CLOCKSS respects your privacy and is committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data when you visit our website, regardless of where you visit it from, and tells you about your privacy rights and how the law protects you.
This privacy policy aims to give you information on how CLOCKSS collects and processes data through your use of our websites, including when you register for an event or complete a survey.
- IMPORTANT INFORMATION
It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.
This version was last updated on 6 October 2026.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our websites are not intended for children, and we do not knowingly collect data relating to children.
Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites, we encourage you to read the privacy policy of every website you visit.
- WHO WE ARE
CLOCKSS is the controller and responsible for your personal data (referred to as “CLOCKSS”, “we”, “us” or “our” in this privacy policy).
CLOCKSS is a not-for-profit geographically distributed dark archive to ensure the long-term survival of digital scholarly publications.
We are bound by applicable data protection laws in respect of the handling and collection of your personal data.
If you have any questions about this privacy policy, including any requests to exercise your legal rights as set out in section 11, please contact us using the contact details in section 12.
- APPLICABLE PRIVACY LAWS
CLOCKSS is a California-based nonprofit organization. Our processing of personal information is subject to applicable US and state privacy and data-security laws. Depending on where an individual is located and the nature of our activities, our processing may also be subject to data-protection laws in other jurisdictions. Where such laws apply, CLOCKSS will comply with the requirements applicable to the relevant processing.
- THE DATA WE COLLECT
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data) or data relating to a corporate entity.
We may collect, use, store and transfer different kinds of personal data about individuals within organizations that participate in, engage with, or otherwise interact with CLOCKSS. This may include:
Contact information
- name
- job title
- organization
- work email
- work telephone
- postal address
Relationship information
- organization represented
- participation status in CLOCKSS
- correspondence and communications with CLOCKSS
Website and technical information
- IP address
- Browser and device information
- pages visited and information about how our website is used
- approximate location derived from an IP address, if collected
- cookie or analytics identifiers, if applicable
Transaction information
- invoices
- payment records
- bank account details where required to process a refund
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, or information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
- IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of an agreement we have with you or your organization, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with your organization (for example, to provide your organization with our archive services). In this case, we may have to cancel the service your organization has with us, but we will notify you if this is the case at the time.
- HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
6.1 Direct interactions
You may provide us with information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes data you provide when you:
- request information about CLOCKSS or our services;
- request marketing or other information to be sent to you;
- enter information into a survey; or
- give us feedback.
6.2 Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies.
6.3 Third parties or publicly available sources
We may obtain professional contact information from publicly available sources such as organizational websites. We may use this information to communicate with people about CLOCKSS services and activities.
We may also receive personal data about you from various third parties including:
Technical Data from analytics providers such as Google Analytics; and
Information that you provide when registering for an event, subscribing to communications, or completing a survey through third-party sites such as Eventbrite, Mailchimp, or SurveyMonkey.
- HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- To perform the services we have agreed to provide.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
The types of lawful basis that we will rely on are:
- Consent means agreement which must be freely given, specific, informed and be an unambiguous indication of your wishes by which you, by a statement or by a clear positive action, signify agreement to the processing of personal data relating to you.
- Legitimate Interest means the interest of our organization in providing our service. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Performance of Contract means processing your data where it is necessary for the performance of an agreement to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
We will obtain your consent before sending you electronic marketing communications. Where applicable law permits us to send marketing communications without consent, we will provide the option to opt out.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose | Personal information | Legal basis |
| Manage CLOCKSS participation and provide services | Contact, relationship, website usage, and transaction information | Agreement/contract; legitimate interests |
| Communicate about CLOCKSS services | Contact and relationship information | Agreement/contract; legitimate interests; consent where required |
| Process invoices and payments | Contact, relationship, and transaction information | Agreement/contract; legal obligation; legitimate interests |
| Respond to enquiries | Contact and relationship information | Legitimate interests; steps at individual's request |
| Operate and secure the website | Website usage information | Legitimate interests; legal obligation where applicable |
| Improve the website and services | Website usage information | Consent where required; legitimate interests where permitted |
| Meet legal, regulatory and governance requirements | Relevant contact, relationship, website usage, and transaction information | Legal obligation; legitimate interests |
7.1 Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing. We have established the following personal data control mechanisms:
- Unsubscribe link displayed on marketing communications;
- Individuals are able to report a change to their preferences to us and we will update our records accordingly.
7.2 Cookies
Our website uses cookies. Some cookies are necessary for the website to function properly, while others may be used to help us understand how visitors use our website and to improve its performance.
We may use third-party services, including analytics providers such as Google Analytics, which may set or access cookies when you visit our website. These cookies may collect information such as your IP address, browser and device information, and information about how you interact with our website.
You can configure your browser to refuse some or all cookies, or to alert you when websites set or access cookies. Please note that disabling certain cookies may affect the functionality of the website.
7.3 Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- DISCLOSURES OF YOUR PERSONAL DATA
For the purposes set out in section 6, we may have to share your personal data with the following parties:
8.1 External Third Parties such as:
- Service providers who provide IT and system administration services.
- Professional advisers including accountants, lawyers, bankers, auditors and insurers who provide banking, legal, insurance and accounting services.
- Regulators and other authorities who require reporting in certain circumstances.
8.2 Specific Third Parties that provide services to CLOCKSS such as:
- Accounting
- Event registration
- IT support
- Marketing support
- Office administration tools including shared cloud storage
- Surveys
- Website analytics
8.3 Third parties to whom we may choose to transfer the CLOCKSS service under the terms of our Trustee Agreement.
In line with good practice for digital preservation services, CLOCKSS has robust plans in place for the safeguarding of content entrusted to its care. Should anything happen to CLOCKSS our Trustee Committee is empowered to make necessary arrangements. If a change happens to our organization, then the Trustee Committee and new service provider may use your personal data in the same way as set out in this privacy policy.
8.4 We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
- INTERNATIONAL TRANSFERS
CLOCKSS is based in the United States and some of the service providers we use may process personal information outside the country in which you are located. Where UK or EU data-protection law applies, we will use an appropriate lawful transfer mechanism and safeguards for international transfers, as required by applicable law.
Further information about the safeguards applicable to a particular transfer is available from us on request.
- DATA SECURITY
CLOCKSS maintains administrative, technical and organizational safeguards designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. Access to personal information is restricted to individuals and service providers who require it for legitimate business purposes. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- DATA RETENTION
11.1 We will only retain personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
11.2 To determine the appropriate retention period for data, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
11.3 We will retain data in alignment with our Document Destruction Policy, to ensure that we are able to assist you should you have any questions or feedback in relation to our services or to protect, or defend our legal rights.
11.4 Where we have processed your personal data to provide you with marketing communications with consent, we may contact you every twelve (12) months to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our marketing lists (but may be added to a “do not contact” list).
11.5 In some circumstances you can ask us to delete your data: see section 11.1.3 below for further information.
11.7 In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
- YOUR LEGAL RIGHTS
12.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are detailed below:
12.1.1 Request access to your personal data . This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
12.1.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
12.1.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
12.1.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
12.1.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
12.1.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
12.1.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us directly.
12.2 No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
12.3 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
12.4 Time limit to respond
We will normally respond to a valid request without undue delay and within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- CONTACT DETAILS AND COMPLAINTS
Full name of legal entity: Digital Distributed Community Archive (dba CLOCKSS Archive)
Charity Number: 3163688
Data Privacy Manager: Alicia Wise
Email address: awise@clockss.org
Postal address:
CLOCKSS Archive
Cecil H. Green Library
557 Escondido Mall, Room 101
Stanford, CA 94305-6004
USA
Telephone number: + 1 813-710-4263