US/California Privacy Policy

Clarasys, Inc.

United States Privacy Statement

Last Updated: October 19, 2023

Thank you for visiting our website. This Privacy Statement is intended to inform you about our policies and procedures regarding the collection, use and disclosure of information from individuals in the United States by Clarasys, Inc. and its affiliates, including Clarasys Limited (together, “Clarasys”) at www.Clarasys.com and any other websites, features, applications, widgets or online services that are owned or controlled by Clarasys and that post a link to this United States Privacy Statement (collectively, the “Site”).

If you are a resident of California, see below for additional information about our privacy practices.

Our Site and the services we provide are aimed at companies and their representatives and not at individual consumers or households.

We value your privacy and protect your personal information as described in greater detail below. This Privacy Statement is for informational purposes and sets forth our policy with respect to the collection, use and disclosure of business information that we collect when engaging with prospective U.S. Customers and existing Customer Representatives and Authorized Users. By using the Site, you agree to the data collection, use, disclosure and storage practices described in this Privacy Statement.

Our Site provides information about our company and our platform and related services to potential and existing corporate customers (“Customers”). When you interact with us through the Site on behalf of a Customer, we may collect information from you as a “Customer Representative,” as further described below.

By accessing or using the Site, you consent to the information collection, disclosure and use practices described in this Privacy Statement. Certain features or services referenced in this Privacy Statement may not be offered on the Site at all times.

We do not sell or share your information with third parties, other than with our service providers who support the internal operations of our company or who help us provide our products and services to Companies.

INFORMATION COLLECTION

Information We Collect from You

If you are using Clarasys products or services as part of your Company’s enterprise relationship with Clarasys, we consider you an “Authorized User,” and we may collect personally identifiable information from you on behalf of your Company and when you choose to provide it to us. The use of this information by Clarasys is subject to our agreement with our Customers. These Customers decide how the information you provide is collected and used, including what is shared with us for our use.

We collect business contact information from Company Representatives and Authorized Users, including name, address, email address, telephone number, mobile telephone number or geolocation information.

Information Collected Automatically and cookie policy

As is true of most web sites, Clarasys automatically collects some information about your computer when you visit our Site, such as your IP address, browser type, referring/exit pages, and operating system. In addition to personal information, Clarasys may also gather non-personally identifiable information, which may be used by Clarasys. Generally, “non-personally identifiable information” means information that is collected by automatic or electronic means, using technologies such as cookies, pixel tags and web beacons, browser analysis tools, and web server logs or other technologies to automatically collect certain information when you use our Site or interact with our emails and online or mobile advertisements. As you use our website, your browser and devices communicate with servers operated by us, our business partners and service providers to coordinate and record the interactivity and fill your requests for services and information.

Our websites actively log and record information of a non-personal nature such as referral websites, visits, length of sessions, domains, browser software and more. We aggregate and use this non-personal data to improve our website experience for you. We also record the IP address of the computers that visit our website. We also may collect information about your online activity, such as content viewed and pages visited. One of our goals in collecting this automatic information is to help us understand the interests of our travelers and customize your user experience. We may also use information about your online activities for offline marketing purposes.

We capture the following information:

• Domain Name – through which you access the Internet

• IP address – from the computer or network used to access our website

• Web browser – and operating system used

• Date and time – you accessed our site

• Referral Internet address – of the website from which you clicked to get to our website

• Search terms – used in a search engine (like google.com) that brought you to our website.

We may also use third-party tools or services, such as Google Analytics, to assist us with analyzing and improving the Site or our services. These service providers are not permitted to use the information collected on our behalf except to help use conduct and improve our business.

We will also facilitate the implementation of third party tags on our website and to deploy third party cookies and similar device tracking technologies; such tags will facilitate the collection of pseudonymous information relating to an individual’s interactions with our Site.

The information we collect also includes the Internet Protocol (“IP”) address or other device identifier (“Device Identifier”) for any device (computer, mobile phone, tablet, etc.) used to access the Site. A Device Identifier is a number that is automatically assigned or connected to the device you use to access the Site, and our servers identify your device by its Device Identifier. Some mobile service providers may also provide us or our third party service providers with information regarding the physical location of the device used to access the Site. If such information is linked to your Personal Information, we will treat it as Personal Information under this Privacy Statement.

Choices About How We Use and Disclose Your Information and

  California Do Not Track Disclosures.

You may adjust your browser or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Site or take full advantage of all of our offerings. Check the “Help” menu of your browser or operating system to learn how to adjust your tracking settings or cookie preferences.

On your mobile device, you can adjust your privacy and advertising settings to limit your tracking for advertising or control whether you receive more relevant advertising. Note that our systems may not recognize Do Not Track headers or requests from some or all browsers.

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising. Clarasys does not share your personal information with unaffiliated or non-agent third parties for online or offline promotional purposes.
• Promotional Offers from Us. If you do not wish to have your email address used by us to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to info@clarasys.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions or click the unsubscribe link.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an email to info@clarasys.com or call us at +1 (888) 629-8182. 

Third Party Analytics Providers, Ad Servers and Similar Third Parties

• Clarasys works with (or may in the future work with) network advertisers, ad agencies, analytics service providers, and other vendors to provide us with information regarding traffic on the Site, including pages viewed and the actions taken when visiting the Site; to serve our advertisements on other web sites, within mobile apps and elsewhere online; and to provide us with information regarding the use of the Site and the effectiveness of our advertisements. Our service providers lsmay collect certain information about your visits to and activity on the Site as well as other web sites or services, they may set and access their own tracking technologies on your device (including cookies and web beacons), and may use that information to show you targeted advertisements. Some of these parties may collect Personal Information when you visit the Site or other online websites and services.

• While we may use a variety of service providers to perform advertising services, some of these companies are members of NAI or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You may want to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and the “opt-out” procedures of NAI members. You may also want to visit or http://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an “opt-out” by participating companies in the DAA Self-Regulatory Program. Please note that opting out through these mechanisms does not opt you out of being served advertising, and you will continue to receive generic ads while online.

Your Choices and Opting Out

We strive to provide you with choices regarding the personal information you provide to us or that we collect about you as a Company Representative.

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information, and you must update any changes through your online account.

• In order to opt-out of receiving communications from us by email or postal mail, or to access, delete or modify your information, please email us at: info@clarasys.com or by telephone at +1 (888) 629-8182.
• You may opt-out of receiving marketing e-mails from us by following the opt-out instructions provided in those e-mails.
• We reserve the right to send you service-related emails even if you voluntarily opt-out of email notifications.

Please note that we reserve the right to send you certain communications relating to your use of the Site (for example, administrative and service announcements) via email and other means and these transactional account messages may be unaffected if you opt-out from receiving marketing communications.

Accessing, Modifying or Deleting Your Information

We may not accommodate a request to change or delete information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We will use commercially reasonable efforts to honor your request; however, your Personal Information may remain in our archives and information you update or delete, may persist internally or for our administrative purposes. It is not always possible to completely remove or delete information from our databases.

INFORMATION USE

We have the utmost respect for your privacy and security. Clarasys may use information collected through the Site, including Company Representative information and Device Identifier for the following purposes:

• To facilitate your access to and use of our site
• To submit proposals or enter into agreements with a Customer
• To improve the content of our websites
• To customize the content and/or layout of our page for each individual visitor
• To process information requests
• To communicate with you and send you online and offline marketing communications
• To enable us to publish your reviews to the Clarasys community
• To respond to your questions and comments and provide Company service to you
• To measure interest in and improve our products, services, and website
• To notify you about special offers and products or services available from us that may be of interest to you
• To solicit information from you, including through surveys
• To improve the content and functionality of our websites or our services and for internal business purposes
• To develop new programs, products or services
• To enforce this privacy statement
• To resolve disputes or troubleshoot problems
• For other administrative and analytical purposes such as information systems management, marketing, Company-relations correspondence,

The usage information we collect helps us to improve our Site, services and to deliver a better and more personalized experience by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our services according to your individual interests.
• Speed up your searches.
• Recognize you when you use the Site

If you supply us with your postal address on-line, you may receive periodic mailings from us with information about new products and services or upcoming events

Combination of Information

We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Site as well as information collected offline or from third party sources to help us tailor our communications to you and to improve our Site or services.

CHILDREN’S PRIVACY

Clarasys does not knowingly collect personal identifiable information from children under the age of 18 on this Site. If you are under the age of 18, please do not provide your name and address or other contact details or any other personally identifiable information of any kind whatsoever. If you are a parent or guardian of someone under the age of 18 who has provided us information without your knowledge and consent, you may request that we remove this information by contacting us at info@clarasys.com.

INFORMATION SHARING AND DISCLOSURES

Your privacy is important to us. Any information that we collect online or via the telephone is done to provide you with the best website experience and service possible.

We may disclose Personal Information to third parties in our discretion as otherwise described in this Privacy Statement.

In particular, we may share the information we have collected about you for the following purposes:

1. With service providers we use to support the internal operations of our products or services and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential. We may employ third party companies and individuals to perform services on our behalf, such as to host the Site, perform Site-related functions (e.g., without limitation, maintenance services, database management, data analytics, web analytics and online advertising, payment processing, fraud detection and improvement of our product or service features) or to assist us in analyzing how our Site is used. These service providers may have access to your Personal Information in order to perform these tasks on our behalf subject to the privacy policies of those third parties.

(2) With our affiliated companies, in connection with delivering services and information to you and with other parties in connection with the arrangement of travel services, such as hotels and providers of transportation.

You also may request that we share information about you with a third party and we will typically do so under those circumstances.

(4) As necessary if we believe that there has been a violation of our rights or the rights of any third party, or this Privacy Statement

(5) When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

(6) To respond to judicial process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, national security or law enforcement, as permitted by law, or otherwise as required by law.

Clarasys may transfer and disclose information, including your Personal Information and Device Identifier (including IP addresses), to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Site policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, Site visitors or the public. We may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies, in our discretion.

(7) for internal and affiliate purposes.

Clarasys may share information, including Personal Information, with its parents, subsidiaries, and affiliates, primarily for business and operational purposes. We may sell, transfer or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due diligence process with any potential acquiring entity).  In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information provided through the Services in a manner that is consistent with this Privacy Statement.

(8) as described to you at the point of collection.

We also may share aggregate or anonymous non-personal information with third parties for their marketing or analytics uses.

EXTERNAL LINKS

This website contains links to other websites. We are not responsible for the privacy practices of other websites. This Privacy Statement applies solely to information collected by Clarasys and its affiliates. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We recommend that you examine the privacy statements posted on those other websites to understand their procedures for collecting, using, and disclosing personal information.

SECURITY

The security of your personal information is important to us. We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about You as a Company Representative. In addition, our agreements with Companies include specific security and privacy requirements.

While we make every effort to help ensure the integrity and security of our network and systems, the transmission of information via the internet is not completely secure. Email sent to or from the Services may not be secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

DATA STORAGE AND RETENTION

Your personal information is stored on servers in the United States or in other countries in accordance with the data storage locations of our third party vendors. You understand and agree that we may collect, use, disclose, and otherwise process the information you provide as described in this Privacy Statement. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the United States. We will retain your personal information for as long as it is needed to provide you with the Site, our services, or to fulfill any legal or contractual obligations we may have.

Changes to Our Privacy Statement

We reserve the right to revise this Privacy Statement at any time. When we do, we will post the changes on the Site. If we change the Privacy Statement in a material way, we will provide appropriate notice to you. Your continued use of the Site or our services after any changes or revisions to this Privacy Statement shall indicate your agreement with the terms of such revised Privacy Statement.

Please also feel free to contact us at info@clarasys.com. if you have any questions about our Privacy Statement or the information practices of the Site.

If you need to access this Policy in an alternative format due to having a disability, please contact us at info@clarasys.com or +1 (888) 629-8182.

How you can contact us

If you have questions about this privacy policy, or if you believe that this site is not following its stated Privacy Policy, please contact us at:

info@clarasys.com

+1 (888) 629-8182

Clarasys, Inc.

33 Arch Street, 17th Floor

Boston, MA 02110

YOUR CALIFORNIA RIGHTS

Thank you for visiting our website. This California Privacy Statement supplements our United States privacy policy and is intended to inform you about our policies and procedures regarding the collection, use and disclosure of information collected from individuals in California by Clarasys, Inc. and its affiliates including Clarasys Limited (“Clarasys” or “We”) as further set forth in above.

We do not sell or share your information with third parties, other than with our service providers who support the internal operations of our company or who help us provide our products and services to Companies.

Company Representatives who are California residents have the following rights:

• The right to know the categories of personal information we’ve collected and the categories of sources from which we got the information;
• The right to know the business purposes for sharing personal information;
• The right to know the categories of third parties with whom we’ve shared personal information;
• The right to access the specific pieces of personal information we’ve collected;
• The right to delete your information;
• The right to opt-out of automated decision-making and the sale or sharing of your information.
• The right to correct information;
• The right to limit use and disclosure of sensitive information.

California residents also have the right to not be discriminated against if they choose to exercise their privacy rights.

YOUR PERSONAL INFORMATION UNDER THE CCPA

We collect your personal information as set forth in the below chart.

To learn more about the sources from which this personal information is collected, please refer to our Privacy Policy.

To learn more about why this personal information is collected and whom we share this personal information with, please see the above privacy statement.

Sensitive Personal Information Category	Government identifiers (social security, driver’s license, state identification card, or passport number)	NO	NO
	Complete account access credentials (user names, account numbers, or card numbers combined with required access/security code or password)	NO	NO
	Precise geolocation	NO	NO
	Racial or ethnic origin	NO	NO
	Religious or philosophical beliefs	NO	NO
	Union membership	NO	NO
	Genetic data	NO	NO
	Mail, email, or text messages contents where we are not the intended recipient of the communication	NO	NO
	Unique identifying biometric information	NO	NO
	Health, sex life, or sexual orientation information	NO	NO

Sales of or Sharing Personal Information

We do not sell or share your information with third parties.

We may share your personal information with Service Providers and with third party advertisers, analytics, aggregators, and content providers. When we disclose personal information to service providers for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

A. Identifiers

B. Personal information categories listed in

the California Customer Records statute

(Cal. Civ. Code § 1798.80(e)).

D. Commercial Information

E. Biometric Information

Exercising your Rights

In order to exercise your California rights, please contact us by email or phone and provide us with your name, customer number and address:

info@clarasys.com

+1 (888) 629-8182

Clarasys, Inc.

33 Arch Street, 17th Floor

Boston, MA 02110

Right to Access/Data Portability

Consumers have the right to request that a business that collects personal information about them disclose the following:

(1) The categories of personal information it has collected about that consumer;

(2) The categories of sources from which the personal information is collected;

(3) The business or commercial purpose for collecting, disclosing or selling personal information;

(4) The categories of third parties with whom the business shares personal information;

(5) The specific pieces of personal information it has collected about that consumer.

Our disclosure will cover a 12-month period preceding the date of your request.

Within 45 days, we will provide you with a copy of the information listed in “Right to Access / Data Portability,” above, by mail or electronically. To the extent possible, this information shall be provided in a portable and usable format.

Right to Deletion

Consumers have the right to request that a business delete any personal information about them. However, there are exceptions to this rule. For example, a business does not have to delete information if it is necessary to: a) complete a transaction; b) prevent illegal activity; c) exercise free speech; d) comply with a legal obligation; e) identify or repair errors that impair functionality; or f) otherwise use a Consumer’s personal information, internally, that is compatible with the context in which the Consumer provided that information.

We have created a two-step process for responding to requests for deletion. After you submit the initial request, we will ask that you separately confirm that you would like your information deleted.

If your request does not fall within one of the exceptions to deletion listed in “Right to Deletion,” above, we will confirm deletion within 45 days. If we are not required to delete your account, we also let you know within 45 days.

Right to Correct Information

Consumers have the right to request that a business correct any inaccurate personal information about them.

How to Exercise Your Rights

To exercise your right to access, delete or correct your information, please submit a Verifiable Consumer Request by sending an email to info@clarasys.com. Please include “Consumer Privacy Right” in the subject line.

We will reach out within 10 days to confirm that we have received your request.

We will then take steps to determine whether your request is a valid Verifiable Consumer Request. If you have an account, we may ask you to login to confirm this information. We will not ask you to create an account if you do not already have one. We will only ask for information that is reasonable in light of the nature of your request.

In the event we need additional time, we will inform you within the initial 45-day period of our need for an additional 45 days (for a maximum of 90 days between request and provision of information).

We are not required to provide personal information to a Consumer more than twice in a 12-month period.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

1. Deny you goods or services.
2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
3. Provide you a different level or quality of goods or services.
4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We do not offer consumers financial incentives that can result in different prices, rates, or quality levels.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@clarasys.com.