Last Updated: 13th January 2026

1. Introduction
2. What is personal data?
3. Personal data we collect and its sources
4. How we collect your personal data
5. Purposes for which we use your personal data and the lawful bases
6. Sharing your personal data
7. International transfers
8. How long we keep your personal data
9. Security of your personal data
10. Your rights
11. How to complain
12. How to contact us

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1. Introduction

ClearStake Limited (“ClearStake”, “we, “our”, “us”) is committed to protecting the privacy and security of the personal data we collect about users of our website, end customers and users of our services (“you/your”). ClearStake is a limited company registered in England and Wales under registration number 12144899, and we have our registered office at 29 Harbour Exchange Square, London, England, E14 9GE. We are registered with the UK supervisory authority, the Information Commission (“IC”), in relation to our processing of personal data under registration numberZB047307.

The purpose of this privacy policy is to explain what personal data we collect about you when you visit our website, purchase and access services from us, enquire about our services or provide us with your personal data at a conference or summit. When we do this, we are the data controller and are subject to the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act2018. We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we offer to individuals in the European Economic Area (EEA).

Please see our Service User Privacy Policy for more information on how your personal data will be handled when using the ClearStake platform as a service user or..

We update this Privacy Policy from time to time in response to changes in applicable laws and regulations, changes to our processing practices and to products and services we offer. When changes are made, we will update the header section of this policy.

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2. What is personal data?

‘Personal data’ is any information from which you can be identified, either directly or indirectly. For example, your name or an online identifier.

‘Special category personal data’ is more sensitive personal data and includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying someone, data concerning physical or mental health or data concerning someone’s sex life or sexual orientation.  

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3. Personal data we collect

For the type of Personal Data we may collect about you, please see the table below in the section entitled ‘Purposes for which we use your personal data and the lawful basis’.

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4. How we collect your personal data

We collect most of this personal data directly from you, such as where you provide information through filling in our “Let’s talk” form on our website, or from any interactions we may have over social media, email, phone or in person where you provide your personal data.

We also collect personal data though cookies and similar technologies on our site. As you interact with our website, we may collect technical information and data about your usage of our site. For more information about the use of cookies and similar technologies on our site, please visit our Cookie Policy.

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5. Purposes for which we use your personal data and the lawful basis

When you interact with us in the manner described above, we may use your personal data for the following purposes and under the following lawful bases:

6. Sharing your personal data

For some business activities, we may share your personal data with our vendors and third party service providers, for instance, with the third parties listed below:

• Service providers based internationally who provide marketing, IT and system administration services.
• Professional advisors, such as lawyers, accountants, auditors and other professionals.
• Third-party companies in the event that we are involved in a corporate transaction, such as an actual or potential merger, joint venture, consolidation or asset sale. We may, from time to time, expand or reduce ClearStake and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to the part of our business that is being transferred, be shared alongside that. The new owner or newly controlling party will be permitted to use that personal data only for the purposes for which it was originally collected by us.
• Personal data may also be shared with other third parties including government authorities and/or law enforcement officials for the prevention or detection of crime, if required by law or if required for a legal or contractual claim and to other third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

7. International transfers

We will not usually transfer your personal data outside the UK and the European Economic Area (“EAA”). However, in certain circumstances this may be necessary in order to provide our services to you, such as if a supplier we use to provide our service to you is based outside of the UK or EEA.

We have taken appropriate steps to ensure that  personal data  processed outside the UK or EEA has an essentially equivalent level of protection to that guaranteed in the UK and EEA. We do this by ensuring that:

• Your Personal Data is only processed in a country which the UK Secretary of State and the European Commission has confirmed has an adequate level of protection (an adequacy regulation); or
• We enter into Standard Contractual Clauses (“SCCs”) and UK Addendum with the receiving organisations and adopt supplementary measures, where necessary (A copy of the UK International Data Transfer Addendum can be found here); or
• When transferring your Personal Data to America, we may rely on the UK Extension to the EU-US Data Privacy Framework, where appropriate.

8. How long we keep your personal data

We will retain your personal data for as long as is necessary to provide you with our services and for a reasonable period thereafter to enable us to meet our contractual and legal obligations and to deal with complaints and claims. For more information about our retention periods, please contact us at privacy@clearstake.com.

At the end of the retention period, your personal data will be securely deleted or anonymised, for example by aggregation with other data, so that it can be used in a non-identifiable way for statistical analysis and business planning.

9. Security of your personal data

We have implemented appropriate technical and organisational measures to safeguard your personal data and protect it from accidental or unlawful destruction, loss or alteration and from unauthorised disclosure or access.

In addition to the technical and organisational measures we have put in place, there are a number of simple things you can do to in order to further protect your personal information, such as;

1. If you’re logged into any online service do not leave your computer unattended.
2. Close down your internet browser once you’ve logged off.

Secure Online Services

You can easily identify secure websites by looking at the address in the top of your browser which will begin https:// rather than http://.

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10. Your rights

You have certain rights in relation to the processing of your personal data, including to:

1. Request access to your personal data (commonly known as a “Subject Access Request”). This enables you to receive a copy of the personal data we hold about you.
2. Request rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. If you object to us using your personal data for marketing purposes we will stop sending you marketing material.
5. Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data, for example if you want us to establish its accuracy or the reason for processing it.
6. Request the transfer of your personal data to another party (data portability).
7. Automated decision-making. You have the right not to be subject to a decision based solely on automated processing which will significantly affect you. We do not use automated decision-making.  

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we are permitted by law to do so.

How to exercise your rights

You will not usually need to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. If you wish to exercise your rights, please contact us at privacy@clearstake.com.

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12. How to complain

You have the right to complain if you consider that we have not complied with the data protection law when handling your Personal Data. We will acknowledge receipt of your complaint within 30 days, investigate the matter without undue delay, and keep you informed of the progress and outcome. If you wish to complain please use the contact details given below under “How to contact us”.  We will do our best to resolve the matter to your satisfaction.

If you are not satisfied with the outcome of your complaint, you can complain with the relevant supervisory authority. The supervisory authority in the UK is the Information Commission who can be contacted online at:

• Contact us | ICO
• Or by telephone on 0303 123 1113

For supervisory authorities in other countries within the EU see the link below:

https://edpb.europa.eu/about-edpb/about-edpb/members_en

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13. How to contact us

If you wish to contact us in relation to this privacy policy or if you wish to exercise any of your rights outlined above, then please address your correspondence to:

29 Harbour Exchange Square, London, England, E14 9GE

Alternatively, you can email us at privacy@clearstake.com.

We have also appointed a Data protection Officer (“DPO”). Our DPO is Evalian Limited and can be contacted by emailing dpo@evalian.co.uk or via our postal address. If sending correspondence to our postal address, please mark the envelope to the ‘Data Protection Officer’.