Effective on:  July 12, 2018

Purpose:

This Privacy Policy (“Policy”) explains the personal information that Clearwater Compliance LLC (“Clearwater”, “Our,” “We,” or “Us”) collects from you, or that you may provide to us, through our websites, https://blog.clearwatercompliance.com/blog, and https://clearwatercompliance.com.

This Policy applies to all websites operated by Clearwater (other than the IRM | Pro™ website, which has its own privacy policy), and a copy of this Policy is posted on each of Clearwater’s websites other than the IRM | Pro™ website, which has its own privacy policy.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use this website. By accessing or using this website, you agree to this privacy policy and to the international transfer of your data. This Policy may change from time to time. Your continued use of this website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

Children Under the Age of 13

Our websites are not for use by children under 13 years of age. If you are under 13, do not use or provide any information on this website or on or through any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please email us at info@clearwatercompliance.com

Information You Provide to Us

You may choose to provide the following information to us through this website:

  • Your business contact information, including your name, address, telephone number, email address, url, company name and job title;
  • Your company’s classification under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). For example, “covered entity” or “business associate”; and your company’s industry and type of business; or
  • records and copies of your correspondence, if you contact us.

IMPORTANT NOTE:  If you receive an email that looks like it is from us asking you for confidential personal information, do not respond.  We will never request your user name, password, credit card information or other confidential personal information through email.

Cookies and Web Beacons

As you navigate through and interact with this website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

  • Details of your visits to this website, including traffic data (including date and time of visits), and other communication data and the resources that you access and use (including your page views and search queries) on the website; and
  • Information about your computer and internet connection, including your IP address, location data, operating system and browser type and version.

The technologies we use for this automatic data collection are:

  • cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser.  Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to this website;
  • web beacons. Pages of this website may contain small electronic files known as web beacons (also known as smart pixels) that permit us to count users who have visited those pages and for other related website statistics.

We use cookies and web beacons to help us to improve this website and to provide you with a more personalized experience.  For example, we use cookies and web beacons to recognize your usage patterns and preferences whenever you return to this website.  Some of these cookies may remember your information for purposes of auto-populating a form.

We may use these technologies to collect information about your online activities over time and across third-party websites or other online services to deliver advertising tailored to your interests (behavioral tracking).  Please contact info@clearwatercompliance.com for information on how you can opt out of behavioral tracking on this website.

The information we collect automatically is statistical data and may include personal information, or we may maintain it or associate it with personal information we collect in other ways, including information that you provide to us, or that we receive from third parties.

How We Use Your Information

We use information that you provide to us, or that we collect about you, in the following ways:

  • To provide you with information that you request from us, or to respond to your inquiries;
  • To communicate with you and your organization about solutions, services, and information that may be of interest;
  • To conduct market research, including research about potential new solutions and services;
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you/your organization and us, including for billing and collection;
  • To notify you about changes to this website or any services or solutions we offer or provide through the website;

If you do not want us to use your information for direct marketing purposes or behavioral tracking, please contact info@clearwatercompliance.com.

How We Disclose Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose the personal information that we collect or you provide as described in this Policy to the following third parties:

  • To third parties who support Clearwater’s business, including those with which we partner to deliver webinars or symposia;
  • To an entity acquiring information about visitors to Clearwater’s websites as part of a corporate transaction, including in connection with a merger, divestiture restructuring, reorganization, dissolution, or other sale or transfer of Clearwater’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding;
  • To our affiliated companies, partners, or affiliates;

We may also disclose your personal information to third parties to fulfill the following purposes:

  • for order fulfillment or customer support;
  • to comply with the law or legal requirements, such as subpoenas, court orders or regulatory requests;
  • to enforce or apply our Terms of Service and other agreements, including for billing and collections purposes; or
  • to enforce Clearwater’s contractual rights or the Terms and Conditions of this website.

Use and Disclosure of Email Addresses

With respect to email addresses, Clearwater may contact you directly (or disclose your email address to a third party that performs services for Clearwater, as described above) for such purposes as: a) to determine your satisfaction with your interaction(s) with Clearwater, its web sites and/or its solutions and services, b) to provide you with newsletters and/or information about other products and services from Clearwater that may be of interest, and c) to conduct market research, including research about potential new solutions and services. Upon receipt of written notice from you that you are no longer interested in receiving such contact or information, Clearwater will remove you from our mailing list within ten (10) business days.

Links to External Websites

This website may contain links to external websites owned and maintained by third parties. When you click on one of these links, you are opening a session to another website.  Clearwater does not accept liability or responsibility for any website to which Clearwater may link.  Clearwater therefore encourages you to read the privacy statements of such linked sites, as their privacy policies may differ.

Information Security

We have implemented measures designed to secure your personal information and other business information you may provide from accidental loss and from unauthorized access, use, alteration and disclosure. Information is protected in transit via HTTPS and SSL security. No payment information is collected on this website, but payment transactions are redirected to our vendors for processing.  While Clearwater will exert commercially reasonable efforts to protect the confidentiality, integrity and availability of your personal information, Clearwater cannot guarantee that such efforts will prevent an unauthorized breach of the information.

The safety and security of your information also depends on you. If you have created a user name and a password for access to certain parts of this website (or if we have provided you with one), you are responsible for keeping your user name and password confidential. We ask in particular that you not to share your password with anyone.  We urge you to be careful about giving out information in public areas of our websites.  The information you share in public areas may be viewed by any user of our websites, other than the IRM | Pro™ website, which has its own privacy policy.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do take measures to protect your information, we cannot guarantee the security of your information transmitted to this website. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the website.

Testimonials

Clearwater may post any positive feedback that you choose to provide to us on this website or in material promoting or describing Clearwater and its solutions and services.  Before publishing any feedback that you may provide, we will first contact you to obtain your written consent.

Legal Disclaimer

This Policy is subject to existing laws and legal process, and nothing contained in this Policy will control over Clearwater’s right to comply with governmental, court, and law enforcement requests or requirements relating to the information. In the event of a legal requirement or a regulatory or legal request or order for the information, to the extent permitted by law, Clearwater will provide the individual or organization with prompt notice of such request so that the individual or organization may take such actions it may deem appropriate to protect the confidentiality of such information and/or oppose the request.

Changes to this Policy

It is Clearwater’s policy to post any changes it makes to its Policy on this page. If Clearwater makes material changes to how it treats its users’ information, it will notify you through a notice on the website home page. The date the Policy was last revised is identified at the top of this page. You are responsible for ensuring Clearwater has an up-to-date active and deliverable e-mail address for you, and for periodically visiting Clearwater’s website and this Policy to check for any changes.

If anyone should have any questions or suggestions regarding this Policy, contact Clearwater by emailing: info@clearwatercompliance.com.