LAST UPDATED: July 2020
PRIVACY POLICY
ClareFolio & Company (“we”, “us” or “ClareFolio”) knows that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. We want you to understand the types of information we collect, how we use that information, how we secure it, and how we share it.
This Privacy Policy applies to all information gathered for and on behalf of the ClareFolio through any website operated by or on behalf of ClareFolio, including, but not limited to, http://www.clarefolio.com, together with any and all future websites that are operated by or on behalf of ClareFolio (collectively, the “Website”). By using the Website, you consent to the data collection and use practices described in this Privacy Policy. If you have questions about this Privacy Policy or the protection of your information, please contact us at info@clarefolio.com.
1. Collection of Information
Information we collect that you provide to us:
- In order to purchase products or services from us, you must provide us with certain contact, demographic and credit card information.
- We may also ask you to provide information to us so that we can provide support to you in connection with your use of the Website.
Information obtained indirectly:
- “Cookies” (which may be html files, Flash files or other technology) are text files that help store user preferences and activity. “Web beacons” (also known as image tags, gif or web bugs) are small pieces of code used to collect advertising data, such as counting page views, promotion views or advertising responses. The Website and/or third parties may use “cookies”, “web beacons” and other similar tracking technologies (collectively, “Tracking Technologies”) to collect information from you automatically as you browse the Website and the web.
- Other Tracking Technologies.We use Tracking Technologies to help tailor our content, understand Website and internet usage, improve or customize the content, offerings or advertisements on the Website, personalize your experience on the Website (for example, to recognize you by name when you return to the Website), save your password in password-protected areas, save your online video player settings, help us offer you programs or services that may be of interest to you, deliver relevant advertising, maintain and administer the Website and for other purposes described in the “Uses of Information”.
These Tracking Technologies collect “click stream” data and information regarding your visits to the Website, such as your visits, use of our features, and preferences and may also collect your IP address or some other identifier unique to the device you use to access the Website (“Identifier”). Your Identifier is automatically assigned to the device you use to access the Website. By visiting the Website, whether as a registered user or otherwise, you acknowledge, understand and hereby agree that you are giving us your consent to track your activities and your use of the site through these Tracking Technologies.
This Website may additionally use a variety of third party advertising networks, third party promotion networks, data exchanges, traffic measurement service providers, marketing analytics service providers and other third parties (collectively, “Third Party Advertising Website Providers”) to, for example, serve advertisements on the Website, facilitate targeting of advertisements and/or measure and analyze advertising effectiveness and/or traffic on the Website (“Targeting Services”). These Third Party Advertising Website Providers may enable us to display advertisements based on your visits to the Website and other websites you have visited. Targeting Services enable us to, among other things, help deliver advertisements or other content to you for products and services that you might be interested in, to prevent you from seeing the same advertisements too many times and to conduct research regarding the usefulness of certain advertisements to you.
Although these Third Party Advertising Website Providers do not have access to Tracking Technologies set by the Website, the Third Party Advertising Website Providers, as well as Advertisers, may themselves set and access their own Tracking Technologies on your Device if you choose to have Tracking Technologies enabled in your browser (or, for Flash cookies, if you have not removed them) and/or they may otherwise have access to information about you.
- Linked Accounts.If you link your account to another service, or use other, third-party sites or services in conjunction with your account with the Website, we may collect information related to your use of third party sites and services accessed through the Website or when you access the Website through a third-party site or service.
2. Use of Information
Operations. We use information that can be used to identify or contact you (“Personal Information”) to (i) process your registration on the Website, such as verifying that your e-mail address is active and valid; (ii) verify your identification; (iii) contact you regarding the administration of your account, any services, features or functions you have enrolled in or registered to use, any promotions you have participated in or have entered, or any other transactions you have undertaken with the Website; (iv) allow you to participate in the public areas and/or other features of the Website; (v) respond to your questions or other requests; (vi) contact you regarding your use of the Website, for informational purposes related to the Website or, in our discretion, regarding changes to the Website’s policies; (vii) improve the Website and for internal business purposes; (viii) tailor your experience on the Website and/or otherwise customize what you see when you visit the Website; (ix) save your User ID or other personal information, so you don’t have to re-enter it each time you visit the Website; and (x) otherwise to maintain, operate and administer the Website and for other purposes disclosed at the time you provide the information.
Disclosure to Third Parties. In addition to aggregate information (discussed previously), we may share some kinds of Personal Information with third parties as described below.
- Companies and people who work for us: We contract with other companies and individuals to help us provide the Website. For example, we may host some of our Website on another company’s computers, hire technical consultants to maintain our sites, or work with companies to remove repetitive information from customer lists, analyze data, provide marketing assistance, and provide customer service. In addition, we may validate your identity and other information against available databases. In order to perform their jobs, these other companies may have limited access to some of the personal information we maintain about our users. Other companies may collect information on our behalf through their web sites. We require that such companies not use your information for any purpose other than fulfilling their responsibilities to us. We also require that such companies keep your personal information confidential and to comply with applicable laws. ClareFolio cannot, however, guarantee that any third party will maintain the privacy of your information.
- Promotional and informational offers: Sometimes we send offers to selected groups of users. To accomplish this, we may use third parties working on behalf of ClareFolio. We provide a variety of mechanisms for you to tell us you do not want to receive such promotional – informational offers. For example, we may provide an opt-in box for customers to receive information that is sent by a third-party fulfillment house, and we make clear that, by opting in, you are submitting your data to a third-party. You can elect not to receive promotional or informational material from us by following the instructions to opt-out as mentioned or included in each of our programs we send to you.
- Business transfers: If we transfer a business unit (such as a subsidiary) or an asset (such as the Website) to another company, we will require it to honor the terms of this Privacy Policy.
- Legal requirements: We may be obligated to cooperate with various law enforcement inquiries. ClareFolio reserves the right to share or transfer your information to comply with a legal requirement, disclose any activities or information about you to law enforcement or other government officials as we, in our sole discretion, determine necessary or appropriate, in connection with an investigation of fraud, for the administration of justice, intellectual property infringements, or other activity that is illegal or may expose us or you to legal liability. We may release information if, in our judgment the release may be necessary to prevent the death or serious injury of an individual.
Information Collected by Third Party Advertising Website Providers. The use of Tracking Technologies by Third Party Advertising Website Providers is within their control and not ours. Even if we have a relationship with the Third Party Advertising Website Provider, we do not control their web sites, services or their policies and practices regarding your information and you should be aware that different rules might apply to the collection, use or disclosure of your Information by third parties in connection with their advertisements or promotions and other sites you encounter on the Internet. This Privacy Policy does not cover any use of information that a Third Party Advertising Website Provider may directly collect from you. Use of Third Party Advertising Website Providers’ Tracking Technologies is governed by the Third Party Advertising Website Providers’ own specific privacy policies and not this Privacy Policy.
3. Sharing of Non-Identifiable Information. Information we collect that is not Personal Information or Personal Information that has been converted to information which cannot be used to identify you is not limited in any way by this Privacy Policy and can be used and disclosed by us in any manner and for any purpose.
4. Protection of Information. While no data transmission over the Internet is 100% secure from intrusion, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Personal Information. However, regardless of our efforts and the device you use to access the Website, it is possible that third parties may unlawfully intercept or access transmissions or private communications over an unsecured transmission. In the registration form you complete when registering for our Website, you may have an opportunity to elect to receive recurring informational/promotional e-mail from us. Our email correspondence will include instructions on how to update certain personal information and how to unsubscribe from our emails. Please follow the instructions in the emails to opt-out of an email. We will unsubscribe you from that newsletter or other programs within thirty business days. You can always contact us at info@clarefolio.com in order to change your preferences with respect to marketing contacts.
5. Updating Your Personal Information. You can review and update your account information. You can modify, add, or delete certain personal information by accessing your account through the Website. Even after you remove information from your profile or delete your account, copies of that information may remain viewable elsewhere to the extent it has been made generally available or shared with others, or it was copied or stored by other users once you made the information publicly available. We may also retain copies of your information in our archives. However, your name will no longer be associated with that information on the Website. If you have given third party applications or websites access to your information, they may retain your information to the extent permitted under their terms of service or privacy policies. But they will no longer be able to access the information through our Website after you disconnect from them.
6. Children’s Policy. We are committed to protecting the privacy of children. We do not collect personally identifiable information from any person we actually know is under the age of 18. If we learn that we have collected personal information from a person under age 18, we will delete that information as quickly as possible. If you believe that we might have any information from a person under age 18, please contact us through the contact us information provided in the Website.
7. Social Media and Online Engagement. We use a variety of new technologies and social media options to communicate and interact with consumers. These sites and applications include popular social networking and media sites, online communities and more. To better engage the public in ongoing dialog, we use, or in the future may use, several third-party platforms including, but not limited to, Facebook, Twitter, and YouTube. These third party platforms are Web-based technologies that are not operated or controlled by us. Your use of such platforms is subject to the privacy policies of such platforms and is not covered by this Privacy Policy, and we encourage you to review the privacy policy of any company or website before submitting your Personal Information.
8. U.S. Governing Law. The Website is designed and targeted to U.S. audiences and is governed by and operated in accordance with the laws of the U.S. We make no representation that this Website is operated in accordance with the laws or regulations of, or governed by, other nations. If you are located in the European Union or elsewhere outside of the U.S., you do so at your own risk and initiative and you, not us, are responsible for compliance with any applicable local and national laws.
9. Changes to this Privacy Policy. We may update this Privacy Policy occasionally. When we post changes to this Privacy Policy, we will also revise the “Last Updated” date at the end of this Privacy Policy. If there are material changes to this Privacy Policy, we will notify you by email, or by means of a notice on our home page. We encourage you to review this Privacy Policy periodically to be informed of how we are using your information and to be aware of any changes to the Privacy Policy. Your continued use of the site after the posting of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy are effective immediately after being posted by us.
10. Notice for California Users. Under California’s “Shine the Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship (a) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to that customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (b) the names and addresses of all such third parties. To request the above information, please email us at info@clarefolio.com. We will respond to such written requests within 30 days following receipt at the email address above. We reserve the right not to respond to requests submitted other than to the address specified or otherwise exempted by law. Please note that we are required only to respond to each customer once per calendar year.
11. Questions. If you have any questions about our privacy policy, you can contact our privacy officer, please email us at info@clarefolio.com.