CLEARLIGHT respects the personal information of people that it collects (such as title, name, telephone number, date of birth, address etc) and complies with the General Data Protection Regulation (EU 679/2016) (GDPR).
We ask that you read this privacy notice carefully as it contains important information on:
- who we are;
- how and why we collect, store, use and share personal information;
- your rights; and
- how to contact us and supervisory authorities in the event you have a complaint.
- Transfer of your personal information out of the EEA
- Keeping your personal information secure
1. WHO WE ARE
CLEARLIGHT with its registered office at 3867 W Market St. Ste 168 Akron OH 44333, USA collects, uses and is responsible for certain personal information about you.
When we do so we are regulated under the GDPR which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
2. THE PERSONAL INFORMATION WE COLLECT AND USE
a) Information collected by us:
In the course of providing our marketing services we collect the following personal information:
- Information you provide to us when you contact us to request our services.
- Information obtained through the use of emails and cookies to identify you when you contact us about our services.
- Information collected through publicly available sources such as social media platforms (Facebook, LinkedIn and any others) for the purposes of our B2B marketing activities.
- The types of information we collect includes name, business address, email address, telephone contact numbers and dates.
b) We use personal information to:
- To provide our marketing services to you.
- Verify your identity
- Improve our services
- Where you have given explicit consent, we may use your personal Information to send you information about products or services that may be of interest to you.
- For business related purposes.
This website is not intended for use by children and we do not knowingly collect or use personal information relating to children.
c) Who we share your personal information with
We will only share personal information with law enforcement or other public authorities and regulators if required by applicable law.
As we are a company which operates globally, we may share your information with third party recipients who may be based outside the European Economic Area.
d) Whether information has to be provided by you, and if so why.
You will be required to provide your name, address, email address and telephone number. If you choose not to provide this information to us, we may not be able to provide our services to you.
e) How long your personal information will be kept
We will hold your personal data in accordance with applicable laws and for as long as we need your data to provide services. Where we do not require your data we will delete it.
f) Reasons we can collect and use your personal information
We rely on a combination of legal bases to collect, use, process and store your personal data. These include consent (which we may collect at the point of entering a contract with you), legitimate interests and contract performance.
g) Transfer of your personal information out of the EEA
To provide our marketing services, we may transfer the personal information we collect to countries outside of the EEA which do not provide an adequate level of data protection similar to that which applies in the EEA in the country in which you live and which are not recognised by the European Commission as providing the same level of data protection. We only transfer personal information to these countries when it is necessary for the services we provide you.
Transfers of data are subject to safeguards that assure the protection of your personal information such as European Commission approved standard contractual clauses.
If you would like further information please contact us, or our Data Protection Officer (see ‘How to contact us’ below).
3. YOUR RIGHTS
Under the GDPR you have a number of important rights. In summary, those include rights to:
a) Opt-out / object to processing
You have the following opt-out rights/rights to object to processing which are set out in more detail below:
- to object to direct marketing;
- to object to processing on the basis of a legitimate interest;
- to withdraw consent;
- the right of erasure; and
- the right to restriction of processing.
b) Our contact details for exercising your opt-out rights/rights to object to processing
You can exercise your opt-out rights/rights to object to processing as follows:
In the case of the processing of personal data for direct marketing, by clicking here Direct Marketing Opt-Out
In any case, by:
- emailing us at email@example.com;
- phoning us on (888) 978-9262 709, between 9 am and 5 pm USA Eastern Time; or
- writing to us at 3867 W Market St. Ste 168 Akron OH 44333, USA
c) Your right to object to direct marketing
You have the right to object at any time to processing of personal data concerning you for the purposes of direct marketing. This includes the right to object to processing which amounts to profiling and which is related to direct marketing.
d) Your right to object to processing on the basis of a legitimate interest
If we are processing your data, including if we are carrying out profiling in respect of it, on the basis of our legitimate interest, you have the right to object at any time on grounds relating to your particular situation.
If you object, we will cease to process the data unless we have compelling legitimate grounds to continue to do so or need to continue to process the data for the establishment, exercise or defence of legal claims.
You can object to this kind of processing by using the contact details above.
e) Your right to Withdraw Consent
If you have given us consent to use your personal data, you have the right to withdraw that consent at any time.
You can withdraw consent by using the contact details above.
f) Your right of Erasure
You have the right to require us to erase your personal data without undue delay where:
- the data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- you have withdrawn your consent on which the processing is based and there is no longer any legal ground for the processing;
- you exercise your right to object to the processing when that processing is based on legitimate grounds or you exercise your right not to be subject to a decision based solely on automated processing (these rights are explained elsewhere in this policy);
- the personal data have been unlawfully processed (of course we have no intention of carrying out any unlawful processing and do our utmost to avoid any unintentionally unlawful processing); or
- the personal data have to be erased for compliance with a legal obligation to which we are subject.
You can exercise this right by using the contact details above.
g) Your right to Restriction of Processing
You have the right to in certain circumstances to require us to restrict processing of your data. The right applies:
- during a period to enable us to verify data which you have said is inaccurate;
- where the processing is unlawful, and you oppose the erasure of the personal data and request restriction of its use instead (of course we have no intention of carrying out any unlawful processing and do our utmost to avoid any unintentionally unlawful processing);
- we no longer need the data for the processing, but you need the data for the establishment, exercise or defence of legal claims; and
- you have objected to processing based on a legitimate interest for a period to enable us to verify whether our legitimate interests override yours.
If you exercise that right, processing of your personal data will be limited to:
- processing to which you have consented;
- processing for the establishment, exercise or defence of legal claims, the protection of the rights of others or for reasons of important public interest.
You can exercise this right by using the contact details above.
h) Your right to fair processing of information and transparency over how we use your personal information.
i) Your right to access to your personal information. Please provide enough information to identify yourself correctly; you may make such a request by emailing us at firstname.lastname@example.org.
j) Your right to require us to correct any mistakes in your information which we hold. You can request us to rectify and correct any personal data that we are processing about you which is incorrect by contacting us at email@example.com. We will update your personal details and keep your data accurate.
Please note that some of these rights apply in specific circumstances and are qualified by exemptions in data protection legislation. We will advise you if we are relying on any such exemptions when we respond to you.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
4. KEEPING YOUR PERSONAL INFORMATION SECURE
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach in 72 hours where we are legally required to do so.
You should also note that whilst we will use all our efforts to protect your privacy and data, we cannot ensure or warrant the security of any information you transmit to us over the internet because no method of transmission over the internet or method of electronic storage can be guaranteed to be absolutely secure.
5. HOW TO COMPLAIN
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the United Kingdom is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
7. HOW TO CONTACT US
Please contact us if you have any questions about this privacy notice or the information by emailing us at firstname.lastname@example.org. or writing to us at 3867 W Market St. Ste 168 Akron OH 44333, USA.
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