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Privacy Policy

The Clearpool Group Commitment to Privacy

The Clearpool Group is committed to maintaining your confidence and trust, and accordingly maintains the following Privacy Policy to protect personal information you provide online. To make this notice easy to find, it appears on our home page (www.clearpoolgroup.com) and at every point that personally identifiable information may be requested.

This Privacy Policy describes the types of information we collect on the Sites, how we use such information and to whom and under what circumstances we may disclose it. This Privacy Policy applies only to our website and client portal (the “Sites”), and any other personal information obtained when you call, email, or otherwise communicate with The Clearpool Group. By accessing the Sites on any computer, mobile phone, tablet, or other device (collectively, “Device”), making a purchase from the Clearpool Group, or otherwise interacting with The Clearpool Group, you agree to the terms of this Privacy Policy. If you do not agree to the policy, please do not use the Sites.

We may modify this Privacy Policy at any time and will post the current version on the Sites. We encourage you to periodically review our Privacy Policy to stay informed about how we are using the information we collect.

Information Collection Overview

For the 12-month period prior to the data of this Privacy Policy, we explain here what categories of personal information we have collected, where we got it from, what we do with it, and with whom we have shared it:

Category of Personal Information Collected Source Purpose for Collection Categories of Recipients
Contact information: such as name, address, and phone number Clients provide us with this information when they visit the Sites, call us, or otherwise interact with us To communicate with and to help us improve our services to you; to provide you with the products you have requested; to inform you about additional products or services that may be of interest to you; for marketing purposes; and for other internal and legal obligation purposes. We may share this information to select The Clearpool Group companies and their advertising and promotional agencies and consultants. We may also occasionally hire companies to provide limited services on our behalf including packaging; mailing and delivering purchases; answering customer questions about products or services; sending mail; and processing event registration. We provide these companies with only the information they need to deliver their service and they are prohibited from using that information for any other purpose.
Browsing information: such as your IP address, MAC address or other device identifier, the kind of browser or computer you use, pages and content that you visit on the Site, what you click on, the state and country from which you access the Site, date and time of your visit, and web pages you linked to our Site from. Our Sites and your interactions with the Sites, including through the use of cookies and other tracking technologies explained further below. To evaluate usage of the Sites and improve performance and client services; to protect the security and integrity of the Sites and our business, such as preventing fraud, hacking, and other criminal activity or to meet legal obligations. Our service providers who help us with fraud protection and website analytics.

In some jurisdictions, individuals may have the right to opt-in or withdraw consent for certain uses. If you reside in such jurisdictions, you may have additional rights which are detailed below, “Access, Correction and Deletion.”

In Connection with Business Transfers: In the event that a division, a product or all of The Clearpool Group is bought, sold or otherwise transferred, or is in the process of a potential transaction, personal information will likely be shared for evaluation purposes and included among the transferred business assets, subject to client contractual requirements and applicable law.

To Comply with Laws: The Clearpool Group may also disclose specific personal information when such disclosure appears necessary to comply with applicable law, a subpoena in the course of managing a dispute, governmental inquiry or other litigation process. We may also disclose information to our accountants, auditors, agents, lawyers and other advisors in connection with the enforcement or protection of our legal rights or to protect the interests or safety of our clients, employees or others, in accordance with or as authorized by law.

At any time while accessing our Sites, any user while online may decline participation in any activity that asks for information (e.g., survey email, ecommerce). Your choice not to participate will in no way affect your ability to use any other feature on our site.

If you do not wish to receive communications from us about special offers and promotions, you can opt-out of receiving these communications by following the instructions contained in the messages you receive. Even if you opt-out of receiving these messages, we reserve the right to send you certain communications relating to the services we provide, and we may send you service announcements and administrative messages. We do not offer you the opportunity to opt-out of receiving those communications. For more information about interest-based advertising, including how you can manage advertising, please see below “Interest-Based Advertising.”

Information We Collect Automatically

When you visit the Sites, we may collect certain information from you, including your Internet Protocol (IP) address, MAC address, browser type, operating system, device-identifying information, the specific web pages visited during your connection, and the domain name from which you accessed the Sites. In addition, we may collect information about your browsing behavior, such as the date and time you visit the Sites, the areas or pages of the Sites that you visit, the amount of time you spend viewing the Sites, the number of times you return to the Sites and other clickstream data. We may also use non-personal or aggregated information for statistical analysis, research, and other purposes.

Like many commercial websites, we analyze how visitors use our Sites through what is known as “cookie” technology. A cookie is a small text file that is placed on your computer when you access the Sites and allows us to recognize you each time you visit the Sites. We may use cookies to: (1) allow you to use the Sites without having to re-enter your user name and password; (2) enhance or personalize your Site usage; (3) monitor Site usage; (4) manage the Sites; and (5) improve the Sites and our products and services, including providing you with interest-based ads. For more information on our advertising, see below: “Interest-Based Advertising.” If you choose, you can set your browser to reject cookies or you can manually delete individual cookies or all of the cookies on your computer by following your browser’s help file directions. However, if your browser is set to reject cookies or you manually delete cookies, you may have some trouble accessing and using some of the pages and features that are currently on our Sites, or that we may put on our Sites in the future. Note that browser-management tools for cookies are outside of our control and we cannot guarantee their effectiveness.

We may also use web beacons on the Sites, in our emails, and in our advertisements on other websites. Web beacons are tiny graphic images that are used to collect information about your visit to the Sites, such as the pages you view and the features you use, as well as information about whether you open and/or act upon one of our emails or advertisements. We may also collect the URL of the website you visited immediately before coming to the Sites. Web beacons help us analyze our Site visitors’ behavior and measure the effectiveness of the Sites and our advertising. We may work with service providers that help us track, collect and analyze this information.

The Clearpool Group may use Google Analytics to evaluate use of the Sites for our internal purposes such as evaluating usages of the Sites. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners

We may combine the information we collect through cookies and web beacons with other information we have collected from you or information from other sources.

Interest-Based Advertising

We may use third-party advertising companies that use tracking technologies to serve our advertisements across the Internet. These companies may collect information about your visits to the Sites and other websites and your interaction with our advertising and other communications. These advertising companies serve ads on behalf of us and others on non-affiliated sites, and some of those ads may be personalized, meaning that they are intended to be relevant to you based on information collected about your visits to the Sites and elsewhere over time. Other companies may also use such technology to advertise on our Sites.

You have the choice to tell us not to collect and use this information, and in some jurisdictions, we will only engage in interest-based advertising if you opt-in. If you would like more information about this practice and to know your choices concerning interest-based ads, visit:

http://www.networkadvertising.org/choices/

www.aboutads.info/choices

In Canada, please visit: http://youradchoices.ca/choices/

In the EU, please visit: http://www.youronlinechoices.eu/]

Access, Correction, & Deletion

We respect your right to access and correct your personal information. You may access your personal information by signing into your account. From there, you can correct or modify your information. You may also exercise your rights, subject to applicable laws, to request that we delete or restrict access to your personal data. We may need to retain it for legally permitted purposes and this will be explained to you if necessary.

If you need assistance correcting or updating your personal information, or would like to request that we delete your personal information, please contact us using the contact information detailed in the “How to Contact Us” section below.

Retention of Personal Information

Personal information that we collect, access or process will be retained only as long as necessary for the fulfilment of the purposes for which it was collected, unless otherwise provided in agreements between you and The Clearpool Group or as required or authorized by law. Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased or made de-identified.

Security

The Clearpool Group has implemented a number of security features throughout this website to prevent the unauthorized release of or access to personal information. For example, database information is kept separate from live servers and is firewall protected. Please be advised, however, that although The Clearpool Group has endeavored to create a secure and reliable site for you, the confidentiality of any communication or material transmitted to or from The Clearpool Group via the The Clearpool Group website or e-mail cannot be guaranteed. When disclosing any personal information, you should remain mindful of the fact that it is potentially accessible to the public and consequently, may be collected and used by others without your consent. The Clearpool Group has no responsibility or liability for the security of information transmitted via the Internet.

Children

The Sites are not directed to children, nor do we knowingly collect any personal information from children under the age of thirteen without verifiable parental consent. If you believe that a child has provided personal information to us, please contact us promptly as described below, and we will endeavor to investigate and delete such information from our systems.

Third Party Websites

The Sites may contain links to third-party websites, such as social media sites like LinkedIn and Twitter, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these websites. Accordingly, we recommend that you review the privacy policy posted on any external site before disclosing any personal information. Please contact those websites directly if you have any questions about their privacy policies.

Changes to This Privacy Policy

We may change this privacy policy from time to time, including as required to keep current with rules and regulations, new technologies and security standards. When we do, we will post the change(s) on our Sites. If we change the policy in a material and retroactive manner, we will provide appropriate notice to you.

Your California Privacy Rights

If you are a California resident, California law provides you with the following rights with respect to your personal information:

When you exercise these rights and submit a request to us, we will verify your identity by asking you for your email address, telephone number, and/or information about your account with The Clearpool Group. We also may use a third party verification provider to verify your identity. The Clearpool Group will endeavor to honor client’s requests unless such a request conflicts with certain lawful exemptions under the California Consumer Privacy Act of 2018.  Please note that The Clearpool Group is only required to honor such requests twice in a 12-month period.

Your exercise of these rights will have no adverse effect on the price and quality of our goods or services.

For the 12-month period prior to the date of this Privacy Policy, The Clearpool Group has not sold any personal information about its clients; nor does it have any plans to do so in the future.

Visitors from Outside the United States—Cross-Border Transfer

The Sites are hosted in the United States. If you are visiting the Sites from outside the United States, your information may be transferred to, stored and processed in the United States or other countries in accordance with this Privacy Policy.  The data protection and other applicable laws of the United States or other countries may not be as comprehensive as those laws or regulations in your country or may otherwise differ from the data protection or consumer protection laws in your country. Your information may be available to government authorities under lawful orders and law applicable in such jurisdictions. By using the Sites and/or providing personal information to us, you consent to transfer of your information to our facilities as described in this Privacy Policy.

Right to Lodge Complaints

We are transparent about the ways in which we collect and use personal information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or the United States. You may contact the US Federal Trade Commission regarding your concerns. For more information, please see https://www.ftc.gov/faq/consumer-protection/submit-consumer-complaint-ftc.

How to Contact Us

If you have questions or concerns about this Privacy Policy or how we collect and use the information of our customers or to request a copy of this Privacy Notice in another format, you can contact us by telephone at 212-531-8500. If we need, or are required, to contact you concerning any event that involves your information, we may do so by email, telephone, or mail.

Copyright © The Clearpool Group. All rights reserved.