Cloudhouse Technologies Limited (Cloudhouse) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data (i) when you visit our website (regardless of where you visit it from) and (ii) when we collect your data off-line and tell you about your privacy rights and how the law protects you.
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
1. Important information and who we are
personal data through:
• your use of this website and related systems, including any data you may provide when you sign up to our newsletter, register for a webinar or trial, complete a contact us form or when our Partners use our Portal, Lead Registration Forms, Partner Forum and Support systems; and/or
The Cloudhouse Group of Companies (“Cloudhouse Group”) is made up of different legal entities comprising:
• Data Cloud Limited
• Cloudhouse Technologies Limited
• Data Accelerator Limited.
Cloudhouse Technologies Limited is the controller and responsible for this website. Aspire Creative host this website on behalf of Cloudhouse.
Our full details are:
Full name of legal entity: Cloudhouse Technologies Limited
Name or title of data privacy manager: Nick Coleman
Email address: firstname.lastname@example.org
Postal address: PO Box 76590, London SW11 9PF
Telephone number: +44(0) 205 515 1505
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.
The data protection law in the UK changed on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not be able to respond to some of your requests (for example, a request for the transfer of your personal data) until we have finalised changes to our systems and processes. We are working to ensure we will be in compliance with all applicable laws and best practice as soon as reasonably practicable.
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.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites we have no control over how your data is collected, stored, or used by these websites and are not responsible for their privacy statements or policies. When you leave our website, we encourage you to read the privacy notice or policy of every website you visit and before providing any data to or through them.
2. 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 data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name, username or similar identifier and title.
• Contact Data for business contact information only and includes business address, business email address and business telephone numbers (unless you chose to provide your personal details; however we do not encourage you to provide your personal information or data unless strictly necessary).
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
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, 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 goods or services). In this case, 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.
3. 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 and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when:
• You, or your employer, may provide for the supply of our products or services;
• You subscribe to our service or publications;
• You request marketing to be sent to you, e.g. newsletters;
• You express interest in a Free Trial;
• You request sales contact you on our Contact Us; or
• You create an account on our website, under the Partner Portal or Partner Discussion Forum;
• You provide feedback or contract us through our Product Feedback Portal, or Support Forum.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
• Usage Data from the following parties: – Documentation providers, Helpjuice.com based outside of the EU. However this usage
data is anonymous and therefore is not strictly identifiable personal data;
• Technical Data from the following parties:
– analytics providers, such as Google based outside the EU;
– search information providers such as Google based outside the EU.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4. 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 need to perform the contract, we are about to enter into or have entered into with you or your employer.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via post, email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
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 where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you or your employer as a prospective customer.||(a) Identity
|Necessary for our legitimate interests (to develop and grow our business)|
|To register you or your employer as a new customer, this is not done via our website||(a) Identity
|Performance of a contract with you|
|To process and deliver your or your employer’s purchase order including:
(a) Manage payments, fees and charges.
(b) Collect and recover money owed to us
(c) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you and/or your employer which will include:
(b) Asking you to leave a review or take a survey (c) managing your or your employer’s account
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to complete a survey||(a) Identity
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
| (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website and off-line content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
|To communicate with you. This may include responding to emails, correspondence and calls from you||(a) Identity
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
|Partners use our Portal, Lead Registration Forms, Partner Forum and Support systems||(a) Identity
|Necessary for our legitimate interests (to help you use, or us develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established personal data control mechanisms in connection with marketing and advertising options. You may request not to receive marketing or advertising information from us; see below your right to opt out.
Trial Usage, White Papers, Webinars, Contact Us
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 from us, Trial our product, request White Papers, Webinars, Contact Us forms or purchased our product or services from us and, in each case, you have not opted out of receiving that marketing.
We do not share your personal data outside of the Cloudhouse Group . We will get your express opt-in consent before we share your personal data with any company outside the Cloudhouse Group for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us 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 purchase of a product/service, partner portal account, partner forum account, product feedback or support request.
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.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in
the table in paragraph 4 above.
• Internal Third Parties as set out in the [Glossary].
• External Third Parties as set out in the [Glossary].
• In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
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. If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the United Kingdom and under the GDPR, as explained above in section 6 below.
6. International transfers
We store data at our office locations in the United Kingdom. Data is also stored on our servers or servers operated and managed by third parties on our behalf; these servers are currently located in the EU.
We may share your personal data within the Cloudhouse Group. This may involve transferring your data outside the European Economic Area (EEA). The “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein.
Countries outside the EEA are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the United Kingdom and under the GDPR as set out below.
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”. For further details, see European Commission: Binding corporate rules.
Many of our external third parties are based outside the European Economic Area (EEA) so their holding and processing of your personal data may involve a transfer of data outside the EEA. Whenever we hold or 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:
• 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• 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 the Europe and the US. For further details, see European Commission: EU-US Privacy
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
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.
8. Data retention
How long will you use my personal data for?
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 or your employer.
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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. By law we have to keep basic information about our customers (including Contact and Identity Data) for six years after they cease being
customers for certain (including tax) purposes. In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.
Any requirement to delete personal data shall not apply to the extent we are required by applicable law to retain data or to data we have archived on back-up systems, which data we shall securely isolate and protect from further processing except to the extent required by applicable law until such time as the relevant back-up is destroyed in accordance with our standard backup destruction policies.
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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
• [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 charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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 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.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
Legitimate Interest 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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties
Other companies in the Cloudhouse Group acting as joint controllers or processors and who are based in the United Kingdom and provide IT and system administration and related services and undertake leadership reporting.
External Third Parties
• Service providers acting as processors based in the United Kingdom, EU and/or United States who provide website, partner portal, IT and system administration and related services, including Aspire Creative, Microsoft, Microsoft Azure.
• Service providers acting as processors based in the United Kingdom, EU and/or United States who provide financial systems, including Xero.
• Service providers acting as processors based in the United Kingdom, EU and/or United States who provide sales and marketing systems and related services, including SalesForce and Dynamics 365.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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.