Privacy Policy

PRIVACY POLICY
Last Modified: July 5, 2018

Protecting your private information is our priority. This privacy policy (“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 the Services in any manner, you indicate to CommuniClear Global that you have read and accept our Privacy Policy and consent to the data practices, including without limitation the collection and use of your personal data, 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. If required by applicable law, we will seek your express consent to process personal data (i) provided by you and/or (ii) collected during your use of the Services. Any consent shall be entirely voluntary. In the event you do not provide consent to us to process your personal data, then you may not access and/or use the Services.

INFORMATION WE COLLECT
When you use the 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.  Examples of the foregoing may include, without limitation, first name, last name, e-mail address and IP address and further described herein.  We collect information from you when you (a) use and/or access the 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 the 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/orservicesis 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.

Personal Data We Collect
When you access and/or use the Services, we may automatically collect information about you, including:

Cookies:  In an effort to be transparent with our data collection practice and the technologies we use to provide the Services, the following explains how we use Cookies. We use cookies and web log files to track website usage and trends, to improve the quality of the 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 device and web browser and enables CommuniClear Global to collect information about how you use our Services.  Information gathered through Cookies may include the date and time of visits, the pages viewed, and time spent at using the Services.   If you do not agree to our use of Cookies, you should set your browser settings accordingly or not use the Services.   You may remove or block Cookies using the settings in your browser, but in some cases that may impact your ability to use the Services and/or user experience while using the Services.  CommuniClear Global uses Cookies and web log files for the following, which may include without limitation (i) to track usage and trends, (ii) to improve the quality of the Services, (iii) to customize your experience and/or (iv) to compile anonymous, aggregated information that allow us to understand how our Services are used.

Cookies are categorized by how long they are stored and their function.  The Cookies CommuniClear Global uses are as follows:
·      Persistent Cookies: Persistent Cookies remain on a visitor’s device for a set period of time specified in the Cookie. They are activated each time that the visitor visits the Services that created that particular Cookie.
·      Session Cookies: Session Cookies are temporary and deleted from your computer when you close your web browser. They allow CommuniClear Global to link the actions of a user while using the Services.
·      Strictly Necessary Cookies: Strictly necessary Cookies are essential to navigate around the Services and to use its features.
·      Performance Cookies: Performance Cookies collect anonymous data for statistical purposes on how users use the Services, they don’t contain personal information and are used to improve the user experience.
·      Functionality Cookies: Functionality Cookies allow CommuniClear Global to operate the Services in accordance with your choices, such as ‘remembering’ you in between visits.

You can adjust the settings on your browser and reject the setting of all or some Cookies and it will alert you when a Cookie is placed on your device.  You may also delete previously stored Cookies; however this will not prevent the Services from placing future Cookies on your device unless and until you adjust your settings as described above.  Please note, blocking any or all Cookies may impact your use of the Services as mentioned above.

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 the 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.

Analytics:  CommuniClear Global uses analytic software to gather statistics and usage trends for product and service improvement purposes.  The Service may record data from your phone, tablet, or computer such as how frequently you use the Service, what actions you take and performance data.

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, and/or other demographic information.  This information is used to maintain the accuracy of information on the 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’ 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 Services and/or the information and/or content that you have requested, and, in some cases, to contact you about our products, features and/or other services.  We also use the information collected to take the following actions:
·      operate, maintain and improve the Services;
·      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;
·      facilitate and process skills training, real-time and/or recorded speech samples;
·      improve the design and content of our Services;
·      analyze programs, products and services we offer; and
·      use information for other purposes about which we notify you.

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 agreeto receive certain communications from usincluding but not limited to the following:

Special Offers, Newsletters and Updates.  We will occasionally send you information on products, special deals, promotions and newsletters. Out of respect for your privacy, you may electnot to receive these types of communications by contacting us or replying to our emails.

Customer Service.  Based 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 Information.  In order to process your credit card orders, we use a third party provider to validate and verify your account information.  All billing and account informationis transmitted via https, which is a secure encrypted protocol system.

Parties with whom we may share your information:
Service Providers:  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 strive to use commercially acceptable means to protect your personal information. If Service Providers acquire confidential or proprietary information belonging to CommuniClear Global or its customers, such information is required to be handled in confidence and may not be disclosed to unauthorized third parties. Service Providers who violate our security and safe maintenance of data policies are subject to appropriate discipline including, but not limited to, termination.  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.  We encourage our Service Providers to adopt and post privacy policies; however, such Service Provider’s use of personally identifiable information obtained through CommuniClear Global is governed by such Service Provider’s privacy policies and is not subject to our control. Certain Service Providers will automatically collect non-identifying information about your use of the Services by using Cookies and other technologies as similarly used by CommuniClear Global.

Compliance with Laws:  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.

Business Transfers:  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
Depending on the situation, CommuniClear Global may obtain consent to the collection of personal information in different ways. In the event express consent is required, it will be obtained in writing. Implied consent may be obtained through your use of our skills training and related Services, or when you approach us to obtain information, inquire about or request Services from us.
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 the 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 the Services.  Following termination of Services , CommuniClear Global may retain information (including without limitation your personally identifiable information) for a commercially reasonable time for backup, archival, and/or audit purposes and/or to comply with legal obligations, resolve disputes and enforce agreements. 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 the 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@communiclearglobal.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 waysother 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@communiclearglobal.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.  In general, changes will be made to this Privacy Policy to address new or modified laws and/or new or modified business procedures.  However, we may update this Privacy Policy at any time, with or without advance notice, so please review it periodically.  We will update the ‘Last Modified’ date above and may provide you additional forms of notice of modifications and/or updates as appropriate under the circumstances.  You can determine when this Privacy Policy was last revised by referring to the date it was “Last Modified” above.  If you disagree with any changes to this Privacy Policy and do not wish your information to be subject to the revised Privacy Policy, you will need to stop using the Services.  Your continued use of the Services after any modification to this Privacy Policy will constitute your acceptance of such modifications and/or updates.

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.  CommuniClear Global has adopted appropriate physical, electronic and managerial procedures to safeguard and secure the personal information we process. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. Since 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; however, CommuniClear Global implements and maintains appropriate technical, security and organizational measures to protect personal data against unauthorized or unlawful processing and use, and against accidental loss, damage, destruction, theft or disclosure. Please do your part to help CommuniClear Global.  Please do your part to help CommuniClear Global.  You are responsible for maintaining the secrecy of your 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 the Services.   We are not responsible for the functionality, privacy and/or security measures of any other organization.

DIRECTIVE 95/46/EC & GENERAL DATA PROTECTION REGULATION
CommuniClear Global adheres to the Directive 95/46/EC (“Directive”) and, commencing on May 25, 2018, the European Union’s (“EU”) General Data Protection Regulation (“GDPR”).

DATA TRANSFERS
Please be aware that our Services are subject to United States laws, including those governing privacy and security of your information.  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. Regardless of the laws in place in such countries, we will treat the privacy of your information in accordance with this Privacy Policy.

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.

DATA PROCESSING AGREEMENT
If you or your organization are required to enter into a contract with your data processor under the GDPR, please contact CommuniClear Global at sgallant@communiclearglobal.com for its data processing agreement (“DPA”). In addition, CommuniClear Global has a data processing agreement in place with any sub-processors it uses to process EU personal data in compliance with the Directive and the GDPR.

LANGUAGE
The governing language of this Privacy Policy is English, which shall prevail over any other languages used in any translated document.

HOW TO CONTACT US
If you have questions and/or comments about this Privacy Policy, please email us at sgallant@communiclearglobal.com.