Clearitty Privacy Policy
Effective date: May, 21st, 2024
Scope of this Privacy Policy
This Privacy Policy of Clearitty Inc. and its wholly owned subsidiaries (collectively “Clearitty”, “we” or “our”) applies to information, including personal information (collectively, “information”), collected by us from contributors of reviews to our platform and users of our platform, from visitors of our website, and that is otherwise obtained by us. Some of the information collected by us may be “personal information” – information that identifies you personally, alone or in combination with other information available to us.
If you are located in the European Economic Area, in addition to the general information in this Privacy Policy, the section “For Individuals in the European Economic Area” below contains further information about our processing of your personal information, as required by European data protections laws.
1. Information We Collect
Information that is Provided to Us. We collect the information that you enter on our website, provide when you contribute reviews or register to use our platform, provide when you interact with us, and information that is provided to us in any other manner. Such information may include your name, email address, LinkedIn URL, current position, current employer, past positions, past employers, general location (country and city), sign-in information and feedback.
Information that is Collected Automatically. We automatically collect certain types of information when you visit and interact with us on our website. This information may include IP address, the browser you used to visit our site, time and duration of your connection. The information we receive may depend on your browser or device settings.
Cookies, Pixel Tags, and Similar Technologies. We use cookies, pixel tags, and similar technologies for various reasons, such as to understand and save your preferences for future visits, and to compile aggregate data about site traffic and site interaction. The information collected by cookies, pixel tags, or similar technology may include your IP address, operating system, browser type and version, browser language, the requested page and the time of the access. Please see Section 4 for further details on our use of cookies and similar technologies.
Opting Out. You can prevent collection of your information by not providing such information, by not contributing to or using our platform, by ceasing to visit our website and interacting with us, or by contacting us as mentioned in Section 12 below.
2. How We Use Your Information
We access and use your information, including your personal information, that is collected by us:
to provide you with information about us and our platform;
to sign you up and provide you with our platform;
to provide you with a personalized experience when using our platform;
for our internal purposes, such as to understand traffic to our website and/or improve our website’s functionality, content and usability;
to improve our platform and services;
to improve our marketing and promotional efforts;
for any other purpose identified in an applicable click-through agreement or other agreement between you and us; and
to comply with any legal obligation we are subject to under applicable law, for example, for security, credit or fraud prevention purposes.
Legal Basis. If you contribute reviews to our platform or register to use our platform, our legal basis for processing your personal information is that it is necessary for the performance of the contract between you and us concerning contribution of reviews to the platform and/or use of the platform. If we obtain your personal information through your visit to our website, interaction with us or any other manner, our legal basis for processing your personal information is that it is necessary for our legitimate interest in providing and developing our platform and meeting the requirements of our current and prospective contributors, users, and partners.
Promotional Use. We may use your information to contact you by email or otherwise, to deliver promotional materials or updates in which you may be interested, or to provide you with newsletters that you may register to receive. With respect to such use, our legal basis for processing your personal information is that it is necessary for our legitimate interests in conducting direct marketing of our platform to current and prospective contributors and users.
Opting out. You may choose at any time not to receive our promotional materials, updates and newsletters, by clicking the unsubscribe link at the bottom of each promotional material, update or newsletter or by contacting us as mentioned in Section 12 below.
3. Disclosure of Your Information
To Whom We May Disclose Your information. We may disclose your information, including your personal information, as follows: (i) to providers of infrastructure on which our platform operates, (ii) to service providers that operate on our behalf and who agreed to adhere to terms consistent with this Privacy Policy, (iii) to governmental, administrative or law enforcement authorities, where we in good faith believe it is required to be disclosed by applicable law or court order, (iv) to third parties in connection with a merger, acquisition, or sale of all or a portion of our business or assets, (v) where we in good faith believe it is necessary in order to protect our safety or rights, or those of a third party, including but not limited to in connection with fraud detection or prevention, and security or technical issues, and (vi) where we in good faith believe it is necessary in order to enforce the provisions of this Privacy Policy or our agreement with you. We do not sell your personal information.
Third Party Privacy Policies. Upon your information being shared with our infrastructure providers and other service providers, we will treat this information according to the terms of this Privacy Policy, and the relevant infrastructure provider or other service provider will treat it according to the terms of its own privacy policy. If required under applicable laws, we will enter into data processing agreements with any third party to which we disclose your personal information. These data processing agreements will require any third party to protect your personal information in substantially the same way as we are required to protect your personal information under applicable laws.
Third-Party Opting Out. If you would like to request the deletion of your information that was disclosed to third parties, or further details about the third parties to which your information may have been disclosed, please contact us at: info@clearitty.com.
4. Cookies, Pixel Tags, and Other Similar Technologies
Cookies are used to store information on your computer and are a way to have your web browser "remember" specific bits of information about your previous visits to our site. If your browser is set to accept cookies, then it adds the text in a small file. Cookies save you time as they help us to remember you and they help us to be more efficient. We can learn about what content is important to you and what is not.
Clearitty uses cookies to better understand your use of our website and platform, including by: (a) tracking parts of our platform or website you were interested in, (b) identifying users and visitors to our website, and (c) analyzing email campaigns.
The information we collect may depend on your browser settings and may include IP address, operating system, browser type, browser language, device type, application version, the page served, the time, the preceding page views, and your use of features on our website and platform. Most web browsers automatically accept cookies, but you can usually alter the setting of your browser to prevent that. However, doing so may limit your use of certain sections of our platform. If you do not wish to receive cookies, please refer to the help section of your Internet browser to learn how to either block all cookies or receive a warning before a cookie is stored on your computer.
Clearitty also uses pixel tags to further assist our understanding of the behavior and preferences of visitors to our website and contributors to, and users of, our platform. Pixel tags are transparent graphic images placed on our website, platform or in our emails to establish an appreciation of the behavior of the website visitor, platform user or of the recipient of an email, including by allowing us to know when an email has been opened. While you are unable to opt out of our use of pixel tags, your policies with respect to cookies may limit our use of pixel tags.
Clearitty also allows third-party companies, including Google Analytics and others, to use cookies and spotlight tags to collect certain information when you visit our website or use our platform (“Usage Information”). Usage Information helps us measure the performance of our online advertising campaigns, analyze visitor activity on our website and platform, and utilized for other business purposes. Usage Information may include browser type, device type, operating system, application version, the page served, the time, the preceding page views, and your use of features on the website and platform. Similarly to altering your cookie settings, you can also install the Google Analytics Opt-out Add-on, which prevents Google Analytics from collecting information about your website visits.
5. Information Security
We make reasonable and appropriate efforts, applying physical, electronic and procedural safeguards, to maintain and protect the confidentiality and security of all information collected by us, including your personal information. However, no company can fully eliminate security risks. So, although we make an effort to store your information in a secure manner, we cannot guarantee security. You understand and agree that all information collected through our website, in connection with your contribution and/or registration to our platform, or otherwise obtained by us, is subject to the provisions and disclaimers of this Privacy Policy.
You are responsible for keeping your username and password secret. Do not share your password with anyone else.
In the event that we become aware of any accidental or unauthorized access to your information, we will notify you of such access in accordance with applicable law.
6. Transfer of Information to a Different Jurisdiction
Clearitty operates internationally and may process your information, or store it using cloud infrastructure providers, outside your country of residence. We or our infrastructure providers may decide to transfer information to a different jurisdiction at our or their sole discretion. In the event of such transfer, we will ensure that it takes place in accordance with applicable law. For individuals in the European Economic Area, please refer to Section 9 below for more information on how we transfer your personal information internationally.
7. Links to Other Websites
Our website may contain links to external third-party websites. We are not responsible for the privacy policies, practices or content of such websites. Any information you provide on third-party websites is covered under their privacy and data collection policies and is not covered by this Privacy Policy. We encourage you to review the privacy policy of any website you visit before using the website or submitting your information.
8. Retention of Your Information
If you contribute reviews or register to use our platform, provide information on your visit to our website, interact with us, or if we obtain your information in any other manner, we will store the information we collect about you for as long as it is necessary for the purpose(s) for which we collected it and in accordance with applicable law and legitimate business interests. This includes accommodating your choices regarding marketing and promotional materials.
When assessing the data retention period, we take into account the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information and whether we can achieve those purposes through other means, and the applicable legal requirements. After the retention period ends, we will delete the personal information. Where we are unable to do so, we will ensure that appropriate measures are put in place to prevent any further use of such information.
If you will request the deletion of your information that is stored on our systems, your information will be deleted from our active database, but a copy of such information, generated by our automated computer archival back-up systems, may remain in our archives for a period of up to 18 additional months. Such copy will not be displayed on our active database and be used for back-up purposes only.
If you would like more information on our retention practices or request the deletion of your information that is stored on our systems, please contact us using the contact information in Section 12 below.
9. For Individuals in the European Economic Area
For the purpose of applicable data protection laws in the European Union (including the EU 2016/679 General Data Protection Regulation (GDPR)), Clearitty is the data controller of your personal information to which this Privacy Policy applies. You may contact Clearitty using the contact information in Section 12 below. Nothing is this section is intended to bind Clearitty in respect of the personal information of any other individual.
Categories of Personal Information We Collect
Please see Sections 1 and 4 above for details on the personal information we collect, and see Sections 2 and 3 above for details on how we use and disclose your personal information.
Our Legal Basis for Processing Your Personal Information
Please see Section 2 above for details on the legal basis we rely on for the collection, processing and use of the personal information we collect about you.
We will only use your personal information for the uses and purposes set out in this Privacy Policy, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original uses and purposes.
Your Rights
Subject to any local or national law exceptions, if you are in the EEA and your personal information is processed by Clearitty, you have the right to:
withdraw your consent to the processing of your personal information if such processing is based on consent (this will not affect our right to process your personal information up until such time as you provide us with notice that you no longer consent);
access your personal information;
receive or ask that we provide you with (or transfer to a third party) your personal information in a structured, commonly used and machine readable format;
request us not to process your personal information for marketing purposes (including profiling to the extent that it is related to our marketing activities). We will provide you with appropriate choices to opt-in or opt-out as set out above. You can also exercise the right at any time by using the contact information in Section 12 below;
request us to rectify any inaccurate personal information that we may hold;
request us to erase personal information where: (a) it is no longer necessary for us to hold such personal information; (b) you no longer consent to the processing of your personal information (if processing is based on consent); (c) your personal information has been unlawfully processed; or (d) we are otherwise required by law to erase your personal information;
make a complaint with the national data protection authority in the country where you are based. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority so please contact us by using the contact information in Section 12 below.
You may contact us at any time to exercise any of the rights which apply to you by using the contact information in Section 12 below. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights).
Cross-Border Data Transfers
Clearitty operates internationally and may process your information, or store it using cloud infrastructure providers, outside your country of residence, including outside the EEA. We or our infrastructure providers may decide to transfer information to a different jurisdiction, at our or their sole discretion. In the event of such transfer, we will ensure that it takes place in accordance with applicable law.
With respect to transfers from the EEA to non-EEA countries with respect to which there is no adequacy decision of the European Commission or to organizations in non-EEA countries that do not participate in the Data Privacy Framework program, we implement standard contractual clauses as approved by the European Commission, and other appropriate solutions to address cross-border transfers as required or permitted by the GDPR. Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us using the contact information in Section 12 below.
10. Privacy Rights in Other Jurisdictions
You may have rights in relation to your personal information under applicable privacy and data protections laws in other jurisdictions. If you wish to exercise any such rights, please contact us using the contact information in Section 12 below.
11. Updates to this Privacy Policy
We may update this Privacy Policy from time to time by posting an updated version, and in some cases, in our sole discretion, we may also notify you by email or through the platform of updates to this Privacy Policy. Your continued use of our website and/or platform is subject to the most current effective version of this Privacy Policy. If you object to the Privacy Policy after it becomes effective, you may no longer use our website and/or platform. We encourage you to periodically check for Privacy Policy updates.
12. Contact Us
If you have a question about this Privacy Policy or our information collection practices, please contact us at: info@clearitty.com.