Last Updated: 20th May 2025

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 Commissioner’s Office (“ICO”), in relation to our processing of personal data under registration number ZB047307.

The purpose of this privacy policy specifically, is to explain what personal data we collect about you when visit our website. When we do this, we are the data controller. Please note that this privacy policy applies to website users only. This privacy policy applies to you if 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. 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. If you are a commercial user of the ClearStake platform, this privacy policy will apply to you.

Please read this privacy policy carefully as it provides important information about how we handle your personal data and your rights. 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. If you have any questions about any aspect of this privacy policy you can contact us using the information provided below or by emailing us at privacy@clearstake.com.

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2. What is my 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

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. 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). The personal data we collect includes:

• Full name
• Email address
• Address
• Organisation
• Job title
• Login details required to provide our service to you
• A record of your correspondence with us (including any details or attachments)

We may also collect technical data about you via cookies on our website. This 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 this website. Please see our “How we collect your personal data” section for more information on this.

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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 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:

We will process your personal data to respond to any enquiries, questions and complaints you send. We rely on the lawful basis of legitimate interests to process this data. We have a legitimate interest in communicating with you to ensure your enquiry, question or complaint is dealt with appropriately.

We will process your personal data to provide you with access to our service through the provision of login information and relevant account details. We process this data under the lawful basis of the performance of a contract.

We may also process your personal data to administer this website. This includes enabling you to use our website, troubleshooting, testing, system maintenance, support and reporting of data. We rely on the legal basis of legitimate interests to perform this processing. It is necessary for our legitimate interest in running our business, nuisance caller management, to defend our servers against malicious attacks and operational performance improvement.

Your personal data may also be used to deliver relevant website content and ensure that it is presented in the most effective manner for you and your device. This is in our legitimate interest to achieve the most user-friendly website navigation experience.

Where your personal data has been collected for marketing purposes, we may send you emails from time to time informing you of products and services that are of interest to you. We rely upon your consent to do so. You can withdraw your consent at anytime by using the unsubscribe feature contained within the emails.

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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 and IT and system administration services.
• Professional advisors, such as lawyers, accountants, auditors and other professionals.
• Your employer or the corporate entity you represent, for the purposes of providing the service to you and/or your employer where we have a contract with your employer or the company you represent.
• 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.

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7. International transfers

When we collect your personal data, it may be processed outside the UK. This is because the organisations we use to provide our services to you are located in other countries.

We have taken appropriate steps to ensure that where personal data processed outside the UK, it has an essentially equivalent level of protection as it has within the UK. We do this by ensuring that:

• Your personal data is only processed in a country which the Secretary of State has confirmed has an adequate level of protection (an adequacy regulation); or
• We enter into either International Data Transfers Agreements (IDTAs) or Standard Contractual Clauses with the UK Addendum with the receiving organisations and ensure that supplementary measures are also applied, where necessary

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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.

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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.  

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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.

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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 lodge a complaint with the supervisory authority, if you believe we are infringing the UK data protection laws or you are concerned about the way in which we are handling your personal data. The supervisory authority in the UK is the Information Commissioner’s Office who can be contacted online at:

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

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13. How to contact us

If you wish to contact us in relation to this privacy notice 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’.