Executive Summary

EyesClear as a strategy does not retain client data. EyesClear provides an advanced Transaction MIS system for banks and the data EyesClear product processes is very sensitive so no data leaves client premises and never processed on EyesClear development systems.

Responsibility Matrix

All EyesClear team is required to take action on incidences.

Individual\Team Responsibility:

CEO

Be escalation point as well as periodically review incidences.

DPO

Second line of communications to manage the incidence response

Product Management Team

First line of communication to respond to incidences identified\raised


Identity & Access

EyesClear’s incidence management system retains user contact information. The creation of the contact information is through maker and checker process and the password is identified by the user itself at the point of raising an incidence or logging into the support portal.

You always have the right to access the personal information we store about you. And, if you wish to further limit our use of your personal information, please informationsecurity@eyesclear.com .

  • We only share your information as required by law or 

  • if EyesClear is acquired by or merged with another company — we don’t plan on that, but if it happens — we’ll notify you well before any info about you is transferred and becomes subject to a different privacy policy.

EyesClear does not share individual’s personal data with non-agent third parties. If this policy changes in the future, we will notify individuals and provide them with an opportunity to opt-out of having their data shared.

Your Rights With Respect to Your Information

GDPR gives people under its protection certain rights with respect to their personal information collected by us on the Site. Accordingly, EyesClear recognizes and will comply with GDPR and those rights, except as limited by applicable law. The rights under GDPR include:

  • Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.

  • Right to Correction. This is your right to request correction of your personal information.

  • Right to Erasure. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession (also known as the “Right to be forgotten”). However, if applicable law requires us to comply with your request to delete your information, fulfillment of your request may prevent you from using Userflow services and may result in closing your account.

  • Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority.

  • Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed.

  • Right to Object. This is your right, in certain situations, to object to how or why your personal information is processed.

  • Right to Portability. This is your right to receive the personal information we have about you and the right to transmit it to another party.

  • Right to not be subject to Automated Decision-Making. This is your right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable European law, or is based on your explicit consent.

All of those rights can be exercised through reaching out to informationsecurity@eyesclear.com.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en

Security & Encryption

All data is encrypted via SSL/TLS when transmitted from our servers to your servers. 

Cookies

In order to improve our services and the website, and provide more convenient, relevant experiences to you, we and our vendors may use “cookies”, “web beacons”, and similar devices to track your activities.

Third Parties

You understand that EyesClear uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to provide you with our services. A current list of vendors is available upon request.

Data Deletion

When you cancel your account, you can request to get your data deleted on informationsecurity@eyesclear.com. This information can not be recovered once it has been permanently deleted.

When transferring personal data from the EU

Since EyesClear don’t hold any client data, the data sits in your servers and it is in your discretion on the selection of the location. Eyesclear provides necessary support for the transfer if needed but the management of the data location sits with internal teams.

EU-US and Swiss-US Privacy Shield Framework

The EU-US Privacy Shield is an agreement between certain European jurisdictions and the United States that up until July 16, 2020, allowed for the transfer of personal data from the EU to the US. Participation in the Privacy Shield program is voluntary. The Swiss-US Privacy Shield is a similar program for data transferred to the US from Switzerland that was in effect until September 8, 2020.

EyesClear don’t use its client data with any third parties. To request to limit the use and disclosure of your personal information, please submit a written request to informationsecurity@eyesclear.com.

Law Enforcement

While we may be required to disclose your personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements, EyesClear won’t otherwise hand your data over to law enforcement unless a court order says we have to. And unless we’re legally prevented from it, we’ll always inform you when such requests are made. We will provide delayed notice if the legal prohibition is lifted.

EyesClear’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, EyesClear remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless EyesClear proves that it is not responsible for the event giving rise to the damage.

EU-US and Swiss-US Privacy Complaints

In compliance with the Privacy Shield Principles, Eyesclear commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact EyesClear by email at informationsecurity@eyesclear.com or via post at:

EyesClear Ltd, Level 39, One Canada Square, E14 5AB, London.

EyesClear has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints for more information and to file a complaint.

Location of Site and Data

This Site is operated in the United Kingdom.

Changes & Questions

EyesClear may update this policy once in a blue moon — we’ll notify you about significant changes by emailing the account owner or by placing a prominent notice on our site. You can access, change or delete your personal information at any time by contacting us at informationsecurity@eyesclear.com, or by mail at EyesClear Ltd, Level39, One Canada Square, E14 5AB, London UK.

Questions about this privacy policy? Please contact us at informationsecurity@eyesclear.com, or by mail at EyesClear Ltd, Level39, One Canada Square, E14 5AB, London UK., and we’ll be happy to answer them!

This policy have been adapted from the Basecamp open-source policies / CC BY 4.0.

For further info please write to: info@eyesclear.com