​Simantea Ltd Privacy Policy
Updated Oct 2024
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1. Introduction
Welcome to Simantea Ltd ('we,' 'our,' or 'us'). We value your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and share your data when you use our services in compliance with UK law and the General Data Protection Regulation (GDPR). Please make sure that you read this Policy carefully. By accepting the Clear! Terms & Conditions, downloading the Clear! application or registering you consent to us using your personal data in the ways described in this Policy. Where you provide information relating to other members of your household, they must give their consent to the use of their personal data in the ways described in this Policy.
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2. Data Controller
Simantea Ltd is the data controller for the personal data collected and processed through our Clear! application and services. If you have any questions about this Privacy Policy or your rights, please contact us at:
Full name of legal entity: Simantea Ltd (14924270)
Name or title: Data Protection Manager
Email address: support@clear-app.com
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3. Data Processor
Some data collection processes are provided by RealityMine, these are described in section 4.2
Additional contact: RealityMine Ltd acting as Data Processor
Full name of legal entity: RealityMine Ltd
Name or title: Data Protection Manager
Email address: dpm@realitymine.com
Postal address: Data Protection Manager, RealityMine Limited. Warren Bruce Court, Warren Bruce Rd, Stretford, Manchester, M17 1LB, United Kingdom
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4. What Data We Collect
We collect personal data to provide our services effectively. The types of data we collect include:
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4.1. Data that you actively provide
- Registration details: Data collected prior to registering to join Clear! application. Name, postcode, email, basic household composition, main phone operating system.
- Receipts: Paper and digital receipts submitted by users through the Clear! application or through user forwarding of digital receipts. We will process and store the products, prices, promotions, retailer name and address, totals, date and payment methods as well as an image of the receipt.
- Surveys: Data collected through voluntary surveys within the Clear! application.
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4.2. Passively Collected Data collected by RealityMine
These services can be stopped and re/started by users in the Clear! application account settings.
RealityMine may collect both personal information and non-personal information from you as described below. Personal data, or personal information, means any information which relates to an identified or identifiable person. It does not include data where the identity has been removed (anonymous data). RealityMine may collect, use, store and transfer different kinds of personal data about you which RealityMine have grouped together follows:
• Contact Data includes email address and telephone numbers.
• Technical Data includes applications and websites used, search terms entered, internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use
The processing and grouping of personal data will be completed by RealityMine.
RealityMine do not intentionally collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor does RealityMine collect any information about criminal convictions and offences. However, such data may be collected in connection with the collection of other information (e.g., website visits, search terms entered, etc.) and may be processed and used in connection with our services to or for our client(s). WHILE THE APP IS ACTIVE ON YOUR DEVICE PLEASE DO NOT ENTER DATA/INFORMATION OR USE APPS OR THE INTERNET IN A WAY THAT WILL LEAD TO THE COLLECTION AND PROCESSING OF SENSITIVE PERSONAL DATA.
4.2.1. How RealityMine Collect the Information:
RealityMine use different methods to collect data from and about you. RealityMine have set out below further detail on exactly how data is collected from you when using the Application.
The Application collects ‘clickstream data’ and may also gather diary/survey data if configured. Clickstream data is information generated by you and your device while surfing the Internet and interacting with various sites, services and device functions.
The service will either install the “Meter” (a piece of software on your device to collect the data described above) and/or will establish the “VPN” (a profile on your device to direct all internet data generated by and for your device through RealityMine to enable Us to collect the data). Regardless of whether data is collected via the Meter or the VPN, RealityMine will only use the data as described in this Notice.
On Android and iOS mobile & tablet devices, RealityMine may use a VPN to collect the web traffic for applications and websites. Panellists are asked to install a root certificate which is used to decrypt the HTTPS traffic from specific browsers and applications, and the URL and some specific HTTP headers are collected - these would NOT include passwords or credit card details.
On Android, the root certificate is uniquely and randomly generated per device meaning that no external party, including RealityMine nor Simantea Ltd, is able to decrypt the traffic outside of the device. Additionally, from Android 7 and above, even with the root certificate, decryption of traffic is prevented by the operating system from apps other than browsers and applications where the developers have opted into trusting the root certificate. This data is used to report on web pages the user visits, including those of video services when using the browser. For iOS VPN, the private key needs to be securely stored on the VPN server for the solutionai to function.  
Data collected via the Application is encrypted on-device using public key technology such that if the device is ever compromised, stolen or lost, the collected data cannot be decrypted because the private key is not known.
In greater detail, Reality Mine may collect the following types of information:
Online browsing This includes the sites you visit and apps you use, including news sites/apps or social networks, and your interactions with them. In some instances, this may also include specific content from within applications, such as the Title of a show viewed on a specific SVOD service, or an advert exposed to within a social media application.
Online activities This includes the search terms you enter and the results of such searches, the videos you view, the products you shop for online, information you enter into forms, the materials you download or upload, the advertisements you see, cookies on websites you visit, information and content on sites or apps that you visit or use and with which you interact and may include personal, financial and health information (subject to the process described below in the section entitled “Protecting Personal & Sensitive Information”).
System information This includes information about the device and browser that you are running on, including the IP address and phone number of the device, how the Application is operating, and which other applications are installed or running.
Location Information Meaning data which reveals the geographic location of you and your mobile device, where you have given us your consent to collect such information. When you first download the Application, you will be asked if you agree to your location information being disclosed to us. If you consent, then RealityMine may collect and transmit this information on a semi-continuous and passive basis, which does not require any further activation on your part. If you wish at any stage to turn off this passive location tracking, you will need to uninstall the Application, by following all of the defined steps from the instructions set out in the Application Removal section below.
RM Connect This includes the capture of media viewing of a profile or account across all devices for connected streaming services, such as content viewed, when, for how long and on what device. At no point are account details captured or stored including emails and passwords.
The above list contains examples of the type of data collected and is not a comprehensive list of every single data element.
4.2.2. Protecting Personal & Sensitive Information
RealityMine is accredited to both ISO 9001 (Quality Management) and ISO 27001 (Information Security Management) standards. RealityMine has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, RealityMine limits access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on the Data Controllers instructions and they are subject to a duty of confidentiality.
RealityMine has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where RealityMine are legally required to do so
4.2.3. Cookies
RealityMine may collect certain information in part through the use of a technology called a “cookie.” A cookie is a small text file that is saved to your device using your browser, which allows sites to recognize you and store preferences and other information if you return to the site using the same device and browser.
RealityMine use temporary session cookies during the download and registration process to correctly identify the research panel that you have joined, enable the creation of a unique, anonymous identifier and to trigger the download process.
RealityMine may use cookies apart from the Application and link that data to other data in your profile, including data that is collected through your use of the Application.
You may remove cookies and/or control their operation by adjusting your browser settings. Please visit the ‘help’ section of your browser for more information.
4.3. Passively collected data by Simantea
Audio Content Information. The devices may sample background audio content using the device’s microphone. The actual audio is never stored, but immediately converted into a “fingerprint” in a non-reversible process. The “fingerprint” is used to try and identify the TV/radio/audio show, content, channel, service, promotion or commercial being listened to. This feature is disabled during phone calls.
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5. How We Use Your Data
We use your data for a variety of purposes to provide our services effectively and to deliver insights to our clients. Typically, the data we collect is aggregated and reported in the form of consumer segments, which are groups of users who share common characteristics or interests. For example, “women between the ages of 28-34 that buy olives.” These aggregated consumer segments are shared with our clients and other authorized parties to help them understand trends and behaviours, without directly identifying individual users. Examples of this are outlined below:
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5.1. Advertising Research (To assess the effectiveness and return on investment of advertising, promotional, sponsorship or product placement campaigns)
We combine your data with that of other users to form pools that are then analysed to measure exposure to certain advertisements. The results, which do not identify any particular user, are shared to help brands understand how their advertising spending impacts consumer behaviour and decision-making. For example, we may compare the behaviours of a group of users who viewed a particular advertisement with another group who did not, allowing clients to understand the effectiveness of their ad campaigns.
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5.2. Media Use Analysis (To help brands and advertisers understand the composition of their audience without targeting or marketing to individual users)
Your data is used to form consumer segments that we share with clients to help them understand how different audiences interact with content, applications, promotions, sponsorships and advertisements. This information is used to identify where consumers go online and offline and how they engage with media. For instance, we may analyse how users interact with a client’s website compared to how they interact with a competitor’s site, helping our clients optimize their digital properties and content.
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5.3. Shopper behaviour (To help brands and retailers understand consumer behavior to enhance their business strategies)
Your data is used to form cohorts of shoppers that behave in a similar way and the prior or subsequent behaviour is tracked to understand behavioural change. For example a group of individuals may be identified that bought a specific brand when it was on promotion, that groups purchasing of the category pre and post the promotion could be of interest to clients. Your data is also used to estimate the total volume of sales at a brand, retailer and product level, to monitor changes in these estimates over time and to help understand he key drivers of changes
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In some cases, we may share or use non-aggregated data for limited purposes, which are explained below:
5.4. Linking with other datasets (To build a deeper understanding of your characteristics)
We may use the personal data you have directly provided to us to obtain additional data about you from public and private data sources. This information may include household and lifestyle data, purchase history (both online and offline), and demographic or viewing data. We combine this information to create enhanced profiles, which help us understand your behaviour and preferences. For example, we may identify a consumer segment that visits specific websites during their product research phase but prefers to make purchases in-store. Such insights can assist brands in reaching their potential customers more effectively.
If we work with third-party data providers to supplement your profile, we protect your privacy by requiring these providers to sign confidentiality agreement and linking would occur in ‘clean room’ ensuring personal data is not shared across organisations. These agreements prohibit third parties from using your data for any purpose other than those explicitly authorized by us. We instruct these providers to maintain the confidentiality, security, and integrity of the data we provide.
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5.5. Consumer Segmentation Analysis (To enable clients to enhance their understanding of segments of consumers they have built for marketing planning)
We may use your data, including personally identifiable information, to help our clients improve their understanding of existing consumer segments or create new ones. This analysis helps our clients better align their marketing and advertising strategies. Sometimes, we may work with third-party data sources to further enrich the profiles, enabling us to provide deeper insights into consumer behaviour.
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5.6. Targeted Surveys (To enable Simantea to send you surveys)
Based on your behaviour collected through the Clear! application, we may send you invitations to participate in targeted surveys. For example, if your browsing patterns indicate an interest in travel, you may receive a survey about travel services. Survey responses are shared with clients in a way that does not directly identify any user but provides valuable feedback that helps them refine their products and services.
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5.7. Application Maintenance and Functionality
We use your information for purposes related to the configuration and proper functioning of the Clear! application, database management, customer support, or data quality assurance. This ensures that the Clear! application remains efficient and effective for all users.
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5.8. Contact Information and Communications
During the registration process or when participating in surveys, you may provide personal information such as your name, email address, birth year, household details, income, and gender. This information forms part of your consumer profile and is used to improve the services we provide. Additionally, we may use this contact information to communicate with you regarding Clear! application maintenance, upgrades, or other service-related updates.
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5.9. Authorized Vendors and Service Providers
We may share your data with authorized vendors and service providers who perform services on our behalf. These third parties are required to maintain the confidentiality and security of your data and are prohibited from using your data for any other purposes.
By combining your data with data from other users, we ensure that insights are delivered to our clients in a way that protects individual privacy, while enabling the development of rich consumer segments that help businesses understand and engage with their audiences more effectively.
6. Legal Basis for Processing
We process your data under the following legal bases:
- Consent: We obtain your consent before collecting or processing your data where required.
- Legitimate Interests: We process data based on our legitimate interest in conducting market research and analyzing consumer behavior, provided it does not override your rights and interests.
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7. How We Share Your Data
We do not sell or share your personal data with third parties for their marketing purposes. We may share your data with:
- Service Providers: To help us perform data analysis and provide our services.
- Partners/Clients: In aggregated and/or anonymized form, to help brands and advertisers understand audience trends and behavior.
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8. Data Retention
We retain your personal data only as long as necessary to fulfill the purposes for which it was collected, comply with our legal obligations, and resolve disputes. After this period, your data will be securely deleted or anonymized.
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9. Your Rights
Under UK law and GDPR, you have the following rights regarding your personal data:
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9.1. Right to Access
You have the right to request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
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9.2. Right to Rectification
You have the right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data corrected, though we may need to verify the accuracy of the new data you provide to us.
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9.3. Right to Erasure
You have the right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Your request will be actioned within 90 days following company policy.
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9.4. Right to Object
You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
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9.5. Right to Restriction of Processing
You have the right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it, as you need it to establish, exercise, or defend legal claims.
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
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9.6. Right to Data Portability
You have the right to request the transfer of your personal data to you or to a third party. We will provide you or the third party with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
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9.7. Right to Withdraw Consent
You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of these rights, you can submit your request through our website at www.clear-app.com or contact us directly at support@clear-app.com
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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10. Security of Your Data
We take appropriate technical and organizational measures to protect your data against unauthorized access, loss, or misuse. This includes;
Using encryption and secure servers to store your data.
Hashing and encryption of audio content captured on device to ensure no audio leaves an individual’s device.
2FA as standard to access any information in the system
Principle of Least Privilege: In considering who has access to which data we consider each Simantea role and only make data available to those that need it.
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11. International Data Transfers
Your data may be transferred and stored outside the UK or the European Economic Area (EEA). We ensure that any such transfers are made in compliance with GDPR requirements and that your data is adequately protected.
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12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Any changes will be posted on this page with the updated date. We encourage you to review this policy periodically.
If we materially change this Policy, we will take steps to inform you of the change. We may do this through an in-application notification or another appropriate method of contacting you.
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13. Contact Us
If you have any questions, concerns, or complaints regarding this Privacy Policy or our data practices, please contact us at:
- Email: support@clear-app.com
- Website: www.clear-app.com