Privacy Policy

At ICOE Technology Ltd we are committed to protecting your personal information. We have published this privacy notice to ensure that you are fully aware of what personal information we collect from you, how we use it, who we share it with and what your rights are. This privacy notice applies to prospective, existing and former customers and any individuals who visit our website. 

Our website uses cookies. Please read our cookie policy here https://loudandcleartech.com/privacy-policy/ carefully as it contains important information about who we are and how we use cookies on our website. This privacy notice relates to your use of our website loudandcleartech.com and personal information we collect, store and use throughout our business relationship with you. 

WHO ARE WE?

“We”, “our” or “us” means ICOE Technology Ltd trading as Loud and Clear (“ICOE”). Our company number is 11946518. Our registered office is at Po Box 359, Hampton, TW12 9ET. We offer our goods and services on a Business-to-Business basis. 

If you visit our website for access to information or to set up an account as an end user, we are the controller of your personal information. This means that we are responsible for deciding how we collect, store and use personal information about you. 

If you access our website because we have a contract with the business that you work for i.e. to access our support services or to use the Hub, we will be acting as the processor of your personal information. This means that we will be collecting, storing and using your personal information on the instructions of one of our customers. We will not be deciding what personal information to collect from you, what to do with it once collected or how long your personal information will be kept for. We will not use your personal information for any other purpose. 

This privacy notice sets out what we do with your personal information as controller. Please see below for more information.

If you have any questions about this privacy notice, please contact dataprotection@loudandcleartech.com. 

NAVIGATION

• What personal information do we collect about you?
• How will we use your personal information and what is our legal basis for using it?
• What personal information do we collect about you when you contact us, how will we use your personal information and what is our legal basis for using it? 
• What happens if you don’t provide the personal information we have asked for?
• Does this privacy notice cover websites you link to from this website?
• Will we use your personal information for automated decision-making?
• Will we change the way we use your personal information?
• How long will we keep your personal information?
• Who will we share your personal information with?
• Will we transfer your personal information outside the UK?
• How do we keep your personal information secure?
• What rights do you have over your personal information?
• How will we tell you about changes to this privacy notice?
• How can you contact us?

WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

We have set out below what personal information we collect about you.

When you visit our website, we collect, store and use the following personal information: 

• name;
• business/company name;
• job title;
• profession;
• contact information such as email addresses and telephone numbers;
• demographic information such as post code, preferences and interests;
• IP address (automatically collected);
• web browser type and version (automatically collected);
• operating system (automatically collected);
• a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected).

Some of the personal information we collect is obtained through cookies. We use both essential and non-essential cookies on our website. Please see our cookie policy for more information. 

When you are (or the organisation you work for becomes) a prospective or actual customer of ours, we will collect, store and use the following personal information:

• name;
• work email address. 

HOW WILL WE USE YOUR PERSONAL INFORMATION AND WHAT IS OUR LEGAL BASIS FOR USING IT?

We have set out below how we use your personal information. In addition, we have set out our legal bases to use your personal information as we need to tell you these under data protection law. 

We will use your personal information to enable us to provide the best possible products and services to you. We will also use your personal information to:

• Provide and manage your Account;
• Provide and manage your access to our site;
• Personalise and tailor your experience on our site;
• Supply our products and services to you;
• Personalise and tailor our products and services for you;
• Respond to communications from you;
• Supply you with email e.g. Newsletters, Alerts etc that you have subscribed to (you may unsubscribe or opt-out at any time by clicking the ‘unsubscribe’ at the bottom of each email correspondence;
• Carry out market research;
• Analyse your use of our Site and gather feedback to enable us to continually improve our site and your user experience;
• Enter into a contract with you (or with the organisation that you work for) and administer that contract.

When we collect information about your from our website using essential cookies we will use your personal information on the basis that it is in our legitimate interests to do so. We consider it is our legitimate interest for our website to be able to run properly. 

When we collect information about you from our website using non-essential cookies, we will use your personal information on the legal basis that you have given us your consent. You can, of course, withdraw your consent at any time by deleting our cookies or by managing your browser’s cookie preferences. For further details on how to manage your preferences please see aboutcookies.org or www.allaboutcookies.org.

For all other uses of your personal information, we will use your personal information on the basis that it is in our legitimate interests to do so. We believe that this is a proportionate use of your personal information as it is in accordance with your reasonable expectations, is relevant and appropriate to our relationship with you and we only use your contact details [and other personal information] for matters which relate directly to our relationship with you. We do not use them outside of the business context. Please contact dataprotection@loudandcleartech.com if you would like further detail about our legitimate interests. 

Other uses of personal information

We may collect, store and use your personal information for the purposes of bringing or defending any legal proceedings or meeting any legal or compliance obligations we have. 

Where we use your personal information for the purposes of meeting any legal or compliance obligations, we will do this on the legal basis that it is necessary for compliance with a legal obligation. 

Where we use your personal information for the purpose of bringing or defending legal proceedings our legal basis will be that it is in our legitimate interests. Please contact dataprotection@loudandcleartech.com if you would like further detail about our legitimate interests.

WHAT HAPPENS IF YOU DON’T PROVIDE THE PERSONAL INFORMATION WE HAVE ASKED FOR?

If you don’t provide the personal information we need when we ask for it, we may not be able to respond to you or enter into a contract with you. For example, if you do not give us your contact details, we may not be able to answer any queries that you have raised. If you have any concerns about whether you need to provide your personal information, please contact dataprotection@loudandcleartech.com.

DOES THIS PRIVACY NOTICE COVER WEBSITES YOU LINK TO FROM THIS WEBSITE?

Links within our website to other websites, such as LinkedIn, Facebook and Instagram, are not covered by this privacy notice. You should review the privacy information on those websites to find out how they may use your personal information. 

Third parties that our website links you to may also use cookies, over which we have no control. The third parties may include, for example, advertising networks and providers of external services such as web traffic analysis services. These third party cookies are likely to be analytical or performance cookies or targeting cookies and each will have their own cookie policy in place that can provide you with further information that explains how they will use cookies. 

WILL WE USE YOUR PERSONAL INFORMATION FOR AUTOMATED DECISION-MAKING?

We do not use your personal information to make decisions that will have a significant impact on you based solely on automated decision making (i.e. one without human intervention).

WILL WE CHANGE THE WAY WE USE YOUR PERSONAL INFORMATION?

We will only use your personal information for the purposes set out in this privacy notice. We can only change the purposes we use your personal information for, by telling you where we need to use it for another reason and that reason is compatible with those purposes set out in this privacy notice. If we need to use your personal information for any other purpose, we will notify you and we will explain the legal basis which allows us to use your personal information for this other purpose in a similar way to how we have done it in this privacy notice. 

HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION?

We will not keep your personal information for longer than we need it for the purposes we have explained in this privacy notice. We have outlined our retention periods below. 

We will keep your personal information in our active systems for the length of time you are within the role relevant to our communications with you for the duration of our contract with you. 

We will keep previous communications which we have had with you, which may contain your personal information for as long as you are a customer with us. 

We will keep any personal information we collect about you from the cookies on our website, for the period of time set out in our Cookie Policy. 

If a dispute arises between us, we will keep your personal information for the purposes of responding to and dealing with this dispute and this may mean that we keep your personal information for longer than as set out above. Please contact dataprotection@loudandcleartech.com if you would like any further information about our retention periods. 

We will ensure that your personal information is securely deleted after the retention periods stated above have expired. 

WHO WILL WE SHARE YOUR PERSONAL INFORMATION WITH? 

We may share your personal information with trusted third parties from time to time. We do not sell any personal information to any third party so that they can sent you their marketing material. 

We have set out below the third parties we may share your personal information with. If we do this, we will put in place a contract with them which controls how your personal information may be used and which requires that your personal information is treated in accordance with data protection laws. 

• With companies who provide support for our internal IT systems: We use reputable third parties to provide us with our IT systems (including our website) and support for them. They may access your personal information to the extent that they need to in order to provide their services and deal with any issues. 
• With a company that we merge with our transfer our business assets to: In the event that we sell all or part of our business, or merge with another company, we may transfer personal information that we have collected as described in this privacy notice, along with our other business assets, to the company that we are selling to our merging with. 
• With entities, organisations or individuals for legal reasons: We will share your personal information with entities, companies or individuals where this is strictly necessary to comply with any law, rule, regulation, governmental request or legal procedure that is applicable to us. 
• With entities, companies or individuals to obtain advice: We will share your personal information with external professional advisors such as lawyers or accountants in order to take advice and for the purposes of legal and tribunal proceedings or to enforce the terms of our agreements. 
• With website tracking companies: We will share data that we collect from cookies with external website tracking companies in order to obtain the business names for companies that visit our website. 

We will only disclose such personal information to any third party as is necessary to enable them to carry out the function or purpose for which it is disclosed. If you would like further information on the third parties we may share your personal information with and our legal basis for sharing your personal information with third parties, please contact dataprotection@loudandcleartech.com. 

WILL WE TRANSFER YOUR PERSONAL INFORMATION OUTSIDE THE UK?

European Economic Area (“EEA”) countries are all EU Member countries together with Iceland, Liechtenstein and Norway. The United Kingdom (“UK”) is no longer an EEA country but its data protection laws are aligned with those of the EEA countries. At the present time we store your personal information in the UK and will not transfer it outside of the UK. 

HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?

We have put in place appropriate security measures to prevent your personal information being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties (see above) who have a business need-to-know. 

We have put procedures in place to deal with any suspected data security breach and will notify you, if we have your contact details, and any applicable regulator of a suspected breach where we are legally required to do so. 

Our security procedures mean that we may occasionally request proof of identity before we are able to disclose personal information you. 

WHAT RIGHTS DO YOU HAVE OVER YOUR PERSONAL INFORMATION?

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) if you are unhappy about the way your personal information is being used – please refer to the ICO website for further information about this (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO and so, if you are happy to do so, please contact dataprotection@loudandcleartech.com. 

You have a number of other rights over your personal information which are:

• The right to ask us what personal information we have about you and to have a copy of your personal information from us;
• The right to ask us to correct any errors in your personal information;
• The right to object to our legitimate interests, profiling activities and direct marketing communications (if any); 
• The right to ask us to provide you with a copy of the personal information you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit that personal information to another entity where: (i) we are using your personal information on the basis of your consent or on the basis that it is necessary to perform a contract with you; and (ii) the use we are making of your personal information if carried out by automated means;
• The right to ask us to delete your personal information where: (i) we don’t need your personal information anymore; (ii) you withdraw your consent to our use of your personal information and we have no other legal basis to keep your personal information; (iii) you have asked us to review and explain our legitimate interests to you and we don’t actually have a valid legitimate interest to do what we are doing; (iv) our use of your personal information is illegal; and (v) we have to delete your personal information to comply with our legal obligations;
• The right to ask us to restrict the use that we are making of your personal information where: (i) you don’t think the personal information we have about you is correct so that we can check if it is correct; (ii) what we are doing with your personal information is illegal but you would rather we stop using your personal information rather than delete it; (iii) we don’t need your personal information anymore, but you need us to keep it so that you can exercise any legal rights; and (iv) you have asked us to review and explain our legitimate interests to you, so that we can check whether we actually have a valid legitimate interest to do what we are doing; and
• Where our use of your personal information is based on your consent, the right to withdraw your consent at any time by contacting dataprotection@loudandcleartech.com. 

If you want to access or correct your personal information, request your personal information to be deleted, object to, or restrict the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact dataprotection@loudandcleartech.com. 

HOW WILL WE TELL YOU ABOUT CHANGES TO THIS PRIVACY NOTICE?

We keep our privacy notice under regular review. Any changes we make to our privacy notice in the future will be posted on our website and if the changes will have an effect on you or the way we use your personal information, we will bring them to your attention by email where appropriate and where we have your contact details. This privacy notice was last updated in October 2023. 

HOW CAN YOU CONTACT US?

If you have any questions about this privacy notice or about the way we use your personal information, please contact dataprotection@loudandcleartech.com.