Early Access and Newsletter Privacy Notice
Version: PN-2 (replaces PN-1, the early-access-only notice) · Last updated: [DATE OF PUBLICATION]
This notice explains how Clearline Systems ("we", "us") handles your personal information when you:
- ask for early access to our kits, download them and give us feedback;
- sign up for a free gap-analysis checklist on https://clearlinekits.com; or
- tick the optional box to get our news emails (newsletter).
While early access is open, this notice applies to these sign-ups. Our Privacy Policy (https://clearlinekits.com/privacy/) covers the same information and our website. If the two differ, this notice applies to these sign-ups.
1. Who we are
Clearline Systems, [CONTACT ADDRESS], support@clearlinekits.com. We're based in New South Wales, Australia, and we are the controller of your information for early access, the checklist and our news emails.
2. What we collect, why, and our lawful basis
2A. Early access
| Information | Why we use it | Lawful basis (EU/UK GDPR) |
|---|---|---|
| Name and work email (required) | To check your request, send your download link, send feedback surveys and reply to you | Performing our agreement with you (the Early Access License) |
| Organization (optional) | To keep to one early-access place per organization | Legitimate interests (running a fair, limited test) |
| The page you came from and signed up on, including any campaign tags in its address (for example utm_source=linkedin) | To see which posts and pages lead to useful requests | Legitimate interests (improving our resources and understanding interest before launch) |
| Which standards you chose, and which price card you came from (for example "Core Kit for ISO 9001:2026, US$490 at launch") | To send the right kits, group feedback by kit, and understand interest in each kit | Performing our agreement with you (standards); legitimate interests (understanding interest before launch) |
| Your checkbox choices, with the date and time | To record that you accepted the license and, if you ticked it, agreed to launch emails | Legal obligation / legitimate interests (keeping evidence of consent) |
| Your feedback (survey answers, emails, call notes) | To improve the kits and decide how to launch them | Legitimate interests (improving our products). You can choose not to answer. |
| Download and email activity (email delivery, bounce, click and unsubscribe records, and requests for the download files, which our hosting provider logs) | To deliver the kits, check that the download links worked, and honor unsubscribes | Legitimate interests; legal obligation (unsubscribes) |
| Launch and marketing emails (only if you tick the optional box) | To tell you when the kits launch and send occasional news | Consent. You can withdraw it at any time. |
2B. Free gap-analysis checklist
| Information | Why we use it | Lawful basis (EU/UK GDPR) |
|---|---|---|
| Email (required) and first name (optional) | To give you the checklist you asked for (on screen and/or by one delivery email) and reply if you write to us | Performing the service you asked for (contract) |
| Which checklist (standard), your role (for example "new certification" or "transition", if you choose one) and the page you signed up on, including any campaign tags in its address (for example utm_source=linkedin) | To send the right checklist, understand which checklists are useful and see which posts and pages lead to sign-ups | Performing the service you asked for; legitimate interests (improving our free resources) |
| Sign-up date and time, and the IP address our email provider records at sign-up | To keep a record of the sign-up and prevent abuse | Legitimate interests (keeping records and preventing abuse) |
Getting the checklist doesn't sign you up for news emails. You only get those if you tick the separate box (2C).
2C. News emails (newsletter), only if you tick the optional box
| Information | Why we use it | Lawful basis (EU/UK GDPR) |
|---|---|---|
| Email and first name (if given) | To send occasional emails with practical tips and news about Clearline Systems kits | Consent. You can withdraw it at any time, by clicking unsubscribe in any email or by writing to us. |
| Your consent record: which box you ticked, the wording version shown (for example checklist_news_optin = yes-CL-1 for the checklist form, or yes-EA-1 for the early-access form), and the date, time and IP address of sign-up | To show that you agreed, and to what wording | Legal obligation / legitimate interests (keeping evidence of consent) |
| Email delivery, bounce and unsubscribe records | To deliver emails and honor unsubscribes | Legitimate interests; legal obligation (unsubscribes) |
The news box is never pre-ticked, and you get the checklist or early access whether or not you tick it.
We don't collect payment details (nothing is for sale), and we don't ask for sensitive information. Please don't include it, ISO standard text, or other people's personal information in feedback or replies.
Email tracking: we turn off open tracking in all our emails. Our email provider records whether links in our emails are clicked. We use that only to see whether download links worked and which resources are useful, not to build profiles.
2D. Website analytics (Umami) and hosting logs
Website analytics (Umami). We use Umami Cloud, a privacy-focused analytics service run by Umami Software, Inc., to count visits and clicks on buttons such as downloads and sign-up buttons. It records the page address (including any campaign tags and click IDs in it, such as utm_source or gclid), the page you came from, page title, browser, operating system, device type, screen size, language and an approximate location worked out from your IP address. Umami says it doesn't store your IP address. It doesn't use cookies and doesn't receive anything you type into a form. It doesn't follow you across other websites, and we don't use advertising pixels or build profiles of individual visitors. Umami stores this data on its cloud servers. Umami Software, Inc. is a US company. You can object at any time by emailing support@clearlinekits.com. Blocking scripts or turning on your browser's tracking protection also stops it. Our lawful basis is legitimate interests (running and improving our website).
Server logs. Our website host keeps server logs (IP address, pages and files requested) to serve the site and keep it secure, kept by Netlify for the period its service sets.
3. Testimonials
We'll only publish your name, organization, a quote or a testimonial if you give us separate, written permission. We may use feedback without identifying you (for example, "a testing organization found the risk register hard to follow").
4. Who we share it with
We don't sell your information or use it for advertising. We share it only with providers that help us run early access, the checklist and our news emails:
| Service | Provider | Role | Where |
|---|---|---|---|
| Email sending (early-access, checklist and news emails), sign-up lists, consent records and surveys | MailerLite, Inc. (548 Market St, PMB 98174, San Francisco, CA 94104-5401, USA). MailerLite's privacy policy: https://www.mailerlite.com/legal/privacy-policy | Processor | United States (MailerLite, Inc.); data stored in Google Cloud data centers in the Netherlands (EU). Its sub-processors are Google Cloud EMEA Ltd (Ireland) and Vercom S.A. (Poland). |
| File delivery (early-access download links) | Netlify (a separate download site) | Processor | United States |
| Support mailbox | Porkbun LLC (forwards emails sent to support@clearlinekits.com) and Google (Gmail, where we receive and keep support emails) | Processor (Porkbun passes emails on; Google stores them) | United States |
| Website hosting (server logs; also serves the free checklist downloads) | Netlify | Processor | United States |
| Website analytics (above) | Umami Software, Inc. (Umami Cloud) | Processor | Umami Software, Inc. (United States) |
Emails to support@clearlinekits.com are forwarded by Porkbun to a Google (Gmail) mailbox.
MailerLite also uses some data about how its service is used (for example delivery and technical logs) for its own purposes, such as security and product development. For that data, MailerLite is responsible under its own privacy policy.
We may also disclose information where the law requires it.
5. Overseas transfers
We're in Australia, and some providers are in other countries. Our email provider, MailerLite, Inc., is in the United States and stores data in the Netherlands (EU). Umami Software, Inc., our analytics provider, is in the United States. Our hosting and file-delivery provider Netlify, our domain and email-forwarding provider Porkbun, and Google (our support mailbox) are also in the United States. This applies to early-access, checklist and news sign-ups alike. When information goes from the EU or UK to us or our providers, we rely on appropriate safeguards, such as an adequacy decision (including the EU-US Data Privacy Framework and its UK Extension, for certified US providers), Standard Contractual Clauses or the UK International Data Transfer Addendum. For MailerLite, its Data Processing Addendum includes the EU Standard Contractual Clauses (with the UK Addendum), and MailerLite, Inc. says it is certified under the EU-US Data Privacy Framework, its UK Extension and the Swiss-US Data Privacy Framework. You can read MailerLite's Data Processing Addendum at https://www.mailerlite.com/legal/data-processing-agreement. Where the Australian Privacy Principles apply, we take reasonable steps to make sure overseas providers handle your information consistently with them.
6. AI-assisted support
Replies are AI-assisted. When you email us, your message (including your name, email address and anything you include) may be processed by an AI service to help draft a reply. Replies drafted this way say so. We don't use AI to make decisions with legal or similarly significant effects on you. A person reviews every early-access request and decides who gets a place.
7. How long we keep it
| Information | Kept for |
|---|---|
| Requests that weren't approved (for example duplicates, or requests we couldn't accept before early access closed) | Deleted within [30] days |
| Tester details and download records | Until 6 months after early access ends (that is, after the last tester's feedback period ends), then deleted, unless you're on the launch list. When we delete someone from MailerLite, MailerLite says its "forget" function erases their data within 30 days. |
| Feedback | Identifiable feedback until 6 months after early access ends (that is, after the last tester's feedback period ends); after that, only in anonymous form |
| Launch/marketing list (if you ticked the early-access launch box) | Until you unsubscribe, or after [12] months without launch |
| Checklist sign-ups, checklist only (no news box ticked) | Deleted 6 months after sign-up, unless you've asked us to delete them sooner. |
| News subscribers (you ticked the news box) | Until you unsubscribe or ask us to delete your details. If you haven't clicked or replied to any of our emails in 24 months, we send you a last-chance email and then remove you. |
| Unsubscribed addresses | We keep only the email address, the date and the fact that you unsubscribed, so we don't email you again. |
| Consent records for news emails | For as long as you're subscribed, plus 2 years after you unsubscribe or are removed, as evidence of your consent. |
| License acceptance and consent records | Consent records (for example the early-access launch-email box): for as long as you're subscribed, plus 2 years after you unsubscribe or are removed. License acceptance records: [LICENSE ACCEPTANCE PERIOD: not yet decided]. We export these records from MailerLite and keep the export securely, so we can delete other details from MailerLite sooner. |
| Support emails | [SUPPORT RETENTION PERIOD] |
| Website analytics (Umami) | [UMAMI RETENTION] |
| Website server logs | Kept by Netlify for the period its service sets. |
Our email provider keeps our data for as long as we use its service. If we close our MailerLite account, MailerLite says it deletes or anonymizes the data within 30 days, apart from backups it isolates and data it must keep by law. (Source: MailerLite Privacy Policy s 11 and DPA s 9.)
8. Your choices and rights
- Withdraw consent / unsubscribe from news emails at any time with the link in any email, or by writing to support@clearlinekits.com. We act on unsubscribes promptly, and within 5 business days at the latest. Withdrawing consent doesn't affect emails already sent.
- Good to know: the unsubscribe link stops all our emails to that address, including early-access emails such as download links and surveys. If you only want to stop news emails, write to us and we'll switch off just those.
- Delete or correct your details: email support@clearlinekits.com with "delete my details" or your correction. We'll confirm when it's done. If you've already downloaded kits or the checklist, you can keep using them under their terms.
- Access, restriction, objection and portability: you can ask for these too. EU/UK residents can also withdraw consent at any time and complain to their data protection authority (in the UK, the ICO). In Australia, you can complain to the OAIC if you're not satisfied with our response.
- We'll verify requests and reply within the time the law requires.
9. Security
We use reputable providers, strong passwords and two-factor authentication. Early-access download links aren't listed publicly, but anyone who has a link can use it, so please don't share yours. No system is completely secure. If a breach is likely to cause serious harm, we'll tell you and the regulator where the law requires it.
10. Contact
Clearline Systems · [CONTACT ADDRESS] · support@clearlinekits.com