Privacy Policy
This Privacy Policy explains how Clearway Acquisition, trading as Clearway Aesthetics ("Clearway", "we", "our", or "us") collects, uses, stores, and protects personal information when you visit clearwayaesthetics.com, contact us, use our services, or interact with systems and technology provided by us (collectively, the "Service").
Clearway provides technology, infrastructure, software, automation, analytics, marketing, and patient acquisition services to aesthetic, surgical, medical, and healthcare practices.
This Privacy Policy applies to information we process in our own capacity as a controller, including information collected through our website and our direct business relationships.
Where Clearway processes personal information solely on behalf of a client practice, that practice may be the data controller and Clearway may act as a data processor. In those circumstances, the relevant Data Processing Agreement ("DPA") between Clearway and the client governs that processing.
Where HIPAA applies and Clearway acts as a Business Associate, the applicable Business Associate Agreement ("BAA") governs our handling of Protected Health Information ("PHI") alongside applicable law.
1. Who We Are
The entity responsible for this website and Clearway's services is:
Clearway Acquisition
Trading as Clearway Aesthetics
Email: info@clearwayaesthetics.com
Website: clearwayaesthetics.com
For purposes of applicable UK data protection law, Clearway Acquisition may act as the data controller for personal information collected directly from individuals through our website and business operations.
2. Information We Collect
Depending on how you interact with Clearway, we may collect the following categories of information.
Information you provide directly
This may include:
name;
email address;
telephone number;
company or practice name;
job title or professional role;
business address;
information about your practice;
procedures or services offered;
information provided through contact forms;
information contained in communications with us;
billing and payment information;
information provided when requesting a consultation or demonstration; and
other information you voluntarily provide.
Information collected through our Service
Where Clearway provides services to a client practice, our systems may process information relating to prospective or existing patients, including:
names;
contact details;
enquiry information;
procedure interests;
appointment information;
communications and enquiries;
booking information;
payment or deposit information;
website interaction information;
information supplied by the patient to the practice; and
other information necessary to provide the Service.
The information processed on behalf of a client practice is generally controlled by that practice rather than Clearway.
Automatically collected information
When you visit our website or use certain aspects of the Service, we may automatically collect information such as:
IP address;
browser type;
device type;
operating system;
pages viewed;
referring website;
approximate geographic information derived from IP address;
interaction and usage information;
timestamps; and
technical information relating to the security and operation of our systems.
3. How We Use Information
We use personal information for purposes including:
providing and operating the Service;
responding to enquiries;
communicating with prospective and existing clients;
arranging demonstrations and consultations;
managing client accounts;
providing customer support;
processing payments;
administering contracts;
providing marketing and patient acquisition services;
operating software, automation, analytics, and infrastructure;
monitoring system performance and security;
preventing fraud, abuse, and unauthorised access;
improving our products and services;
developing new software and functionality;
generating aggregated or anonymised analytics;
complying with legal and regulatory obligations; and
protecting our rights, property, and systems.
We will not use personal information for purposes incompatible with the purposes described in this Privacy Policy unless permitted or required by applicable law.
4. Legal Bases for Processing
Where UK GDPR or EU GDPR applies, we process personal information on one or more lawful bases, including:
Performance of a contract
Where processing is necessary to provide services, manage an account, process payments, or perform obligations under an agreement.
Legitimate interests
Where processing is necessary for legitimate business purposes and those interests are not overridden by the individual's rights and interests.
This may include operating and improving our services, securing our systems, communicating with business contacts, preventing fraud, and managing our business.
Consent
Where we rely on consent, you may withdraw that consent at any time.
Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
Legal obligation
Where processing is necessary to comply with applicable law or a lawful request from a regulatory or governmental authority.
5. Patient Information Processed on Behalf of Practices
Clearway provides systems that may allow practices to collect, communicate with, book, and manage prospective patients.
Where a practice uses Clearway to process patient information, the practice generally determines:
what information is collected;
why it is collected;
how it is used;
how long it should be retained; and
the legal basis for processing it.
In these circumstances, Clearway generally acts as a data processor on the practice's instructions.
We process such information only as necessary to provide the contracted Service, subject to the applicable DPA and any other written instructions or agreements.
The practice remains responsible for providing patients with appropriate privacy information and ensuring that it has a lawful basis for collecting and processing patient information.
6. Healthcare Information and HIPAA
Clearway may provide services to healthcare providers in the United States.
Where information constitutes Protected Health Information ("PHI") under HIPAA and Clearway is acting as a Business Associate, Clearway will process such information in accordance with the applicable Business Associate Agreement and HIPAA requirements.
Our HIPAA obligations may include implementing appropriate safeguards, limiting permitted uses and disclosures, reporting applicable security incidents or breaches, and requiring appropriate protections from relevant subcontractors.
HHS states that a software provider may become a Business Associate where it has access to PHI on behalf of a covered entity; merely selling software without access to PHI does not necessarily create that relationship. HHS.gov
Clearway's BAA governs the specific HIPAA relationship where applicable.
This Privacy Policy does not constitute a healthcare provider's Notice of Privacy Practices and does not replace any notice that a covered healthcare provider is required to provide to its patients.
7. Artificial Intelligence
Certain Clearway services may use artificial intelligence and machine-learning technologies.
AI may be used to:
analyse business and operational information;
generate summaries and insights;
identify patterns and opportunities;
assist with patient communications;
generate content;
assist with workflow automation;
provide recommendations; and
perform authorised actions within connected systems.
Where AI processes personal information on behalf of a client practice, such processing is subject to the applicable client agreement, DPA, BAA where applicable, and instructions from the client.
We do not use client or patient information to train publicly available AI models unless expressly authorised by the applicable client agreement or otherwise permitted by law.
AI-generated information may contain errors. AI outputs should not be treated as medical advice, diagnosis, or clinical decision-making.
8. How We Share Information
We may share personal information with:
Service providers
We may use third-party providers for services such as:
cloud hosting;
data storage;
CRM;
communications;
email and messaging;
analytics;
payment processing;
advertising;
scheduling;
security;
artificial intelligence;
software integrations; and
technical infrastructure.
These providers may process information on our behalf where necessary to provide the Service.
Client practices
Where information relates to a patient enquiry made through a Clearway system operated for a client practice, that information may be provided to the relevant practice.
Legal and regulatory authorities
We may disclose information where required by law, legal process, court order, regulatory authority, or where reasonably necessary to protect our rights, users, systems, or others.
Business transfers
If Clearway is involved in a merger, acquisition, restructuring, financing, sale of assets, or similar transaction, personal information may be transferred as part of that transaction, subject to applicable law.
We do not sell personal information as a standalone commercial product.
9. Third-Party Services
Clearway integrates with third-party platforms and services.
These may include advertising platforms, payment processors, CRM systems, communication providers, scheduling platforms, hosting providers, AI providers, analytics services, and other technology providers.
Your use of a third-party service may be governed by that provider's own privacy policy and terms.
Where Clearway acts as a processor, third-party providers that process personal information on our behalf may be appointed as subprocessors where permitted by the applicable agreement.
10. International Data Transfers
Clearway is based in the United Kingdom and may work with clients, service providers, and technology providers located in other countries, including the United States.
As a result, personal information may be transferred outside the UK or European Economic Area.
Where UK GDPR or EU GDPR applies, we will use appropriate legal safeguards for international transfers where required, which may include:
adequacy regulations or decisions;
UK International Data Transfer Agreements or Addendums;
EU Standard Contractual Clauses; or
other legally recognised transfer mechanisms.
11. Data Security
We take reasonable technical and organisational measures designed to protect personal information against:
unauthorised access;
accidental loss;
destruction;
alteration;
disclosure; and
other unlawful processing.
Security measures may include access controls, authentication, encryption where appropriate, monitoring, secure infrastructure, and restricted access.
No internet-based system can be guaranteed to be completely secure.
If we become aware of a personal-data breach requiring notification under applicable law or contract, we will take appropriate steps to investigate, contain, and respond to the incident and make notifications where legally required.
Where we process personal data on behalf of a client, our obligations regarding security incidents and breach notifications may be governed by the applicable DPA or BAA.
12. Data Retention
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including to:
provide the Service;
maintain business and financial records;
comply with legal obligations;
resolve disputes;
enforce agreements; and
protect our legitimate business interests.
Retention periods may vary depending on the nature of the information and the reason for processing.
Where Clearway processes personal information solely on behalf of a client practice, retention and deletion will generally be governed by the client's instructions and the applicable DPA or BAA.
When personal information is no longer required, we will delete, anonymise, or securely dispose of it where reasonably practicable and where permitted by applicable law.
13. Cookies and Similar Technologies
Clearway may use cookies and similar technologies to:
operate the website;
remember preferences;
understand website usage;
measure performance;
improve user experience;
maintain security; and
support marketing activities where permitted.
Where required by law, we will obtain consent before placing non-essential cookies or similar technologies on your device.
You can control cookies through your browser settings and, where available, our cookie preference controls.
Some website functionality may not operate correctly if certain cookies are disabled.
14. Marketing Communications
We may use your contact information to send business communications, including information about Clearway's services, product updates, demonstrations, or relevant developments.
Where consent is required, we will obtain it before sending marketing communications.
You may unsubscribe from marketing communications at any time by following the unsubscribe instructions contained in the communication or contacting us directly.
We may continue sending transactional or service-related communications where necessary to provide a service or administer a contractual relationship.
15. Your Rights
Depending on your location and applicable law, you may have rights including:
the right to access your personal information;
the right to correct inaccurate information;
the right to request deletion;
the right to restrict processing;
the right to object to processing;
the right to data portability;
the right to withdraw consent;
rights relating to automated decision-making and profiling; and
the right to lodge a complaint with a relevant supervisory authority.
These rights are not absolute and may be subject to legal exceptions.
If you wish to exercise a right, contact us using the details below.
Where Clearway processes information solely on behalf of a client practice, you may need to direct your request to that practice. We will provide reasonable assistance where required by applicable law or our agreement with the practice.
16. Children's Information
The Service is not directed toward children.
We do not knowingly collect personal information from children through our website for independent commercial purposes.
Where a client practice uses Clearway's systems to communicate with patients, the practice remains responsible for ensuring that its collection and processing of information from minors complies with applicable law.
If you believe a child has provided personal information to Clearway without appropriate authorisation, please contact us.
17. Third-Party Websites
Our website or Service may contain links to third-party websites or services.
We are not responsible for the privacy practices, security, content, or policies of third-party websites.
We recommend reviewing the applicable privacy policy before providing personal information to a third party.
18. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our services, technology, legal obligations, or privacy practices.
Where changes are material, we will take reasonable steps to notify affected individuals where required by law.
The latest version will always be made available on our website.
The "Last updated" date at the beginning of this Privacy Policy indicates when it was most recently revised.
19. Contact Us
If you have questions about this Privacy Policy, wish to exercise a privacy right, or have a concern regarding our handling of personal information, contact us:
Clearway Acquisition
Trading as Clearway Aesthetics
Email: info@clearwayaesthetics.com
Website: clearwayaesthetics.com