Date of last update: 06 February 2025
Summary of how we use your data
- Future Motion Solutions Ltd (also referred to as "Clearwatt", "we, "us") uses your personal data as a data controller for certain purposes including to provide you with the ClearWatt service.
- Data is shared with others including other ClearWatt group companies and third-party vendors. In some instances, personal data is transferred outside the EEA/UK. More information is set out in the “who we may share your personal data with” and “where we transfer your personal data” sections below.
- It also describes your data protection rights, including the right to object to some of the processing which we carry out and the right to withdraw your consent where we rely on it such as for direct marketing. More information about your rights, and how to exercise them, is set out in the “Your rights” section.
What does this notice cover?
This policy describes how Clearwatt makes use of your personal data that you provide us or we collect in relation to the provision of the ClearWatt service to you, which includes any services accessible through the website www.clearwatt.co.uk (“Website”) and the Clearwatt App (the "App").
For the avoidance of doubt, ClearWatt is a brand and product line managed, owned and operated by Future Motion Solutions Ltd.
The personal data we collect
We collect and process personal data which:
- you give to us when you register with us, use the ClearWatt service or when you communicate with us. This includes personal data you provide when you sign up to use the ClearWatt service, provide us with feedback, participate in surveys, and when you report a problem;
- is required for the provision of the ClearWatt service, such as your recorded Drives and driving behaviour. Please note that, in order to provide you with the ClearWatt service, the ClearWatt App will ask you to enable the collection of additional personal data after you install the ClearWatt app. The provision of this data is compulsory for ClearWatt to provide the service;
- we collect and process about you based on your use of the ClearWatt services, including the App and Website; and
- we receive from other sources, such as third parties who give us information about you.
We collect and process the following personal data about you:
Sometimes, we receive information about you from third parties. In particular:
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the ClearWatt service). The provision of all other data is optional.
How we use the personal data
We will only use your personal data for the purposes and legal bases set out below:
There are instances where we have a legitimate interest to use your data. Our legitimate interest will vary depending on what we are using your data for, and we explain above what the interest is and how it relates to the processing operations that we are carrying out. Where we process personal data on the basis of a legitimate interest, then – as required by data protection law – we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by using the contact details at the end of the notice.
Who we may share your personal data with
We share your data with the following categories of recipients:
Where we transfer your personal data
Where possible, we try to only process your personal data within the UK and European Economic Area (“EEA”). However, we may transfer your personal data to countries outside the UK / EEA. Whenever we transfer personal data outside of the UK / EEA, we ensure that appropriate safeguards are in place to protect the personal data. A copy of the relevant mechanism can be obtained for your review on request by using the contact details below.
How long do we keep your personal data for?
How long we keep your personal data will depend on the purpose for which we use it. We keep your information for no longer than is necessary to fulfil the purpose for which we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
After deletion of your account, we will retain your personal data for a period of up to seven years for fraud prevention and legal purposes (for example if we need to defend ourselves from a legal claim or are required to do so by law).
Where we process personal data for marketing purposes with your consent, we process the data until you ask us to stop and for a short period of 30 days after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.
Where we process personal data for site security purposes, we retain it for 24 months.
Where we process personal data in connection with performing a contract, we keep the data for 6 years from your last interaction with us.
Links to and from third parties
Our Website and our App may, from time to time, contain links to and from third party websites, plug-ins and applications, such as our partner networks, advertisers and affiliates. If you follow a link to any of these websites, plug-ins and applications, please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for these privacy notices.
Your rights
You have the following rights:
• Right to rectification: you have the right to correct any inaccurate or incomplete personal data we hold about you. Please keep us informed if your personal data changes during our relationship with you.
• Right of access: you can ask to receive a copy of your personal data.
• Right to erasure: you can ask us to delete your personal data/account in certain circumstances.
• Right to data portability: you have the right to request us to transmit personal data that you have provided to us, to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party, where technically feasible.
• Right to object: you have the right to object to us processing your personal data on the basis of our legitimate interests (or those of a third party), including processing for direct marketing purposes or profiling for purposes of direct marketing - your objection will be upheld, and we will cease processing your personal data, unless the processing is based on compelling legitimate grounds or is needed for the exercise or defence of legal claims that may be brought by or against us.
• Right to restrict processing: you have the right to 'block' or suppress further use of your information in certain circumstances (for example, where you think the information we are using about you is inaccurate, whilst we verify its accuracy). When usage is restricted, we can still store your personal data, but may not use it further.
• Right to withdraw consent: If you have given your consent for us to use your personal data, you have the right to withdraw your consent at any time. In particular, you will be able to withdraw it at any time either by (i) visiting the 'Account' section of our App and managing your preferences or by (ii) deleting your account or deleting the ClearWatt App. If you choose to do so that will not affect the lawfulness of any processing carried out before you withdraw your consent. In addition, we may continue to use the information we collected prior to your withdrawal of consent in an anonymised form for our internal business purposes, for analysis and to improve our services.
If you would like us to stop sending direct marketing to you, we offer simple ways to do this. Whenever you receive direct marketing, you will be given the option to unsubscribe. You may also update your preferences on your ‘Account’ section of the App. You can also tell us that you do not wish to receive any more marketing communications at any time by email or post using the details set out below in the ’Contact us’ section.
Please note that these rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.
For the exercise of any of your rights, you can contact us via email or post using the details set out below in the ’Contact us’ section. We may need to request specific information from you to help us confirm your identity and ensure your rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
If you have any unresolved concerns about our use of your personal data, you can make a complaint to us using the contact details provided on the ‘Contact us’ section below.
In addition, you have the right to complain to a data protection authority in the country that you reside in or, the country of your place of work or the country where the alleged infringement took place.
If you are located in the UK, you can make a complaint to the Information Commissioner's Office (ICO).
Changes we make to our Privacy Notice
Any changes we may make to our Privacy Notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Notice.
Contact us
The data controller of your information is Future Motion Solutions Ltd of County Hall, Floor 5, Westminster Bridge Road, London, SE1 7PB.
You can address any questions, comments, complaints or requests regarding this Privacy Notice to the following email address hello@clearwatt.co.uk or by post at:
Data Protection Officer
Future Motion Solutions Ltd
County Hall, Floor 5, Westminster Bridge Road, London, SE1 7PB
