IDCLEAR WEBSITE PRIVACY NOTICE


Last updated: 30.06.2021


idclear is the trading name of Dolya Solutions Limited (“we”, “us” and “our”), a limited company registered in Gibraltar with company incorporation number 120437 and a registered office at 6.20 World Trade Center, 6 Bayside Road, Gibraltar, GX11 1AA. We’ve drafted this Privacy Notice in order to provide you with information and understanding of how we treat your Personal Data which we gather through your use of our website www.idclear.com (“Site”). Personal Data means any information relating to you as an identified or identifiable natural person (known also as a “Data Subject”). 

This Privacy Notice sets out what Personal Data we collect and how we utilise/process it in accordance with data laws, including the General Data Protection Regulations (“GDPR”), the Gibraltar implementation of the GDPR and the Data Protection Act 2004. 

We may make changes to this Privacy Notice but a current version will always be available on our Site. 


  1. WHAT DATA WE COLLECT

We may collect the following data when you browse or otherwise use our Site or when communicating with us over email:


  1. HOW WE COLLECT AND STORE YOUR PERSONAL DATA

We only process Personal Data that you provide to us through filling out our contact form, communicating with us over email or when asking to be informed of updates on our business. We always store Personal Data securely on our cloud based document management system. 

Our Data Protection Office (“DPO”) oversees the storage and maintenance of your Personal Data. We have physical, technical and administrative security measures in place, which will ensure the confidentiality of the information contained including, but not limited to, the encryption of electronic communications. These measures will be reviewed over time and upgraded in line with technological developments and legal requirements. 


  1. HOW AND WHY WE PROCESS YOUR PERSONAL DATA

We will only collect and process your Personal Data through our Site where we are legally allowed to do so and namely (but not exclusively) in situations where you give us consent or where the processing of your personal data is necessary for us to develop our business. The table below shows the purpose for which we will process your Personal Data and our lawful basis for doing so. 

Purpose

Type of data

Lawful basis for processing

To keep you informed of developments with our business.

Your name and contact information, such as email. 

Your consent and our legitimate interest to keep you informed of developments you have shown interest in. 

We will always stop updating you if you tell us to do so.

To communicate with you.

Your name, contact information, such as email, and any other data you may choose to share with us over correspondence. 

Your consent and our legitimate interest to interact with actual and potential customers and manage our business. 

Change of purpose

We will only ever process your Personal Data for a purpose which is either listed in the table above or compatible with those already listed. Should we have a legal basis to process your Personal Data for any other reason, we will always inform you directly of the processing and explain why we are allowed to do so. 


  1. KEEPING YOUR PERSONAL DATA CURRENT

To keep the Personal Data we hold about you accurate and current, please keep us informed of any changes to your information. From time to time we may also ask you to review and update your Personal Data. 


  1. SPECIAL CATEGORY PERSONAL DATA

We do not gather or process any sensitive or special category data through our Site. 


  1. WHO MAY RECEIVE YOUR PERSONAL DATA 

Sometimes, we may share some aspects of your Personal Data with the following:

Where possible, we do not allow our third-party service providers, agents, advisors, business partners or contractors to use your Personal Data for their own purposes and only permit them to process your Personal Data in accordance with our instructions. Where any third-parties to whom we provide your Personal Data act themselves as data controllers, they are responsible for the treatment of your Personal Data. 

Should we ever choose to sell, transfer or merge parts (or the entirety) of the idclear business to or with another company, the new entity may also use your Personal Data in accordance with this Privacy Notice. 


  1. TRANSFERS OUTSIDE OF THE EEA

Should we need to transfer your Personal Data outside of the UK and the European Economic Area (EEA), we will comply with at least one of the following requirements:


  1. HOW LONG WE KEEP YOUR PERSONAL DATA

We will only keep your Personal Data for as long as it is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, reporting or regulatory requirements. For more information please contact our DPO using the email at the end of this Notice.

We may retain anonymised and/or aggregate data indefinitely as long as it is no longer considered Personal Data. 


  1. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

You have the right to:

If you have any questions or wish to exercise any of the rights specified above, please contact the idclear DPO on privacy@idclear.com

Fees and confirming your identity

You will not have to pay a fee to exercise any of your rights in relation to your Personal Data, but we may charge a reasonable fee or refuse to comply with your request if it is clearly unfounded, repetitive or excessive. 

We will ask you for information and documents to confirm your identity prior to you exercising your rights in relation to your personal data. 


  1. CONTACT, QUESTIONS AND COMPLAINTS

We are committed to robust standards of privacy protection, but if you become concerned about our management of your Personal Data, please contact the idclear DPO at privacy@idclear.com.

You also have the right to make a complaint at any time to the Information Commissioner under the Data Protection Act – currently the Gibraltar Regulatory Authority (“GRA”). However, we would appreciate an opportunity to resolve your concerns in the first instance.

The contact details for the GRA are:

Gibraltar Information Commissioner

Gibraltar Regulatory Authority

2nd Floor, Eurotowers 4

1 Europort Road

Gibraltar

Email: info@gra.gi

Phone: (+350) 200 74636

Fax: (+350) 200 72166