Privacy notice

Who we are

ClearSky is a group of companies working in environmental markets: reforestation carbon credits, energy savings certificates and environmental commodities. The company responsible for your details (the "controller") is the ClearSky company you deal with:

• Clear Sky Limited, a company registered in England and Wales, number 13995377. Registered office: 27 Old Gloucester Street, London WC1N 3AX, United Kingdom.
• ClearSky Carbono, S.L., a Spanish company, NIF B75955468. Address: Paseo de la Castellana 43, 28046 Madrid, Spain.

To contact us about your details or your rights: email emmanuel.mendoza@clearskyltd.com, or write to either address above.

Who this notice is for

People who work at our customers, suppliers, project owners, partners, advisers and prospects. That includes people who email us, people copied into email with us, people named in contracts we hold, and people whose work details we find in business sources.

What we hold

• Your name, job title, company, work email, work phone and work address.
• What you and we have discussed or agreed in business: dates, subjects, documents, next steps.
• If you sign or are named in a contract with us, your name and your role in it.

We do not ask for sensitive information, and we do not hold ID numbers or bank details in these records.

Where we get it

• From you, when you email us, call us, meet us or sign with us.
• From others: colleagues and introducers who put us in touch, people who copy you into email with us, and contracts and related documents that name you.
• From public business sources: your company's website and official registers, such as Spain's carbon footprint registry (Ministry for the Ecological Transition), the companies gazette BORME, the EU VAT checker VIES and the global LEI index GLEIF.
• From business data providers: contact-finding services that give us work emails and phone numbers for people at companies we want to reach, an email checking service that confirms an address works, and a company information provider for company identity only. You can ask us which providers we use.

What we do with it

• Contact you about our work, and about deals, projects and contracts with your company.
• Keep our email in order: we file business email to the right company and deal in our records.
• Read contracts: we read contracts and related documents we hold to record their terms, parties and deadlines. This may include the names and roles of people who sign them or are named in them.
• Sort our contacts: we record how each contact relates to us (for example client, supplier or adviser). There is no scoring or ranking, and a person can change it at any time. We may copy your job title from the signature of an email you sent us.
• Keep the records the law requires for accounting, tax and company law.

Our legal basis

• Legitimate interest: developing and running our business with other businesses. We have weighed this against your interests and written that assessment down; you can ask us for a summary.
• Contract: performing a contract with your company or with you, or taking steps towards one.
• Legal obligation: keeping the records the law requires.

We do not sell your details. We do not make automated decisions about you that have legal or similarly significant effects.

You do not have to give us your details, but we cannot deal with you or your company without basic work contact details.

Who sees it

Our staff who need it for their work; our professional advisers, such as lawyers and accountants, where needed; and our service providers, who act only on our instructions.

Our service providers, and transfers outside the UK and EU

Our records are kept in Microsoft 365, Notion and our own systems on Microsoft Azure in Western Europe. We use AI services from Anthropic and TypeSafe to file email, sort contacts and read contract terms. All of them act only on our instructions under data processing terms, and none of them may use your details to train their models.

Some of these providers are in the United States. When your details leave the UK or the EU, they are protected as follows:

You can ask us for a copy of these safeguards.

How long we keep it

• While we have a business relationship with your company, and then for as long as the law requires us to keep the related records: usually 6 years after the end of the financial year in which the relationship or the contract ends, or longer while a tax period is still open.
• If we found your details in a business source and you never became a contact we work with, we delete them within 24 months of our last contact.

Checking identity (KYC)

Before some trades or contracts, we check the identity of a counterparty where the law requires it, or where a bank or counterparty requires it of us. We may then collect identity details of directors, owners or signatories. These are kept in a restricted area and used only for those checks. Where the law requires us to keep them, we keep them for the period it sets: 5 years after the relationship ends for Clear Sky Limited (UK Money Laundering Regulations 2017) and 10 years for ClearSky Carbono, S.L. (Spanish Law 10/2010). Otherwise we keep them only as long as the check needs. Our basis is legal obligation where the law requires the check, and otherwise our legitimate interest in meeting our banks' and counterparties' requirements and in not dealing with sanctioned or fraudulent parties.

Your rights

You can ask us for a copy of your details, or ask us to correct them, delete them, restrict how we use them, or send them to you in a portable format.

You can object at any time to our using your details for our legitimate interests, and in particular to our contacting you about our work. We will then stop. Reply "remove" to any of our emails, tell us on a call, or write to the address above. We mark you "do not contact" the same day and never switch it back on. If you ask us to delete your details, we keep only your email address and the date, so that we never contact you again.

We answer within one month.

If you are unhappy

Please tell us first. You can also complain to a data protection regulator: in the UK, the Information Commissioner's Office (ico.org.uk); in Spain, the Agencia Española de Protección de Datos (aepd.es); or the regulator where you live or work.

When we tell you

If you email us, our emails link to this notice. If we got your details from someone other than you, we tell you at our first message to you, or within one month of getting them, whichever is sooner.

Changes

We update this notice when what we do changes, and show the date at the top.