Owner and Data Controller
Clearpoint Business Group, LLC.
429 Fourth Avenue, Suite 300
Pittsburgh, PA 15212
(877) 884-3646
Owner contact email: privacy@clearpointbusiness.com
Types of Data collected
Among the types of Personal Data that Clearpoint Business Group collects, by itself or through third parties, there are:
Cookies; Usage Data; first name; last name; phone number; company name; address; country; state; email address; ZIP/Postal code; city; various types of Data; gender; date of birth; password; province; county; latitude (of city); longitude (of city); metro area; geography/region; IP address; device information; app information; device logs; operating systems; browser information; language; launches; number of sessions; session duration; scroll-to-page interactions; mouse movements; scroll position; keypress events; motion sensor events; touch events; video views; clicks; browsing history; search history; session statistics; page views; interaction events; page events; custom events; Application opens; Data communicated while using the service; social media accounts; name; calendar information; education history; interview-related data; job position; work history; payment info.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Clearpoint Business Group.
Unless specified otherwise, all Data requested by Clearpoint Business Group is mandatory and failure to provide this Data may make it impossible for Clearpoint Business Group to provide its services. In cases where Clearpoint Business Group specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by Clearpoint Business Group or by the owners of third-party services used by Clearpoint Business Group serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through Clearpoint Business Group.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Clearpoint Business Group (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Analytics, Contacting the User, Traffic optimization and distribution, Hosting and backend infrastructure, Data transfer outside the EU, Handling payments, SPAM protection, Displaying content from external platforms, Registration and authentication, Managing contacts and sending messages, Platform services and hosting, User database management, Interaction with data collection platforms and other third parties, Collection of privacy-related preferences and Handling activities related to productivity.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Universal Analytics) (Google LLC)
Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of Clearpoint Business Group, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
Cloudflare Web Analytics (Cloudflare, Inc.)
Cloudflare Web Analytics is an anonymized analytics service provided by Cloudflare, Inc. that gives the Owner insight into the use of Clearpoint Business Group by Users without needing to identify them. Further information may be found here and within the service's privacy policy.
Personal Data processed: device information; language; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information; inferences drawn from other personal information.
This processing constitutes:
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Collection of privacy-related preferences
This type of service allows Clearpoint Business Group to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.
iubenda Privacy Controls and Cookie Solution (iubenda srl)
The iubenda Privacy Controls and Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information, and in particular to the use of Cookies and other Trackers on Clearpoint Business Group.
Personal Data processed: Trackers.
Place of processing: Italy – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
iubenda Consent Database (iubenda srl)
The iubenda Consent Database allows to store and retrieve records of Users’ consent to the processing of Personal Data, and information and preferences expressed in relation to the provided consent.
In order to do so, it makes use of a Tracker that temporarily stores pending information on the User’s device until it is processed by the API. The Tracker (a browser feature called localStorage) is at that point deleted.
Personal Data processed: Data communicated while using the service; Trackers.
Place of processing: Italy – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
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Contacting the User
Contact form (Clearpoint Business Group)
By filling in the contact form with their Data, the User authorizes Clearpoint Business Group to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: address; city; company name; country; email address; first name; last name; phone number; state; ZIP/Postal code.
Category of Personal Information collected according to the CCPA: identifiers; commercial information.
This processing constitutes:
Phone contact (Clearpoint Business Group)
Users that provided their phone number might be contacted for commercial or promotional purposes related to Clearpoint Business Group, as well as for fulfilling support requests.
Personal Data processed: phone number.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
Mailing list or newsletter (Clearpoint Business Group)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Clearpoint Business Group. Your email address might also be added to this list as a result of signing up to Clearpoint Business Group or after making a purchase.
Personal Data processed: email address; first name; last name.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
- a Sale in the United States
Integration of Freshsales with Freshdesk Messaging and/or Freshdesk (Freshworks, Inc.)
If a User provides their email address through the Freshdesk Messaging widget or a Freshdesk support ticket, the User's email address and other Data may be added to Freshsales, a customer relationship and contact management service (CRM). All services are provided by Freshworks, Inc.
The provision of the email address within Freshdesk is voluntary and serves the main purpose of being contacted for the fulfilling of requests related to support. In addition to making support requests easier to handle, the Owner can make use of the full range of the CRM features provided by Freshsales.
Personal Data processed: company name; email address; first name; last name; phone number; physical address; social media accounts.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; commercial information.
This processing constitutes:
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Data transfer outside the EU
The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Users can inquire with the Owner to learn which legal basis applies to which specific service.
Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield (Clearpoint Business Group)
If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU - U.S. and Swiss - U.S. Privacy Shield.
In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List.
Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce.
Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Owner to learn about such legal grounds.
Personal Data processed: various types of Data.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of Clearpoint Business Group and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Font Awesome (Fonticons, Inc. )
Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows Clearpoint Business Group to incorporate content of this kind on its pages.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Google Fonts (Google LLC)
Google Fonts is a typeface visualization service provided by Google LLC that allows Clearpoint Business Group to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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Handling activities related to productivity
This type of service helps the Owner to manage tasks, collaboration and, in general, activities related to productivity. In using this type of service, Data of Users will be processed and may be retained, depending on the purpose of the activity in question.
These services may be integrated with a wide range of third-party services disclosed within this privacy policy to enable the Owner to import or export Data needed for the relative activity.
Calendly (Calendly, LLC)
Calendly is a service provided by Calendly, LLC, that facilitates online scheduling of appointments.
Personal Data processed: calendar information; email address; name; phone number.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers.
Human resources managed internally (Clearpoint Business Group)
Clearpoint Business Group uses an internal human resources system that does not involve third parties.
Personal Data processed: city; education history; email address; first name; interview-related data; job position; last name; phone number; social media accounts; work history.
Category of Personal Information collected according to the CCPA: identifiers.
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Handling payments
Unless otherwise specified, Clearpoint Business Group processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. Clearpoint Business Group isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
Stripe (Stripe Inc)
Stripe is a payment service provided by Stripe Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Payment by bank transfer (Clearpoint Business Group)
In the event that the chosen payment method is a direct bank transfer to the current account indicated by Clearpoint Business Group, the Owner will collect the payment details of the User, i. e. the current account number of the sender, the SWIFT code, the bank and the name of the sender. Such data will be collected and processed exclusively within the transaction and for billing purposes only.
Personal Data processed: company name; first name; last name; payment info; physical address.
Category of Personal Information collected according to the CCPA: identifiers; commercial information.
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable Clearpoint Business Group to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Clearpoint Business Group.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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Interaction with data collection platforms and other third parties
This type of service allows Users to interact with data collection platforms or other services directly from the pages of Clearpoint Business Group for the purpose of saving and reusing data.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Global Distribution System (GDS) - IATA
Your personal data will be processed in accordance with the applicable carrier’s privacy policy and, if your booking is made via a reservation system provider (GDS), with its privacy policy. These are available at www.iatatravelcenter.com/privacy or from the carrier or GDS directly. You should read this documentation, which applies to your booking and specifies, for example, how your personal data is collected, stored, used, disclosed and transferred.
This processing constitutes:
- a Sale in California
- a Sharing in California
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Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Amazon Simple Email Service (Amazon)
Amazon Simple Email Service is an email address management and message sending service provided by Amazon.com Inc.
Personal Data processed: email address.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
- a Sale in California
- a Sharing in California
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Platform services and hosting
These services have the purpose of hosting and running key components of Clearpoint Business Group, therefore allowing the provision of Clearpoint Business Group from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Apple App Store (Apple Inc.)
Clearpoint Business Group is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.
By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enables the Owner to view usage analytics data and measure the performance of Clearpoint Business Group. Much of this information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Google Play Store (Google LLC)
Clearpoint Business Group is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google LLC.
By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Webflow (Webflow, Inc.)
Webflow is a platform provided by Webflow, Inc. that allows the Owner to build, run and host Clearpoint Business Group. Webflow is highly customizable and can host websites from simple blogs to complex e-commerce platforms.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy – Opt out.
Category of Personal Information collected according to the CCPA: identifiers.
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Registration and authentication
By registering or authenticating, Users allow Clearpoint Business Group to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, Clearpoint Business Group will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Direct registration (Clearpoint Business Group)
The User registers by filling out the registration form and providing the Personal Data directly to Clearpoint Business Group.
Personal Data processed: address; city; company name; country; date of birth; email address; first name; gender; last name; password; phone number; state; various types of Data; ZIP/Postal code.
Category of Personal Information collected according to the CCPA: identifiers; commercial information; biometric information; internet or other electronic network activity information.
This processing constitutes:
CBG OneID
Personal Data collected: address; city; company name; country; date of birth; email address; first name; gender; last name; password; phone number; state; various types of Data; ZIP/Postal code; citizenship; country of residence.
CBG OneID collects citizenship and country of residence information to comply with US and International Export Control Regulations. These regulations include, but are not limited to, the International Trafficking in Arms Regulations (ITAR), Export Administration Regulations (EAR), and the Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons lists.
CBG OneID adheres to privacy regulations by our Identity Management Platform, Okta, Inc., found at https://www.okta.com/privacy-policy/.
This processing constitutes:
- a Sale in California
- a Sharing in California
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SPAM protection
This type of service analyzes the traffic of Clearpoint Business Group, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Akismet (Automattic Inc.)
Akismet is a SPAM protection service provided by Automattic Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Google reCAPTCHA (Google LLC)
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Cloudflare Bot Management (Cloudflare, Inc.)
Cloudflare Bot Management is a malicious bot protection and management service provided by Cloudflare, Inc.
Personal Data processed: app information; Application opens; browser information; browsing history; city; clicks; country; county; custom events; device information; device logs; geography/region; interaction events; IP address; keypress events; language; latitude (of city); launches; longitude (of city); metro area; motion sensor events; mouse movements; number of sessions; operating systems; page events; page views; province; scroll position; scroll-to-page interactions; search history; session duration; session statistics; state; touch events; Trackers; Usage Data; video views; ZIP/Postal code.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information; geolocation data; inferences drawn from other personal information.
This processing constitutes:
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Traffic optimization and distribution
This type of service allows Clearpoint Business Group to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Clearpoint Business Group and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare (Cloudflare Inc.)
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through Clearpoint Business Group, i.e., communication between Clearpoint Business Group and the User's browser, while also allowing analytical data from Clearpoint Business Group to be collected.
Personal Data processed: Cookies; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to Clearpoint Business Group, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving Clearpoint Business Group.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Clearpoint Business Group.
Pipedrive (Pipedrive OÜ)
Pipedrive is a User database management service provided by Pipedrive OÜ.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Estonia – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
Further information about the processing of Personal Data
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Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by Clearpoint Business Group depends on the payment system used.
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We do not collect personal data about Colorado consumers below the age of 13
We do not knowingly collect personal data of Colorado consumers who are below the age of 13 nor do we sell or process their data for targeted advertising purposes.
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We do not collect personal data about Connecticut consumers below the age of 13
We do not knowingly collect personal data of Connecticut consumers who are below the age of 13 nor do we sell or process their data for targeted advertising purposes.
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We do not collect personal data about Utah consumers below the age of 13
We do not knowingly collect personal data of Utah consumers who are below the age of 13 nor do we sell or process their data for targeted advertising purposes.
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The Service is not directed to children under the age of 13
Users declare themselves to be adult according to their applicable legislation. Minors may use Clearpoint Business Group only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use Clearpoint Business Group.
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Equal protection of User Data
Clearpoint Business Group shares User Data only with third parties carefully selected to ensure that they provide the same or equal protection of User Data as stated in this privacy policy and requested by applicable data protection laws. Further information on data processing and privacy practices by third parties can be found in their respective privacy policies.
Cookie Policy
Clearpoint Business Group uses Trackers. To learn more, Users may consult the Cookie Policy.
This section applies to all Users in the European Union, according to the General Data Protection Regulation (the “GDPR”), and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Further information for Users
in the United States
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running Clearpoint Business Group and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information
(and Sensitive Personal Information).
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.
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Internet or other electronic network activity information
Personal Information collected or disclosed:
Cookies, Usage Data, various types of Data as specified in the privacy policy of the service, various types of Data, first name, last name, gender, date of birth, phone number, address, email address, company name, country, state, ZIP/Postal code, city, province, county, latitude (of city), longitude (of city), metro area, geography/region, Trackers, IP address, device information, app information, device logs, operating systems, browser information, language, launches, number of sessions, session duration, scroll-to-page interactions, mouse movements, scroll position, keypress events, motion sensor events, touch events, video views, clicks, browsing history, search history, session statistics, page views, interaction events, page events, custom events, Application opens, Data communicated while using the service
Sensitive Personal Information collected or disclosed ℹ️:
password
Purposes:
- Analytics
- Traffic optimization and distribution
- Hosting and backend infrastructure
- Data transfer outside the EU
- Handling payments
- SPAM protection
- Displaying content from external platforms
- Registration and authentication
- Platform services and hosting
- Collection of privacy-related preferences
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Google Inc., Cloudflare Inc., Amazon Web Services, Inc., Clearpoint Business Group, Stripe Inc, Automattic Inc., Google LLC, Fonticons, Inc. , Apple Inc., Cloudflare, Inc., iubenda srl
Service providers or contractors: Clearpoint Business Group
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Identifiers
Personal Information collected or disclosed:
first name, last name, phone number, company name, address, country, state, email address, ZIP/Postal code, city, gender, date of birth, various types of Data, various types of Data as specified in the privacy policy of the service, province, county, latitude (of city), longitude (of city), metro area, geography/region, Usage Data, Trackers, IP address, device information, app information, device logs, operating systems, browser information, language, launches, number of sessions, session duration, scroll-to-page interactions, mouse movements, scroll position, keypress events, motion sensor events, touch events, video views, clicks, browsing history, search history, session statistics, page views, interaction events, page events, custom events, Application opens, social media accounts, physical address, name, calendar information, education history, interview-related data, job position, work history
Sensitive Personal Information collected or disclosed ℹ️:
password, payment info
Purposes:
- Contacting the User
- Registration and authentication
- Managing contacts and sending messages
- Platform services and hosting
- Spam and bots protection
- User database management
- Further information about Personal Data
- Handling activities related to productivity
- Handling payments
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Amazon, Webflow, Inc., Cloudflare, Inc., Pipedrive OÜ, Freshworks, Inc., Clearpoint Business Group, Calendly, LLC
Service providers or contractors: Clearpoint Business Group, Clearpoint Business Group
-
Commercial information
Personal Information collected or disclosed:
first name, last name, phone number, company name, address, country, state, email address, ZIP/Postal code, city, gender, date of birth, various types of Data, social media accounts, physical address
Sensitive Personal Information collected or disclosed ℹ️:
password, payment info
Purposes:
- Contacting the User
- Registration and authentication
- Handling payments
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Freshworks, Inc.
Service providers or contractors: Clearpoint Business Group, Clearpoint Business Group
-
Biometric information
Personal Information collected or disclosed:
first name, last name, gender, date of birth, phone number, address, email address, company name, country, state, ZIP/Postal code, city, various types of Data
Sensitive Personal Information collected or disclosed ℹ️:
password
Purposes:
- Registration and authentication
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Service providers or contractors: Clearpoint Business Group
-
Geolocation data
Personal Information collected or disclosed:
city, ZIP/Postal code, state, province, country, county, latitude (of city), longitude (of city), metro area, geography/region, Usage Data, Trackers, IP address, device information, app information, device logs, operating systems, browser information, language, launches, number of sessions, session duration, scroll-to-page interactions, mouse movements, scroll position, keypress events, motion sensor events, touch events, video views, clicks, browsing history, search history, session statistics, page views, interaction events, page events, custom events, Application opens
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Cloudflare, Inc.
-
Inferences drawn from other personal information
Personal Information collected or disclosed:
city, ZIP/Postal code, state, province, country, county, latitude (of city), longitude (of city), metro area, geography/region, Usage Data, Trackers, IP address, device information, app information, device logs, operating systems, browser information, language, launches, number of sessions, session duration, scroll-to-page interactions, mouse movements, scroll position, keypress events, motion sensor events, touch events, video views, clicks, browsing history, search history, session statistics, page views, interaction events, page events, custom events, Application opens
Purposes:
- Spam and bots protection
- Analytics
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Cloudflare, Inc.
ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.
To know more about your rights in particular to opt out of certain processing activities and to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use Clearpoint Business Group.
For example, you directly provide your Personal Information when you submit requests via any forms on Clearpoint Business Group. You also provide Personal Information indirectly when you navigate Clearpoint Business Group, as Personal Information about you is automatically observed and collected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of Clearpoint Business Group and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
- the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
- the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
- the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
- the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
- the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
- the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have
- The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
- The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas and Oregon, you have
- The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
- The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
Additional rights for users residing in Utah
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah, you have
- The right to opt out of the processing of your Personal Information for Targeted Advertising;
- The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on Clearpoint Business Group.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Additional information for Users in the United States
We do not collect personal data about Virginia consumers below the age of 13
We do not knowingly collect personal data of Virginia consumers who are below the age of 13 nor do we sell their data or process them for targeted advertising purposes.
We do not collect personal information about California consumers below the age of 16
We do not knowingly collect personal information of consumers who are below the age of 16 nor do we sell or share it.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Clearpoint Business Group or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, Clearpoint Business Group may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, Clearpoint Business Group and any third-party services may collect files that record interaction with Clearpoint Business Group (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Clearpoint Business Group and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
/ Personal Information (or Information)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.
Usage Data
Information collected automatically through Clearpoint Business Group (or third-party services employed in Clearpoint Business Group), which can include: the IP addresses or domain names of the computers utilized by the Users who use Clearpoint Business Group, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using Clearpoint Business Group who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Clearpoint Business Group. The Data Controller, unless otherwise specified, is the Owner of Clearpoint Business Group.
Clearpoint Business Group (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by Clearpoint Business Group as described in the relative terms (if available) and on this site/application.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.
Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
education history
Provides access to education history.
work history
Provides access to work history.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to Clearpoint Business Group, if not stated otherwise within this document.