Privacy Policy
September 2020
The business of Clever Keith is marketing and involves the collection of personal information
from individuals who may be interested in a specific type of service, and the sale of this
personal information to our clients, who are businesses that provide services in the area for
which the personal information was collected.
We use advertising, for example on social media sites, to attract individuals that may be suited
for business products or services of our clients. We are upfront and open about what we do, and
this privacy policy sets out how we collect your personal data, what we do with it, who we give
it to, how we keep it safe and how long we store it for. Although we sell personal data, we
believe that transparency is important, and we strive to do our best to protect your personal
information in accordance with this privacy policy.
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DEFINITIONS
- When we talk about 'us', we mean Clever Keith and the entity detailed in the schedule.
We are the operator of this website. When we talk about 'you', we mean the person using
this website or services of this website or participating in any surveys, questionnaires
or quizzes produced by this website. When we talk about ‘client’ we mean the business or
businesses that engage or deal with us to purchase the information we collect. Our
client(s) details are listed in this schedule.
- 'Personal data' or 'personal information' is information that directly identifies you,
such as your name and email address, or data that could be used, on its own or in
combination with other data, to identify you.
- It is very important to us to protect your personal data and to use it strictly in
adherence with applicable privacy and data protection laws.
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STAYING ANONYMOUS
- You can browse our website anonymously, although cookies may be collected. You will not
be able to access surveys or questionnaires anonymously.
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COLLECTION OF DATA
- We collect personal data about you when you give it to us or explicitly consent for it
to be given to us. This generally occurs when you complete an online form, survey, quiz
or questionnaire in which case you have chosen to consent to the collection and
subsequent sale of your personal data.
- We collect and process the minimum amount of information we need to be able to sell your
details to our client, so that our client is able to contact you about their services
and deliver effectively to you the service you have expressed interest in, or to fulfil
a service contract, or to meet a legal obligation. How much data we collect depends on
the type of service you have expressed an interest in. This information can include:
- First Name
- Last Name
- E-mail address
- Phone Number
- Mailing address
- We will not seek sensitive personal data from you, such as health details or information
revealing your religious beliefs or ethnic origin.
- Other than listed above, we do not collect financial information relating to you such as
bank card details.
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COOKIES
- We may also use ‘cookies’ on our website to provide a way for the website to recognise
you and keep a track of your preferences, and to enable you to contact us directly from
the website. Cookies may also be used to optimise website speed for your convenience, to
allow you to customise our web pages and so that you do not have to keep filling in your
details repeatedly. We may collect information about your IP address and how you used
our site.
- That data collected by cookies does not usually identify you, but may be combined with
other information to identify you. If we identify you using information from cookies, we
may use that information to track how you use our website and send you information more
specific to your needs, or to invite you to purchase one of our services.
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USE OF DATA
- We sell your personal data to our clients who may use your personal data to contact you
about products or services they deliver or sell. It allows us to align the products and
services of our clients as closely as possible to your needs and situation. Our clients
may then contact you to offer or market their services to you.
- e process data by selling it and transferring it to our clients to enable our clients to
deliver to you, products, services and information that you have expressed interest in,
or that are compatible with the reason you provided your personal data. We may do this
because you gave your consent. Once we have delivered your personal data to our client,
that client becomes the controller of your personal data and they will treat your
personal data in accordance with their privacy policy. Once your personal data has been
delivered to our client we are no longer responsible for your personal data. Our clients
have their own privacy policies in relation to the data they hold or process. You can
ask them about their privacy policy when they contact you.
- We may also process your usage data (your IP address, geographical location, manner in
which you used our site etc) for our legitimate business purpose of monitoring and
improving our website.
- We will also disclose your personal data where legally compelled to do so.
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STORAGE AND DISCLOSURE OF DATA
- The personal data you provide to us is stored at CRM which has strict security to ensure
data protection, integrity and confidentiality. While we do our best to ensure the
security of your data, no storage is 100% secure and we cannot guarantee the safety of
your data. From CRM, your data is then transferred to our client. Such a transfer may
include transfer of information across borders depending on where the client is. This
means your data may be transferred to, and stored, on computers outside of your state or
country and the data protection laws may be different from those where you live. By
agreeing to this policy, you agree to such a transfer.
- Data is deleted from our storage at CRM every 364 days. This means, if we have collected
your personal data, we will delete it within 365 days.
- CRM have their own privacy policy in relation to how they manage and store your personal
information.
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COLLECTION OF DATA OF MINORS
- We do not intend to collect the personal data of persons under the age of 13. If you are
the guardian of a minor and suspect they may have provided us with their personal
information, please contact us and request to have the minor’s personal information
destroyed (use the contact information in the schedule below).
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DATA RIGHTS
- At your request, we will tell you what personal data about you is being processed, on
what basis, and by whom. If you decide your data should not be processed for one or more
purposes, you may withdraw your consent from using your data in that way. Please note
that we will action your request as soon as practically possible however such a request
will not take effect immediately and you may still be contacted by our client in the
meantime.
- You may amend inaccurate, incomplete or outdated personal data at any time by applying
directly to us using the contact information in the schedule below.
- You may also request that all personal data we have collected about you be deleted from
our records and erased from information stored by any third party organisations
processing data on our behalf. We have implemented an ongoing destruction process so
that any collected data is securely destroyed within 31 days of collection.
- If data we have collected about you is processed using automated means, you have the
right to receive that data in a structured, machine-readable format and to transmit it
to another data controller without hindrance.
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CONTACT US
- Please let us know if you have any requests, feedback or concerns regarding the way we
manage your personal data. Use the contact details listed in the below schedule. We will
respond to you within 30 days and take action, within reason, as quickly as possible.
- If you are not happy with how we manage your concerns, you can contact your local data
protection supervisory office, which in the UK is the Information Office Commissioner.
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Changes to this Privacy Notice
It is important to us that our privacy notice is regularly reviewed and we will do so to keep it
relevant and up to date with changing laws. We will notify you of any changes by posting the new
policy on this page.
Where used in this privacy policy, we and us means: Stillbloom LTD
This website is owned and operated by Stillbloom LTD
Our principal place of business is:
Stillbloom LTD
Framlingham Technology Centre
Station Road Woodbridge,
Suffolk IP13 9EZ
If you have questions about your information we hold or how we use it, please contact us via
email at:
[email protected]
We work with Contact State
We work with Contact State in order that we can pass on your request
to our partners correctly. Contact State provides lead validation services
to us and our insurance provider partners and their intermediaries.
Contact State receives "de-identified" data from us about your request -
this means devoid of any contact information, or anything else identifying
you as an individual person in the "real world". It uses that de-identified
data to help confirm your request has been submitted by a "real" human and
not a robot, or automated request generator. This is done by examining a
"browser fingerprint" associated with your request – it contains, for example,
details of the model of device you are using, your Internet browser,
and the region from which you submit your request. Contact State retains
that de-identified data for its own purposes as "data controller" and uses it
to help verify requests submitted through other websites.
If you do not want us to pass your de-identified data to Contact State,
please contact us by emailing [email protected].
We also use Contact State to check some basic details in your submission
(for example, the postcode), and to route your submission in its "raw" plain-text
form to the insurance providers and intermediaries we work with. In doing this,
Contact State acts as our "data processor" - it does not use the raw data
for its own purposes.
You can find out more about how Contact State uses this data here –
https://www.contactstate.com/legal/prospect-notice/084c86ae-c6b2-490b-8b9f-dcd1a0405dbc