perform the contract we are about to enter into or have entered into with you; and
Where it is necessary based on a legitimate interest (including our or that of a third party) and your interests and fundamental rights do not override those interests.
See the glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
By engaging on our website, signing up to our mailing list(s), entering competitions, requesting information from us or engaging in any other way in person or digitally we conclude you have a legitimate interest in Claro’s business activities. We accept your legitimate interest in us and use this as a legal basis for processing your personal data.
You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information, joined our mailing lists or, where applicable, waitlist(s), entered a competition or give-away, downloaded an eBook, template or any Claro content or if you have purchased, or are about to purchase, products or services from us and you have not opted out of receiving that marketing. You may opt-out of communications from us by unsubscribing from the footer of any email you receive from us or by contacting us with your request at firstname.lastname@example.org at any time.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at email@example.com at any time.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Specific third parties as set out in the list below:
We require all third parties to respect the security of your personal data and to 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 for specified purposes and in accordance with our instructions.
Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
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.
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.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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 employees, 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.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for 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, regulatory, tax, accounting or other requirements.
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 rights below 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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
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 require you to pay a reasonable fee if your request is clearly unfounded, repetitive or excessive. We reserve the right to reject any request deemed to be malicious, unfounded, repetitive or excessive and will contact you immediately outlining our assessment should this be the case.
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 will 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.
means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
“Performance of Contract”
means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
“Comply with a legal obligation”
means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External Third Parties
Your Legal Rights
You have the right to:
“Request access” to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
“Request correction” of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
“Request erasure” of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, 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.
“Object to processing” of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
“Request restriction of processing” of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
“Request the transfer” of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
“Withdraw consent at any time” where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.