Privacy Policy

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

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, Customers/Clients 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, Customers/Clients, Clearmatics Software 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, Customers/Clients, Clearmatics Software 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, Customers/Clients, Clearmatics Software 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, Customers/Clients, Clearmatics Software Users Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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.

No Special Categories of Personal Data

We do not collect any “Special Categories of Personal Data” about our Site Visitors (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.

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 we use your Personal Data and why

We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

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.

What is our “legal basis” for processing your Personal Data?

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“). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below
  • 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 have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.

Purpose Categories Why we do this Our legal basis for this use of data
Customer Relationship Management Identity Data, Contact Data To record the relevant contact information of individuals who we communicate with for commercial or operational reasons during the normal course of doing business Legitimate Interests. We have a legitimate interest to hold information where we believe that doing so is in the reasonable expectations of individuals who have contacted us (or vice versa) and with whom the business communicates with for commercial or operational reasons, excluding explicitly communications for marketing purposes
Fraud Prevention Identity Data, Contact Data To keep our website and associated systems operational and secure Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our services, website and associated IT services and networks
Marketing Identity Data, ContactData, Marketing and Communications 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 services and offers may be relevant for you Consent
Suppression Identity Data, Contact Data Compliance with the Suppression request Legitimate Interests. Limited personal information is held in instances where individuals have asked us to not hold their personal information to ensure that the company can remain compliant with their request

What happens when you do not provide necessary Personal Data?

Where we need to process your Personal Data either to comply with law, or to perform 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 the functionalities of the Site).

In this case, we may have to stop you using the Site have with us but we will notify you if this is the case at the time.

Personal Data from Third Party sources

In addition to the Personal Data that we collect directly from you (as described in the What Personal Data we collect section), we also collect certain of your Personal Data from Third Party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.

Third Party data source Publicy available Categories
Social Media sites Yes Identity Data, Contact Data

How we use cookies and other tracking or profiling technologies

What are cookies?

We may collect information using “cookies“. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on the Site.

We use two broad categories of cookies:
– First Party cookies, served directly by us to your computer or mobile device
– Third Party cookies, which are served by our partners or service providers on the Site

Cookies we use

The Site uses the following types of cookies for the purposes set out below:

Type of cookie Purpose
General data cookies These cookies are used to collect information about traffic to the Site and how users use the Site. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to the Site, the websites that referred them to the Site, the pages they visited on the Site, what time of day they visited the Site, whether they have visited the Site before, and other similar information
Analytics & Performance cookies We use this information to help operate the Site more efficiently, to gather broad demographic information and to monitor the level of activity on the Site. We use Google Analytics and other Third Party analytics services for this purpose. Google Analytics uses its own cookies. It is only used to improve how the Site works. You can find out more information about Google Analytics cookies here. You can find out more about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of the Site by downloading and installing the browser plugin available via this link
Functionality cookies These cookies allow the Site to remember choices you make when you use the Site. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit the Site
Social Media cookies These cookies are used when you share information using a social media sharing button or “like” button on the Site or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter, or Google+. The social network will record that you have done this

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of the Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit the Site.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.

You can also prevent the use of Google Analytics relating to your use of the Site by downloading and installing the browser plugin available via this link.

Sharing your Personal Data

The table below describes with whom we share your Personal Data, what we share, and, why we share it.

Many of our external Third Parties are based outside the European Economic Area (“Europe“) so their processing of your Personal Data will involve a transfer of data to countries based outside of Europe.

We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of the Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Recipients Categories Why we share it Location(s)
Service Providers Identity Data, Contact Data, Technical Data Our service providers provide us with IT and system administration services Europe, United States
Professional advisors Identity Data, Contact Data Identity Data, Contact Data, our lawyers, bankers, auditors and insurers provide consultancy, banking, legal, insurance and accounting services Europe, United States

How we keep your Personal Data secure

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.

We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people 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.

How long we store your Personal Data

We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above (see How we use your Personal Data and why), unless a longer retention period is required by law (for example for regulatory purposes).

The table below shows our standard retention practices:

Categories Retention period
Marketing and Communications Data For as long as you continue to opt-in to receiving marketing information
Contact Data For so long as retention is necessary to fulfil the Purposes/Use for which it is used (see How we use your Personal Data and why)
Recruitment Data For a maximum period of 12 months to fulfil the firms recruitment obligations

Our policy on children

This Site is not intended for children below 16 and we do not knowingly collect data relating to such children.

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.