(1) Introduction
This Privacy Notice explains how Clarify collects and uses personal data.
We provide B2B marketing, demand generation, and outreach services across the United Kingdom, European Economic Area (EEA), and the United States.
We process personal data in accordance with applicable data protection laws, including the UK GDPR, the Data Protection Act 2018, the Data (Use and Access) Act 2025, the EU General Data Protection Regulation (EU GDPR), and relevant US state privacy laws where applicable.
(2) Who we are
Clarify is a data controller in respect of its own business activities, such as marketing, recruitment, and operation of its website.
When delivering services to clients, Clarify typically acts as a data processor, processing personal data on behalf of those clients in accordance with their instructions.
Contact details:
Email: info@clarifyb2b.com
Address: Building 1330, Arlington Business Park, Theale, RG7 4SA
(3) The personal data we collect
We may process the following types of personal data:
- Name and job title
- Business contact details (email address, telephone number)
- Employer and company information
- Communication history (emails, call notes, call recordings where applicable)
- Marketing preferences
- Technical data (IP address, website usage data)
- Recruitment data (CVs, employment history, assessment results)
We do not intentionally collect special category data.
(4) How we collect personal data
We collect personal data from:
- Individuals directly
- Employers or organisations
- Publicly available sources (such as company websites and professional networking platforms)
- Third-party data providers and enrichment services
- Website interactions and cookies
- Recruitment platforms and assessment tools
(5) How we use personal data (as a data controller)
a) Delivering our own services and managing relationships
- Managing client relationships
- Communicating with clients and suppliers
Lawful basis: Contract and legitimate interests
b) Business development and outreach
- Contacting business professionals about relevant services
- Building and maintaining prospect databases
- Improving and personalising outreach campaigns
Lawful basis (UK/EU): Legitimate interests
US approach: Processing carried out in line with applicable state privacy laws, with opt-out mechanisms where required
We consider this use proportionate in a B2B context. Individuals can object to this processing at any time.
c) Marketing
- Sending marketing communications
- Managing marketing preferences
Lawful basis (UK/EU): Consent (where required) or legitimate interests
US approach: Opt-out of marketing communications at any time
d) Website use and analytics
- Monitoring and improving website performance
- Understanding user behaviour
Lawful basis (UK/EU): Consent (for non-essential cookies) and legitimate interests
e) Recruitment
- Managing applications and assessing candidates
Lawful basis: Legitimate interests and steps prior to entering into a contract
f) Call recording
We may record calls for training, quality assurance, and compliance purposes.
Lawful basis (UK/EU): Legitimate interests
Where required under applicable laws, we will obtain consent before recording calls.
Individuals will be informed at the start of the call and can request that the call is not recorded.
(6) Processing personal data on behalf of clients
When providing services to clients, we act as a data processor. In these cases:
- Our client is the data controller
- We process personal data only in line with their documented instructions
This may include:
- Contacting individuals as part of client campaigns
- Managing prospect and lead data
- Recording and managing communications on behalf of clients
The personal data processed typically includes business contact details and communication history.
If you have been contacted as part of a campaign delivered by us on behalf of a client, that client is responsible for explaining how your personal data is used.
(7) Data sharing
We may share personal data with:
- Service providers (e.g. CRM, hosting, email platforms)
- Data enrichment and prospecting providers
- Recruitment and assessment providers
- Professional advisers
- Regulators or authorities where required
Where we act as a data processor, personal data is shared in accordance with our client’s instructions.
(8) International transfers
Given the global nature of our operations, personal data may be transferred between the UK, EEA, and the United States.
Where personal data is transferred internationally, we ensure appropriate safeguards are in place, such as:
- UK International Data Transfer Agreements (IDTAs)
- UK Addendum to Standard Contractual Clauses
- EU Standard Contractual Clauses (SCCs)
- Transfers to countries recognised as providing adequate protection
(9) Data retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law or regulation. The periods below represent maximum standard retention windows. We may retain data beyond these where we have a legitimate interest in doing so, which we assess on a case-by-case basis.
- Prospect and marketing data: up to 5 years from last meaningful contact
- Client data: duration of the contract plus up to 7 years
- Employee data: duration of employment plus 6 years
- Call recordings: up to 12 months, unless retained longer in connection with a complaint, investigation, or legal matter
We review retained data periodically and delete or anonymise it when it no longer meets the criteria above. Where you have the right to request erasure, you may do so at any time, subject to any overriding legal obligation.
(10) Your rights
You have the right to:
- Access your personal data
- Request correction of inaccurate data
- Request deletion of your data
- Object to or restrict processing
- Request data portability (where applicable)
- Withdraw consent where applicable
Individuals in certain US states may also have the right to opt out of specific types of processing, including targeted advertising.
You also have the right to lodge a complaint with your local supervisory authority. In the UK, this is the Information Commissioner’s Office.
(11) Data security
We implement appropriate technical and organisational measures to protect personal data.
(12) Changes to this Privacy Notice
We may update this Privacy Notice from time to time. The latest version will always be available on our website.
(13) Contact
If you have any questions relating to Clarify’s GDPR policies, please contact our DPO:
Email: dpo@clarifyb2b.com
Address: Building 1330, Arlington Business Park, Theale, RG7 4SA