1. PURPOSES FOR COLLECTION
With regard to the practices associated with this Site, “Personal Information” means any combination of information, in the possession of or likely to come into the possession of Clarifacts, that can be used to identify, contact, or locate a discrete individual. Clarifacts collects, uses and discloses your Personal Information in its normal course of business for the following purposes:
- Establishing and maintaining communications with you;
- Where you have requested information about a service, to set up access and administration of such service;
- Responding to your inquiries about other services;
- Making proposals for future service needs;
- Meeting legal, security, processing and regulatory requirements;
- Protecting against fraud, suspicious or other illegal activities;
- Developing an understanding of your interests for our services by keeping track of your browsing habits; and
- Compiling statistics for analysis of our sites and our business.
2. WHAT INFORMATION WE COLLECT
The information gathered by Clarifacts from this Site falls into two categories: (1) information voluntarily supplied by visitors to our Site and (2) tracking information gathered as visitors navigate through our Site.
2.1 Information voluntarily provided by you
When using this Site, you may choose to provide us with information to help us serve your needs. The Personal Information that we collect will depend on how you choose to use this Site.
2.1.1 Where you request additional information
If you request information from us, we require you to submit your name, email address, the name of your organization, and the country in which you are based so we may send you the material you have requested, and to enable us to identify if you are an existing client of Clarifacts.
2.1.2 Where you register with us and/or request services
If you register for information with the Site, request a service, or register or log into our client portal, we may ask you for your name, email address, country, telephone number, the reason for your communication, as well as information about your position and organization and such other information as is reasonably necessary so that we can provide you information about our services or industry trends. On the data submission form, we shall indicate by way of an asterisk, which information is optional and which information is mandatory.
Following an inquiry into receiving information or services from us, if you decide to proceed, we will collect Personal Information necessary to proceed, such as your name, address, post code, contact telephone number, email address, billing address or payment details, as relevant to the service. We will use your Personal Information to administer your account, process inquiries, and generally manage your relationship with us.
2.2 Website Navigational Information
As you navigate the Site, we may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (collectively “Website Navigational Information”). Website Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Site (such as the Web pages viewed and the links clicked).
There are different kinds of cookies with different functions:
- Session cookies: these are only stored on your computer during your Web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log into each page. They do not collect any information from your computer.
- Persistent cookies: a persistent cookie is one stored as a file on your computer, and it remains there when you close your Web browser. The cookie can be read by the website that created it when you visit that website again.
- First-party cookies: the function of this type of cookie is to retain your preferences for a particular website for the entity that owns that website. They are stored and sent between Clarifacts’ servers and your computer’s hard drive. They are not used for anything other than for personalization as set by you. These cookies may be either Session or Persistent cookies.
- Third-party cookies: the function of this type of cookie is to retain your interaction with a particular website for an entity that does not own that website. They are stored and sent between the Third-party’s server and your computer’s hard drive. These cookies are usually Persistent cookies.
In addition to Google Analytics, we use several different third-party cookies on this Site. These cookies allow third parties to track your browsing behavior to help us best manage your experience on this Site.
The major browsers have attempted to implement the draft “Do Not Track” (“DNT”) standard of the World Wide Web Consortium (“W3C”) in their latest releases. As this standard has not been finalized, Clarifacts’ Sites are not compatible with DNT.
Where strictly necessary
These cookies are essential in order to enable you to move around the Site and use its features, such as accessing secure areas of the Site. Without these cookies, services you have asked for, such as logging into your account, cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the Internet.
These cookies collect information about how visitors use a Site, for instance, which pages visitors go to most often, and if they get error messages from Web pages. They also allow us to record and count the number of visitors to the Site, all of which enables us to see how visitors use the Site in order to improve the way that our Site works. These cookies do not collect information that identifies a person, as all information these cookies collect is anonymous and is used to improve how our Site works.
These cookies allow our Site to remember choices you make (such as your username, language or the region you are in) and provide enhanced features. For instance, a Site may be able to remember your log-in details, so that you do not have to repeatedly sign in to your account when using a particular device to access our Site. They may also be used to provide services you have requested such as viewing a video or commenting on an article. The information these cookies collect is usually anonymized. They do not gather any information about you that could be used for advertising or remember where you have been on the Internet.
Please consult your Web browser’s ‘Help’ documentation or visit aboutcookies.org for more information about how to turn cookies on and off for your browser.
2.2.2 Web Beacons
The Site may also use Web beacons (including Web beacons supplied or provided by third parties) alone or in conjunction with cookies to compile information about users’ usage of the Site and interaction with emails from Clarifacts. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Site tied to the Web beacon, and a description of a Site tied to the Web beacon. We use Web beacons to operate and improve the Sites and email communications. We may use information from Web beacons in combination with other data we have about our clients to provide you with information about Clarifacts and our services. We will conduct this review on an anonymous basis.
2.2.3 IP Addresses
When you visit our Sites, Clarifacts collects your Internet Protocol (“IP”) addresses to track and aggregate non-Personal Information. For example, Clarifacts uses IP addresses to monitor the regions from which users navigate the Sites.
3. DISCLOSURE OF INFORMATION TO OTHERS
Third parties to whom we disclose information are required by law and contract to keep your Personal Information confidential and secure, and to use and disclose it for purposes that a reasonable person would consider appropriate in the circumstances, in compliance with all applicable legislation.
If these third parties wish to use your Personal Information for any other purpose, they will have a legal obligation to notify you of this and, where required, to obtain your consent. Contact us for more information on these third parties.
3.1 Affiliate Sharing
In the normal course of performing services for our clients, Personal Information may be shared within Clarifacts and its affiliates for research and statistical purposes, system administration, and crime prevention or detection. When you supply us with information containing third party Personal Information (names, addresses, or other information relating to living individuals), we will hold and use that Personal Information to perform services for you on the understanding that the individuals to whom the Personal Information relates have been informed of the reason(s) for obtaining the Personal Information, the fact that it may be disclosed to third parties such as Clarifacts, and have consented to such disclosure and use.
3.2 Service Providers
Because a number of the service providers we use are located in the United States, including certain Clarifacts affiliates, your Personal Information may be processed and stored inside the United States, and the U.S. government, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your Personal Information under U.S. laws.
Clarifacts’ service suppliers adhere to the same protections regarding the collection, use, and retention of data as we do.
3.3 Business Transactions
As we continue to develop our business, we might sell or buy assets. In such transactions, user information, including Personal Information, generally is one of the transferred business assets. Also, if either Clarifacts itself or substantially all of Clarifacts’ assets were acquired, your Personal Information may be one of the transferred assets. Therefore, we may disclose and/or transfer your Personal Information to a third-party purchaser in these circumstances.
3.4 Other Legally Required Disclosures
Clarifacts preserves the right to disclose without your prior permission any Personal Information about you or your use of this Site if Clarifacts has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of Clarifacts, employees, other users of this Site, or the public; (b) enforce the terms and conditions that apply to use of this Site; (c) as required by a legally valid request from a competent governmental authority; or (d) respond to claims that any content violates the rights of third parties. We may also disclose Personal Information as we deem necessary to satisfy any applicable law, regulation, legal process or governmental request.
4. CALIFORNIA’S”SHINE THE LIGHT” LAW
California Civil Code Section 1798.83 requires any operator of a website to permit its California-resident customers to request and obtain from the operator a list of what Personal Information the operator disclosed to third parties for direct marketing purposes, for the preceding calendar year; and the addresses and names of such third parties. If you would like to receive a list of the third parties we have disclosed Personal Information to for marketing purposes, please contact us at firstname.lastname@example.org.
Your knowledge of and consent to Clarifacts’ collection, use and disclosure of your Personal Information is critical. We rely on the following actions by you as indications of your consent to our existing and future Personal Information practices:
- Your voluntary provision of Personal Information to us directly;
- Your express consent or acknowledgment contained within a written, verbal or electronic application; and
- Your verbal consent solicited by Clarifacts (or our agent) for a specified purpose.
Where Clarifacts relies on consent for the fair and lawful processing of Personal Information, the opportunity to consent will be provided when the Personal Information in question is collected. Your consent may be given through your authorized representative such as a legal guardian, agent or holder of a power of attorney.
Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw this consent at any time. Clarifacts will inform you of the consequences of withdrawing your consent. In some cases, refusing to provide certain Personal Information or withdrawing consent for Clarifacts to collect, use or disclose your Personal Information could mean that we cannot provide requested products, services or information for you.
However, there are a number of instances where Clarifacts does not require your consent to engage in the processing or disclosure of Personal Information. Clarifacts may not solicit your consent for the processing or transfer of Personal information for those purposes which have a statutory basis, such as:
- The transfer or processing is necessary for the performance of a contract between you and Clarifacts (or one of its affiliates);
- The transfer or processing is necessary for the performance of a contract, concluded in your interest, between Clarifacts (or one of its affiliates) and a third party;
- The transfer or processing is necessary or legally required, on important public interest grounds, for the establishment, exercise, or defense of legal claims, or to protect your vital interests; or
- The transfer or processing is required by applicable law.
6. LIMITING COLLECTION AND RETENTION OF PERSONAL INFORMATION
Clarifacts will collect, use, or disclose Personal Information that is necessary for the Identified Purposes or as permitted by law. If we require Personal Information for any other purpose, you will be notified of the new purpose, and subject to your consent (where appropriate), that new purpose will become an Identified Purpose.
Clarifacts will collect Personal Information by fair and lawful means. We will normally retain Personal Information as long as necessary for the fulfillment of the Identified Purposes. However, some Personal Information may be retained for longer periods as required by law, contract, or auditing requirements.
We have in place physical, electronic, and procedural safeguards appropriate to the sensitivity of the information we maintain. Safeguards will vary depending on the sensitivity, format, location, amount, distribution, and storage of the Personal Information. They include physical, technical, and managerial measures to keep Personal Information protected from unauthorized access. Among such safeguards are the encryption of communications via SSL, encryption of information while it is in storage, firewalls, access controls, separation of duties, and similar security protocols. However, due to the nature of the Internet and related technology, we cannot absolutely guarantee the security of Personal Information, and Clarifacts expressly disclaims any such obligation.
8. EXTERNAL LINKS
9. ACCURACY, ACCOUNTABILITY, OPENNESS AND CUSTOMER ACCESS
Our knowing about changes to some of your Personal Information (e.g. email address) may be key to effectively communicating with you at your request. If any of your details change you can update us by emailing us at email@example.com. Please keep us informed of changes to your Personal Information.
You have the right to access your Personal Information and request rectification of any Personal Information in the file that may be obsolete, incomplete or incorrect.
323 West Roosevelt Street
Phoenix, AZ 85003
10. QUESTIONS, COMPLAINTS, OR TO WITHDRAW CONSENT
You may exercise your right to withdraw your consent to applicable uses or disclosures of your Personal Information (which may limit or terminate the products and services that Clarifacts provides to you) by writing or sending an email to us at the above address. We will need to validate the identity of anyone making such a request to ensure that we do not provide your information to anyone who does not have the right to such information. Normally we will respond to access requests within 30 days.
We attempt to resolve complaints and disputes regarding use and disclosure of your PI in accordance with the principles contained in this Statement.
Clarifacts will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Privacy Statement.
12. Effective Date: 10/15/2015