This is the Privacy Statement and Policy of Clearsulting, LLC; Clearsulting, LTD; and its affiliates (“Clearsulting”). This Private Policy was last updated on September 30, 2021.
Clearsulting understands that your privacy is important. This privacy describes why and how we collect, use, and share personal information collected from individuals themselves or from other third parties, and provides information about individuals’ rights with respect to their personal information. Clearsulting is committed to protecting your privacy and personal information you provide.
When it applies
Clearsulting collects information from you when you take any of these actions (“Sources”):
- Visit www.clearsulting.com
- Receive communications from us, including emails, phone calls, or text messages
- Visit our offices
- Register for, attend, and/or take part in our events, webinars, conferences, or other Clearsulting-sponsored events
- Visit our social media sites, social media plugins, and tools
- Request copies of publications or subscribe for email newsletters or press releases
- Seek additional information regarding our services or employment opportunities
What data Clearsulting collects
The collection of personal information is initiated by Clearsulting and it may include identifiers, professional or employment-related information, education information, commercial information, visual information, internet activity information, and inference drawn from any of these categories. We may also collect information like an IP address, web browser information, and actions while on the Clearsulting website.
When used, our forms will typically ask for:
- Name (first and last)
- Email address
- Dietary restrictions
We will not intentionally collect or process—and do not want you to provide—any sensitive data, including:
- Data that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership
- Genetic or biometric data
- Data concerning your medical or health condition
- Data concerning your sex life or sexual orientation
Sources where this data is gathered
- Public website (www.clearsulting.com)
- Event registrations (conferences, webinars, in-person networking) hosted by Clearsulting or shared by one of our partners
- Office visitors
- Other sources such as third parties like ZoomInfo and LinkedIn, email communications, other individuals at your organization
- Clearsulting social media sites and social media plugins and tools
Purpose of the data collection
Clearsulting uses the personal information we collect for the following purposes:
- Respond to inquiries made on the website
- Tailor content and information we may send or display to you
- Send marketing information about Clearsulting including information about our services, promotions, special offers, or events or to contact you about services or information we think may interest you
- Better understand how individuals access and use our website to support site improvements
- Communicate with you about the specific event for which you registered or that you attend
- Send follow-up information about the event and/or services or information we think may also be of interest
- Internal reporting
- To support management and organization of the specific event
- Research and analytics
- Any other purpose you consent to in connection with the specific event
- Security and access to a specific office space
- Register visitors to our offices
- To support management and organization of the meeting
- Respond to inquiries
- Deliver relevant email content and/or marketing information
- Augment personal data already provided to us
- Contact leads or referrals about services they might be interested in and/or delivering relevant email content
- Identifying new customers
We process your data on one of the following legal bases:
- Administering, managing, and developing our business and services. We may process personal information to run our business, including:
– Managing our relationship with clients
– Providing services and customer support to our clients
– Developing our business and services, such as identifying client needs and improvements in service delivery and learning more about a client relationship or opportunity we have an interest in
– Analyzing and evaluating the strength of interactions between Clearsulting and a contact
– Performing analytics, including producing metrics for leadership, such as on trends, relationship maps, sales intelligence, and progress against account business goals
– Maintaining and using IT systems
– Hosting or facilitating the hosting of events
– Conducting quick surveys, quizzes, or benchmarking surveys
– Administering and managing our website, systems, and applications
- Performance of a contract. When you or your company enter into an agreement with us, we will process your data to fulfill the terms of our contract.
- Legitimate interests. We may use your data for our legitimate interests provided that our legitimate interests are not outweighed by any prejudice or harm to your rights and freedoms, including:
– Improving our services and the content on our website (for example to manage our network, improve the service, and better tailor the features, performance, and support of the service)
– Operating and administering our website
– Fulfilling your requests and communicating with you when you contact us
– Marketing and promoting our services
- Consent. In some cases, you will give us consent to use your data for a specific purpose. For example, we will rely on your consent to use technical information such as cookie data.
- Legal obligations. We may be required to process your data to comply with our legal obligations.
We may disclose identifiers, professional and employment-related information, education information, commercial information, visual information, etc., for our business purposes and when we are legally permitted to do so. When we share information with others, we put contractual arrangements and security mechanisms in place as appropriate to protect the information and to comply with our information protection, confidentiality, and security standards. Unless specified otherwise, we will not share your personal data with third parties except as follows:
- Technology partners. We may disclose data to our business partners as part of business development efforts; event promotion, sponsorship, and/or registration efforts; or other promotional reasons.
- Business transfers. If we are acquired by or merged with another company, if we are involved in a reorganization or other fundamental corporate change, or if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the data we have collected to the other company.
- In response to legal process. We also may use and disclose data we collect from you in order to comply with the applicable laws, or a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena or to meet national security or law enforcement requirements.
- Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation. We may receive requests from third parties with authority to obtain disclosure of personal information, such as to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfill requests for personal information where we are permitted to do so in accordance with applicable law or regulation.
- Vendors, service providers, contractors, agents. We may disclose data to our third-party vendors, service providers, contractors, agents, and technology partners who assist us in business and technical operations. They provide services relating, but not limited to, IT and system administration and hosting, billing, financial transactions, customer support, internet and connectivity, marketing, event organizing, or security.
- Professional advisors. In individual instances, we may share your data with professional advisors (including lawyers, bankers, auditors, and insurers) who provide consultancy, banking, legal, insurance, and accounting services, and to the extent we are legally obligated to share or have a legitimate interest in sharing your data.
- Aggregate and de-identified information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research, or similar purposes.
Blogs and other social media
Clearsulting may host various blogs, forums, and other social media applications or services that allow you to share content with other users (collectively Social Media Applications). Any personal information or other information that you contribute to any Social Media Application can be read, collected, and used by other users of that Social Media Application over whom we have little or no control. Therefore, we are not responsible for any other user’s use, misuse, or misappropriation of any personal information or other information that you contribute to any Social Media Application.
Clearsulting has applied organizational, technical, and physical measures designed to safeguard against the loss, misuse, alteration, or destruction of personal information. Only authorized Clearsulting personnel and the third parties described in this privacy statement are provided access to personal information and these employees and third parties have agreed to maintain the confidentiality of this information. Please note that in the unlikely event that we might need to contact you about a matter involving your personal information, we may email you about the matter.
Clearsulting only uses third party providers that are bound to maintain appropriate levels of data protection, security, and confidentiality.
We will store data for as long as reasonably necessary, and only for as long as required to fulfill the purposes of processing the data. We may retain data if such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect vital interests or the vital interests of another natural person. If we process data, it may be erased automatically, or saved in a format which does not allow any direct conclusions to be drawn as to your identity as soon as the last specific purpose has been fulfilled
You can opt-out of being contacted by us for marketing or promotional purposes by following the instructions in marketing emails sent by Clearsulting. Additional restrictions on Clearsulting’s ability to send you marketing information may apply depending on jurisdiction. Please note that opting out of marketing communications does not affect your receipt of business communications that are important to your interaction with Clearsulting, such as communications about your projects or engagements with us, billing communications, security updates, event registration updates, or account management communications.
Do not track requests
“Do Not Track” is a preference you can set in your web browser to let the websites you visit know that you do not want them collecting information about you. The website does not currently respond to a “Do Not Track” or similar signal. We do not engage in the collection of personal information about your online activities over time and across third-party websites or online services to provide targeted advertising and we do not allow third parties to collect such personal information when you use the website.
Children’s online privacy protection
We understand the importance of protecting children’s online privacy. Our content is not designed for or intentionally targeted at children under the age of 16. It is not our policy to intentionally collect or maintain information about anyone under the age of 16. If we obtain knowledge that we have received such information, we will take steps to delete it.
Rights to access and control your personal information
Depending on the jurisdiction in which you are located, you may have the right to request that we modify, delete, or stop processing your personal information, and you may also have the right to request that we provide the following information regarding the personal information we hold about you:
- The categories and/or specific pieces of personal information we collected
- The categories of sources from which personal information is collected
- The business or commercial purpose for collecting personal information
- The categories of third parties with whom we shared personal information
Contact us via the contact form or mailing address on our website at any time to:
- see what data we have about you, if any
- change/correct any data we have about you
- ask us to delete any data we have about you
- opt out of future communications from us
Applicable laws may also give you the right to lodge a complaint with a local supervisory authority related to this Privacy Notice/Policy. We will not discriminate against you for exercising any of your rights with respect to your personal information.
For certain personal information requests, we must first verify your identity before processing your request. To do so, we may ask you to provide us with your full name, contact information, and relationship with Clearsulting. Depending on the scope of your request, we may ask you to provide additional information. Once we receive this information, we will then review it and determine whether we are able to match it to the information we maintain about you to verify your identity.
Special notices to California residents
If you are a California resident, you are entitled to request information concerning any personal information you provide to us as part of an established business relationship for personal, family, or household purposes that we disclose to nonaffiliated third parties for their direct marketing purposes. We do not share such personal information with non-affiliated third parties for such purposes.