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CLIPFIX – PRIVACY POLICY

Introduction

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data.

We are committed to protecting your personal data and respecting your privacy. This Privacy Policy, together with our Terms of Use (User T&Cs / Tradesman T&Cs) and any other documents referred to in them, applies to your use of the Clipfix application (the App), and the service provided through it (the Service), once you have downloaded a copy of the App onto your mobile telephone, tablet or other device (Device). It also applies to your use of our website located at www.clipfix.co.uk (our site) and, to the extent relevant, references in this Privacy Policy to the App shall be deemed to include our site.

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, (whether via the App or otherwise in the course of using the Service) will be processed by us. Please read it carefully to understand our views and practices regarding your personal data and how we will treat it.

The App is not intended for children and we do not knowingly collect data relating to children.

Who we are

Clipfix Limited is the controller and is responsible for your personal data (we, us or Clipfix). We are a limited company registered in England and Wales under company number 11252161 and have our registered office at 9 High Street, Wellington, Somerset, TA21 8QT. Our main trading address is Tempo House, 15 Falcon Road, London, SW11 2PJ and our VAT number is GB 296 0728 71. Our ICO registration number is ZA479477.

How is your personal data collected?

We may collect and process the following information about you:

• Information you give to us. This is information you consent to giving us about you by filling in forms on the App, by corresponding with us (for example, by email or through the App) and/or by sharing videos or photographs with us. It includes information you provide when you register to use the App, use the App or the Service, connect with other users of the App, make use of the App’s interactive features, complete a survey, provide comments and/or feedback or when you correspond with us by phone, email or otherwise or when you report a problem with the App. The information you give us may include, without limitation, your title, name, address (and billing address, if different), email address, telephone number, location, photos, videos and payment information. If you contact us, we may keep a record of that correspondence.
• Information we collect about you. Each time you use the App, we may automatically collect and process the following information using cookies and other similar technologies:

• Information we receive from other sources, including third parties and publicly available sources. We may receive information about you from various third parties and public sources, including, without limitation, tradesmen and service providers from whom you request advice, guidance and/or instruction through the App, social media providers through whom you register to use the App, business partners, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies). Any data received from such other sources may be combined with data collected via the App.
• We may also collect, use and share aggregated data such as statistical or demographic data for any purpose (Aggregated Data). Aggregated Data may be derived from your personal data but is not considered personal data in law as it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the App or our site. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
• 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), nor do we collect any information about criminal convictions or offences.

Profile

If you register to use the App using Facebook, Twitter or any other third party platform, your user profile on the App may be linked to your profile with such third party. However, you will have control over the information contained within your Clipfix profile on the App and you may review, correct or update this information at any time via the App.

If you request advice, guidance and/or instruction from a tradesman or service provider through the App (whether an independent tradesman or service provider or a tradesman or service provider appointed by, or acting on behalf of, one of our partners (for example, a provider of household insurance)), that tradesman or service provider will be able to see your user name and profile information, including any photos and/or videos  (if applicable) you choose to make available to other users via the App.

Cookies

We may use cookies and/or other similar technologies (for example, analytics) (together Cookies) to distinguish you from other users of the App and to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App. By continuing to use the App or our site, you are agreeing to our use of Cookies.

A Cookie is a small file of letters and numbers that we store on your Device, if you agree. Cookies contain information that is transferred to your Device’s hard drive.

We may use the following categories of Cookies:

• Strictly necessary Cookies. These are Cookies that are required for the operation of the App. They include, for example, Cookies that enable you to log into secure areas of the App, request services via the App or make use of e-billing services.
• Analytical/performance Cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the App when they are using it. This helps us to improve the way the App works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality Cookies. These are used to recognise you when you return to the App. This enables us to personalise our content for you, greet you by name and remember your preferences.
• Targeting Cookies. These Cookies record your visit to the App, the pages you have visited and the links you have followed. We will use this information to make the App and the advertising displayed on it (if any) more relevant to your interests. We may also share this information with third parties for this purpose.
• Social media cookies. These Cookies allow you to share what you have been doing on the App on social media such as Facebook and Twitter. These Cookies are not within our control. Please refer to the respective privacy policies of the relevant social media outlet for how their cookies work.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use Cookies, over which we have no control. These Cookies are likely to be analytical/performance Cookies or targeting Cookies.

You can block the download of Cookies or remove/disable them (including the Cookies we use) by altering the privacy settings on your device. Guidance on how to do this can be found at www.cookiepedia.co.uk. However, if you block all Cookies (including essential Cookies), you may not be able to access or use all or parts of the App and your user experience may deteriorate as a result.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

• Where you have consented before the processing. This means that you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
• Where it is necessary for the performance of a contract we are about to enter or have entered with you.
• Where it is necessary for the legitimate interests of our business in conducting and managing our business to enable us to give you the best service 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).
• Where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

We will only send you direct marketing communications if you have requested information from us, if you have not opted out of receiving information from us or we have your consent. You have the right to withdraw that consent at any time by contacting us (or by clicking on the “unsubscribe” link in any marketing or other communication you receive from us).

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

Disclosure of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table above:

• Other members of our group from time to time, which means our subsidiaries, our ultimate holding company and its subsidiaries, in each case as defined in section 1159 of the UK Companies Act 2006 (as amended from time to time).
• Tradesmen and service providers from whom you request advice, guidance and/or instruction through the App.
• Professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue and Customs, regulators and other authorities.
• Business partners (including payment processing service providers and identity checkers), suppliers and contractors for the performance of any contract we enter into with them or you.
• Analytics and search engine providers that assist us in the improvement and optimisation of the App.
• Clipfix partners who have subscribed to the App (for example, providers of household insurance) if you want to be connected with them or any tradesman or service provider appointed by them or acting on their behalf.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We will not allow our third party service providers to use your personal data for their own purposes and we will only permit them to process your personal data for specified purposes and in accordance with our instructions.

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom (UK). It may also be processed by staff operating outside the UK who work for us or for one of our partners. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.

Whenever we transfer your personal data out of the UK, 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 and the Information Commissioner’s Office (ICO).
• Where we use certain service providers, we may use specific contracts approved by the European Commission and the ICO which give personal data the same protection it has in the UK

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security

We employ generally accepted industry standards to protect your personal information and all information you provide to us is stored on secure servers. Any payment transactions carried out by us or by our chosen third party provider of payment processing services will be encrypted using TLS or SSL technology. Where we have given you (or where you have chosen) a password that enables you to access the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We may also collect and store personal data on your Device using application data caches and other technology.

If you use any of the App’s interactive features, please ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purpose we collected it for.

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 requirements.

In some circumstances, we may 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

You have the right to make a complaint at any time to the ICO. We would, however, appreciate the chance to deal with any concerns you may have about data protection before you approach the ICO, so please contact us in the first instance.

Under certain circumstances, by law you also 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 the 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: (i) if you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful, but you do not want us to erase it; (iii) 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; or (iv) 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, you may not be able to use the App or the Service.

You can exercise any of the rights referred to above at any time by emailing us at support@clipfix.co.uk. We try to respond to all legitimate requests within one month. Occasionally, it may 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.

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 as referred to above). 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.

You do not have to pay a fee to access your personal data (or to exercise any of your other rights as referred to above).

Third party links

The App and/or our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, without limitation, websites on which the App or the Service are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

Changes to this Privacy Policy and your duty to inform us of changes

We keep this Privacy Policy under regular review. This version was last updated in August 2021. It may change and, if it does, these changes will be posted on this page. We may also notify you of any changes by SMS, by email or when you next start the App. You may be required to read and accept the changes to continue your use of the App. If you do not agree to any changes, please stop using the App and delete or remove the App from your Device.

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 our relationship with you.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be sent to us by email at support@clipfix.co.uk or in writing to Clipfix Limited, Tempo House, 15 Falcon Road, London, SW11 2PJ.