Pre-Cleared Ltd ("We") are committed to protecting and respecting your privacy.
IF YOU DO NOT AGREE WITH THIS POLICY, DO NOT ACCESS OR USE OUR SERVICES OR INTERACT WITH ANY OTHER ASPECT OF OUR BUSINESS.
For the purpose of relevant legislation including General Data Protection Regulation (“the Act”), the data controller is Pre-Cleared Ltd of International House, 101 King's Cross Road, London, WC1X 9LP, England.
INFORMATION WE COLLECT FROM YOU
We will collect and process the following data about you:
Information you give us. This is information about you that you give us by filling in forms on our site www.clicknclear.com and our sub-domains (“our site”) or by corresponding with us by e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our service, search for content, order on our site, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph.
Your music mix and music license agreements when you use our License Verification System (LVS) service.
When you engage with us for support you will be asked to provide contact information, a summary of the problem and any other documentation. The contact information we ask you to provide is one or more of Email Address, Name, Username.
If you do not provide an email address, we will not be able to resolve your problem.
Information you provide to us is not always provided via our site but potentially via third-party services, such as social media.
INFORMATION WE COLLECT ABOUT YOU
With regard to each of your visits to our site we will automatically collect the following information:
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version;
information about your visit, including content you viewed or searched for or bought, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
Information you give to us.
We will use this information:
to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, content and licenses that you request and/or license from us, including providing you with current information about the content and / or platform features we offer, including newly-available content and/or content that is similar to those that you have already licensed or enquired about, and providing access to our License Verification System (“the Services”);
to enable our sports organisation partners - with whom you are already affiliated - to operate LVS in order to carry out music copyright license verification checks on your music, including providing you with information about the licensing status of your music and any related notifications;
to notify you about changes to our business; and
to ensure that content from and features of our site are presented in the most effective manner for you and for your computer.
Information we collect about you.
We will use this information:
to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
to allow you to participate in interactive features of our Service, when you choose to do so;
as part of our efforts to keep our site safe and secure;
to measure or understand the effectiveness of advertising we may serve to you and others, and to deliver relevant advertising to you;
to make suggestions and recommendations to you and other users of our site about content and Services that may interest you or them.
Information we receive from other sources.
We will combine this information with information you give to us and information we collect about you.
We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
LAWFUL BASES FOR PROCESSING
As we are a company that operates within the UK, we collect and process information about you only where we have a legal basis for doing so under applicable laws. The lawful basis depends on the Services you use and how you use them. This means we collect and use your information only where:
We need it in order to provide you the Services, including to operate the Services, provide customer support and personalised features and to protect the safety and security of the services.
It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests.
You give us consent to do so for a specific purpose.
We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place.
Where we are using your information because we have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer being able to use the Services.
HOW LONG WE KEEP INFORMATION
How long we keep information we collect depends on the type of information, as described below. After such time, we will either delete or anonymise your information or, if this is not possible (for example, the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
We retain your account information for as long as your account is open. Due to the nature of our Services, if you stop using our Services and do not tell us, your information will remain in case you decide to start using our Services again.
We also retain some of your information that is necessary:
To comply with our legal obligations
To resolve disputes
To enforce our agreements
To support business operations
To continue to develop and improve our Services.
Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services.
Information you share on the services
If your account is deactivated or disabled, some of your information and the content you have provided will remain for other users to make full use of the Services.
If you have elected to receive marketing emails from us, we retain information about your marketing preferences until you opt out using the opt out feature in your account settings. We may remove you from our marketing emails should we receive 5 consecutive hard bounces from your account.
DISCLOSURE OF YOUR INFORMATION
We share information with third parties that help us operate, provide, improve, integrate, customise, support and market our Services.
We work with third-party service providers for the following:
Website and application development
If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your information.
Google Analytics 4
In particular please note that we use Google Analytics 4 (GA4) for analysis of platform activity. GA4 has good privacy features including IP anonymisation, not collecting personally identifiable information, and data storage duration controls. However GA4 is currently not considered GDPR compliant due to Google using servers around the world for GA4 processing and not allowing us to control where your data is stored. We have signed an appropriate data processing agreement with Google, and we have opted out of data sharing with other Google products to minimise risk to your data.
We will also disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If Pre-Cleared Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our secure servers. We use data hosting service providers in Ireland, in the European Union, and the United States to host the information we collect, and we use technical measures to secure your data.
As of July 16, 2020, we no longer rely on the EU-U.S. Privacy Shield to transfer European Economic Area (EEA) and UK personal information to the United States but continue to apply the Privacy Shield Principles to personal data we transmit from the EEA and UK in reliance on the Shield, and leverage the Standard Contractual Clauses related to the Act where possible.
Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Any data that we collect via our Services is transferred over an SSL protocol for security during transmission.
Below is a list of your rights and information on how to exercise them:
Request a copy of your information: send an email to firstname.lastname@example.org and ask for your information. We will provide this information to you within 1 month from the point we have all the information required to process the request.
Withdraw previously given consent: Where you gave us consent to use your information for a limited purpose, you can send an email to email@example.com stating the consent you wish to withdraw, but this will not affect any processing that has already taken place before that time. When you make such requests, we may need time to investigate and facilitate your request. If there is delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honoured or the dispute is resolved.
Request the deletion or restriction of your information: send an email to firstname.lastname@example.org and ask for your information to be deleted. We will notify you if, for any reason, not all the information we hold can be deleted and will inform you of the implications of us deleting your information, including permanent loss of access to our Services. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our contractual and legal obligations.
Object to our use of your information (including for marketing purposes): You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, updating your email preferences within your account settings menu. You can also do this, and object to our use of your information, by emailing email@example.com.
Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our Services do not currently respond to browser DNT signals. You can use the range of other tools we provide to control data collection and use, including the ability to opt out of receiving marketing from us as described above.
You may be able to opt out of receiving personalised advertisements from other companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance's Self-Regulatory Principles for Online Behavioural Advertising. For more information about this practice and to understand your options, please visit: http://www.aboutads.info , http://optout.networkadvertising.org/ and http://www.youronlinechoices.eu.
Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services.
Right to complain to a relevant supervisory authority: visit https://ico.org.uk/concerns/ if you have a concern about our information rights practices.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.
LINKS FROM OUR SITE
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.