Privacy Policy
ADKER LTD (Trading as Cluzen.com)
Registration number: 16667510
Address: 234 Scott Ellis Gardens, London, NW8 9RT, United Kingdom
Contact: privacy@cluzen.com
1. Introduction
ADKER LTD (“we”, “us”, “our”), trading as Cluzen.com, is committed to protecting and respecting your privacy.
This Privacy Policy explains how we collect, use, store and protect your personal data when you use our cloud-storage services, website and related tools (collectively, the “Service”).
By creating an account or using the Service, you acknowledge that you have read this Privacy Policy.
ADKER LTD is the data controller responsible for your personal data.
2. Data We Collect
We collect and process the following categories of data:
2.1 Identity and Contact Data
Name
Email address
Password (encrypted)
Phone number (if provided)
2.2 Technical Data
IP address
Device identifiers
Operating system & browser type
Login timestamps
Security logs
2.3 Usage Data
Pages visited
Buttons clicked
Session activity
Interaction with features
Error logs
2.4 Content Data (Cloud-Stored Material)
This includes any files, documents, media or other material you upload, store or transmit through your Cluzen cloud account.
We do not access your stored content unless required for:
security or fraud prevention,
compliance with law,
solving support issues at your explicit request.
2.5 Communication Data
Emails, chat messages, support tickets and records of correspondence with us.
2.6 Cookies and Tracking Data
Collected in accordance with Section 10 (Cookies).
3. Legal Bases for Processing (GDPR / UK GDPR)
We process your personal data under the following legal bases:
Contract Performance: to provide the Service and operate your cloud account.
Legitimate Interests: to improve security, prevent abuse, ensure proper functioning and enhance user experience.
Legal Obligations: including tax, compliance and regulatory requirements.
Consent: for optional or non-essential data processing (e.g., marketing emails, non-essential cookies).
4. How We Use Your Information
We use your data to:
Create and manage your account
Operate cloud storage features and store your uploaded files
Ensure security, detect misuse and prevent fraud
Provide customer support
Improve the structure, layout and usability of the site
Notify you about updates or changes to the Service
Conduct analytics and performance optimisation
Comply with applicable legal and regulatory obligations
5. Disclosure of Your Information
We may share your data with:
5.1 Third-Party Processors
Providers who assist us with:
secure hosting & cloud infrastructure
data storage and backups
payment processing
analytics and performance monitoring
email services
These providers act strictly under our instructions and under GDPR-compliant data processing agreements (DPAs).
5.2 Corporate Transactions
If ADKER LTD sells or acquires assets, or if the company is acquired, user data may form part of the transferred assets.
5.3 Legal Requirements
We may disclose data where required to comply with legal obligations or lawful requests from authorities.
We do not sell your personal data.
6. International Data Transfers
Where your data is transferred outside the UK or EU, we ensure equivalent protection by using:
Standard Contractual Clauses (SCCs)
Adequacy decisions issued by the UK or EU
Other lawful transfer safeguards
7. Data Retention
We retain personal data only as long as necessary for the purposes described above.
Account Data: stored during the lifetime of your account
Cloud-Stored Content: deleted immediately when you close your account
Backups: retained for up to 30 days before automatic deletion
Payment and legal records: retained for up to 6 years (legal requirement)
You may request deletion of your account and all content at any time.
8. Security Measures
We implement appropriate technical and organisational measures, including:
Encryption in transit and at rest
Secure servers and segregated storage environments
Access controls and authentication safeguards
Continuous system monitoring & intrusion detection
Regular security audits and vulnerability testing
Compliance with industry best practices for cloud environments
No method of transmission over the internet is 100% secure, but we apply rigorous measures to protect your data.
9. Children’s Data
We do not knowingly collect personal data from individuals under 16 years old.
If such data is discovered, we will delete it immediately.
10. Cookies and Tracking
We use cookies to improve the performance and functionality of the Service.
10.1 Essential Cookies
Required for login, security and proper functioning.
10.2 Non-Essential Cookies (Consent Required)
Analytics, preferences and similar cookies are used only with your prior consent.
You may withdraw or update your preferences at any time.
You can also disable cookies in your browser settings, but some features may not work properly.
11. Your Rights (GDPR / UK GDPR)
You have the following rights:
Right of access – to obtain a copy of your data
Right to rectification – to correct inaccurate information
Right to erasure (“right to be forgotten”)
Right to restrict processing
Right to object to processing based on legitimate interests
Right to data portability – to move your data to another provider
Right to withdraw consent at any time
Right to lodge a complaint (see Section 12)
We respond to verified requests within 30 days.
Requests can be made to: privacy@cluzen.com
12. Right to Complain to the ICO
You have the right to lodge a complaint with:
Information Commissioner’s Office (ICO)
Website: www.ico.org.uk
Telephone (UK): 0303 123 1113
We encourage contacting us first so we can resolve your concerns.
13. Where We Store Your Data
Your data is stored in secure data centres operated by vetted third-party providers.
By using the Service, you consent to the transfer, storage and processing of your data in accordance with this Privacy Policy and applicable laws.
14. Changes to This Privacy Policy
We may update this Policy from time to time.
Material changes will be communicated to you with reasonable advance notice.
15. Contact
For privacy requests, questions or complaints:
📩 privacy@cluzen.com
