Privacy Policy
Last Updated: 13/04/2023
Previous Version Number – V1.0
New Version Number – V2.0
1. Who we are and what we do
Who we are
We are Client Bridge Management Limited (“Client Bridge”, “us”, “we”, “our”). We are a limited company registered in England and Wales under registration number 13627919 and we have our registered office at 87 Parker House, Buttermarket Street, Warrington, Cheshire, WA1 2NL. We are registered with the UK supervisory authority, Information Commissioner’s Office (“ICO”), in relation to our processing of Personal Data under registration number ZA508176.
What we do
We provide a data management software platform to clients managing day to day tasks related to the care industry. We are committed to protecting the privacy and security of the Personal Data we process about you.
Controller
Unless we notify you otherwise, we are the controller of the Personal Data we process about you. This means that we decide what Personal Data to collect and how to process it.
Processor
If Client Bridge processes data about you because it has been provided to us or added to our software platform by or on behalf of a Client Bridge customer, we are acting as a data processor and this privacy notice does not apply. You should review the privacy notice of the Client Bridge customer that collected your personal data and added it to our software platform.
2. Purpose of this privacy notice
The purpose of this privacy notice is to explain what Personal Data we collect about you and how we process it. This privacy notice also explains your rights, so please read it carefully. If you have any questions, you can contact us using the information provided below under the ‘How to contact us’ section.
3. Who this privacy notice applies to
This privacy notice applies to you if:
- You visit our website(s) www.clientbridge.co.uk and www.sue.solutions
- You license our software platform from us and create an account
- You enquire about our products and/or services
- You use our Software platform.
- You sign up to receive newsletters and/or other promotional communications from us
- You supply Client Bridge with goods and/or services.
4. What Personal Data is
‘Personal Data’ means any information from which someone can be identified either directly or indirectly. For example, you can be identified by 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.
5. Personal Data we collect
The type of Personal Data we collect about you will depend on our relationship with you. For the type of Personal Data we collect see the table below in the section entitled ‘Purposes, lawful bases and retention periods’.
6. How we collect your Personal Data
We collect most of the Personal Data directly from you in person, by telephone, text or email and/or via our website.
However, we may also collect your Personal Data from third parties such as:
- reputable companies who provide lead generation contact lists
- others to whom you have provided consent
- publicly available sources such as social media platforms
We also collect information from your devices (including mobile devices) and applications you or your users use to access and use any of our websites, applications or services (for example, we may collect the device identification number and type, location information and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history and your web log information). We may do this using cookies, or similar technologies. Please see our Cookie Notice for more information)
7. Purposes and lawful bases
Applicable Data Protection legislation requires us to identify appropriate lawful bases to process personal data. The lawful basis we rely on as a data controller are detailed in the table below, along with information on the categories of personal data and the purposes for the processing.
| Categories of individuals | Categories of Personal Data | Purpose of Processing | Lawful Basis |
|---|---|---|---|
| Customers | Company details, name, address, email address. | To administer the Software Services Subscription Agreement and facilitate account creation. | Contract |
| Customers | Company details, name, address, email address. | To provide service updates, or inform you of new features, changes to our terms & conditions or policies. | Contract/Legitimate Interest |
| Users | Authentication credentials, password hints | To enable you to access our software platform | Contract |
| Prospective customers | Name, email address | To send you newsletters and other promotional material. | Consent |
| Prospective customers | Name, Address, phone number, email address | To respond to you when you enquire about or services. | Legitimate Interest |
| Prospective customers | Name and email address | We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns. | Legitimate Interest |
Where Personal Data is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information.
8. How long we keep your 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, legal and statutory obligations, and to deal with complaints and claims. When we do this we use the Legal Obligation lawful basis to further process your data.
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. Sharing your Personal Data
We may share your Personal Data with our carefully selected third parties, including:
- Our service providers (including their sub-contractors) or third parties which process information on our behalf (e.g. internet service and hosting providers, payment processing providers and those organisations we engage to help us send communications to you) so that they may help us to provide you with the applications, products, services and information you have requested or which we believe is of interest to you. We have contracts in place with them which means that they cannot do anything with your personal data unless we have instructed them to. They will hold it securely and only retain it for the period we instruct them to;
- law enforcement agencies so that they may detect or prevent crime or prosecute offenders;
- any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);
- any third party in order to meet our legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts;
- another organisation if we sell or buy (or negotiate to sell or buy) any business or assets;
- another organisation to whom we may transfer our agreement with you; and;
- Government departments where reporting is mandatory under applicable law;
10. Marketing Communications
From time to time, we may use your information to contact you with details about our services which we feel may be of interest to you. We may also share your information with our group companies and carefully selected third parties so that they (or we) may contact you with information about their products or services which we feel may be of interest to you. You have the right at any time to stop us from contacting you for marketing purposes. If you wish to exercise these rights, you can do so by following the ‘unsubscribe’ link on any emails received.
11. International Transfers
Your Personal Data may be processed outside of the UK. This is because the organisations we use to provide our service to you are based outside the UK.
We have taken appropriate steps to ensure that the Personal Data processed outside the UK has an essentially equivalent level of protection to that guaranteed in 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 an International Data Transfer Agreement (“IDTA”) with the receiving organisation and adopt supplementary measures, where necessary. (A copy of the IDTA can be found here international-data-transfer-agreement.pdf (ico.org.uk)).
12. Your rights and how to complain
You have certain rights in relation to the processing of your Personal Data, including to:
- Right to be informed
You have the right to know what personal data we collect about you, how we use it, for what purpose and in accordance with which lawful basis, who we share it with and how long we keep it. We use our privacy notice to explain this.
- Right of access (commonly known as a “Subject Access Request”)
You have the right to receive a copy of the Personal Data we hold about you.
- Right to rectification
You have the right to have any incomplete or inaccurate information we hold about you corrected.
- Right to erasure (commonly known as the right to be forgotten)
You have the right to ask us to delete your Personal Data.
- Right to object to processing
You have the right to object to us processing your Personal Data. If you object to us using your Personal Data for marketing purposes, we will stop sending you marketing material.
- Right to restrict processing
You have the right to restrict our use of your Personal Data.
- Right to portability
You have the right to ask us to transfer your Personal Data to another party.
- 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
If you have provided your consent for us to process your Personal Data for a specific purpose, you have the right to withdraw your consent at any time. If you do withdraw your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we are permitted by law to do so.
- Right to lodge a complaint
You have the right to lodge a complaint with the relevant supervisory authority, if 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 by telephone on 0303 123 1113
How to exercise your rights
You will not usually need to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
If you wish to exercise your rights, you may contact us using the details set out below within the section called ‘How to contact us and our Data Protection Officer’. We may need to request specific information from you to confirm your identity before we can process your request. Once in receipt of this, we will process your request without undue delay and within one month. In some cases, such as with complex requests, it may take us longer than this and, if so, we will keep you updated.
13. Children’s Privacy
We do not offer our products and services to children and we do not knowingly collect Personal Data of children without parental consent, unless permitted by law. If you are a child, you must have your parent’s permission to use our services. If you learn that a child has provided us with their Personal Data without parental consent, you may contact us, as described below, and if appropriate, we will securely and permanently delete it, in accordance with applicable law.
14. How to contact us and our Data Protection Officer
If you wish to contact us in relation to this privacy notice or if you wish to exercise any of your rights outlined above, please contact us as follows:
Client Bridge Group Limited
1 Peel House
30 The Downs
Altincham
Cheshire
WA14 2PX
Email: dataprotection@sue.solutions
Tel: 0333 44 333 44
We have also appointed a Data protection Officer (“DPO”). Our DPO is Evalian Limited and can be contacted as follows:
West Lodge
Leylands Business Park
Colden Common
Hampshire
SO21 1TH
Please mark your communications FAO the ‘Data Protection Officer’.
15. Changes to this privacy notice
We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify of the changes where required by applicable law to do so.
Last modified 31/07/2023
Please contact us for previous versions of this notice.
Contact Us
Clientbridge Group Ltd
1 Peel House
30 The Downs
Altrincham
Chesire
WA14 2PX
Tel. 0333 44 333 44
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