PRIVACY POLICY

December 8, 2016

Protecting your private information is our priority.  This Statement of Privacy (“Privacy Policy”) applies to CommuniClear Global, Inc., and its subsidiaries and affiliates (hereinafter, variously “CommuniClear Global,” “we,” or “our”), and our mobile services and website (communiclearglobal.com and training.communiclearglobal.com) (collectively, the “Services”), and your choices about the collection and use of your information.     

By using our Services in any manner, you indicate to CommuniClear Global that you have read and accept our Privacy Policy and consent to the data practices described in this Privacy Policy.  If you do not accept this Privacy Policy or do not meet or comply with the provisions set forth herein, then you may not use our Services.

INFORMATION WE COLLECT

When you use our Services, you may provide CommuniClear Global with two main types of information: (1) personally identifiable information that you knowingly choose to disclose, which is collected on an individual basis, and (2) general user information that does not contain personally identifiable information, which is collected on an aggregate basis as you browse and use our Services. We collect information from you when you (a) use and/or access our Services, (b) register an account and/or subscribe to CommuniClear Global, (c) open and/or respond to our emails, (d) contact CommuniClear Global, (e) visit any page online that displays our content, (f) purchase products and/or services through our Services, (g) connect and/or link via social networking website, and/or (h) provide information to any of our vendors.

Personally Identifiable Information You Choose to Provide

We may ask for certain personal information from you for the purpose of providing to you content and/or services that you request.  We collect personal information such as your: (i) contact information (including name, telephone number, email and shipping address); (ii) financial information (such as credit card number, expiration date, verification number and billing address); (iii) username and password (specifically chosen by you or your social media user name/handle); (iv) demographic information (including age, birthdate and gender); (v) location information (such as geographic location of the device you are using) and (vi) preferences and behavior (such as record of purchases made, ratings and comments).  Once you register, you have opted in to receive electronic communications from CommuniClear Global.  CommuniClear Global may also provide you with the opportunity to participate in surveys through our Services.  If you participate, we will request certain personally identifiable information.  Participation in surveys is completely voluntary and you therefore have a choice whether to disclose such information.

If you so choose, you may connect to and/or register an account using an external third-party application, such as ‘LinkedIn’. CommuniClear Global may receive some data from such connected third-party applications. Connecting your account to third-party applications and/or services is optional, and when you connect your account to an external application, you will be given the opportunity to grant permission.  By connecting to external third party applications, we may help you find friends using your account or we may allow people to search for your account using your contact information. You can revoke the foregoing permissions under your account settings and/or with the external third-party application. Depending on which services you choose to use, CommuniClear Global may require additional information and contact information.

Non-Personally Identifiable Information We Collect

Cookies:  We use cookies and web log files to track website usage and trends, to improve the quality of our service and to customize your experience.  A “Cookie” is a tiny data file that resides on your computer, mobile phone, or other device, and allows CommuniClear Global to recognize you as a user when you return to our website using the same computer and web browser.  Information gathered through Cookies may include the date and time of visits, the pages viewed, and time spent at our website. You can remove or block Cookies using the settings in your browser, but in some cases that may impact your ability to use our Services.   

Device Data: We use device data, which is information concerning a device you use to access, use, and/or interact with the Services, such as operating system type and/or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, unique device identifier and/or other device identifier, mobile phone carrier identification, and device software platform and firmware information.

Aggregate:  We may collect non-identifying and statistical information about the use of our Services, such as how many visitors visit a specific page, how long they stay on that page and which links, if any, they click on.  This information represents a generic overview of our users, including their collective habits. Information collected in the aggregate is not associated with you as an individual. We may share user information in the aggregate with third parties.  

Other Tracking Technologies: We may supplement information you provide to us with information from other sources, such as information to validate and/or update your address, payment card and/or other demographic information.  This information is used to maintain the accuracy of information on our Services and for internal analysis.  We may also use clear gifs, pixel tags and web beacons, which are tiny graphic images placed on website pages and/or in our emails that allow us to determine whether you have performed specific actions and are further used to track online movements of our users.  In contrast to Cookies, which are stored on your computer’s hard drive, clear gifs are embedded invisibly on web pages.  We do not tie the information gathered by clear gifs to your personally identifiable information.

Third Party Services:  To support the services we provide to you, we may use services hosted by third parties.  These services may collect information sent by a browser as part of a web page request, including Internet Protocol (“IP”) addresses, browser software, and/or clickstream patterns. If such third party services collect information, they do so anonymously without identifying individual visitors.  However, we may link the information we record using tracking technology to personal information we collect.  In addition, we may allow third parties who list services to use Cookies in connection with your use of the Services.  They may collect and store the same type of information and use it similarly to CommuniClear Global, as described above.

HOW WE USE THAT INFORMATION

General Use

We use information collected as described in this Privacy Policy to provide you with the information and/or content that you have requested, and, in some cases, to contact you about our products, features and/or services.  We also use the information collected to take the following actions:

·       operate, maintain and improve our Services;

·       provide you with interest based ads and products;

·       answer questions and respond to your requests;

·       perform analytics and conduct research;

·       send you reminders, support and marketing messages;

·       manage our administration of the Services;

·       improve the design and content of our Services; and

·       analyze programs, products and services we offer.

 

The information collected in the aggregate enables CommuniClear Global to better understand your use of the Services and to enhance your enjoyment. We may use financial information to process payment for any purchases made on our Service, enroll you in one of our accounts and/or other related services in which you elect to participate.  If you use the Services, you agree to receive certain communications from us including but not limited to the following:

Special Offers, Newsletters and UpdatesWe will occasionally send you information on products, special deals, promotions and newsletters. Out of respect for your privacy, you may elect not to receive these types of communications by changing your account setting through the Services.

Customer ServiceBased upon the personally identifiable information you provide us, we will communicate with you in response to your inquiries, to provide the services you request and to manage your account. We will communicate with you by email or telephone, as you may elect.

Supplementation of InformationIn order to process your credit card orders, we use a third party provider to validate and verify your account information.  All billing and account information is transmitted via https, which is a secure encrypted protocol system.

Parties with whom we may share your information:

We may share your personally identifiable information as well as information from tools like cookies, log files, and device identifiers and location data (such as usage data, referring/exit pages and URLs, platform types, number of clicks, etc.), with employees, contractors, and/or agents that help CommuniClear Global provide the Services to you ("Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Services.  We take the privacy of our users very seriously, and we do not sell, rent, and/or otherwise provide your personally identifiable information to third parties for marketing purposes.  We will not share your personally identifiable information in ways unrelated to those described in this Privacy Policy without providing you with an opportunity to opt out of such use or otherwise prohibit such unrelated use. Certain Service Providers will automatically collect non-identifying information about your use of our Services by using Cookies and other technologies as similarly used by CommuniClear Global.

Disclosures

CommuniClear Global will not disclose your personal information to third parties except as set forth in this Privacy Policy and in the following circumstances: (i) to investigate and defend CommuniClear Global members against any third party claims and/or allegations and/or otherwise to protect CommuniClear Global from liability, (ii) to investigate, prevent and/or take action regarding suspected and/or actual illegal activities, (iii) to assist government enforcement agencies, respond to a legal process and/or comply with the law, (iv) to exercise or protect the rights, property and/or personal safety of the users of the Services and/or (v) to protect the security and/or integrity of the Service.

What happens in the event of a change of control:

If we sell or otherwise transfer part or all of CommuniClear Global or our assets to another organization (e.g., in the course of a transaction such as a merger, acquisition, bankruptcy, dissolution, liquidation, etc.), your information such as name and email address, user content and/or any other information collected through the Services may be among the items sold and/or transferred.

YOUR INFORMATION CHOICES

We respect your privacy and give you an opportunity to opt out of receiving announcements of certain information.  Although we think that you benefit from a more personalized experience when we know more about you and what you like, you can limit the information you provide to CommuniClear Global, and you can limit the communications that CommuniClear Global sends to you.  If you visit our Services and volunteer personally identifiable information, you can opt out of receiving notifications, and you may review, modify, update, and/or delete such personally identifiable information by contacting and/or by changing your preferences on the Service.  Please be aware that even after your request for a change is processed, CommuniClear Global may, for a time, retain residual information about you in its backup and/or archival copies of its database.  Please be aware that we may still email you non-commercial emails related to your account and your transactions through our Services.  Following termination and/or deactivation of your account, CommuniClear Global may retain information (including without limitation your profile information) for a commercially reasonable time for backup, archival, and/or audit purposes. In some cases, if you choose not to provide CommuniClear Global with requested information, you may not be able to use and/or access all of our Services. 

Your California Privacy Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to receive:  (a) information identifying any third party companies to whom CommuniClear Global may have disclosed personal information to for direct marketing, within the past year; and (b) a description of the categories of personal information disclosed. To obtain such information, please email your request to sgallant@ccg-training.com and we will provide a list of categories of personal information disclosed within thirty (30) days of receiving such a request.  This request may be made no more than once per calendar year.  We reserve the right not to respond to requests submitted in ways other than those specified above.

SERVICE ELIGIBILITY AND CHANGES

Children and Minors. CommuniClear Global does not knowingly collect personally identifiable information from children under the age of thirteen (13). If we learn that we have collected personal information from a child under age thirteen (13), we will delete such information as quickly as possible. If you believe that a child under the age of thirteen (13) may have provided us personal information, please contact us at sgallant@ccg-training.com. By using the Services, you represent that you are at least eighteen (18) years old and understand that you must be at least eighteen (18) years old in order to create an account and/or purchase the goods and/or services through the Services.

Changes to Privacy Policy.  We may update this Privacy Policy at any time, with or without advance notice, so please review it periodically.  We may provide you additional forms of notice of modifications and/or updates as appropriate under the circumstances. Your continued use of the Services after any modification to this Privacy Policy will constitute your acceptance of such modifications and/or updates.  You can determine when this Privacy Policy was last revised by referring to the date it was “Last Modified” above. 

SECURITY

We work hard to secure your personal information from unauthorized access to and/or unauthorized alteration, disclosure and/or destruction of information we hold.  Your account is protected by password for your privacy and security.  We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. Because the internet is not a completely secure environment, CommuniClear Global cannot warrant the security of any information you transmit to CommuniClear Global or guarantee that information on the Services may not be accessed, disclosed, altered, and/or destroyed by breach of any of our physical, technical and/or managerial safeguards.  Please do your part to help CommuniClear Global.  You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and CommuniClear Global, at all times.  Please limit your access to your computer and/or mobile device and/or browser by signing off after you have finished accessing your account.   We are not responsible for the functionality, privacy and/or security measures of any other organization.

DATA TRANSFERS

Please be aware that our Services are subject to United States laws, including those governing privacy and security of your information.  We may host and process data including your personal information in the United States.  By using our Services, you agree and consent (and represent that you have the authority to provide such consent) to the information collection, use and sharing practices described in this Privacy Policy and understand that the laws of the United States related to the foregoing may differ from those of other countries and may not be as protective as the laws in the country where you reside.

OTHER WEB SITES AND SERVICES

We are not responsible for the practices employed by any websites and/or services linked to and/or from our Services, including the information and/or content contained therein. Please remember that when you use a link to go from our Services to another website and/or service, our Privacy Policy does not apply to such third-party websites and/or services. Your browsing and interaction on any third-party website and/or service, including those that have a link on our Service, are subject to such third party's own rules and policies. In addition, you agree that we are not responsible and do not have control over any third-parties that you authorize to access your personal information. If you are using a third-party website and/or service and you allow them to access your personal information, you do so at your own risk.

HOW TO CONTACT US

If you have questions and/or comments about this Privacy Policy, please email us at sgallant@ccg-training.com.