We are committed to safeguarding the privacy of our website visitors, service or app users, individual customers and customer personnel. References in this policy to our “website” includes the app and vice versa unless otherwise stated.

This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

Where our users use our app to record personal data relating to the user’s (or his/her company’s) contacts, prospects, leads or customers (“in-app contact data”), we do not have any control over what personal data is recorded, nor how or for what purpose it is collected or the means for collecting it. We are therefore not a data controller in respect of such in-app contact data. We do process that in-app contact data on behalf of our users (or his/her company’s) by virtue of the provision of the Clinchd services and therefore we consider ourselves a data processor in respect of that personal data. Accordingly, how we process that personal data is covered by the Data Processing Addendum which you can find here www.modlify.io/dpa. It is the user’s (or his/her company’s) responsibility to ensure that it complies with applicable data protection laws in respect of how it collects and uses the personal data of any individuals whose details are included in the in-app contact data, including without limitation, the obligation to provide an information notice and to ensure there is a lawful basis for such processing.

We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

In this policy:

1. "we", "us" and "our" refer to Clinchd Limited. For more information about us, see Section 18;
2. “tenant” means the environment on the Clinchd platform that we set up when you first signed up for Clinchd services (or where you have been invited, someone else first signed up for Clinchd services)

In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

We may process data your member data (“member data”). The member data could include information about your company (including the name, email address, relationship), profile data (including name, avatar photo, app settings / preferences, job title or role, contact details, linked social media accounts, notification preferences), administrator-settings (including role, subscription, accessibility preferences), subscription data (including subscription length, subscription type, billing details). The source of the member data is you although some elements of the account data may be generated by our app/website and/or our payment services provider.

We may process data enabling us to get in touch with you ("contact data"). The contact data is general marketing & communications data including name, email address, communication preferences, invitations to use the service (including the business relationship to the company) and may include your name and email address. The source of the contact data is you, (e.g. signing up on our website to “Keep in touch”) or signing up to try / use the app or by accessing gated content on our site); through others inviting them to use Clinchd; from administrators of the tenant that they have signed up to use; and from data we have obtained externally for the purposes of marketing.

We may process information relating to our customer relationships ("customer relationship data"). The customer relationship data may include your [name, the name of your business or employer, your job title or role, your contact details, your classification / categorisation within our customer relationship management system and information contained in or relating to communications between us and you, or between us and your employer]. The source of the customer relationship data is you.

We may process your personal data that are provided in the course of the use of our services and generated by our services in the course of such use ("service data")]. The source of the service data is you and/or our services.

We may process data about your use of our app/website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.

Please do not supply any other person's personal data to us, unless we prompt you to do so.

In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.

Operations - We may process your personal data in some or all of the categories as outlined in Section 2 for the purposes of operating our website/app, providing our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website/app, services and business.

Relationships and communications - We may process contact data, account data, customer relationship data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, [device notifications] and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.

Direct marketing - We may process member data, contact data, , and/or customer relationship data for the purposes of creating, targeting and sending direct marketing communications by [email, SMS and device notifications] and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.

Research and analysis - We may process member data, usage data, and/or service data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business and benchmarking purposes. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.

Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

We may share the personal data described in this notice with the following categories of recipients, where and to the extent necessary for the purposes described in this notice:

1. Group companies: any of our subsidiary companies, our ultimate holding company and all its subsidiaries from time to time.
2. Insurers and professional advisers: such as lawyers, accountants and business and marketing consultants, but only if and to the extent necessary for them to carry out the work we engage them to assist us with, for example in relation to a legal claim made against us or obtaining insurance coverage.
3. Organisations or individuals engaged by us in the course of providing our services: such as individual consultants or their personal service companies who provide software/website programming/development services or assist with providing support and maintenance services to our customers.
4. Prospective buyer: if we propose to sell or do sell any of our business or assets, we may make personal data available to a prospective buyer for the purposes of pre-sale due diligence or to a buyer as information assets transferred as part of the sale – for example a prospective buyer may request details of any outstanding legal claim against us, or a buyer may acquire ownership of our business contacts/customer databases.
5. Service providers: We use a number of service providers in connection with our website, services, communications and IT infrastructure, which involves those service providers processing some of the personal data described in this notice to the extent necessary to provide the relevant services.

We have contracts with all our service providers to ensure that they treat the personal data they receive in compliance with applicable data protection laws, including that they only process the personal data described in this notice to the extent necessary to provide the services.

In all cases, we will only share personal data with such recipients where and to the extent reasonably necessary for the relevant processing purpose and in accordance with applicable data protection law.

In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.

We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.

We transfer some personal data to the service providers described in Section 4 above section above that are based in countries outside the UK. Below we describe these transfers and the safeguards in place to protect personal data once it has been transferred.

In addition to the known transfers described above, it may become necessary to transfer personal data described in this notice to organisations based outside the UK in connection with the purposes described in the ‘Other processing purposes’ section above, such as to comply with a legal obligation or to defend or bring a legal claim. If this happens, we would ensure that such a transfer complies with the conditions for transfers stipulated by applicable data protection law.

You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain data only for so long as is necessary for the purposes for which we hold it. This may vary according to the type of personal data and the purposes for which we use it. If you would like to know what that means in respect of your personal data, please contact us by emailing support@clinchd.com.

In determining how long we retain personal data, we take into consideration the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means, our legal obligations, good industry practice, the guidance of relevant UK authorities such as HM Revenue & Customs, and also tax, accounting and health and safety rules.

Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

The following personal data will be stored by us in encrypted form: your name, contact information and password(s).

You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

In this Section 8, we have listed the rights that you have under data protection law.

Your principal rights under data protection law are:

1. the right to access - you can ask for copies of your personal data;
2. the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
3. the right to erasure - you can ask us to erase your personal data;
4. the right to restrict processing - you can ask us to restrict the processing of your personal data;
5. the right to object to processing - you can object to the processing of your personal data;
6. the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
7. the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
8. the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

Our website includes hyperlinks to, and details of, third party websites.

In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.

Our website and services are targeted at persons over the age of 18.

If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

Please let us know if the personal information that we hold about you needs to be corrected or updated.

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

We use cookies for the following purposes:

1. authentication and status - we use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website
2. personalisation - we use cookies to store information about your preferences and to personalise our website for you.
3. security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally.
4. analysis - we use cookies to help us to analyse the use and performance of our website and services.
5. cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.

Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

1. We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy.
2. We use Auth0 for user authentication and identity management services. This service uses cookies for security and authentication and status. You can view the Auth0 privacy policy at https://auth0.com/privacy.

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

1. https://support.google.com/chrome/answer/95647 (Chrome);
2. https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
3. https://help.opera.com/en/latest/security-and-privacy/ (Opera);
4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
5. https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
6. https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).

Blocking all cookies will have a negative impact upon the usability of many websites.

If you block cookies, you will not be able to use all the features on our website.

You can manage your preferences relating to the use of cookies on our website by visiting: (Coming soon)

We may update this policy from time to time by publishing a new version on our website.

You should check this page occasionally to ensure you are happy with any changes to this policy.

We may notify you of significant changes to this policy by email.

This website is owned and operated by Clinchd Limited.

We are registered in England and Wales under registration number 11299003, and our registered office is at 128 City Road, London, England, EC1V 2NX.

Our principal place of business is at 128 City Road, London, EC1V 2NX.

You can contact us:

1. by post, to the postal address given above;
2. using our website contact form;
3. by telephone, on the contact number published on our website; or
4. by email, using the email address published on our website.

We are registered as a data controller with the UK Information Commissioner's Office.

Our data protection registration number is ZA747472.

We have appointed a data protection lead who may be reached at privacy@clinchd.com.