Privacy Policy
Effective Date: February 2026
1. Introduction
1.1 This Privacy Policy describes how Clarity London Ltd ("we", "us", or "our") collects, uses, and shares your personal information when you use our website and software-as-a-service platform (collectively, the "Service").
1.2 We are committed to protecting your privacy and handling your personal data in accordance with applicable data protection laws. By using our Service, you agree to the collection and use of information in accordance with this Privacy Policy.
2. Information We Collect
2.1 Information You Provide Directly: We collect personal information that you voluntarily provide to us when you:
(a) register for an account;
(b) use our Service;
(c) contact our customer support;
(d) subscribe to our newsletters or marketing communications; and
(e) participate in surveys or promotions.
2.2 The types of personal information we may collect directly from you include:
(a) name and contact information (such as email address, phone number, and mailing address);
(b) account credentials (such as username and password);
(c) payment information (such as credit card details and billing address);
(d) profile information (such as job title, company name, and preferences); and
(e) any other information you choose to provide.
2.3 Information Collected Automatically: When you access or use our Service, we automatically collect certain information, including:
(a) usage data (such as pages viewed, features used, time spent on the Service, and clickstream data);
(b) device information (such as device type, operating system, browser type, and unique device identifiers);
(c) IP address and approximate geographic location;
(d) cookies and similar tracking technologies (such as web beacons and pixels); and
(e) log data (such as access times, error logs, and referring URLs).
3. How We Use Your Information
3.1 We use the personal information we collect for the following purposes:
(a) to provide, operate, and maintain our Service;
(b) to process your transactions and manage your account;
(c) to communicate with you, including responding to your inquiries and providing customer support;
(d) to send you technical notices, updates, security alerts, and administrative messages;
(e) to personalize your experience and deliver content and features that match your interests;
(f) to improve and optimize our Service, including conducting analytics and research;
(g) to send you marketing communications, promotional materials, and offers (with your consent where required);
(h) to detect, prevent, and address technical issues, fraud, and security threats;
(i) to comply with legal obligations and enforce our terms and policies; and
(j) for any other purpose with your consent or as permitted by law.
4. How We Share Your Information
4.1 We may share your personal information in the following circumstances:
(a) Service Providers: We may share your information with third-party service providers who perform services on our behalf, such as payment processing, data hosting, email delivery, customer support, and analytics. These service providers are contractually obligated to use your information only as necessary to provide services to us.
(b) Business Partners: We may share your information with business partners who offer complementary services or with whom we co-market products or services, subject to your consent where required.
(c) Legal Compliance: We may disclose your information if required to do so by law or in response to valid requests by public authorities, such as to comply with a subpoena, court order, or legal process.
(d) Business Transfers: In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your information may be transferred to the successor entity or third party.
(e) Protection of Rights: We may disclose your information when we believe it is necessary to protect our rights, property, or safety, or the rights, property, or safety of our users or others.
(f) Aggregated or Anonymized Data: We may share aggregated or anonymized information that cannot reasonably be used to identify you.
4.2 We do not sell your personal information to third parties.
5. Your Data Protection Rights
5.1 Subject to applicable law, you may have the following rights regarding your personal information:
(a) Right of Access: You have the right to request access to the personal information we hold about you.
(b) Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal information.
(c) Right to Erasure: You have the right to request that we delete your personal information, subject to certain exceptions.
(d) Right to Restrict Processing: You have the right to request that we restrict the processing of your personal information in certain circumstances.
(e) Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit it to another controller.
(f) Right to Object: You have the right to object to our processing of your personal information for certain purposes, including direct marketing.
(g) Right to Withdraw Consent: Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time.
5.2 To exercise any of these rights, please contact us using the contact information provided in section 9. We will respond to your request in accordance with applicable law.
5.3 You also have the right to lodge a complaint with a supervisory authority if you believe that our processing of your personal information violates applicable data protection laws.
6. Data Security
6.1 We implement appropriate technical and organizational security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include:
(a) encryption of data in transit and at rest;
(b) regular security assessments and penetration testing;
(c) access controls and authentication mechanisms;
(d) employee training on data protection and security practices; and
(e) incident response and breach notification procedures.
6.2 However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security. You are responsible for maintaining the confidentiality of your account credentials.
7. Third-Party Links
7.1 Our Service may contain links to third-party websites, services, or applications that are not owned or controlled by us. This Privacy Policy does not apply to those third-party sites.
7.2 We are not responsible for the privacy practices or content of third-party websites. We encourage you to review the privacy policies of any third-party sites you visit before providing any personal information.
8. Changes to This Privacy Policy
8.1 We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will update the "Effective Date" at the top of this Privacy Policy.
8.2 If we make material changes to this Privacy Policy, we will notify you by:
(a) posting a notice on our website;
(b) sending you an email notification (if you have provided us with your email address); or
(c) any other method required by applicable law.
8.3 Your continued use of our Service after the effective date of any changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information.
9. Contact Us
9.1 If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:
(a) Email: privacy@surfacd.com
(b) Postal Address: Clarity London Ltd, Zetland House Units 2AB, 5-25 Scrutton Street, London EC2A 4HJ
(c) Phone: +44 207 100 1333
9.2 We will make every effort to respond to your inquiry promptly and address any concerns you may have.