1.  Introduction

Thank you for your interest in our company, our products and/or services. When you enter into a relationship with us, you entrust us with your information. This information, presented in this document (herein called   „Privacy Policy”) is important. We recommend you read them carefully.

The purpose of this Privacy Policy is to explain what data we process (collect, use, share), why we process it, how we are doing it, and your rights regarding GDPR and the ways you can exercise your rights. While collecting this information, we act as data operators and by law we are required to provide you this information.

The protection and confidentiality of your personal data is very important to us. Being fully aware that your personal information belongs to you, we do everything we can to store them and process them carefully. We do not share the information with third parties without informing you about it according to the law. We do not make exclusively automated decisions that may impact you significantly.

By visiting the website, purchasing our products and/or services or by interacting with us through any means (e-mail, phone, social networks, etc.), you agree with this Privacy Policy and consent using your personal information for promotional or marketing purposes, as it is described in the sections below regarding Marketing and promotion. In case you do not agree with our Privacy Policy terms, please do not use our services or products.

 

2.    Other services

This Privacy Policy does not cover any third-party applications and website you may interact with by accessing the links on our website. These exceed our control. We encourage you to review any Privacy Policy from any website or application you encounter before handing them your personal data.

 

3.  Who are we?

CM Cleans   LTD, based in 37 Shirley Avenue RG2 8TE, Reading Berkshire, UK, Tax Code 14667788, is responsible for processing your personal data that we directly or through other sources are collecting from you.

According to the legislation, our company is a personal data processor. For the safety of your data, we have implemented any adequate and reasonable measures, technical and organizational, to protect your personal data.

4.  Who are you?

According to the legislation, you, the individual who is the beneficiary of our products and/or services, the representative or contact person of a company, the visitor of the website or a person in any relationship with our company, are a „data subject”, meaning an identified or identifiable person. In order to be fully transparent about our data processing, and to allow you to easily exsert your rights at any time, we have implemented a range of measures to facilitate the access to information, please refer to Sections 7, 10 and 11 in this document.

 

5.  Our commitment

The protection of your personal information is very important to us. For this reason, we are committed to closely follow the European and national legislation regarding personal data protection, especially special Regulation (EU) 679/2016, also known as GDPR and the following principles:

• Legality, fairness and transparency

We process your personal data legally and correctly. We are always transparent about the data we are processing, and you are appropriately informed.

• The control belongs to you

Within the limits of the law, we offer you the possibility of examining, modifying, deleting your personal data you shared with us and to exercise your other rights. For more information, please follow Sections 7, 10 and 11 from this document.

• Data integrity and purpose limitation

We are using your data only for the purposes described at the moment we are collecting the data or ones that are compatible with our initial purposes. In all cases, our purposes are compatible with the existing legislation. We take reasonable precautions to ensure your data is correct, complete and updated.

• Security

We have implemented reasonable security and encryption measures, so that your personal information is best protected. However, please remember that no website, no application and no Internet connection is perfectly safe.

6.   Changes

We may change this Privacy Policy at any time. All updates and changes are effective immediately after notifying, either through the website and/or through email.

7.   Questions and requests

If you have any questions or concerns regarding the processing of your personal data or you want to exercise your legal rights about the processing of the data about you or you are worried about how we treat any confidentiality issues, you can contact us at this e-mail: admin@cmcleans.co.uk.

8.  Your information.

8.1.  What type of information are we collecting about you?

When you browse our website, or send us a request through email, or contact us with any purpose and any communication channel, you can communicate us the following personal data, which we may collect directly from you or from other sources, such as:

• Surname and first name
• Age
• Email address
• Phone number
• Company position
• Password

Most of the information is collected directly from you (for example, by filling-in a website form). Most of the information can be the one described above, but there may be cases when we collect data from third parties (i.e. partners, advertising platforms), such as information regarding your purchases and interests.

In addition to the above indicated information, it is possible we collect the following information, depending on circumstances:

• The way you are interacting with our website/websites or our advertisements (for example, information about how and when you are accessing our website, what device you are using to access our);
• Information provided when filling in website forms or questionnaires;
• The content of the messages you send through email and messaging;
• The interactions between yourself and us on Social Media (for example likes, shares and comments);
• The information we collect about you from other companies withing the group or third parties who have obtained your consent or have the legal right of sharing this information with us (including content publishing or advertising partners/platforms and data aggregators who have obtained this right).

In case you are making a purchase, certain payment information will be collected about you (your payment card data), but they will be stored by our processing partners in a way we can’t read and directly access. We are only informed whether the transaction was successful or not.

We may collect personal data through cookies and other similar technologies, such as:

• IP Address
• Your Internet browser
• Location
• The web pages you are accessing on our website

8.2.  Why are we collecting this information?

We are collecting the personal data for the following purposes:

• For the purpose of closing or performing a contract between you and our company;
• To answer to your questions and inquiries and to provide the customer support service;
• For marketing purposes, for the situation where we have your consent or when there is a legal exception to obtaining it;
• To provide and to improve the services we offer;
• To diagnose and remedy technical problems;
• To defend against cyber-attacks;
• To create and maintain accounts;
• To comply with the law, for example the fiscal law requiring us to keep the accounting documents for a ten years period;
• To determine and to claim a certain right in court;
• For analytics and research purposes;
• For promotional activities and contests;
• For crime and fraud prevention;

8.3.  What is the legal basis for the data processing?

We may use the following legal grounds, depending on the specific case:

• The consent for processing the personal data;

Please keep in mind, in case you are an existing customer, we can send you promotional materials (direct marketing) with regards to similar goods and services, without needing your consent prior to that, according to article. 12 paragraph 3 from Law no. 506/2014.

In all of the cases though, you can object to any direct marketing and/or you can retract your consent at any moment following the unsubscribe instructions or by sending a written request to the following e-mail admin@cmcleans.co.uk.

• The data processing is necessary for closing or performing a contract between yourself and our company; 

• The data processing is necessary for protecting our legitimate interests or those of a third party, with the exception of the cases when your interests, rights or freedoms prevail.

In the situation where we are using our legitimate interest, we carry out a legitimate interest analysis (balancing test) through which we measure our interest and your interest. In case our interests prevail, we are going to use the legitimate interest. In case your interests prevail, we will not use the legitimate interest, and in the situation where we care not able to determine another correct legal basis, we will not carry out the respective processing activity. 

• The data processing is needed to meet certain legal requirements (for example conforming to the fiscal legislation requiring us to keep accounting documents for 10 years or offering certain information to the competent public bodies institutions);

• In certain situations, the data processing can be necessary for protecting your vital interests or another individual’s interests;

Please keep in mind that obtaining your consent is not mandatory, and we will proceed to obtaining your consent only in those cases where we couldn’t use a legal basis.

8.4.  For how long are we storing the data?

We store your personal data only for the necessary period for the fulfillment of the goals, but no more than 5 years from the contract closure or your last interaction with us.

After this period has passed, your personal data will be destroyed or erased from our systems or anonymized in order to be used for scientific research, historical research or statistics.

Please keep in mind that for certain cases specifically stipulated by law, we store the data for the period of time required by law.

8.5.  How do we share your information with others?

We may share your data, following the applicable law, to the business partners or other third parties. We constantly make reasonable efforts to make sure these third parties have taken adequate data protection and security measures. With these third parties we have contract clauses to protect your personal data. In these situations, we will make sure that any data transfer is legitimate, having your consent or a legal basis.

For example, we may share your data with other companies, such as our suppliers, IT or telecommunications companies, accounting, legal services and other third parties we have a contractual relationship with.  These third parties are carefully selected so your personal data is processed just for the purposes we indicate.

Also, we may share your personal data to out business partners in a common effort to offer a product or service.

Although very unlikely, we might sell our business, or part of it, this situation including the transfer of your personal data as well.

We may transmit your data to other third parties, when we have your consent or a request from you, as for example, when you request data portability.

We may also supply your personal data to the Prosecutor’s Office, the Police, Judicial Courts and other competent bodies, withing the limits of the law and after a formal request.

We will make sure, within reasonable limits, that your data does not leave the European   Economic Area, but, in those situations where we transfer your data to a country outside of EEA, we will make sure, in all cases, the transfer is legitimate, with your explicit consent, or with a legal basis.

 

9.   Marketing

After previously obtaining your consent, or when you already are a customer of our company, we may use direct marketing techniques and targeted advertisements, using the data collected about you with regards to your interests, preferences, purchases, age, location, etc. For example, we may send you emails, we may display advertisements within our website or on Social Media or we may place advertisements on third party websites, in apps or on other devices connected to the Internet.

9.1.   What type of data are we collecting for marketing purposes?

For direct marketing or targeted advertising, we may use the following information:

• Information collected through cookie modules or other similar technologies (location, device, browser, age etc.);
• Your purchases, your interaction with our goods and services, your feedback and opinion;
• Age, country, region, sex;
• Other information obtained from our marketing partners, information that was received with your consent.

9.2.  Marketing partners

Our marketing partners, such as Facebook, Google and/or other agencies help us transmit marketing to you based on the information collected by them directly from you and with your consent. In some cases, we share ourselves data we collected from you. We make sure, in all cases, these transfers are legal, as explained at 8.5.

Our partners can place advertisements for our products and services, based on the previously collected data (interests, preferences) on other sites and/or services. Also, our marketing partners can use the information collected about you to improve their services and/or algorithms (including AI algorithms).

This Privacy Policy does not include information about how our partners are processing your data, but we encourage you to read our marketing partner’s Privacy Policy for more information. You can consult the list of our marketing partners, together with the link to their Privacy Policy.

9.3.   How can you opt-out of the direct marketing?

You can oppose the direct marketing and/or opt-out at any moment removing your consent by following the unsubscribe instructions from each e-mail („unsubscribe”) or by sending a request about this at this e-mail address (admin@cmcleans.co.uk)

To deactivate interest based targeted advertising, please consult our Cookies Usage Policy.

 

10.  What are your rights?

Your rights according to the GDPR regulation are the following:

• The right to withdraw consent

You can withdraw at any moment your consent for the processing of your personal  data by sending a request for this to e-mail address (please insert e-mail address).  Please keep in mind though, in case we determine there is a legal basis to continue processing your personal data, we will continue to do so. Legally we have the   possibility to use one or more legal grounds to process your personal data.

• The right to be informed about the processing of your data
• The right to access your data

You have the right to get from us a confirmation about whether we process your personal data or not,  and in case we are, you have access to that data and to the            information stipulated by art. 15 section. (1) from GDPR.

• The right to updated inaccurate or incomplete data

You have the right to obtain from us, without any unjustified delays, the correction of inaccurate data we hold about you.

• The right to deletion („the right to be forgotten”)

In the situations stipulated in art. 17 from GDPR, you have the right of requesting the deletion of your personal data.

• The right to restrict the processing

In the cases stipulated in art. 18 from GDPR, you have the right to ask for and obtain the restricting of the processing of your data.

• The right to transmit the data we have about you to another operator („the right for portability”)

In those cases, stipulated in art. 20 from GDPR, you have the right to ask and to obtain the portability of your personal data.

• The right to oppose the data processing

In those cases, stipulated in  art. 21 from GDPR, you have the right to oppose the data processing.

• The right to not be the subject of a decision based exclusively on the automated data processing, including creating profiles with legal effects or similar effects regarding you.
• The right to address the Justice System to protect your interests.
• The right to complain to a Supervisory Authority

Please remember:

• You can withdraw your consent for direct marketing at any time, by following the unsubscribe instructions from every email/SMS or any other electronic email.
• If you want to exercise your rights, you can do it by sending a written request, signed and dated to the following e-mail address: admin@cmcleans.co.uk.
• The rights stated above are not absolute. There are exceptions, and for this reason, each individual request will be analyzed in order to decide whether it is founded or not. In case it is founded, we will facilitate you exercising those rights. If it is unfounded, we will reject it, but we will inform you on the reasons and about your rights to file a complaint with the Supervising Authority and to address the Justice System.
• We are trying to reply to each request within a month period. Even so, this term can be extended depending on various aspects, such as the complexity of the request, th high number of requests, or the impossibility of identifying you in a reasonable period of time.
• If, despite all our efforts, we are unable to identify you, and you do not offer us additional information needed to identify you, then we are not obliged to follow your request.

11.  Questions, requests and exercising your rights

If you have questions or uncertainties about the processing of your data or you want to exercise your legal rights or you have any privacy concerns, you can write us on this e-mail admin@cmcleans.co.uk.

Also, the contact details of the person in charge with the Data Privacy are:

Name:	Administrator of CM Cleans LTD
E-mail address:	admin@cmcleans.co.uk
Phone:	+44 0751 2639 182