Blueclearsky Ltd. (Hereinafter “US”/”We”) a company incorporated under the laws of Cyprus with an address at Griva Digeni, 3 Patsalos House, 5th Floor, Flat/Office 501 is committed to protecting the privacy of its users (“you”/”your”) of the website blue-clearsky.com (the “Site”).

Blueclearsky Ltd understands that your privacy is important to you and is committed to safeguarding the confidentiality and privacy of personal information entrusted to it.

This Privacy Policy describes how Blueclearsky Ltd handles and protects your personal information in connection with the hosting of this website, and the provision of its diverse business advisory services.

1. Scope of this policy

This policy applies to personal information which is collected and/or used by Blueclearsky Ltd in its capacity as a controller as that term is defined in the EU General Data Protection Regulation (GDPR).

When we provide Services to clients, we sometimes handle personal information as a processor (for example, the hosting of client data on our e-discovery platforms). This means that we process the information solely on the instructions of our clients, who retain control of the information.

Our Site may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or Processing of your Personal Data. Please check these policies before you submit any personal information to such third party websites.

2. Glossary

“Data Controller” means the organization which alone or jointly with others determines the purpose and means of the processing of Personal Data. Clearsky Network Limited is the Data Controller under this Policy.

“Data Processor” means the organization which processes Personal Data on behalf of the Data Controller (not including employees of the Data Controller). Service providers that handle Personal Data on the Data Controller’s behalf will be Data Processors.

“Personal Data” means any information relating to you as 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 online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.

“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Special Categories of Personal Data” means types of data that is subject to more stringent processing conditions than other Personal Data, and in the EU includes Personal Data which reveals racial or ethnic origin, political opinion, religious or philosophical beliefs, trade-union membership, and the processing of genetic data, biometric data in order to uniquely identify a person or data concerning health, sex life and sexual orientation. Data concerning health covers Personal Data relating to the physical or mental health of an individual which reveals information about the individual’s health status. In the EU, Personal Data relating to criminal convictions or offences or related security measures may only be processed when authorized by Member State or EU law.

3. Acceptance

In respect of personal information collected over this and other Blueclearsky Ltd website, your continued use of these websites constitutes your understanding of, and agreement to, the practices described in this Privacy Policy and elsewhere on the websites as well as any subsequent updates.

4. When do we collect personal information?

We collect information about you if:

4.1 you use this website;

4.2 you enquire about, or engage Blueclearsky ltd provides, its Services (either in a personal capacity, or as a representative for your employer or client);

4.3 the use of your personal information is reasonably necessary to provide our Services (in these circumstances, your personal information may be disclosed to us by our client who may, for example, be your employer or service provider, or we may obtain your personal information from a range of public or subscription sources, directly from you, or from your associates or persons known to you);

4.4 you apply for a position with Blueclearsky ltd;

4.5 you attend a Blueclearsky ltd hosted or sponsored event or webinar;

4.6 you contact us with any other enquiry, complaint or notice

5. How we collect personal data

Blueclearsky ltd collects Personal Data about users (either directly or from third parties, such as your employing organization where you are acting on behalf of such organization) when the user:

5.1 visit and use our Site;

5.2 register for, and use our Site;

5.3 provide us with certain information including as part of the registration process;

5.4 contact and communicate with us either through our website or through other channels;

5.5 enter into a contract with us or other participants on the Site; and

5.6 information provided to us through registration/resulting from registration

5.7 credit, identity and anti-fraud information

5.8 our correspondence: if you contact us, we will typically keep a record of that correspondence;

5.9 Survey information: we may also ask you to complete surveys that we use for research purposes. In such circumstances we shall collect the information provided in the completed survey;

5.10website and communication usage

We retain your Personal Data only for as long as is necessary for the processing purpose(s) for which the Personal Data was collected (as set out in this Policy) and for any other permissible, linked purpose(s) in accordance with our internal retention and deletion policy. Records can be held on a variety of media (physical or electronic) and formats.

Retention periods are determined based on the type of record, the nature of the record, business need and activity and the legal or regulatory requirements that apply to those records. Typically, Personal Data which is collected pursuant to our legal obligations (such as AML) are retained for 2 years. Where Personal Data is collected pursuant to a contract or prior to the creation of a contract, these are retained for 2 years after the termination of the contract pursuant to our legitimate interests in establishing or defending any related legal claims.

However, we may retain your Personal Data for a longer period of time where such retention is necessary for compliance with a legal obligation to which we are subject.

6. Data Security

We have put in place commercially reasonably security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other service providers 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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. You are responsible for keeping your password and private key confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password/private key with anyone.

7. Transferring information outside of the EFTA

We only do this where we have a legal basis for doing so. This may also require us to take certain additional steps to ensure that appropriate safeguards are in place if that third country is not deemed by the European Commission to offer an adequate level of protection for your privacy rights, which may include use of contractual safeguards to allow you to be able to enforce your rights and ensure these are preserved.

In certain circumstances, we may need to ask you for your explicit consent to such third country transfers, and will always do so in writing and giving you full information about why we need your consent and your right to withdraw that consent at any time (together with the consequences of withdrawal). Please contact us as per the “Contacting us” section below if you would like to see a copy of these safeguards.

Contacting us

Blueclearsky Ltd., a company incorporated under the laws of Cyprus with an address at Griva Digeni, 3 Patsalos House, 5th Floor, Flat/Office 501 Questions can be sent by email to: [email protected]