Privacy policy.
Clockwork Dog Limited (“we/us/our”) created our software and hardware (“System”) which we operate through our Website for our clients and for entertainment purposes. We therefore respect your privacy through the provision of our Software or the use of our System and our Website generally. Our services are therefore provided on an ‘as is available’ basis.
This Privacy Policy (together with our Licence Agreement, EULA, Cookie Policy and any other documents or terms incorporated by reference) describe the types of information that we collect from our visitors or clients (“you/your”) through the use of our products and services available to you (“Services”), or the use of our website found at the domain cogs.show/legal (“Website”), and how that information may be used or disclosed by us and the safeguards we use to protect it. The personal information that we collect is used for providing and improving our Services. We will not use or share your information with anyone except as described in this Privacy Policy.
We have drafted this Privacy Policy to be as clear and concise as possible. Please read it carefully to understand our policies regarding your information and how we will treat it. By downloading our Software, accessing our System, using or accessing our Website or the Services, you agree to the collection, use and disclosure of information in accordance with this Privacy Policy.
This Privacy Policy may be amended from time to time and your continued use of the Website, Software or the Services is deemed to be acceptance of such changes, so please check periodically for updates. 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.
We have appointed a data privacy manager 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 the data privacy manager using the details set out below.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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.
Who are we?
We will only process personal information you in accordance with the UK Data Protection Legislation which for the purposes of this Privacy Policy shall mean: all applicable data protection and privacy legislation in force from time to time in the UK including the General Data Protection Regulation ((EU) 2016/679) UK GDPR; the Data Protection Act 2018; the Privacy and Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended and any other applicable privacy laws. Here are the details that the UK Data Protection Legislation says we have to give you as a 'data controller':
Our site address is www.cogs.show
Our company name is Clockwork Dog Limited
Our registered address is 5-7 Buck Street, London, NW1 8NJ
Our company number is 10115397
Our data privacy manager is Alex Hylands-White and they can be contacted at alex@clockwork.dog
What information do we collect?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes contact address, billing address, email address and telephone numbers.
Financial Data that may include bank account and payment card details if you purchase anything from us. [However, we may use secure third party payment providers]
Transaction Data that may include details about payments to and from you if relevant, as well as other details of other products and services.
Technical Log Data includes internet protocol (IP) address, your login data, 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 System, Software and our Website.
Profile Data includes your username and password, purchases or orders made by you (if applicable), your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our Website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Interaction Data includes any information that you might provide to any discussion forums on the Website or the System.
Cookies Data like many websites, we may use some "cookies" to enhance your experience and gather information about visitors and visits to our websites. Please refer to the "Do we use 'cookies'?" section below for information about cookies and how we use them and what kind.
Third Parties and Information we receive from other sources We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Website. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, affiliates, analytics providers and search information providers etc) and may receive information about you from them.
Analytics includes third-party analytics services (such as Google Analytics) to evaluate your use of the System and Website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our Website and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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.
We do not collect any Special Categories of Personal Data about you (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.
How is your personal data used?
We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through:
Direct interactions. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you when you fill in forms through the System and the Website (together “Our Sites”), or by corresponding with us (for example, by email or chat). It includes information you provide when you register or subscribe to any of our Services, enter a promotion or survey, use the Website when you create an account with us or request marketing to be sent to you, and finally when you report a problem with our Services, or our Website. If you contact us, we will keep a record of that correspondence.
Information we collect about you and your device either automated or otherwise. Each time you visit our Website or use our System or the Services, we will automatically collect personal data including Technical Log Data. We collect this data using cookies and other similar technologies including server logs. We may also receive technical data about you if you visit other websites employing our cookies.
Location Data. We may use GPS technology in the use of the Software. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings but this may impact your use of the Website.
Marketing Data. If you have opted-in to receive any e-mail newsletters or marketing services, we may send you periodic e-mails. If you would no longer like to receive promotional e-mail from us, let us know.
Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties [and public sources] as set out below
Device Data from the following parties: analytics providers such as Google based outside the EU; Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside the EU;
IT and Software;
Professional advisors - we may also share your personal information with our professional advisors (including lawyers and accountants) to take advice etc;
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
If you are already registered as a client, we will only contact you electronically about services or products similar to those previously sold to you or downloaded by you.
If you are a new client, you will only be contacted if you agree to it.
We may keep a record of those links which are used the most to enable us to provide the most helpful information but we agree to keep such information confidential and you will not be identified from this information
Cookies
Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device’s internal memory.
All Cookies used by and on our Website and System are used in accordance with current English and EU Cookie Law. For further information on Cookies and how we use them in our Services, please refer to our Cookie Policy www.cogs.show/cookies.
Purpose for which we will use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
Where you have consented before the processing.
Where we need to perform a contract we are about to enter or have entered with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us at alex@clockwork.dog.
We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Please note this list is not exhaustive of the forms of data that we may collect.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of Data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To download/ install the Software, use the System and register an account. | Identity Contact Financial Device |
Your consent Performance of a contract with you. |
| To manage your account and deliver Services, including managing payments and collecting money owed to us | Identity Contact Financial Transaction Device Marketing and Communications Location |
Your consent Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us and for payment for Services) |
| Receiving details on our System and Website, to register new clients, including completing registration forms or to submit an enquiry with us by phone, email or via our website. | (a) Identity (b) Contact |
(a) Necessary for our legitimate interests (to complete new business and provide Services) (b) Performance of a contract |
| Information to carry out our Services with our clients including: (a) accounting services (b) invoicing (c) Manage payments, fees and charges (d) Collect and recover money owed to us (e) Process purchases (f) Undertake customer reviews |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract (b) Necessary for our legitimate interests (to recover debts due to us and process payments) |
| Information to manage our relationship with our clients, or prospective clients which will include: (a) Notifying about changes to our terms or our privacy policy (b) Asking to leave a review or take a survey (c) Correspondence (d) For internal administrative purposes |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our products/services) |
| To enable clients and prospective clients to partake in promotion or complete a survey | (a) Identity (b) Contact (c) Technical (d) Cookies (e) Marketing and Communications |
(a) Performance of a contract (b) Necessary for our legitimate interests (to study how clients use our products/services, to develop them and grow our business) |
| To administer and protect our business (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (g) Cookies |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business re-organisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant System, Software and Website content and advertisement and promotional activity to measure or understand the effectiveness of the advertising we are providing | (a) Technical (b) Usage (c) Cookies |
Necessary for our legitimate interests (to study how clients use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To recruit, support and manage staff for operational reasons | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to operate the business) |
How do we store your data and security?
We will keep personal data for as long as is necessary which is usually the life of our relationship and up to a period of six years after our relationship have ended. We may however be required to retain personal data for a longer period of time to ensure we comply with our legislative and regulatory requirements. We review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.
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 in respect to our relationship with you.
International Transfers
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website and the System.
We have implemented security measures such as a firewall to protect any data and maintain a high level of security.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.
If we give you a password upon registration on our Website or the System, you must keep it confidential. Please don't share it.
How do we protect personal information?
We implement a variety of security measures to protect and maintain the safety of your personal information including encrypted software. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.
Disclosure of information to other parties?
As already indicated above, to enable us to provide our Services to you, we will contract with third parties to supply services to you on our behalf. Other third parties providers may include payment processing, our business partners, software providers, delivery of solutions or additional services, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
We are also allowed to disclose your information in the following cases:
If we want to sell our business, or our company, we can disclose it to the potential buyer
We can disclose it to other businesses in our group
We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety or rights;
in connection with legal proceedings (including prospective proceedings);
in order to establish or defend our legal rights; and
we can exchange information with others to protect against fraud or credit risks.
Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.
Change of Purpose
We will only use your personal data for the purposes for which we collect it and to enable us to carry out our business with you, 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 contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Links to Other Sites
Our Website and App may contain links to other websites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Children’s Privacy
These Services do not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. In the case we discover that a child under 18 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.
Your Rights
When you submit information to us, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details).
Under the UK Data Protection Legislation, you have the right to:
request access to, deletion of or correction of, your personal data held by us at no cost to you;
request that your personal data be transferred to another person (data portability);
be informed of what data processing is taking place;
restrict processing;
to object to processing of your personal data; and
complain to a supervisory authority.
You also have rights with respect to automated decision-making and profiling.
To enforce any of the foregoing rights or if you have any other questions about our System, Website or this Privacy Policy, please contact us at alex@clockwork.dog
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
Social Media
Communication, engagement and actions taken through external social media platforms that this Website, the System and us participate on are custom to the terms and conditions applicable by the social media supplier as well as the privacy policies held with each social media platform respectively.
You are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to your own privacy and personal details. This Website nor its owners will never ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by email.
The Website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. You are advised before using such social sharing buttons, that you do so at your own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
We may share web links through our social media platform accounts to relevant web pages. By default some social media platforms shorten lengthy urls [web addresses] (this is an example: http://bit.ly/zyVUBo).
You are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by this Website. Despite the best efforts to ensure only genuine urls are published, many social media platforms are prone to spam and hacking and therefore we cannot be held liable for any damages or implications caused by visiting any shortened links.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.
Contact Us
If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us.
Your Consent
By using our Website and/or the System or our Services and by way of acknowledgment, you consent to our Privacy Policy.
Dispute Resolution
The Parties will use their best efforts to negotiate in good faith and settle any dispute that may arise out of or relate to this Privacy Policy or any breach of it.
If any such dispute cannot be settled amicably through ordinary negotiations between the parties, or either or both is or are unwilling to engage in this process, either party may propose to the other in writing that structured negotiations be entered into with the assistance of a fully accredited mediator before resorting to litigation.