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I. PRIVACY POLICY
Last updated: 1 November 2022
1. CLEARHALO.COM’S APPROACH TO PRIVACY
1.1 www.clearhalo.com is a website and a mobile application owned and operated by clearhalo.com We are committed to protecting and respecting your privacy in accordance with the applicable data protection legislation (the "Data Protection Legislation"). This privacy policy (“Privacy Policy”) sets out how we collect, use and share information that identifies you or is associated with you (“personal data”)
1.2 You should also be aware that we use cookies to store and access information whilst providing access to our platform. You can find out more about our use of cookies in our Cookies Policy.
2. PERSONAL DATA WE COLLECT ABOUT YOU
2.1 We collect personal data from you when you voluntarily submit information directly to us or via our platform. This can include information you provide when you register to use the platform, create an account on our platform, set up a profile on Services and interact with other users, visit one of our showrooms, use a tablet or similar device in one of our showrooms, complete a form, provide feedback or reviews on our products or platform, enter competitions through our platform, correspond with us, purchase products from the platform, subscribe to our email lists or respond to surveys or promotions.
2.2 The categories of personal data we collect include the following:
(a) Contact details: Such as your name, your email address, your telephone number and addresses associated with your account.
(b) Profile information: Such as your contact details (as above) and other any information you share when creating a profile on Services.
(c) Comments and opinions: Such as, comments and opinions you share on clearhalo.com’s services, when you provide feedback or reviews on our products or platform, or when you respond to our surveys, competitions and promotions.
(d) Messages to us or between users: Messages you send to us such as email and written correspondence and messages to other users using clearhalo.com’s services.
(e) Payment and transaction information: Records of the products and services you purchase from us and the payment method, and credit/ debit card details, you use for the transaction.
(g) Your preferences: Choices you make such as notification and messaging preferences or choices about how the platform is displayed.
(h) Information about products you have looked at: We collect information about the products that you have looked at on the platform or in one of our showrooms, or that you have added to your basket on the platform or to your wishlist on a tablet or similar device in one of our showrooms.
(i) Information about how you use and connect to the online service:
(i) We automatically collect information about how you use the platform such as the pages and links you access, the time you access the platform and duration you are on it, the platform you come to the platform from or go to after leaving the platform and selections and choices you make when using the platform.
(ii) We also automatically collect information about the computer or other electronic devices you use to connect to the platform such as details about the type of device (which can include unique device identifying numbers), its operating system, browser and applications connected to the platform through the device, your Internet service provider or mobile network, your IP address and your device’s telephone number (if it has one).
(iii) Typically, the information we collect about how you use or connect to the platform is associated with your device.
(j) Information about your location: Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may help us determine an approximate location but this will be no more precise than the city, state or country you are using your device in.
(k) Information about the location of purchases: We will display a catalogue image of any purchase made through our platform on a searchable map as a way of showing the approximate location of the delivery address which customers give when making a purchase. We do not disclose any personal data on our map and only display our catalogue image of the purchase made by reference to the postcode of the delivery address.
(l) Information provided by other users: Sometimes, other visitors to our platform provide your personal data. For example, other visitors may provide your personal data to us when they invite you to use the platform or through clearhalo.com’s services.
(m) Information from fraud prevention organisations: Where permitted by law, if fraudulent activity is suspected relating to your account, we may be provided with information by credit reference, fraud and crime prevention organisations.
2.3 We also automatically collect personal data indirectly from you such as information about the pages you look at on the platform or the device you connect to the platform with, or the products you add to your wishlist using a tablet or similar device in one of our showrooms.
2.4 We may also collect personal data about you from Facebook via its Connect functionality: The received information includes login details and profile information such as your log-in token, user name and photo and other information from that service as permitted by you and that service.
3. HOW WE USE YOUR INFORMATION
3.1 We will also use your personal data for the purposes specifically described below:
(a) Contact details: we will use your contact details so that we can communicate with you directly via phone, SMS messaging, or email, in particular, about queries, issues, problems we have detected or concerns you or other users have. We may also use your contact details to send you information about similar products and services that we think may be of interest to you (such communications will be in accordance with your marketing preferences as explained in more detail in section 5 below).
(b) Profile information: we use your profile information to provide clearhalo.com’s services to you and ensure that you are able to interact with our users as permitted by the functionality of the service and your preferences which you can set by using the ‘my preference’ functionality on your profile page.
(c) Comments and opinions: we will use your comments and opinions to determine similar products and services that may be of interest to you and to provide our clearhalo.com’s service to you and ensure that you are able to interact with our users as permitted by the functionality of the service and your preferences which you can set by using the ‘my preference’ functionality on your profile page.
(d) Payment and transaction information: we will use payment and transaction information you provide to process payment for any product or service you purchase from us. We may also use the history of your transactions with us to determine similar products and services that may be of interest to you.
(e) Messages to us or other users: we will use messages you send to us to help us respond to any query, issue or concern you raise and to provide clearhalo.com’s services to you and ensure that you are able to interact with our users as permitted by the functionality of the service and your preferences which you can set by using the ‘my preference’ functionality on your profile page.
(f) Your preferences: we will use your preference settings which you can set by [insert method by which users can set such preferences] for the purpose of providing notifications, messages, displaying the platform and following other choices you are able to make about how the platform is displayed to you.
(g) Information about products you have looked at: we use this information to send you reminders and further information about these products. We will also use this information to determine similar products and services that may be of interest to you.
(h) Information about how you use and connect to the online service: we use this information to present the platform to you on your device. We will also use this information to determine similar topics, products and services that may be of interest to you.
(i) Information about your location: we may use an approximate location to ensure content on the platform is relevant to the city, state or country you are using your device in. We will not collect or track your precise location without your consent.
(j) Information about the location of purchases: we use this information to show what types of purchases are being made in a particular area on a searchable map and to allow users to contact other users about their purchases through depending on your preferences which you can set by using the ‘my preference’ functionality on your profile page.
(k) Information provided by other users: we will use your personal data that is contained in messages sent to us by other user to respond to any query, issue or concern they raise or to provide clearhalo.com’s services service to you and ensure that you are able to interact with our users as permitted by the functionality of the service and your preferences which you can set by [insert method by which users can set such preferences]. We will use your personal data that is contained in forms submitted by other users to contact you, if you indicate you would like to receive a communication from us.
(l) Information about fraudulent activity relating to your account: we will use information about fraudulent activity relating to your account for the purposes of preventing fraud or crime.
(m) All personal data on an aggregated basis: we will use all the personal data we collect to: (i) monitor and improve the platform and our procedures and processes; and (ii) to help us develop new products and services.
3.2 We may anonymise and aggregate any of the information we collect (so that it does not identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the platform, developing new products and features or displaying information about the purchases made via our platform such as the most popular purchases or purchases based on an approximate location.
3.3. We process your personal data (i) with your consent, (ii) when we need to do this to fulfil a contract with you (for example, the contract of sale), (iii) where we are required to do this by law (for example, where it is necessary to retain it in connection with potential litigation), and/or (iv) when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, we have a legitimate interest in offering and providing clearhalo.com products and services, deter fraud and carry out direct marketing.
4. INFORMATION WE SHARE WITH THIRD PARTIES
4.1 We may share your personal data with the following parties:
(a) Our users: we and you may share your information with other users as part of our services service so you are able to interact with our users as permitted by the functionality of the service and your preferences which you can set by using the ‘my preference’ functionality on your profile page.
(b) Companies in the same group of companies as us: our subsidiaries (i.e. any organisation we own or control) or our ultimate holding company (i.e. any organisation that owns or controls us) and any subsidiaries it owns. These companies will only use your personal data in the same way as we can under this Privacy Policy.
(c) Service providers, partners and advisors: third parties who provide a service to us, partner with us on certain business activities, advise us or that we work within other business capacities. For example, we use a third party delivery service to deliver any products you buy to your postal address. We may also pass your personal data to our marketing and other business partners and other carefully selected third parties who may wish to offer you other goods or services that we or they have identified as likely to be of interest to you. These third parties will only be allowed to use your personal data in accordance with our instructions or your marketing preferences (where applicable) and will be required to keep your information secure.
(d) Purchasers of our business: personal data may be disclosed or transferred to buyers or prospective buyers of our business or any of our assets as part of the sale.
(e) Law enforcement, regulators and other parties for legal reasons: third parties who we are under a legal obligation to disclose your personal data to or who we need to disclose your personal data to protect our rights, property or safety or the rights, property or safety of others, detect and investigate illegal activities and breaches of any agreement we have with you.
(i) INFORMATION WE COLLECT FROM YOU
(a) We collect and process some or all of the following types of information from you:
(i) Information that you provide when you apply for a role. This includes information provided through an online job site, via email, in person at interviews and/or by any other method.
(ii) In particular, We process personal details such as name, email address, address, date of birth qualifications, experience, information relating to your employment history, skills and experience that you provide to https://www.clearhalo.com/.
(iii) If you contact us, We may keep a record of that correspondence.
(iv) A record of your progress through any hiring process that We may conduct.
(v) Details of your visits to clearhalo.com and Workable’s Website including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to Workable’s Website and the resources that you access.
(ii) INFORMATION WE COLLECT FROM OTHER SOURCES
(a) Workable provides Us with the facility to link the data you provide to Us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles. Workable’s technology allows Us to search various databases – some publicly available and others not, which may include your personal data (including your CV or Resumé), to find possible candidates to fill Our job openings. Where We find you in this way We will obtain your personal data from these sources.
(b) Information provided by other organisations who’ve obtained your permission to share information about you with us for the purposes of advertising and customising your experience on our sites.
(iii) LAWFUL BASIS FOR PROCESSING
(a) We rely on legitimate interest as the lawful basis on which We collect and use your personal data. Our legitimate interests are the recruitment of staff for Our business. Where you apply for a job opening through the Indeed Apply functionality, we rely on your consent, which is freely given by you during the application process, to disclose your personal data to Indeed on the basis described below.
(iv) PURPOSES OF PROCESSING
(a) We use information held about you in the following ways:
(i) To consider your application in respect of a role for which you have applied.
(ii) To consider your application in respect of other roles.
(iii) To communicate with you in respect of the recruitment process.
(iv) To enhance any information that We receive from you with information obtained from third party data providers.
(v) To find appropriate candidates to fill Our job openings.
(vi) To help Our service providers (such as Workable and its processors and data providers) and partners (such as the job sites through which you may have applied) improve their services.
(v) AUTOMATED DECISION MAKING/PROFILING
(a) We may use Workable’s technology to select appropriate candidates for clearhalo.com to consider based on criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable candidates is automatic, however, any decision as to who We will engage to fill the job opening will be made by Our staff.
(vi) DISCLOSURE OF YOUR INFORMATION
(a) As set out above, We pass your information to Our third party service providers, including Workable, who use it only in accordance with Our instructions and as otherwise required by law. Where you have applied for a job opening through the Indeed Apply functionality, and where you have consented to this disclosure, We will disclose to Indeed certain personal data that We hold, including but not limited to a unique identifier used by Indeed to identify you, and information about your progress through Our hiring process for the applicable job opening, as well as tangible, intangible, visual, electronic, present, or future information that We hold about you, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively “Disposition Data”). Indeed’s Privacy Notice in respect of Indeed’s use of the Disposition Data is available on Indeed’s website. Where you have applied to a job opening through another service provider, We may disclose data similar to the Disposition Data defined above to such service provider. The service provider shall be the data controller of this data and shall therefore be responsible for complying with all applicable law in respect of the use of that data following its transfer by clearhalo.com.
4.2 We do not disclose personal data to anyone else except as set out above, where permitted by law and/or with your consent. We may provide third parties with aggregate statistical information and analytics about users of the platform but we will make sure that no one can be identified from this information before we disclose it.
5. MARKETING AND ADVERTISING
5.1 Email Marketing - From time to time we may contact you by email with information about our similar products and services which we think you may be interested in if you agree [at the point of registration / sale]. Thereafter, if you do not want us to send you email marketing, please use the contact details provided in section 13 below . You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails we send to you.
5.2 Email Notifications On Behalf of Users – We may send you notifications that users may wish to contact you about purchases you have made through our platform. If you wish to speak to the user, you may do so by signing up to Services. If you do not want us to send you these notifications, please let us know by using the contact details provided in section 13 below.
5.3 Email Notifications About Your Order or Changes to the Services We Provide - We may send you email notifications in relation to your order or changes to the way we provide our services to you.
5.4 Advertising on the Site and other social media websites – We, or our advertising partners, may show advertisements to you on our platform or on other platforms. To do this we, or our advertising partners, may collect information about how you use the platform or the types of other web pages, content and ads you, or others who are using the device you connect to the platform, interact with, visit or view. The information collected might also include the IP address of the device you connect to the platform or the e-mail address you provide to us or our platform. We, or our advertising partners, use the information that is collected to make sure adverts you see either on the platform or other platforms or apps (where our partners have advertising space) are more relevant to you.
5.5 The techniques our advertising partners use recognise the device or e-mail address you are using. Typically cookies and similar technologies are used to provide this type of advertising. You can find out more about cookies and how to manage their use by reading our Cookies Policy.
6. STORING AND TRANSFERRING YOUR PERSONAL DATA
6.1 International Transfers of your Personal data: the personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in, including, in particular, outside the European Union. Some of these jurisdictions offer differing levels of protection in respect of personal data and may, in certain instances, be less protective than the jurisdiction you are resident in. We ensure that your personal data is treated securely and in accordance with this Privacy Policy.
6.2 We put in place European Commission approved standard contractual clauses or rely on alternative transfer mechanisms to protect this data. A copy of these clauses is available for your review upon request to us using the contact details provided in section 12 below.
7. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA
7.1 You may have various rights with respect to our use of your personal data:
- Marketing: As stated above in section 5, you may opt-out of receiving such emails from us by using the contact details provided in section 13 below, or by clicking on the unsubscribe link in the emails we send to you.
- Cookies: Please see our Cookies Policy for more information about your rights as regards our use of cookies.
- Access, rectify, port, block, complete, delete and update: You have the right to access, rectify, block, port, complete, delete and update your personal data, and to restrict its use. You also have the right to request further information about the processing of your personal data.
- Object: In certain circumstances, you also have the right to object to the processing of your personal data by us.
7.2 You can exercise the above rights by contacting us using the details provided in section 13 below at any time. All requests will be dealt with at the earliest opportunity and any delay will be kept to a minimum.
7.3 There are exceptions to these rights; for example, access may be refused if it would reveal personal data about another person or if we are prevented from disclosing such information by law.
7.4 We hope that we can satisfy queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to the competent data protection authority.
7.5 When we ask you to supply us with your personal data we will make it clear whether the data we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any information we ask for is optional.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
8.1 We will retain your information, whether or not your account is active, for as long as we believe it is necessary to fulfil our business purposes or to comply with applicable law, audit requirements, regulatory requests or orders from competent courts.
9. LINKS TO THIRD PARTY SITES
9.1 The platform may, from time to time, contain links to and from third party platforms of our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these platforms, please note that these platforms have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those platforms.
10. CHANGES TO THIS POLICY
10.1 We may update this Privacy Policy from time to time, and when we do so we will update the “last modified” date at the top of this Privacy Policy. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.
11. NOTICE TO YOU
11.1 If we need to provide you with information about something, whether for legal, or business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the platform. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this Privacy Policy.
12. CONTACTING US
12.1 Questions, comments and requests regarding this Privacy Policy are welcome and should be addressed to hello@clearhalo.com or www.clearhalo.com Design No.101, Apt.2, Building 12, Duantou 1 Qu, Jiangdong Street, Attn: Privacy Manager.
II. COOKIES POLICY
Last updated: 12 May 2018
1. SUMMARY
This cookies policy explains what cookies are and how www.clearhalo.com Design Ltd (“we”, “us” or “our”) uses them on www.clearhalo.com (our “platform”). We encourage you to read the policy in full so that you can understand what information we collect using cookies and how that information is used.
2. WHAT ARE COOKIES OR SIMILAR TECHNOLOGIES?
Cookies (or similar technologies) are text files, containing small amounts of information, which are downloaded to your browsing device (such as a computer or smartphone) when you visit a platform. Cookies can be recognised by the platform that downloaded them — or other platforms that use the same cookies. This helps platforms know if the browsing device has visited them before.
3. WHAT ARE COOKIES USED FOR?
Cookies do lots of different jobs, like helping us understand how our platform is being used, letting you navigate between pages efficiently, remembering your preferences, and generally improving your browsing experience. Cookies can also help ensure information and advertising you see online is more relevant to you and your interests.
4. WHAT TYPES OF COOKIES ARE USED BY www.clearhalo.com?
The types of cookies used on our platform can generally be put into one of the following categories: strictly necessary; analytics; functionality; advertising; and social media. You can find out more about each of the cookie categories in the table below.
Strictly Necessary Cookies
These cookies are essential to make our platform work. They enable you to move around the platform and use its features. Without these cookies, services that are necessary for you to be able to use our platform such as accessing secure areas cannot be provided.
Analytics Cookies
These cookies collect information about how people are using our platform, for example, we use Google Analytics cookies to help us understand which pages are visited the most often, how people are moving from one link to another and if they get error messages from certain pages. Overall, these cookies provide us with analytical information about how our platform is performing and how we can improve it.
Functionality Cookies
These cookies allow us to remember choices you make and tailor our platform to provide enhanced features and content to you. For example, these cookies can be used to remember your user name, language choice or country selection, they can also be used to remember changes you've made to text size, font and other parts of pages that you can customise.
Advertising Cookies
These cookies are used to deliver advertisements that are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They remember that you have visited a platform and this information may be shared with other organisations such as advertising partners. This means after you have been to our platform you may see some advertisements about our services elsewhere on the Internet.
Social Media Cookies
In order to enhance your internet experience and to make the sharing of content easier, some of the pages on our platform may contain tools or applications that are linked to third party social media service providers such as Facebook or Pinterest. Through these tools or applications the social media service provider may set its own cookies on your device. We do not control these cookies and you should check the social media service provider’s platform for further details about how they use cookies.
5. HOW LONG WILL COOKIES STAY ON MY BROWSING DEVICE?
The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device after you have finished browsing until they expire or are deleted.
6. FIRST AND THIRD-PARTY COOKIES
“First party cookies” are cookies that belong to us and that we place on your device. “Third-party cookies” are cookies that another party places on your browsing device when you visit our platform. You should check the third party’s website for more information about how they use cookies.
7. HOW TO MANAGE COOKIES FROM THIS PLATFORM
You can usually use the browser that you are viewing this platform through to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note that if you set your browser to disable cookies, you may not be able to access secure areas of the platform and other parts of the platform may also not work properly.
Below are links to managing cookies and privacy in the most popular browsers:
- Chrome
- FireFox
Some third parties may use Advertising Cookies to help gather information about your browsing activity so that they can deliver platform advertising to you that is relevant to your interests. The advertising industries in EU have developed schemes to help you opt-out of receiving cookies used for these purposes. You can find out more about the EU scheme from www.youronlinechoices.eu.
8. CHANGES
Information about the cookies used by us may be updated from time to time, so please check back on a regular basis for any changes. The last modification date of this document is shown at the top of this page.
9. QUESTIONS?
If you have any questions you can either email us at hello@clearhalo.com or you can speak to us through our 24/7 live chat