ClearDATA Privacy Policy

ClearDATA understands the importance of protecting your privacy.

This Privacy Policy describes:

  • Data Collected: the personal data that ClearDATA collects from and about you, as a website user or other prospective customer, and as a services account holder;
  • Use of Data: the ways that ClearDATA uses that personal data, including the ways that it may combine data it collects from you with data it acquires about you from other sources; and
  • Disclosure of Data to Others: the circumstances under which ClearDATA might share your personal data with others.

Please contact us at compliance@cleardata.com if (i) you wish to find out more about our use and disclosure of your information and how to limit it, (ii) you wish to exercise your right to access, amend, or delete any personal data we hold about you that you are unable to accomplish by means of the administrative features of the services;  or (iii) you have any other questions or concerns about this policy.

Please note that this Privacy Policy describes ClearDATA’s privacy policies with respect to personal data that it collects and controls for its own use and for the purpose of managing its customer accounts.  This Privacy Policy does not cover personal data that ClearDATA’s customers or end users process by means of the ClearDATA services.

  • If you are a ClearDATA customer, ClearDATA’s use of personal data that you process by means of the ClearDATA services is subject to ClearDATA’s services terms and any applicable business associate agreement or data privacy agreement that ClearDATA has entered into with you.
  • If you are an individual whose personal data is controlled by a ClearDATA customer and you wish to remove, amend, block, remove consent for processing, or take other action with respect to your personal data, please contact the ClearDATA customer who controls your personal data. ClearDATA acts on the instructions of its customers with respect to personal data that is processed by them using ClearDATA’s services.

Data Collected

You are not required to submit your personal data to ClearDATA to use our website.  You may block collection of your personal data by means of cookies as described below in the section captioned Online Data Collection Technologies.  If you are a customer you must provide personal data regarding the individuals who have rights to control your account with us or manage the services we provide to you.

ClearDATA limits the collection of personal information to only that which is relevant for reasonably serving customer relations, compliance and legal considerations, auditing, security and fraud prevention, preserving or defending our legal rights, communicating with you as a prospective customer, improving products and services, facilitating billing and collections activities, and other purposes consistent with the expectations of a reasonable person given the context of the collection.  ClearDATA takes reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete, and current.

ClearDATA obtains some contact details and other personal information regarding media contacts and influencers from a variety of sources including Cision. If you wish to know more about how such information is collected and used, please refer to Cision’s privacy notice at www.cision.com/us/legal/privacy-policy/.

Site Visitors:

Our Web server may capture any or all of the following: your IP address, the time and duration of your visit, and the pages on the site that your visit.  It may also collect information about your browser, device, location and other information of the type collected by Web servers generally.  We may also use Web analytics tools to capture information about your use of the site, such as mouse clicks and scrolling activity.  We may tie this information to personally identifying information we have about you.

We use “cookies,” “web beacons” “pixel tags” and other techniques to identify you or your browser or device to your activity on the site.  Please see the section below captioned “Online Data Collection Technologies” for more information regarding our use of these techniques and your ability to restrict our collection of data in this manner.

We use third party Web analytics tools to capture information about your use of the site, such as mouse clicks and scrolling activity.  For example, we may use Google Analytics, Google Website Optimizer, or Inspectlet.  The providers of these tools may capture data about your activity on our site, via cookies and other techniques.

If you arrive at our site by clicking on an advertisement or content published by a third party, that third party may provide information to us about your activity on their site.  For example, we may use Google AdWords or other third party advertisers, or may sponsor links on other third party sites.

We may ask you to volunteer information about yourself using forms on the website, including personal data (such as your name and email address), demographic data (such as your profession, age and gender), and information about your general interests.  For example, we may ask you to submit this type of information as part of a survey.  Your submission of this type of information as a website visitor is not required.

We may permit third parties to display content on our site.  If you view this content, the third party may collect information about you.  For example, we may permit content to be displayed by Google Fonts, Google Maps, YouTube or Vimeo.  You should see the third party’s site for more information about the data they collect and their use and disclosure of the data.

Services Users:

To establish a services account with us we require you to provide the names and business contact information of your personnel assigned to manage your account with us.

If any of your personnel contact us for support (whether by phone, chat, email or other means) we may record and save the contents of the communication.

Use of Data

Generally ClearDATA uses the personal and other data it collects to provide its services, operate its website efficiently, and provide a good quality experience for website visitors. ClearDATA may use the information to send you email or other communications about ClearDATA’s or third parties’ content, product or services. ClearDATA only uses and processes personal data for purposes compatible with the original purpose of collection or as subsequently authorized by you. If you do not wish to receive information from ClearDATA via email, you may unsubscribe to our email list at any time by following the link in the communication.

The providers of our analytics tools may use information they collect about your site visit to show you advertisements or other content that may be of particular interest to you.

If you establish a services account, we may tie the information we collect as part of your pre-login site visit to your post login activity on the site and service.

If ClearDATA acquires information about you from third parties, such as marketing or advertising firms, security services, or content providers, it may tie this third party provided information to the information it collects from or about you as part of your visit to the site or use of the services.

Here are some specific examples of the ways we use data we have about you:

  • Account Transactions: We use your account data to communicate with you about account transactions or respond to your requests for support (such as fee payments, support requests, services interactions);
  • Fraud, Abuse, Security: We use account and other data to screen for and reduce fraud, spam, abuse, and security problems. We may remove content or block access to the site in our discretion to reduce the risk of fraud, abuse and security problems;
  • Business Improvements: We use the data we collect to improve our site and services, such as changes to the content or organization of the content, developing new services features, identification of target audiences for our external advertising and publicity efforts;
  • Newsletters and Other Promotional Content. We may use your data to send you communications of interest to you, including promotional communications.  We may use Web beacons to track whether you actually view our messages or content.

Disclosure of Data to Others

We will not disclose your personal data to third parties except as follows:

  • When we believe release is appropriate to comply with the law, such as in response to lawful requests by public authorities to meet national security or law enforcement requirement.
  • To enforce our services agreement and other rights, or to protect the rights and safety of others. This may include exchanging information with government regulatory or law enforcement agencies, or with other companies and organizations for fraud protection and legal compliance.
  • To persons who help us provide our products and services to you. We may provide personal and other information to third parties who work for us, such as companies that verify creditworthiness, verify and process payment card information and payment, manage e-signing, analyze data, manage contact information and communications, remove repetitive information from customer lists, and provide marketing services. These providers are not authorized to further disclose your data or to use your data for any other purpose other than providing services to us.
  • Our site is hosted by a third party and we use third party infrastructure monitoring services. These third parties may have inadvertent or incidental access to your data.  These providers are not authorized to further disclose your data or to use your data for any purpose other than providing services to us.
  • As part of a sale of our assets or a merger of our company. We may in the future sell all or part of our assets or be involved in a merger. It is customary for personal information to be included with the transferred assets in these types of transactions.

We may disclose data we collect from and about you in aggregate anonymous form for the purpose of improving our site and services generally.  This may include combining data about you (in anonymous form) with data we have about other individuals (in anonymous form), and transferring the combined data to third parties.

Online Data Collection Technologies

A cookie is a small text file that is placed on your device, typically a string of numbers and letters.  The cookie is used to uniquely identify your device.   Whoever places the cookie will typically use the information to associate each of your site or services visits to your device, and to you personally if the cookie placer has information that identifies you personally to your device.  Most browsers include features that enable you to block or restrict cookie placement.  If you disable or restrict cookies, you may not be able to use all of the features of the site or service that placed the cookie.

A Web beacon is a small electronic image that is served by a Web server when you view the Web page or email in which it is embedded.   Generally, when you view the content in which the Web beacon is embedded, a call is placed to the Web beacon server that identifies your IP address or device information in a way that enables the operator of the beacon to identify your device, or you, to your activity.

Your Rights

The right to be informed about our collection and use of personal information/data;

You have the right to be informed about the collection and use of your personal data. We govern this right via our internal data protection policies and through our external website policy. These policies are regularly reviewed and updated to ensure they are accurate and reflect our data processing activities.

Right to Access Your Personal Information

You have the right to access the personal information that we hold about you. This is sometimes termed a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you (or someone else authorized to receive it on your behalf), we will provide it to you or them free of charge and in most instances do so within one month unless we rely on an extension or exemption available to us under Data Protection Legislation, in which case we will notify you accordingly.

We would ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information.

If you would like to exercise this right, please contact us as set out below.

Right to Correct Your Personal Information

If any of the personal information we hold about you is inaccurate, incomplete or out of date, you may ask us to correct it.

If you would like to exercise this right, please contact us as set out below.

Right to Stop or Limit Our Processing of Your Data

You have the right to object to us processing your personal information for particular purposes, to have your information deleted if we are keeping it too long or have its processing restricted in certain circumstances.

If you would like to exercise this right, please contact us as set out below.

Right to Erasure

You have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances.

Right to Portability

The right to portability gives you the right to receive personal data you have provided to a controller in a structured, commonly used and machine-readable format. It also gives you the right to request that a controller transmits this data directly to another controller.

If you would like to exercise this right, please contact us as set out below.

Other

Security:  We will use reasonable security measures to protect your personal data from unauthorized use and disclosure. These include:

  • Limiting access to our buildings to those that we believe are entitled to be there;
  • Implementing access controls to our information technology; and
  • We use appropriate procedures and technical security measures (including strict encryption, anonymization and archiving techniques) to safeguard your information across all our computer systems, website and offices.

Data Retention:  We will destroy your personal data when we are no longer using it for the purposes described in this Privacy Policy unless we are required to retain it by applicable law.  If we are required to retain your personal data after the time that we are no longer using it as described in this Privacy Policy due to a legal requirement we will only use your personal data for the purpose of complying with the legal requirement.

Children’s Online Privacy Protection: We will not knowingly collect any data from or about any person under the age of 13.

California

The California Consumer Privacy Act provides California consumers with the right to obtain from ClearDATA information about the personal information about you that we collect, use, and disclose. You can exercise your rights through an authorized agent by providing relevant details to compliance@cleardata.com. Additionally, you have the right to opt-out of the sale of your personal information. ClearDATA does not sell your personal information.

If you choose to exercise your privacy rights, you have the right to not to receive discriminatory treatment or a lesser degree of service from ClearDATA.

Nevada

You have the right to opt-out of the sale of your personal information. ClearDATA does not sell your personal information.

To exercise your rights, or for any questions please contact us a compliance@cleardata.com.

Cross-Jurisdictional Access and Transfer of Personal Data EEA, Switzerland and United Kingdom

ClearDATA is located in the United States.  Personal data covered by this Privacy Policy is stored in the United States and accessed from within the United States, except for customer account data that the customer specifically asks to have stored or accessed from outside the United States.  If we transfer data to the United States from other jurisdictions we will comply with applicable privacy laws, including the laws of the European Union, United Kingdom and Switzerland.

All information you provided to ClearDATA regarding the collection, use, and retention of personal information from European Union member countries and Switzerland is controlled by ClearDATA and processed only on behalf of ClearDATA. ClearDATA uses approved Model Contractual Clauses for the international transfer of personal information collected in the European Economic Area, United Kingdom and Switzerland  Additionally, all third party agents who process personal data on behalf of ClearDATA must provide and sign a Data Protection Agreement (DPA) agreeing to provide the same level of protections as provided by ClearDATA.

If third party agents process personal data on our behalf in a manner inconsistent with the ClearDATA DPA, we remain liable unless we provide that we are not responsible for the event giving rise to the damage.

If you have a question or complaint regarding our privacy and data processing practices, please contact us at compliance@cleardata.com .

Contact Information

ClearDATA’s privacy practices are managed by Chris Bowen, its Chief Privacy and Security Officer.  You may contact him via email at compliance@cleardata.com.  His address is:

Chris Bowen
Chief Privacy and Security Officer
ClearDATA Networks, Inc.
835 W 6th Street, 12th Floor
Austin, Texas  78703

For EEA Residents: Please contact our EU Representative at EURep@cleardata.com. Alternatively, they can be reached by post (Alexandra House, 3 Ballsbridge Park, Dublin, D04C 7H2) or +353 1 631 9460. www.dpocentre.com

Revision date November 4, 2021