Freemium User Registration

REGISTERED USER ACCESS AGREEMENT

Definitions. The following terms shall have the meanings set out below. 

“CLO” refers to CLO Research Group Limited

“Services” means CLO’s information products, data, services, research content and

software via CLO Research website (www.clopremium.co.uk)

“Third-party Provider” means a supplier of data, information, software, services or other items that are part of or otherwise used in connection with the Services.

Registered user shall not (a) license, sublicense, transfer, sell, resell, publish in whole or in part, summarise, reproduce and/or otherwise redistribute the Services or any components thereof in any manner or (b) provide access to the Services or any portion thereof to any person, firm or entity. Registered user shall take all precautions that are reasonably necessary to prevent any unauthorised access, distribution or redistribution of the Services. 

“Registered User” means a registered user who registers to access freemium services and content provided by CLO Research Group

Registered user shall not use the Services, in whole or in part, in any manner that competes with CLO. Registered user shall not use or permit use of the Services or any data included therein in connection with the creation, structuring, development, managing, trading, marketing and/or promotion of any financial instrument or other investment product, investment vehicle or fund. The Services are provided for information purposes only and are not intended to be relied on or intended for any specific purpose. A separate approval is needed by CLO Research for any external use.

Registered user may access the Services via CLO Research website (www.clopremium.co.uk) or other communication means. Registered user shall hold, and shall ensure that any passwords/user IDs issued in connection with access to the Services in strict confidence. Registered user shall promptly advise CLO of any actual or threatened unauthorised disclosure or misuse of the Services or any such passwords/user IDs by registered user and shall cooperate with CLO in enforcing such restrictions and limitations.  

CLO and its Third-Party Providers disclaim any and all warranties and representations, express or implied, including any warranties of merchantability or fitness for a particular purpose or use as to the Services, including the information, data, software or products contained therein or the results obtained by their use or as to the performance thereof. 

A reference to a particular investment or security, a credit rating or any observation concerning an investment or security provided in the services is not a recommendation to buy, sell or hold such investment or security or make any other investment decisions and does not address the suitability of any investment or security. The Services should not be relied on and are not a substitute for the skill, judgment and experience of Registered User, its management, employees, advisors and/or Registered User in making investment and other business decisions. CLO does not act nor shall be deemed to be acting as a fiduciary in providing the Services. 

Neither CLO nor any of its Third-Party Providers guarantee the adequacy, accuracy, timeliness or completeness of the Services or any component thereof or any communications, including oral or written communications (including electronic communications) or output with respect thereto. Neither CLO nor any of its Third-Party Providers shall be subject to any damages or liability for any errors, omissions, interruptions or delays in the Services. The Services and all components thereof are provided on an “as is” basis and registered user use of the Services is at registered user’s own risk. CLO shall not be responsible or have any liability for (a) the procurement, installation or maintenance of any equipment on which the Services are accessed by registered user; (b) any communications connection by which the Services are transmitted; (c) the transmission to registered user of the Services beyond the point of CLO’s or its Service facilitator’s computer facility; or (d) any fees (if any) payable by registered user for any communications lines to any distributor or to any other person, firm or entity.

Notwithstanding anything to the contrary in this Agreement, in no event whatsoever shall CLO or any of its Third-Party Providers be liable for any indirect, special, incidental, punitive or consequential damages, including loss of profits, trading losses, business interruption losses or lost time or good will, even if they have been advised of the possibility of such damages, whether in contract, tort, strict liability or otherwise. Neither CLO nor any of its Third-Party Providers shall be liable (except as expressly provided in Clause below, for any claims against registered user by third parties. 

All proprietary rights (including copyrights, trade secrets, database rights, trademark rights or other intellectual property right of any nature) in the Services are and shall remain the sole and exclusive property of CLO and its Third-Party Providers. The Services are compiled, prepared, revised, selected and arranged by CLO and its Third-Party Providers through the application of methods and standards of judgment developed and applied through the expenditure of substantial time, effort and money, and the Services constitute the valuable intellectual property of CLO and its Third-Party Providers. Subscriber shall protect the copyrights, trade secrets, database rights, trademarks, and other proprietary rights of CLO and its Third-Party Providers in the Services, including any contractual, statutory, or common-law rights, during and after the term of this Agreement. Any branding or statements of attribution provided with the Services shall not be removed by the Subscriber.

Copying of, use of, access to or distribution of the Services or any information, data or software contained therein in breach of this Agreement shall cause CLO and/or its Third-Party Providers irreparable injury that cannot be adequately compensated for by means of monetary damages. CLO and its Third-Party Providers may enforce the provisions hereof by means of equitable relief (including injunctive relief) in addition to any other rights and remedies that may be available. In the event CLO has reasonable grounds to believe registered user is violating the terms and/or conditions set forth in this Agreement, CLO shall have the right to suspend delivery of, or registered user’s access to, the Services. To the fullest extent permitted by law, the registered user shall be jointly and severally liable to and indemnify and defend CLO and its Third-Party Providers from and against any and all costs, claims, damages or liabilities (including reasonable attorneys’ fees) arising out of use of the Services by registered user, except to the extent such claims directly arise from the Clause below.

If CLO or registered user wishes to use promotional material referring to the other party, its services or marks, the party desiring to use such material shall, before using it, submit such material to the other party for review and written approval, which review and written approval shall be in such party’s sole discretion to grant or withhold.

This Agreement shall be interpreted, construed and enforced in accordance with the laws of England, without giving effect to the conflicts of laws provisions thereof. The parties hereto and their successors and assigns irrevocably consent to the exclusive jurisdiction of any courts located in London, England for the resolution of any disputes arising from or related to this Agreement. 

Each registered user and CLO are independent contractors, and nothing in this Agreement shall be construed or implied to create any partnership, joint venture, agency, franchise, sales representative, or employment relationship between the parties. Neither party is an agent or representative of the other or is authorised to make any warranties or assume or create any other obligations on behalf of the other.

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PRIVACY NOTICE

Welcome to our privacy notice. CLO Research Group Limited (”we, the “Company”) is committed to protecting and respecting your privacy. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide directly through this website.

Please read the following carefully to understand our views and practices regarding your personal data and how we will use it.

For the purpose of the Data Protection Act 2018 (the Act), we are the data controller. Our Data Protection Officer is Poh-Heng Tan. He can be contacted at enquiry@cloresearch.co.uk. Our registered address is at Kemp House 124 City Road London, EC1V 2NX. You may contact us to find out more about the way we use personal data via email at enquiry@cloresearch.co.uk.

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.

IF YOU DO NOT PROVIDE PERSONAL DATA

If we need to process the data you provide us with to fulfil our service, and you fail to provide that data when requested, we may not be able to perform the service, in which case, we may have to cancel a service you have with us. We will of course notify you if we need to cancel a service.

WHAT INFORMATION DO WE USE?

We will collect and process the following information about you:

Information you give us about you. You give us this information by filling in forms on our website (cloresearch.co.uk) that you may access directly or through another website, or by corresponding with us by e-mail. It only includes basic personal data required for us to communicate with you if you become a customer. The information you give us may include your full name, email address, physical address.

Information we collect about you.

With regard to each of your visits to our website we will automatically collect the following information:

our communications with you or between you and other users on the website;

content statistics (e.g. your input on the website);

technical information, including device identifiers, device type, geo-location information, connection information, statistics on page views, traffic to and from the website, the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, ad data and platform; and

information based on your activities on the website, including the mobile network information, full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

Information we receive from other sources.

This is the information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (e.g. business partners, sub-contractors in technical, payment and delivery services, search information providers, credit reference agencies). We will notify you when we receive personal data about you from other sources and the purposes for which we intend to use that information.

COOKIES  

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our website. This website uses a cookie control system which you accept on your first site visit. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.

HOW DO WE USE THIS INFORMATION?

We will only use personal data when the law allows us to. You will not be subject to decisions based on automated data processing without your prior consent. Most commonly, we will use your personal data in the following circumstances:

where we need to perform the contract we are about to enter into or have entered into with you;

to provide you with our email notifications, newsletters and marketing communications at either your request or with your consent when completing a registration form for the service;

where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests;

to ensure that our service is delivered efficiently, including where we wish to notify you of any changes to the service, generate relevant content, tailor the website to your interests, and improve your visibility to potential collaborators;

to provide customer service to you in relation to your use of the service, to deal with inquiries and complaints relating to the use of the service and to notify you about any changes to our service;

to administer, support, improve, optimise and develop our service;

to produce reports which may be used, sold, or published by us at our sole discretion provided that any data or reports will be anonymised and not refer to any individual user of the services;

for internal record keeping and marketing and demographic studies to improve the services that we provide;

for security purposes;

where we need to comply with a legal or regulatory obligation; and

to investigate a potential breach of our terms and conditions.

We will ask for your consent before using information for a purpose other than those that are set out in this privacy notice.

MARKETING 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your contact details and technical data that we collect about you, such as your IP address and the way you browse our website to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services through us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at enquiry@cloresearch.co.uk.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any external company for marketing purposes.

CHANGE OF PURPOSE 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to know how the processing for the new purpose is compatible with the original purpose, please email us at enquiry@cloresearch.co.uk.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

HOW DO WE SHARE YOUR INFORMATION?

You acknowledge and agree that from time to time we have the right to share your personal information with:

Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

Selected third parties including:

Rocket Science Group, LLC for use of their service, Mailchimp (“Mailchimp”) based in the US, to send you our newsletter, if you consent;

Google LLC. (“Google”) based in the U.S., for the storage of documents that include your personal data on Google Drive, the use of Gmail in order to contact you about any services we provide to you and Google Contacts to store and maintain our clients’ details;

Microsoft Corporation (“Microsoft”) based in the U.S. for the storage of documents that include your personal data on Microsoft One Cloud;

Xero Limited (“Xero”) based in the EU, Australia, Singapore and the US, to issue our clients with invoices for services we provide them with;

PayPal (Europe) S.à r.l. et Cie, S.C.A. (“PayPal”) based in the EU, for processing payments;

select business partners, suppliers and sub-contractors for the performance of any contract we enter into with you.

Other than as expressly set out in this Privacy Notice or as otherwise required or permitted by law, we will not share, sell, or distribute any of the information you provide us without your consent.

We will disclose your personal information (i) to any third party to whom disclosure is necessary to enable us to fulfil your orders and provide you with any service which you have subscribed to; (ii) where required to do so by law or court order; and (iii) to any person to whom disclosure is necessary to enable us to enforce our rights under this privacy notice or under our Terms and Conditions.

This includes when:

We sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.

The company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements; or to protect the rights, property, or safety of the company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Once we have received your information, we have a Data Protection regime in place to oversee the effective and secure processing of your personal data and we will use strict procedures and security features to try to prevent unauthorised access.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website at transmission stage; any transmission is at your own risk.

HOW LONG DO WE KEEP YOUR DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We generally retain your data for six (6) months. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We are required under UK tax law to keep basic personal data about our customers (name, address, contact details) for a minimum of six (6) years after which time it will be destroyed. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. You can ask us to delete your data in some circumstances. See below for further information.

WHAT ARE YOUR RIGHTS?

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

Request access to your personal data.

Request correction of your personal data.

Request erasure of your personal data.

Object to processing of your personal data.

Request restriction of processing your personal data.

Request transfer of your personal data.

Right to withdraw consent.

EXERCISING YOUR RIGHTS

If you wish to exercise any of your rights set out above, please email us at enquiry@cloresearch.co.uk.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

THIRD-PARTY LINKS 

Our website may contain links to websites or access to plug-ins and applications. We do not control and accept any liability or responsibility for third-party websites. This privacy notice is not applicable to other websites. Please consult the terms and conditions and privacy policies of third-party websites to find out how they collect and use your personal data.

SOCIAL MEDIA PLATFORM

All communications and actions carried out on third-party social media platforms will be subject to the terms and conditions and privacy policies of those websites. Please note that we will never ask for your personal or sensitive information through social media platforms. Please only discuss sensitive information through email.

This website may use social sharing buttons which allow you to share web content quickly on a social media platform. Please use such buttons at your discretion as the third-party platform may track and save your request.

CHANGES TO OUR PRIVACY NOTICE  

Any changes we make to our privacy notice in the future will be posted on this page and notified to you by e-mail. By continuing to use this website, you are agreeing to the changes that have been made, and any future changes, to the policy.