Privacy Policy

Churchill Technologies Ltd, trading as Clara World (“Clara World”, “Website” “we”, “us”, “our”), is a provider of a mobile App based personal services platform called Clara World.

Clara World is the world’s first ‘Super App’ offering everything you need in one single platform, including features such as, making and receiving calls and text messages, ordering food or even booking a taxi. The App is available to download on Android and iOS devices.

We take your privacy seriously and are committed to protecting and respecting your personal data. This privacy policy (“Privacy Policy”) sets out the basis on which the personal data collected from you on this Website, or that you provide to us, will be processed by us. Our App privacy policy is available within the App or on the Android or IOS App store.

Please read the following carefully to understand how we will use your personal data on this Website.

1. WHAT PERSONAL DATA DO WE COLLECT AND PROCESS, AND HOW DO WE USE IT?

We may process the following personal data when you visit our Website.

Identity Data could include name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data could include billing address, delivery address, email address and telephone numbers.
Technical 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 this website, your browsing patterns and actions.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Aggregated Data We may 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 may also receive aggregated personal data from third parties with whom we place adverts, such as Facebook, Twitter, Instagram and Pinterest. This data will include statistics about who has interacted with our adverts, but we will not be able to personally identify you. You can manage how this data

How we use your personal data:

Purpose/activity	Type of data	Lawful basis for processing
● To manage our relationship with you including notifying you of changes to the Website or any Services	● To manage our relationship with you including notifying you of changes to the Website or any Services ● Identity ● Contact ● Device ● Marketing and Communications ● Your consent ● Performance of a contract with you ● Necessary for our legitimate interests (to recover debts due to us)	● Your consent ● Performance of a contract with you ● Necessary for our legitimate interests (to recover debts due to us)
● To enable you to participate in a prize draw, competition or complete a survey	● Identity ● Contact ● Profile ● Marketing and Communications	● Your consent ● Performance of a contract with you ● Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) ● Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
● To administer and protect our business and this Website including troubleshooting, data analysis and system testing	● Identity ● Contact ● Device ● Marketing and Communications	● Your consent ● Performance of a contract with you ● Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business
● To respond to any enquiry you make on our website ‘contact us’ function	● Identity ● Contact ● Device ● Technical	● Your consent ● Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and general issues)

2. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

By using the Website, we may need to disclose your personal data to selected third parties in the following limited circumstances:

We share your personal data with our Website partners in order to help with the proper functioning of the Website, to analyse and understand your usage of the Website and the services, so we can make improvements, as well as marketing and advertising providers. If you would like any more information about the third parties we share your data with, please contact at

feedback@ClaraWorldWebsite.co.uk.

Where there is any other legal requirement or obligation for us to disclose your personal data.

3. TRANSFERS OF YOUR PERSONAL DATA

To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK/EEA.

Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/EEA where:

the UK government or, where the EU GDPR applies, the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
a specific exception applies under data protection law.

Transfers with appropriate safeguards

Technology businesses use and often need third parties to help them host their Website application, communicate with customers, provide analytics services or power their emails etc. We partner with third parties who we believe are the best in their field at what they do.

When we do this, sometimes it is necessary for us to share your data with them in order to get these services to work well. Your data is shared only when strictly necessary and according to the safeguards and good practices detailed in this Privacy Policy. Where personal data is transferred to a third party for example in the USA, or other third party outside the UK/EEA, we take steps to ensure standard contractual clauses (SCC’s) are in place, along with any additional safeguards that are required to protect your data.

4. Cookies

Cookies are small text files containing a string of characters that can be placed on your computer or mobile device that uniquely identifies your browser or device. Some of our third-party service providers (see section 2 above) may place third party cookies on your device that are necessary in order to help with the proper functioning of the Website, such as storing and remembering your log-in details and automatically reporting any bugs or other issues with the Website. For information about the cookies that we use on the Website, please read our Cookies Policy available here:

Cookie Policy

5. Our Website

Our Website may contain links to other third-party websites. If you follow a link to a third-party website please note that this Privacy Policy does not apply to that website. We are not responsible or liable for the privacy policies or practices of any third-party websites, so check their policies before you submit any personal data to those websites.

6. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

When you give us personal data, we take steps to ensure that it’s treated securely. Any personal data is encrypted and protected via SSL and secure data storage. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.

We may store your personal data on AWS Cloud and other CRM or support service we use.

To read the detailed specification of how the third parties we work with keep your data safe, please click on each of the relevant links below:

https://aws.amazon.com/compliance/gdpr-center/

Your personal data, such as email addresses is transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal data, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best efforts to ensure its security on our systems.

7. Data Retention

We store your personal data in line with legal, regulatory, financial and good-practice requirements and we will generally keep your personal data for no longer than necessary.

8. Accessing your Personal Data and your rights

As a result of us collecting and processing your personal data, you have the following legal rights:

- to access personal data held about you;
- to request us to make any changes to your personal data if it is inaccurate or incomplete;
- to request your personal data is erased where we do not have a compelling reason to continue to process such data in certain circumstances;
- to receive your personal data provided to us as a data controller in a structured, commonly used and machine-readable format where our processing of the data is carried out by automated means, and it is based on: (i) your consent; (ii) our necessity for performance of a contract to which you are a party to; or (iii) steps taken at your request prior to entering into a contract with us;
- to object to, or restrict, our processing of your personal data in certain circumstances;
- if we ever use your personal data for direct marketing, you can ask us to stop and we will comply with your request;
- if we use your personal data on the basis of having a legitimate interest (as set out in the table above), you can object to our use of it for those purposes, giving an explanation of your particular situation, and we will consider your objection;
- to object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you; and

to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ico.org.uk or any other Supervising Authority in the EEA. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. To exercise any of your rights set out above, including to withdraw your consent where we have stated we are processing your personal data based on your consent, please contact us at privacy@churchill-technologies.com

privacy@churchill-technologies.com

2. 9. CONTACTING US AND CHANGES TO YOUR PERSONAL DATA

If you have any questions, comments and requests about this Privacy Policy or your personal data, please contact us at

privacy@churchill-technologies.com

Please keep us informed of any changes to your personal data at any time by updating your details on the Website.

3. 10. CHANGES TO OUR PRIVACY POLICY

Any changes we may make to this Privacy Policy in the future will be displayed on our Website and, where appropriate, notified to you by email. Please check back regularly to keep informed of updates or changes to this Privacy Policy.

This Privacy Policy was last updated on 19 May 2022.

PRIVACY POLICY