Privacy notice
Clarity-OO Ltd — Privacy notice — version 2026-10-15
This notice explains what personal information Clarity-OO Ltd ("Clarity", "we", "us") holds about people who use a Clarity account or visit our websites, clarity-oo.com and www.cdm2015.co.uk (CDM Clarity). It explains why we hold it, who else handles it, and your rights.
Who we are. Clarity-OO Ltd, registered in England and Wales, company number 17484245. Registered office: 2b Henry Street, Blackburn, BB1 4JJ, United Kingdom. Contact: support@clarity-oo.com. Clarity-OO Ltd is registered with the Information Commissioner's Office (ICO), registration number ZC267390.
1. Our two roles
- Clarity accounts. We decide what is collected and why, so we are the controller. Much of this notice is about that information.
- Our websites, clarity-oo.com and www.cdm2015.co.uk. We are also the controller of what they collect: enquiries, newsletter sign-ups and visit counts.
- What our customers put into a product (for example, the people on a resource plan or a programme). The customer decides what goes in and why, and we process it for them as their processor under our terms (Schedule 1). If your details are in a customer's plan, please ask that customer first. We will help them answer you.
2. Where we get information
- From you, when you sign up, sign in, contact us, fill in a form on our websites or ask for our newsletter.
- From your organisation's account administrator, when they add you: your name, email address and role, and which products you may use.
- From Stripe, about whether payments have been made.
- From the free programme viewer (planner.clarity-oo.com/viewer), only if you choose to send us a file that would not open.
- From a Clarity product, when somebody without a Clarity account raises a support ticket there (for example a site manager in Clarity PC): their name, email address, company and site.
- Automatically, when you use our websites or products: your IP address, your browser, and the pages you requested.
To have an account we need your name, email address, password and two-step sign-in. Without them we cannot provide one. For a paid subscription, we also need billing details.
3. What we hold, why, and on what basis
| Information | Why | Legal basis |
|---|---|---|
| Name and email address | To run your account and sign you in | Contract, where you hold the account yourself (for example, as a sole trader). Legitimate interests where your organisation added you: providing the service it has contracted for |
| Password (as a one-way hash), two-step secret, hashed recovery codes, and any passkeys you add (only the public half of each key, the name you give it, and when it was added and last used) | To make sure it is you signing in | As above, plus legitimate interests in keeping accounts secure |
| Your organisation, the people in its account and their roles | To manage licences and who can do what | Legitimate interests of your organisation and of us in running the account |
| Subscriptions, invoices, payment status and Stripe customer reference. We never see or store card details: Stripe holds them | Billing | Contract with the paying organisation, and legal obligation to keep accounting records |
| Emails about your account: set-up, password resets, changes to terms and prices | To run the service | Legitimate interests (and contract, where applicable) |
| A record of who did what in an account (for example, licence changes) | Security, and resolving disputes | Legitimate interests |
| Failed sign-ins (email address and IP address) | Stopping password guessing | Legitimate interests |
| Refused automated sign-ups (IP address and the email's domain only) | Keeping out spam sign-ups | Legitimate interests |
| Web server logs (IP address, browser, pages requested) | Security and fixing faults | Legitimate interests |
| Support tickets: what you write, any files you attach, your name and email address, and the product, company and site it is about | Answering you, and fixing what is wrong | Legitimate interests |
| The free programme viewer (planner.clarity-oo.com/viewer): it opens programme files in your browser and keeps nothing. If a file will not open, we note that it happened and why (the file's type, size and the reason), with nothing from inside it and not the file's name. Only if you press "Send this file to Clarity" do we keep the file itself, privately, to find and fix the fault | Making the viewer work with more files | The failure note: legitimate interests. A file you send: consent, which you give by pressing the button |
| Messages you send to support@clarity-oo.com or info@cdm2015.co.uk | Answering you | Legitimate interests |
| Website enquiries: what you enter in a contact or question form on either website. That is your name, email address and message, and on some forms your company name, a subject, and any file you choose to attach. We keep it with a contact record of your name, email address and company. Each message also carries a scrambled code made from your IP address, which changes every day; it is used only to stop floods of automated messages | To answer you, and to follow up your enquiry | Legitimate interests |
| Newsletter (www.cdm2015.co.uk): your email address and name, and a record of when and where you asked. We first email you a link, and add you only when you click it | To send you the newsletter | Consent. You can withdraw it at any time with the unsubscribe link in every newsletter, or by emailing us |
| Website visits (both websites): the pages viewed, the site you came from, any campaign tags in the link, the type of device, the country, and the time spent on the page. The country is worked out on our own server and stored only as a two-letter code. Visitors are told apart only within a single day, by a scrambled code made from the IP address and browser that changes every day. The IP address itself is not stored | To see which pages are used, and to improve the websites | Legitimate interests |
| Google Analytics (both websites), only if you click Accept on the cookie banner: the pages you view, how you arrived, what you do on a page (such as scrolling, clicking a link to another website, downloading a file, searching the site, playing a video or starting a form, but never what you type into a form), your type of device and browser, your approximate location, and a random identifier kept in a cookie so repeat visits can be recognised | To understand how the websites are used, and to improve them | Consent. You can withdraw it at any time with "Cookie settings" at the foot of every page |
Where we rely on legitimate interests, we have weighed them against your interests and rights. You can ask us about that balance.
We do not sell personal information, use it for advertising, or make decisions about you by automated means alone. Filling in an enquiry form does not sign you up to the newsletter.
4. Cookies and similar technologies
- Clarity accounts and products use only the cookies needed to keep you signed in. They are strictly necessary, so we do not ask for consent.
- Our websites set analytics cookies only if you agree. When you first visit, a banner asks whether you accept Google Analytics cookies. Reject is as easy as Accept. If you reject, or do not choose, Google's code is not loaded at all.
- If you accept, Google Analytics sets cookies (named _ga) that last up to 2 years. They let us count visits and recognise a returning visitor. If you move between our two websites, Google may add a short code to the link, so the visit counts once. Google uses your IP address to estimate your location, and says it does not store it.
- To change your mind, use "Cookie settings" at the foot of every page. Withdrawing consent stops Google Analytics and deletes its cookies. We remember your choice in one small cookie, cwm_consent, for six months, so we do not ask on every page. It is strictly necessary, so it needs no consent of its own.
- Our own visit counting uses no cookies, stores nothing in your browser, and runs either way.
There are no advertising cookies, and nothing tracks you across other websites.
Some products save working copies of your files in your own browser's storage, on your own device. We cannot read them.
5. Who else handles it
| Organisation | What it does | Its role | Where |
|---|---|---|---|
| Heart Internet Ltd | Hosts our servers, including both websites | Processor | United Kingdom (Leeds) |
| Amazon Web Services (Simple Email Service) | Sends Clarity's emails, including website form notifications and newsletter confirmations | Processor | United Kingdom (London region, our choice). AWS's UK GDPR Addendum, including the UK international data transfer addendum, applies automatically to any transfer |
| Microsoft (Microsoft 365) | Our support and enquiries mailboxes, and storage (SharePoint) for a daily copy of our databases | Processor | United Kingdom (Microsoft's committed data location for our account) |
| Stripe | Takes payments and emails receipts and billing notices | Processor for our payments. Independent controller for its own purposes, such as fraud prevention and its legal obligations. See stripe.com/privacy | UK, EU and US |
| Google (Google Analytics), on both websites, only if you accept its cookies | Counts and analyses visits | Processor, under Google's data processing terms. We have switched off Google's options to use the data for its own purposes | Worldwide, including the United States (see section 6) |
Each processor works under a contract that requires it to protect the information. We tell business customers before we add or change a processor, as our terms set out.
Copies on our own equipment. A daily copy of our databases is kept on a company computer in the UK, on a drive with its own hardware encryption and password, and synced to our Microsoft 365 storage.
6. Transfers outside the UK
Our servers are in the UK. Some suppliers may process information, or reach it for support, from outside the UK. Stripe and Google, in particular, process in the United States. Where that happens, the transfer is protected by UK adequacy regulations (including the UK Extension to the EU–US Data Privacy Framework) or by the UK International Data Transfer Addendum or Agreement. Email us for details of the safeguards.
7. How long we keep it
- Account information: while your account is open. Deleted within 90 days after it closes, except billing records.
- Billing records: 6 years, as the law requires.
- Failed sign-ins: no more than a day.
- Web server logs: 10 days.
- Support and enquiry emails: 2 years after the conversation ends.
- Support tickets (with any files attached): 2 years after the ticket is closed.
- A file you send from the free programme viewer: deleted within 3 days, or sooner once the fault is fixed. It is never copied into our backups.
- Website enquiries (the message, any attached file, and the contact record): 2 years after the conversation ends.
- Newsletter: until you unsubscribe. After that we keep only your email address and the date you unsubscribed, so that we never email you again by mistake.
- Website visit records: the detail is deleted after 90 days. After that we keep only totals that cannot identify anyone.
- Google Analytics: Google deletes the detail after 14 months, even if you keep visiting. Its cookies last up to 2 years on your device, unless you clear them or withdraw consent.
- Backups: on our servers, deleted within 8 weeks (14 daily and 8 weekly copies). The daily copy on our own computer is also deleted within 8 weeks, but its Microsoft 365 copy stays recoverable for up to 93 days after that. So every copy is gone within about 5 months.
- What customers put into products: as our terms say. Read-only for 90 days after a subscription ends, or 30 days after a free trial ends without one, then deleted.
8. Keeping it safe
- Everything travels encrypted (HTTPS).
- Passwords and recovery codes are stored only as one-way hashes.
- Passkeys: the key itself stays on your device or in your password manager. We hold only its public half, which cannot sign anybody in. The fingerprint, face or PIN that unlocks it never leaves your device, and we never see it. A passkey only works on our real site, so a fake look-alike site cannot use it.
- Two-step sign-in is required for everyone.
- Our servers are in the UK, kept up to date, and backed up nightly to a second UK server.
- Files attached to website forms are kept privately and can be opened only by us.
- Our terms (Schedule 1, Annex A) give more detail.
9. Your rights
Under UK data protection law you can ask us to:
- access: give you a copy of your information;
- rectification: correct it;
- erasure: delete it;
- restriction: limit how we use it;
- objection: stop using it, where we rely on legitimate interests. We will stop unless we have compelling grounds to continue;
- portability: give it to you, or to someone else, in a common format. This applies to information you gave us, where we rely on contract or consent.
Where we rely on consent (the newsletter, and Google Analytics cookies), you can withdraw it at any time. That does not affect anything we did before you withdrew it.
Not every right applies in every case. For example, we must keep billing records even if you ask us to delete them, and we will explain if a right does not apply.
To ask, email support@clarity-oo.com. We answer within one month. This can be extended by up to two more months for complex requests, and we will tell you if it is. We do not normally charge.
10. Complaints
If you are unhappy with how we have handled your information, please tell us at support@clarity-oo.com. We will:
- acknowledge your complaint within 30 days;
- look into it properly;
- tell you the outcome without undue delay.
You can also complain to the Information Commissioner's Office: ico.org.uk, 0303 123 1113. The ICO may ask whether you have complained to us first.
11. Changes
If we change this notice in a way that matters, we will tell account holders by email before the change takes effect, and show the new version on both websites. The version date is at the top.