Last Updated: 07/11/2022
Clear Action Business Advisors, (“Clear Action Business Advisors”, “we”, “us” and/or “our”) is committed to protecting your privacy. Wherever possible, we want to communicate openly and directly with each and every user of our automated marketing and customer engagement service for businesses and related services (the “Services”).
CONFIDENTIALITY OF YOUR CONSUMER INFORMATION AS A CUSTOMER
COLLECTION AND USE OF YOUR INFORMATION, AS A CUSTOMER, CONSUMER OR VISITOR
When you interact with us through the Services, we may collect Personal Data and other information from you, and use such information, as further described below:
Personal Data That You Provide Through the Services:
Non-Identifiable Data: When you interact with Clear Action Business Advisors through the Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Clear Action Business Advisors may store such information itself or such information may be included in databases owned and maintained by DPG Paver's affiliates, agents or service providers.
The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process.
COLLECTION AND USE OF YOUR INFORMATION AS A CONSUMER
The Services use and provide to our Customers certain Personal Data and other non-personally identifiable information about their Consumers and those Consumers’ interactions with our Customers’ products and services. Clear Action Business Advisors obtains this information as a result of information being sent to our servers by Clear Action Business Advisors’s Customers, by the tracking agent (the “Agent”), as embedded by or on our Customers’ behalf, on our Customers’ websites and in emails sent to our Customers’ Consumers. Clear Action Business Advisors uses this data to create reports for our Customers to analyze how their Consumers interact with their products and services and to create reports and/or metrics against which they can compare their user base. In addition, we provide our Customers with aggregated and anonymous benchmark data that includes their Consumer data and our other Customers’ Consumer data.
AGGREGATED PERSONAL DATA
In an ongoing effort to better understand and serve the users of the Services, Clear Action Business Advisors often conducts research on its Customers and their Consumers’ demographics, interests, and behavior based on Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Clear Action Business Advisors may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Clear Action Business Advisors may also disclose aggregated statistics and other anonymized (personally non-identifiable) information about its Customers and their Consumers, in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
OTHER USES OF YOUR PERSONAL DATA AND OTHER INFORMATION
As part of our Services, Clear Action Business Advisors and its affiliates may use Personal Data collected through the Service to contact you in the future about services we believe will be of interest, including marketing communications sent on behalf of multiple Customers or other parties (“Multiple Customer Emails”). All of our communications will include opt-out instructions, as follows:
1. Marketing communications sent on behalf of our Customers will contain instructions permitting the Consumer to opt-out of receiving future marketing communications from that specific Customer, and a Customer may also directly inform Clear Action Business Advisors of an opt-out from such Customer’s Consumer (each, a “Customer-Specific Opt-Out”). If a Consumer opts-out of such marketing communications by informing the Customer, we will not be aware of such opt-out until the Customer informs us; however, the Consumer can still directly opt out of marketing communications by following the instructions provided by us to opt-out.
2. Multiple Customer emails will contain instructions permitting the Consumer to opt-out of receiving such future Multiple Customer Emails. Note that such an opt-out does not constitute a Customer-Specific Opt-Out. Clear Action Business Advisors and its subsidiaries and affiliates (the “Related Companies”) may also use Personal Data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services.
OUR DISCLOSURE OF YOUR PERSONAL DATA AND OTHER INFORMATION
Agents, Consultants, and Related Third Parties:
Clear Action Business Advisors, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Clear Action Business Advisors may disclose Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Clear Action Business Advisors, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
As a Customer, you must plainly and conspicuously notify your Consumers that when they use your website or service, information about their activities online is being collected by a service that collects information about their activities across different websites, and describe the above opt-out procedures, in a privacy agreement or policy with your Consumers.
Clear Action Business Advisors is not responsible for any use by its Customers of any data regarding their Consumers. Those Consumers should review the policies of the applicable Customer(s) to understand their use of such data.
You can visit the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services.
others without limitation or attribution.
Clear Action Business Advisors does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. If you have reason to believe that a child under the age of 13 has provided Personal Data to Clear Action Business Advisors through the Services, please contact us, and we will endeavor to delete that information from our databases.
You may not use the Services:
a) in connection with any product, service, or advertisement directed towards children or
b) to collect any Personal Data of children.
LINKS TO OTHER WEBSITES
Clear Action Business Advisors takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to Clear Action Business Advisors via the Internet.
YOUR CALIFORNIA PRIVACY RIGHTS:
Under California Civil Code 1798, California residents with an established business relationship can request information about sharing their personal information with third parties for the third parties’ direct marketing purposes. If you are a California resident and would like more information, please contact us by emailing us at email@example.com.
ACCESS TO INFORMATION; CONTACTING Clear Action Business Advisors
To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services.