Privacy Policy

Last updated: 5 April 2026

This Privacy Policy explains how 79th Unit Limited ("we", "us", "our") collects, uses, stores, and protects your personal data when you use the ClearSky platform and associated services.

1. What Data We Collect

Account Data

• Name, email address, and password (hashed)
• Organisation name and role (if applicable)
• Billing information processed via Stripe (we do not store card details)

Usage Data

• Pages visited, features used, and session duration
• IP address, browser type, device information
• Searches performed and reports generated

Signals Data

• OSINT intelligence data you submit, upload, or generate through the platform
• Case files, evidence submissions, and investigation notes
• Scraped public-source data processed through our pipelines

2. Legal Basis for Processing

We process your personal data under the following lawful bases as defined by the UK General Data Protection Regulation (UK GDPR):

• Contract: Processing necessary to perform our contract with you (e.g. providing the ClearSky platform, managing your subscription).
• Legitimate Interest: Processing necessary for our legitimate interests (e.g. improving the platform, fraud prevention, security monitoring) where those interests are not overridden by your rights.
• Consent: Where you have given explicit consent (e.g. marketing communications). You may withdraw consent at any time.
• Legal Obligation: Processing necessary to comply with a legal obligation (e.g. responding to lawful requests from law enforcement).

3. Retention Periods

• Account data: Retained for the duration of your account plus 12 months after deletion request.
• Usage data: Retained for up to 24 months, then anonymised or deleted.
• Signals & investigation data: Retained for the duration of the associated case or investigation, plus 6 years to comply with legal obligations.
• Billing records: Retained for 7 years as required by UK tax law.

When data is no longer required, it is securely deleted or irreversibly anonymised.

4. Your Rights Under UK GDPR

As a data subject, you have the following rights:

• Right of Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure: Request deletion of your personal data (subject to legal retention requirements).
• Right to Restrict Processing: Request that we limit how we use your data.
• Right to Data Portability: Receive your data in a structured, machine-readable format.
• Right to Object: Object to processing based on legitimate interest or direct marketing.
• Right to Withdraw Consent: Where processing is based on consent, withdraw it at any time.

To exercise any of these rights, contact us at contact@79thunit.com. We will respond within 30 days.

5. Data Security

All data is encrypted at rest and in transit. We use Supabase PostgreSQL with Row-Level Security (RLS) enabled. Access to personal data is restricted on a need-to-know basis, and all access is logged in our audit trail.

6. Complaints

If you are unsatisfied with how we handle your data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

7. Contact

For any data protection queries or requests, contact:
contact@79thunit.com