Services Privacy Statement

11 August 2021

1 Scope
This Statement only applies to the Personal Data of Athena Spectrum customers whose data are, processed by Cleverclogs Multimedia or hosted by Cleverclogs Multimedia within the Athena Spectrum cloud or environment or any other public cloud as agreed with the Customer.
Any references to ‘we’, ‘us’ or ‘our’ in this Statement refer to Cleverclogs Multimedia.
Any references to ‘you’ or ‘your’ refers to the end user whose data Cleverclogs Multimedia processes on behalf of the Customer.

2 Definitions

2.1 Statement
Statement means Services Privacy Statement. In this Statement, we explain how we collect, store, use, maintain and retain Customer Data.

2.2 Customer Data
Customer Data means Personal Data which our Customers and/or their end-users input or upload into the customer portals or services provided to them by Cleverclogs Multimedia. This does not include Customer Information collected directly by Cleverclogs Multimedia for business activities such as sales and marketing.
Cleverclogs Multimedia is the Data Processor in relation to Customer Data.

2.3 Services Data
Services Data means the data that resides on Cleverclogs Multimedia, customer or third party systems to which Cleverclogs Multimedia is provided access to perform services, including cloud environments, test environment, development and production environments, in order to perform any of the services and business related functions including but not limited to:

  • Hosting
  • Technical Services
  • Consultancy and Training
  • Professional services
  • Support services
  • IT and Administrative operations
  • Managed Services
  • Product / Software Updates and Promotions

Services Data may include Customer Data. Cleverclogs Multimedia is the Data Processor in relation to Services Data and treats it in accordance with the terms of the contractual agreements with the Customer.

2.4 Customer Information
Customer Information means Personal Data we collect from visitors to our websites, data we collect about our customers or prospective customers, vendors, service providers, professional advisers, consultants and other third parties in the course of doing business.
Cleverclogs Multimedia is the Data Controller in relation to Customer Information. Please refer to our separate Privacy Statements in regard to Customer Information.

2.5 Personal Data
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
Where we process Customer Data or Services Data, that includes Personal Data, this is hereon on referred to as Customer Personal Data.

2.6 Data Processor
Under the EU’s General Data Protection Regulation (GDPR) a processor is defined as a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

As a Data Processor, we will process all Customer Personal Data strictly on behalf of our Customers in accordance with our contractual agreements with them and/or as required or permitted by law.

2.7 Data Controller
Under the EU’s General Data Protection Regulation (GDPR) a controller is defined as a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;

3 Data Processing Activities
How do we use Customer Personal Data?
Customer Personal Data may be processed by us as a result of Customer’s use of the services when our Customers or their end-users input or upload information into the relevant Athena Spectrum service. For example, Customers who use any of our products or services may upload Customer Personal Data about themselves, their employees and / or learners to Athena MIS for the purpose of providing training services and as such we may support with ILR related processing.

Why does Cleverclogs Multimedia need to collect and store Customer Personal Data?

Cleverclogs Multimedia needs to collect and / or store Customer Personal Data for the following purposes:

To provide and deliver the services;

To prevent or to address any service or technical problems;

To respond to a customer’s request or instructions, or to provide customer service or support;

For any other purpose as provided for in the agreement between us and the customer, or as otherwise authorised by the customer;

In accordance with or as may be required by law.

Will Cleverclogs Multimedia share Customer Personal Data with third parties?

We do not sell Customer Personal Data to any third-parties.

We may share Customer Personal Data in the following instances:

Within Cleverclogs Multimedia in accordance with this Statement;

Trusted agents, consultants and service providers to perform our business related functions.

How will Cleverclogs Multimedia process Customer Personal Data?

3.1 Legal Basis
The lawful basis for processing Customer Personal Data is it is necessary to support the legitimate interests of our Customers.
How will Cleverclogs Multimedia retain Customer Personal Data?
Cleverclogs Multimedia will retain Customer Personal Data in accordance with the requirements of contractual agreement with the Customer. In addition, Cleverclogs Multimedia is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of Customer Personal Data should be kept may also be governed by specific business-sector requirements and agreed practices.

Cleverclogs Multimedia will not keep Customer Personal Data longer than required for any of the purposes specified above.
Under what circumstances will Cleverclogs Multimedia contact you?
We may contact you in order to perform the services or in relation to the products and services provided to you by the Customer. The means any such communication will be compliant with the terms of the contractual agreement with the Customer.

3.2 Security
We deploy and maintain appropriate security measures across all our services in order to protect Customer Personal Data from unauthorised disclosure, loss or destruction. However, we expect our Customers and their end users to access the services within a secure environment and notify us of any misuse or loss of integrity. If you believe that your password has been misused or compromised, please change it immediately and notify us as soon as possible.

3.3 Data Transfer outside EEA
Cleverclogs Multimedia has a UK presence only with no operations in countries outside EEA.
Cleverclogs Multimedia facilities have a data protection compliance framework and secure architecture in place to keep the data secure.

3.4 Data Subject Rights
As an end user, if you have any questions or concerns about the processing of Customer Personal Data, please contact our Data Protection Lead directly.
Please direct any of the following requests, in relation to Customer Personal Data, to the Customer:
Data Subject Access Request
Requests to rectify/amend/delete your data
Requests to restrict processing of your data
Objections to the processing of your data
Following your request, if the Customer contacts us in order to retrieve, amend or delete your data, we will do so in accordance with our contractual agreement with them and the applicable data protection legislation.

3.5 Contact details
If you have any questions or concerns regarding this Statement or if you need to access, update, change or remove Personal Data (Customer Information) for which Cleverclogs Multimedia is the Data Controller, please contact the Data Protection Lead:

Data Protection Lead

We reserve the right to change, modify, add or remove parts of this Statement. However, we would notify the Customer (Data Controller) in such instances and also alert the end users of these changes by indicating the date on which the Statement was posted. When you access and use our products and services, you are accepting the current version of this Statement posted at that time. We recommend that you visit this Statement occasionally in order to see the latest version.