This policy was last updated in February 2024
Overview
Clearmatics Technologies Ltd (“Clearmatics”, “we”, "us" or “our”) respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data, including in making available our company website (“Site”), your privacy rights, and how the law protects you.
Clearmatics Technologies Ltd owns and operates this site https://clearmatics.com and https://research.clearmatics.com.
Table of Contents
- Introduction
- Your Legal Rights
- Personal Data We Collect
- How and Why We Use Your Personal Data
- Personal Data from Third Party Sources
- Failure to Provide Personal Data
- Cookies and Analytics
- Sharing Your Data
- Data Security
- Data Retention
- Third Party links
This privacy policy covers the following categories of individual: an individual employee, consultant, agent of a business or other commercial organisation we engage with in relation to our business or Services, Client end users; Site visitor: any person accessing our Site; and Applicant: an individual who applies for a job with us.
Introduction
Who We Are
Clearmatics builds decentralised network platforms for the p2p exchange of tokenised value between network members. We care deeply about protocols, p2p architectures, removing friction and market inefficiencies, strong security guarantees, and interoperable exchange across platforms to build p2p ecosystems. This Privacy Policy aims to give you information on how Clearmatics collects and processes your Personal Data, including through use of this Site and including any data you may provide through this Site.
You are free to not give us your information or to revoke your permission that allows us to do so, but please be aware that denying or revoking permissions previously granted may negatively impact your experience with and functionality of our Services due to the reliance on certain collected information. If at any point you want to change our access to your information you may do so via denying web browser permissions when prompted, and changing the privacy setting of your web browser or device. Due to the nature of data collection, storage and management we can only provide further restrictions of data collection and use to our registered users at this time.
How to Contact Us
For the purpose of applicable data protection legislation, the data controller of your Personal Data is Clearmatics Technologies Ltd of 30 Moorgate, London, EC2R 6DA, United Kingdom (referred to as either “Clearmatics“, “we“, “us” or “our” in this Privacy Policy). We have appointed a data privacy team who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our data privacy team using the details set out below.
You will never be discriminated against for exercising any rights afforded to you under this policy or by applicable law.
Changes to the privacy policy and your duty to inform us of changes. We keep our privacy policy under regular review. This version was last updated in February 2024. 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.
If you have questions, comments, or concerns about this Privacy Policy, please contact us at privacy@clearmatics.com with “Privacy Policy” in the subject line.
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.
We ask that you not send us, and you do not disclose to us, any sensitive Personal Data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Site or otherwise to us.
Your Legal Rights
You may review, make changes to, and delete your Personal Information at any time by sending an email to privacy@clearmatics.com with the subject line, “Privacy Policy”.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.
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.
| Legal Rights | Context |
|---|---|
| Be Informed | Receive information about the type of personal data that we collect and how we process and store such data. |
| Access | This enables you to access and receive a copy of the Personal Data we collect, store, and process to check that we are lawfully processing it. |
| Data Portability | Transmit and/or receive a copy of your Personal Data for use in another party’s service. |
| Correction | You may request the correction of the Personal Data we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. |
| Erasure | 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 exercised your right to object to processing (see below). |
| Restrict | You may request the restriction of the processing of some or all of your personal data temporarily or permanently if it is inaccurate, unnecessary for a specific purpose, you object to our processing and we are assessing your request, and/or you believe our processing is unlawful. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes |
| Object | You have the right to object to us collecting, storing, or processing your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes. |
| Not be subject to automate decision making | You have the right to be removed from any decisions without human involvement (an “automated decision”) including profiling, where the decision has a legal effect on you or produces a similarly significant effect. |
| Withdraw Consent | You have the right to revoke your consent to us collecting, storing, and processing your Personal Data provided that we are doing so. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal“). We will advise you if your consent withdrawal affects your access to specific functionalities of the site or network. |
Complaints
If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at privacy@clearmatics.com.
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved or that your data protection rights may have been breached, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
Marketing Communications Preferences
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical and Usage 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 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 or if we provide services to you and you have not opted out of receiving that marketing.
You can ask us 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 at privacy@clearmatics.com.
Personal Data We Collect
The Personal Data we collect, both from you and from Third Parties about you, is outlined in the table below. We will always do our best to ensure that the below information is current and accurate as to our policies and procedures, at minimum this policy is reviewed and updated annually.
The Personal Data we collect is entirely dependent on the nature of your engagement with Clearmatics. For example, the data we collect from Site Visitors will differ from the data we collect from our Recruitment Prospects. For more information and definitions of “Affected Persons” please refer to the table below and/or the “How We Use Your Data” section of the Privacy Policy.
If you have questions, comments, or concerns about this Privacy Policy, please contact us at privacy@clearmatics.com with “Privacy Policy” in the subject line.
| Category | Affected Persons | Definition |
|---|---|---|
| Identity Data | Employees, Contractors Leads, Clients/Suppliers | Including your name, address, telephone number, date of birth, marital status, passport number, employment history, educational or professional background, tax status, employee number, job title and function, and other personal data concerning your preferences relevant to our services. |
| Contact Data | Employees, Contractors, Leads, Clients/Suppliers, Software/Services Users | Includes home and/or business addresses, email addresses and telephone numbers. |
| CV Data | Employees, Contractors, Recruitment Prospects | Includes CVs and other biographical and employment history data provided in relation to a job application. |
| Technical Data | Site Visitors, Clients/Suppliers, Software/Services Users | Includes internet protocol (IP) address, 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 the Site. |
| Usage Data | Site Visitors, Clients/Suppliers, Software/Services Users | Usage Data includes information about how and where you use our Site and Services. We process Technical and Usage Data in Plausible Analytics for statistical purposes, to improve our site and to identify and stop any misuse. |
| MarCom Data | Leads, Clients/Suppliers, Software/Services Users | Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. |
| Medical Data | Employees, Contractors | Includes information regarding allergies, dietary requirements, disabilities, and information regarding absences in order to keep team members safe and to provide the necessary and legal accommodations. |
Aggregated Data
We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute considered Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. 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.
Special Categories of Personal Data
We do not collect any “Special Categories of Personal Data” about our Site Visitors, Clients, Suppliers, Software and Service Users, Leads, or Recruitment Prospects (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 and offences.
The only Special Category of Personal Data we hold is Medical Data about our Employees and Contractors, which primarily includes information about allergies, dietary requirements, and disabilities, and information regarding absences to ensure their health and safety and to provide the needed and legal accommodations. This information is not a requirement from our team, but any Medical Data we hold is given to us with explicit consent.
Minors
This Site is not intended for Minors below 16 and we do not knowingly collect data relating to such Minors. If you have reason to believe that a Minor has provided Personal Information to us, please contact us at privacy@clearmatics.com with the subject line, “Privacy Policy: Minor Persons” so we can promptly remove such information from our databases and take any other curative measures.
How and Why We Use Your Personal Data
We use different methods to collect data from and about you, including through:
- Direct Interactions – You may give us your Identity or Contact data by filling in forms, and questionnaires, or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you contact us about our Services; apply for a job; or request marketing to be sent to you.
- Automated Technologies or Interactions – As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this data through Plausible Analytics, which completely anonymizes the data it collects.
-
Third Parties or Publicly Available Sources. We will collect or receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers, such as Plausible Analytics.
- Identity and Contact Data from publicly available sources, such as Companies House or Linkedin.
- Identity and Contact Data from private sources.
Legal Basis
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use.
Most commonly, we will rely on one of the following legal bases:
- Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”).
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
Generally we do not rely on your Consent as a legal basis for using your Personal Data other than in the context of direct marketing communications.
We will only use your Personal Data for the purposes for which we collected it as listed in the tables below, 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 email privacy@clearmatics.com.
If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.
Employees & Contractors
Below is a table that describes the type of data held and the legal basis for holding the data regarding Clearmatics employees and contractors, where “Employee” is defined as an individual that has been legally employed by Clearmatics to perform a set role, and “Contractor” is defined as a self-employed individual that has been hired under a contract to perform a specific a set of duties or carry out a project for Clearmatics.
If you have any questions, comments, or concerns regarding the below uses please email privacy@clearmatics.com.
| Data Type | Legal Basis |
|---|---|
| Identity Data | Performance of a Contract - Necessary in order to hire employees and contractors. |
| Contact Data | Performance of a Contract - Necessary in order to hire employees and contractors. |
| CV Data | Legitimate Interest - Necessary during the recruitment stage in which CVs are given with explicit consent in order to hire an employee or engage with a contractor. |
| Medical Data | Legitimate Interest - Necessary to ensure the health and safety of employees and contractors when planning events and to provide reasonable work accommodations where needed and legally required. |
Recruitment Prospects
Below is a table that describes the type of data held and the legal basis for holding the data on Recruitment Prospects, where “Recruitment Prospect” is defined as an individual that has explicitly applied for a job at Clearmatics or an individual that has been sought out based on their professional skills and history to potentially fill a job role at Clearmatics.
If you have any questions, comments or concerns regarding the below uses please email privacy@clearmatics.com.
| Data Type | Legal Basis |
|---|---|
| Identity Data | Consent - Necessary in order to accurately identify a job candidate. |
| Contact Data | Consent - Necessary to contact a Recruitment Prospect in order to reject them from a role or proceed with the interview process. Contact data is held for 12 months and may also be used to reach out to a candidate if an appropriate job role opens up. |
| CV Data | Consent - Necessary in order to accurately assess an individual as part of the recruitment process. |
Clients & Suppliers
Below is a table that describes the type of data held and the legal basis for holding the data on our Clients and Suppliers, where “Client and Suppliers” are defined as companies or individuals within organisations who hold or previously held a service agreement with Clearmatics or one of our subsidiaries.
If you have any questions, comments, or concerns regarding the below uses please email privacy@clearmatics.com.
| Data Type | Legal Basis |
|---|---|
| Identity Data | Performance of a Contract - Necessary in order to securely correspond with clients. |
| Contact Data | Performance of a Contract - Necessary in order to correspond with clients. |
| Technical Data | Legitimate Interest |
| Usage Data | Legitimate Interest |
| MarCom Data | Legitimate Interest |
Software/Service Users
Below is a table that describes the type of data held and the legal basis for holding the data on Software/Service Users, where “Software User” and “Service User” are defined as individuals or organisations that use any software, networks, or content created by Clearmatics or any of its subsidiaries.
If you have any questions, comments, or concerns regarding the below uses please email privacy@clearmatics.com.
| Data Type | Legal Basis |
|---|---|
| Identity Data | Legitimate Interest - Necessary in order to securely correspond with Software/Service Users and to provide them with the appropriate service and/or software. |
| Contact Data | Legitimate Interest - Necessary in order to securely correspond with Software/Service Users and to provide any assistance related to the respective service and/or software being used. |
| Technical Data | Legitimate Interest |
| Usage Data | Legitimate Interest |
| MarCom Data | Legitimate Interest |
Leads
Below is a table that describes the type of data held and the legal basis for holding the data on Leads, where “Lead” is defined as, any individual or organisation who has interacted with our business/software or who we believe has the potential to become a future Client, Supplier, or Software User.
If you have any questions, comments, or concerns regarding the below uses please email privacy@clearmatics.com.
| Data Type | Legal Basis |
|---|---|
| Identity Data | Legitimate Interest - Necessary to identify and eventually correspond with Leads. |
| Contact Data | Legitimate Interest - Necessary to identify and eventually correspond with Leads. |
| MarCom Data | Legitimate Interest |
Fraud Prevention
We reserve the right to use any data we collect for fraud prevention services. This is in the legitimate interest of the business or if we need to comply with the legal or regulatory obligations.
Perasonal Data from Third Party Sources
In addition to the Personal Data that we collect directly from you (as described in the Personal Data We Collect section), we also collect certain categories of Personal Data from Third Party sources. These sources are broken down in the table below, together with a description of whether or not they are publicly available.
| Third Party Data Source | Publically Available? | Data Catagory |
|---|---|---|
| Social Media Sites | Yes | Identity Data, Contact Data |
| Recruitment Sites | Yes | Identity Data, Contact Data, CV Data |
| Market Intelligence Databases | No | Identity Data, Contact Data, CV Data |
If you would like more information regarding our third party sources, please contact us at privacy@clearmatics.com.
Information About Other People
If you provide information to us about any person other than yourself, including employees, counterparties, advisers, and suppliers, you must ensure that explicit consent was given for you to share this information. You must also ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us to use it.
Failure to Provide Personal Data
Where we need to collect Personal Data by law or to perform the terms of a contract we have with you, and you fail to provide that data when required, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement with you. For example, we will not be able to hire a contractor if the appropriate data is not provided. We will notify you if this is the case at the time.
Cookies and Analytics
We no longer use cookies or Google Analytics on the Clearmatics site. If you find there are cookies running, please contact privacy@clearmatics.com with “Privacy Policy - Cookies” in the subject line.
Instead, we utilise Plausible Analytics The purpose of Plausible Analytics is to track the usage of a website without collecting personal data or personally identifiable information (PII) and without using cookies, to ensure the privacy of Site Visitors are respected. To read more about Plausible Analytics and what data they collect, please visit https://plausible.io/data-policy.
Sharing Your Data
Some of our external Third Parties are based outside of the United Kingdom and the European Economic Area (EEA), meaning the processing and storage of your Personal Data will involve an international transfer of data to countries based outside of Europe. This includes the United States.
When we transfer your information outside of the UK and EEA, we will use, share and safeguard that information as described in this Notice. To provide services, we may transfer the personal information we collect to countries outside of the EEA which do not provide the same level of data protection as the country in which you reside and are not recognised by the European Commission as providing an adequate level of data protection. We only transfer personal information to these countries when it is necessary for the services we provide you, or it is necessary for the establishment, exercise or defence of legal claims, or subject to safeguards that assure the protection of your personal information, such as these listed below:
- Where we are transferring your Personal Data outside of the UK and EEA, the country to which Personal Data is being transferred has been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details see European Commission: Adequacy Decisions.
- Where we use Service Providers outside the EEA, we use specific contracts approved by the European Commission which give personal data the same protection it has in the UK and Europe. For further information, see EU Standard Contractual Clauses.
- Where we use Service Providers based in the United States, we may transfer data to them if they are part of the EU-US Data Privacy Framework, which requires them to provide similar protection to Personal Data shared between Europe and the United States. For further information, see EU-US Data Transfers.
To make a request in relation to your regional rights, or make them on behalf of someone else as their agent, please contact us at privacy@clearmatics.com. When fulfilling a request, we may ask for additional information or documentation to verify your identity and authority in the event you are an acting agent.
International Data Privacy Rights
| Residents of… | Your full rights can be found at... | Exercised by… |
|---|---|---|
| United Kingdom | For the full text of the GDPR as it applies to the UK and other current privacy legislation please visit Legislation.gov.uk at https://www.legislation.gov.uk/uksi/2020/1586/contents/made. | If you are a resident of the United Kingdom and think we have infringed upon applicable data protection laws you can file a claim with the UK Information Commissioner’s Office in the country or area in which you live or work or where you think we have infringed data protection laws in addition to contacting us as privacy@clearmatics.com. |
| European Economic Area | For the current full text of the GDPR please visit EUR-LEX.europa.eu at https://eur-lex.europa.eu/eli/reg/2016/679/oj. Note that each EEA country or Member State may have their own data protection laws that add to the GDPR. You will need to consult the appropriate records for your country of residence or work in order to view the full text of such laws and the rights they award you. | If you are a resident of a nation within the EEA/EU and think we have infringed data protection laws, you can file a claim with the data protection supervisory authority in the EEA country in which you live or work or where you think we have infringed data protection laws in addition to contacting us as privacy@clearmatics.com. |
| California | For the full text of the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act of 2020 (“CPRA”) please visit leginfo.legislature.ca.gov at https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?division=3.&part=4.&lawCode=CIV&title=1.81.5 . | If you are a resident of California and think we have infringed upon applicable data protection laws you can file a claim with the California Privacy Protection Agency who operates under the guidance of the Office of the Attorney General of California in addition to contacting us as privacy@clearmatics.com. |
| Other Regions | Due to the expansive nature of global authorities we do not post this policy to be comprehensive authority on your privacy rights. If you are a resident of a region not listed above please consult your regional legal authority for your privacy rights. If you feel we are in violation of any such laws please immediately contact privacy@clearmatics.com. |
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, contractors, and other staff and third parties who have a business need to use that data. They will only process your Personal Data on our instructions and they are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
Please understand, however, that no security system is impenetrable, and we do not guarantee the security of our databases, nor can we guarantee that the Personal Data that you supply will never be obtained by malicious or other bad actors.
Data Retention
We will only retain your personal data for as long as 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 with respect to our relationship with you.
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.
In some circumstances you can ask us to delete your data. 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.
Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.
If you want to learn more about our specific retention periods for your personal data established in our retention policy you may contact us at privacy@clearmatics.com.
Third Party Links
This Site 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 your Personal Data. We do not control these Third Party websites and are not responsible for their privacy statements. When you leave the Site, we encourage you to read the privacy policy of every site you visit.