PRIVACY POLICY

The purpose of this privacy policy is to inform you about how your data is being handled by us. You have certain rights in relation to your data, including the right to revoke your consent and the right to object to processing based on legitimate interests, profiling (including the use of custom and lookalike/similar audiences), and direct marketing. At any time, you can exercise your rights by emailing us at dataprotection@mvfglobal.com. For further details about our processing and your rights, please see below.

CONTENTS

ABOUT US

Clearliving.com (“our site”) is an online resource which provides hearing information and advice.

Clear Living is a brand of Marketing VF Ltd ("MVF", "we", "us", "our").

MVF is a company registered in England and Wales (company number: 06951544), whose registered office address is at Imperial Works, Perren Street, London NW5 3ED, United Kingdom.

For the purposes of the General Data Protection Regulation (the "GDPR"), MVF is the controller in relation to your data. We are registered as a controller with the UK’s supervisory authority: Information Commissioner’s Office (ICO) under registration number Z1995728. You can confirm our registration here: www.ico.org.uk

 

WHAT DATA WE COLLECT, AND HOW WE COLLECT IT

Traffic data

We automatically track and collect the following categories of information when you visit our site: (1) IP addresses; (2) types of computers accessing the site; and (3) types of web browsers used to access the site (collectively “Traffic Data”). Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes or for improving your experience on the site. 

Information submitted relating to a request for quotes

On our site, there are opportunities to request quotes for certain products and services through completing online webforms. If you choose to complete our webform it will ask you for your contact details including, but not limited to, (1) your name (2) email address (3) telephone number (4) post code. 

Our webform may also ask you for information regarding your circumstances which are relevant to your request. From time to time we change our webforms and so they may ask you for other information. It will always be clear from the webform what information we’re requesting, and we only request information that is relevant to your request, and the service that we’re providing. If we call you to confirm your details or requirements, we may ask you for some additional information. We may monitor and/or record these calls for the purposes of quality control and staff training. Also, occasionally, we may need to provide Suppliers (as explained below) with limited access to such recordings in order to resolve queries and disputes.

Information provided when contacting us

If you communicate with us by e-mail or post messages, any information provided in such communication may be collected as personal information. 

Information provided when submitting reviews

If you choose to leave a review for any of the products on our site, we will ask you to provide your full name and email address. 

 

HOW WE USE YOUR DATA

To contact you about your enquiry

If you contact us, we will use your information to handle your enquiry and correspond with you. 

Working with Third Party Providers

We share contact data with our Third Party Providers who assist us by performing core services (such as fulfillment, or data storage and security) related to our operation of the site. These include cloud storage providers, email service providers, and cloud telephony providers. We have appropriate contracts in place with such Third Party Providers to ensure the protection and confidentiality of data.

To connect you with relevant Suppliers

If you submit our webform in order to request a quote, we’ll pass your request to one or more relevant product or service suppliers (named on the webform) ("Suppliers"). We will do this in a secure way. For example, using HTTP Secure (HTTPS), which means the data is encrypted. The Suppliers then contact you directly with your quotes. They may contact you by telephone, text/SMS or email. Before we pass your request to any Suppliers, our service may involve an element of automated decision-making. Our technology platform may automatically assess your requirements and pass your request to such Suppliers that would like to receive requests for quotes at the time your request is made. 

To call you to confirm your details or requirements

Before connecting you with relevant Suppliers, we may call you to confirm your details or requirements. We may also call you to ask about your experience using our site and service, and dealing with the Suppliers with which we connected you. 

Withdrawing your consent - If, at any time, you wish to withdraw your consent to be contacted by us or the Suppliers regarding your request for quotes, you can exercise this right by accessing our preference centre.

To email or SMS message you about similar products and services – But only if you haven’t opted out of such emails

If you use our quote request service, then, as an existing user, we would like to email you, or send you text/SMS messages, about similar products and services for which we think you might like quotes or information ("Other Products"). Sometimes your mobile network provider may charge you for such SMS messages.

You will always be given an opportunity to opt out of such messages before we send them, and we will not send such messages if you have opted out.

To create custom and lookalike/similar audiences

We like to work with Facebook, Google and other platforms ("Platforms") to reach out to you with adverts for other products. We also like to use Platforms to reach out to other people who might like to use our quote request service. We do this in two ways. In both cases, your data, along with other data, is used to create a custom audience and/or a lookalike/similar audience. Whenever an audience is shared with a Platform, the data is first hashed and pseudonymised, meaning that any data within the audience that could identify a person is replaced with an artificial identifier. So, the process is secure. Also, we don’t share more data than we need to for the purpose of creating the audience.

As we explain below, at any time, you may object to such activity by emailing us at dataprotection@mvfglobal.com.

Receiving data from Suppliers

From time to time, Suppliers may return data to us. They may do this if they have a query regarding a request for quotes that we have sent to them in order to enable us to resolve the query. They may also return data to us, together with confirmation on whether or not a product has been purchased, in order to enable us to improve our marketing. We may also use such data to create custom and lookalike/similar audiences, as explained above.

Receiving data from our Affiliate Partners

Our site contains Affiliate Links, which will direct you to our Affiliate Partners’ sites. From time to time, our Affiliate Partners may share data with us. In most cases, they do this anonymously (i.e. they don’t provide us with any personal data). If you visit their site from our site, and subsequently purchase their product, they will tell us. We don’t use this information for any purpose, except to record the number of visitors from our site who have purchased our Affiliate Partner’s product.

To confirm that you are a real person and that the review is genuine

If you choose to leave a review for any of the products shown on our site, we use your information to confirm the authenticity.

To email you to remind you to complete our webform where its partially completed

If you start but don’t complete one of our webforms, we may email you to remind you to complete that webform. We will only store data inputted by you in a partially completed webform for two hours from when you leave the webform. If you don’t return to the webform to complete and submit the form in two hours, we will permanently delete the data you’ve inputted, subject to an automatic back-up of that data being made and stored for 30 days from the date you partially completed our form. Such back-up will not be readily accessible by us and your data will not be used for any other purpose.

Public information

We may make commenting available to you on certain pages. Please understand that any information that is disclosed in these areas becomes public information. We have no control over its use and you should exercise caution when deciding to disclose your personal information.

 

COOKIES

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. At the bottom of this policy, we have included a table, setting out what cookies we use, and the purposes for which we use them.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

 

IP ADDRESSES

We store IP addresses in order to stop unwanted traffic (i.e. spam) to our site. For example, if we become aware that spam is coming from a particular IP address (i.e. computer or location), we can block that IP address. From time to time, we also share IP addresses with Suppliers to enable Suppliers to verify that requests for Quotes have come from a particular country.

 

THIRD PARTY ADVERTISEMENTS

This site also uses third party advertisements to generate revenue. Some of these advertisers may use technology such as cookies and web beacons when they advertise on our site, which will also send these advertisers (such as Google through the Google AdSense program) information including your IP address, your ISP, the browser you used to visit our site, and in some cases, whether you have Flash installed. This is generally used for geotargeting purposes (showing New York real estate ads to someone in New York, for example) or showing certain ads based on specific sites visited (such as showing cooking ads to someone who frequents cooking sites).

You can choose to disable or selectively turn off our cookies or third-party cookies in your browser settings (as explained above), or by managing preferences in programs such as Norton Internet Security, McAfee and Eset.com. However, this can affect how you are able to interact with our site as well as other websites. This could include the inability to login to services or programs, such as logging into forums or accounts.

 

TRANSFERRING YOUR DATA

We may transfer your data outside the UK. As of 1 January 2021, the UK is no longer a part of the European Economic Area (the “EEA”). This means that your data may be transferred outside of the UK to countries inside the EEA, or to another country outside of the EEA. For example, if you’re looking for Suppliers in the USA, we may need to transfer your data to the USA.

Although the UK is no longer part of the EEA, we will still hold your data to the same level of protection as we did when we were part of the EEA. This means that for any transfer of your data outside of the UK, we will continue to take steps to ensure that it is protected to the same level of protection that applies to transfers of data outside of the EEA.

Certain countries have a European Commission adequacy decision, which means they are considered to offer an adequate level of data protection and we will continue to only transfer data to those countries on this basis.

Other countries do not have the same level of legal protection as countries in the EEA, or with an adequacy decision. If we do transfer your data in this way, we will take steps to ensure that it is protected to the same levels that apply in the EEA. This may include, for example, adopting the EU’s standard contractual clauses.

 

STORING YOUR DATA

We have a data retention policy, which clearly sets out how long we keep data for, and for what reasons.

We will keep your data only for as long as is necessary to fulfil the purpose/s for which it was collected in the first place, i.e. as set out in this Privacy Policy.

For example, if you haven’t opted out of receiving marketing from us, we will keep your details, and send you emails, until such time as you don’t engage with our emails for a period of 6 consecutive months. Following this period we will not use the data, save that we will hash/anonymise the same, and retain it for a further 3 years for compliance purposes.

 

LEGAL GROUNDS

This Privacy Policy sets out (above) how we use your data. Under the GDPR, controllers must have a valid lawful basis for each processing activity that they undertake. This section sets out our lawful basis for each activity.

Activity Lawful Basis under the GDPR Your Rights

Handling enquiries received from you

Legitimate interests

You have the right to object to processing based on legitimate interests

Connecting you with Suppliers

Consent

To withdraw your consent, as explained below

Automated decision-making (as explained above)

Legitimate interests

You have the right to object to processing based on legitimate interests

Using and sharing IP addresses

Legitimate interests

You have the right to object to processing based on legitimate interests

Calling you to confirm your details or requirements

Consent

To withdraw your consent, as explained below

Sharing call recordings with Suppliers

Legitimate interests

You have the right to object to processing based on legitimate interests

Emailing you about Other Products

Legitimate interests*

To object to processing based on legitimate interests. You also have the right to object to direct marketing

Creating custom and lookalike/similar audiences

Legitimate interests

You have the right to object to processing based on legitimate interests

Receiving data from Suppliers (as explained above)

Legitimate interests

You have the right to object to processing based on legitimate interests

Authenticating reviews

Legitimate interests

You have the right to object to processing based on legitimate interests

*Under the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR), we send such emails on the basis of the existing customer (soft opt-in) exemption.

In each case where we have identified legitimate interests as the legal basis for our processing, we have conducted a legitimate interests assessment

 

YOUR RIGHTS

Your rights will be determined by the country in which you reside. If you reside in the European Economic Area or the United Kingdom, you have certain rights under GDPR in relation to your personal data. In relation to our site, and the service that we provide, those rights are set out in the table above. We further explain these rights, and your other rights, below.

Right of access – You have the right at any time to ask us for a copy of the personal information that we hold about you, and to check that we are lawfully processing it.

Right of rectification – If personal information that we hold about you is not accurate or is out of date and requires amendment or correction you have a right to have the data rectified or completed.

Right of erasure – In certain circumstances, you have the right to request that personal information we hold about you is erased (e.g. if the information is no longer necessary for the purposes for which it was collected or processed).

Right to object to or restrict processing – In certain circumstances, you have the right to object to our processing of your personal information. For example, if we are processing your information on the basis of our legitimate interests, and there are no compelling legitimate grounds for our processing which override your rights and interests.

Right of data portability – In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format.

Right to withdraw consent – In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. You can exercise this right by accessing our Preference Centre.

Exercising your rights

As explained above, you can exercise your right to withdraw consent by accessing our preference centre https://preferences.safe-click.net/.

If you wish to exercise any of your rights under the GDPR, please email us at dataprotection@mvfglobal.com. Alternatively, you can write to us at the address set out above, or inform us if you speak with us on the phone.

Our lead supervisory authority for the processing set out in this Privacy Policy is the UK ICO. If you are unhappy with how we have processed your data, you have the right to make a complaint to the ICO.

If you are based outside of the UK, or you have a complaint concerning our activities outside of the UK, you may prefer to lodge a complaint with a different Supervisory Authority. A list of relevant authorities can be accessed here http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

 

YOUR CALIFORNIA PRIVACY RIGHTS

This section provides more information about the personal information we collect about California consumers and the rights afforded to you under the California Consumer Privacy Act (“CCPA”).

You have certain rights in relation to your data, including the right to have your personal data deleted, and the right to object to your personal data being sold to third-parties. For details about the personal information we have collected over the last 12 months, including the categories of sources, please see the “What data we collect, and how” section above. We collect this information for the purposes set out in the “How we use your data” section above. We share this information with the categories of third parties described in the same section. We do not sell (as defined in the CCPA) the personal information we collect. We use third-party cookies for our advertising purposes as described in the Cookies section above and table below.

Subject to certain limitations, the CCPA provides California consumers the right to request more details about the categories or specific pieces of personal information we collect, such as how we use and disclose this information and to delete their personal information.

California consumers may make a request pursuant to their rights in the CCPA by contacting us at data protection@mvfglobal.com. We will verify your request using the information you have previously submitted to us, including your email address.

Please review our full Privacy Policy for California consumers here.

 

CONTACTING US

If you have any questions regarding this Privacy Policy, or any questions relating to data protection or privacy, you can contact us at dataprotection@mvfglobal.com.

Alternatively, you can write to us at the address set out in the ‘About Us’ section above.

Our EU Representative

As we no longer have an establishment in the European Union, we have appointed a representative based in the Netherlands. The details of our EU representative are as follows: Software Vergelijken B.V. located at Heresingel 4B, 9711 ES Groningen, Netherlands. 

If you are based in the EU and have any questions regarding this Privacy Policy, or any questions relating to data protection or privacy, you can contact our EU representative directly at dataprotection@mvfglobal.com.

 

COOKIES WE USE, AND THE PURPOSES WE USE THEM FOR

Cookie Name Purpose

Universal Analytics (Google)

_ga _gali _gat_UA-1036645-1 _gid

These cookies collect information about how visitors use our website. We use the information to compile reports and to make improvements. The cookies collect information in an anonymous form, including where visitors have come to the website from and the pages they visited. To opt-out: https://tools.google.com/dlpage/gaoptout

Taboola Retargeting

 

These cookies are used to tailor Taboola adverts to a user’s previous viewing habits. For instance, if you have previously visited our page, you may then see other adverts related to that product or service. Taboola is an ad network that shows sponsored content, usually as links below the article on major news sites.

Outbrain Retargeting

 

These cookies are used to tailor Outbrain adverts to a user’s previous viewing habits. For instance, if you have previously visited our page, you may then see other adverts related to that product or service. Outbrain is an ad network that shows sponsored content, usually as links below the article on major news sites.

Adwords Retargeting (Google)

 

These cookies are used to adjust the targeting of our paid search and display advertising to show ads to users who have previously been to our sites and/or engaged with our page such as completing a form. They contain no personal information.

DoubleClick Retargeting

 

These cookies are used to adjust the targeting of our display advertising to show ads to users who have previously been to our sites and/or engaged with our page such as completing a form. They contain no personal information.

Taboola Conversion Tracking

 

These cookies measure ad conversions and optimise spend for advertising campaigns served on Taboola.

Outbrain Conversion Tracking

 

These cookies measure ad conversions and optimise spend for advertising campaigns served on Outbrain.

Yahoo Conversion Tracking

 

These cookies measure ad conversions and optimise spend for advertising campaigns served on Yahoo Gemini.

Zemanta Conversion Tracking

 

These cookies measure ad conversions and optimise spend for advertising campaigns served on Zemanta.

Ligatus/LiquidM Conversion Tracking

 

These cookies measure ad conversions and optimise spend for advertising campaigns served on Ligatus and LiquidM.

Plista Conversion Tracking

 

These cookies measure ad conversions and optimise spend for advertising campaigns served on Plista.

Revcontent Conversion Tracking

 

These cookies measure ad conversions and optimise spend for advertising campaigns served on Revcontent.

EngageYa Conversion Tracking

 

These cookies measure ad conversions and optimise spend for advertising campaigns served on EngageYa.

Adwords Conversion Tracking

 

These cookies measure when a user has completed an action on site such as completing a form. They contain no personal information.

Bing Conversion Tracking

UET Tag

These cookies measure when a user has completed an action on site such as completing a form. They contain no personal information.

DoubleClick Conversion Tracking

 

These cookies measure when a user has completed an action on site such as completing a form. They contain no personal information.

Facebook Pixel

 

These cookies measure ad conversions, optimise and build audiences for advertising campaigns served on Facebook. To opt-out: https://www.facebook.com/policies/cookies/.

Nanigans JavaScript Pixel

 

These cookies measure ad conversions and optimise advertising campaigns managed through Nanigans. They contain no personal information. To opt-out: http://www.nanigans.com/privacy-policy/

Twitter Pixel

 

These cookies measure ad conversions and optimise advertising campaigns served on Twitter. To opt-out: https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads

LinkedIn Pixel

 

These cookies measure ad conversions, optimise and build audiences for advertising campaigns served on LinkedIn. To opt-out: https://www.linkedin.com/legal/cookie-policy

Pinterest Tag

 

These cookies are used to track conversions, optimise and build audiences to reach customers on Pinterest. To opt-out: https://help.pinterest.com/en/articles/personalized-ads-pinterest

Skimlinks

 

Our website receives paid commission on sales of those products or services we write about. In some instances, we use a 3rd Party to enable these affiliate partnerships. To opt-out: https://skimlinks.com/privacy-policy#users

Amazon Associates

 

These cookies track referral visits to Amazon for which we may earn commission for any eventual purchases.

Adsense

 

AdSense uses cookies to improve advertising e.g. displaying targeted advertisements and avoiding showing advertisements that the user has already seen. These cookies contain no personally identifiable information.

VWO

_vwo

These cookies are used to help us optimise our sites by running tests and measuring user conversions. It is also used to track user information when visiting the site (e.g. browser and device information).

HotJar

 

Hotjar uses cookies and other technologies to collect data on our users’ behaviour (e.g. how much time they spend on which pages, which links they choose to click etc) and their devices (in particular device’s IP address, captured and stored only in anonymised form, preferred language settings etc). This enables us to better understand our users’ needs and to optimise this service and experience. Hotjar stores this information in a pseudonymised user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. To opt out: https://www.hotjar.com/legal/compliance/opt-out

CHANGES TO THIS PRIVACY POLICY

From time to time, we may update this Privacy Policy. This Privacy Policy is our most up-to-date version and it supersedes any earlier version.

Last reviewed: December 2020