Clair Global Privacy Policy
Effective as of May 25, 2018
1. Privacy Policy
This is the privacy policy of Clair Global Corporation. In this document, “Clair Global”, “we”, “our”, or “us” refer to Clair Global Corporation, its affiliate and subsidiary companies, JPJ Audio Ltd Pty Ltd (“JPJ Audio”), and Britannia Row Productions, collectively “the Company.”
Clair Global Corporation is registered in the state of Pennsylvania, USA.
Address:
Clair Global Corporation
1 Ellen Avenue
Lititz, PA 17543
Phone: +1 (717) 626-4000
E-Mail: info@clairglobal.com
Data Protection Officer: Jason Heitmann
2. Introduction
This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not.
PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our Privacy Policy carefully to get a clear understanding of how we collect, store, process, protect or otherwise handle your Personally Identifiable Information.
In the context of the law and this policy, “process” means collect, store, transfer, use or otherwise act on information.
If there are one or more points below with which you have questions or concerns, leave our website immediately and contact us at info@clairglobal.com.
We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website, our employees, vendors and customers are entitled to know that their personal data will not be used for any purpose unintended by them and will not accidentally fall into the hands of a third party.
We aim to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
The law requires us to tell you about your rights and our obligations to you regarding the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org.
Our policy complies with USA law, and includes provisions required by the EU General Data Protection Regulation (GDPR). EU Data Subjects may learn about their rights by referencing the General Data Protection Regulation here:
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0679&from=EN
Except as set out below, we do not share, or sell, or disclose to any unrelated third parties, any information collected through our website or by way of our normal course of business, unless we are compelled to do so by law or unless you expressly consent. We may provide anonymous, non-personally identifiable demographic information to third parties.
3. Bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your data.
If the basis changes then if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
4. Information we process because we have a contractual obligation with you
When you enter into an official contract with the Company, buy a product or service from
us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
To carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it to:
4.1. verify your identity for security purposes
4.2. sell products to you
4.3. provide you with our services
4.4. provide you with technical support
4.5. manage your account with us
4.6. meet contractual obligations with our clients
4.7. communicate with you
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
5. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, our products and services, you provide your consent to us to process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information. Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at info@clairglobal.com. However, if you do so, you may not be able to further use our services.
6. Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
6.1. Where we process your information on this basis, we do so after having carefully considered:
6.1.1 whether the same objective could be achieved through other means
6.1.2 whether processing (or not processing) might cause you harm
6.1.3 whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
6.2. For example, we may process your data on this basis for the purposes of:
6.2.1 record-keeping for the proper and necessary administration of our business
6.2.2 responding to unsolicited communication from you to which we believe you would expect a response
6.2.3 protecting and asserting the legal rights of any party
6.2.4 insuring against or obtaining professional advice that is required to manage business risk
6.2.5 protecting your interests where we believe we have a duty to do so
7. Information we process because we have a legal obligation
We may process your information to comply with a statutory obligation. We may be required to give information to legal authorities if they so request or if they have the proper authorization such as a search warrant or court order. This may include your personal information.
8. Specific uses of information you provide to us
8.1 Provide necessary information to vendors and customers required to conduct our normal course of business and to meet contractual obligations
8.2 Process purchase orders, invoices, and payments
8.3 General communication required to conduct our normal course of business
9. Information provided on the understanding that it will be shared with a third party
To conduct our normal course of business, it may be required to share your personal information with a vendor or customer.
Examples include:
9.1. a customer team tasked with booking travel and accommodations
9.2. a wire transfer company making a payment to you on behalf of the company
9.3. obtaining certifications or regulatory documentation required to commence work
In providing personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.
We do not specifically use this information except to conduct our normal course of business.
We do store it, and we reserve a right to use it in the future in any way we decide.
Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at info@clairglobal.com.
10. Complaints regarding content on our website or social media outlets
From time to time, we may publish photos or print to our website or social media outlets based on services we render. If you complain about any of the content we publish, we shall investigate your complaint. If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
11. Information relating to methods of payment
Payment information is never taken by us or transferred to us either through our website. Our employees and contractors never have access to it, except members of our accounting department. We do not store any payment information after a payment transaction has been processed.
12. Communications with us
When you contact us, we collect the data you have given to us to reply with the information you need. We record your request and our reply to increase the efficiency of our business. We keep personally identifiable information associated with your communication, such as your name and email address so as to be able to track our communications with you to provide a high-quality service.
13. Complaints
When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
14. Affiliate and business partner information
This is information given to us by you in your capacity as an affiliate of us or as a business partner. It allows us to conduct business transactions in cooperation with one another. The information is not used for any other purpose.
It is our intent to preserve the confidentiality of the information and of the terms of our relationship.
We expect any affiliate or partner to agree to reciprocate this policy.
15. Use of information we collect through automated systems when you visit our website
We do not use automated systems to collect your data when you visit our website.
16. Cookies
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalized experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.
If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.
We use cookies in the following ways:
16.1. to track how you use our website
16.2. to record whether you have seen specific messages we display on our website
17. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
18. Disclosure and sharing of your information
We will not sell or trade on your personal information to a third party and we will not pass your personal information to any unconnected third party.
To the extent necessary for providing our service, the personal data which you give us may be transferred to third parties who we engage with from time to time to provide us with services or facilities which we use for administering our business and providing our products and services to customers.
We may share your personal data with other companies in our group to fulfil contract requirement and execute contracts with our clients.
We may sometimes contract with third parties to supply products and services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some of your personal data that we hold.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
If any personal data is transferred to a third party outside of the EEA, we will take suitable steps to ensure that your personal data is treated just as safely and securely.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
19. Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this policy), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
20. Locations of Data and Data Processing activities
Our websites and databases are hosted in the USA, EU and Australia.
We may also use outsourced services in countries outside those mentioned above from time to time in other aspects of our business. Accordingly, data we collect could be processed outside the above-mentioned countries.
We use the following safeguards with respect to the transfer of data:
20.1. the processor is within the same corporate group as our business or organization and abides by the same binding corporate rules regarding data processing.
20.2 the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union
20.3. we comply with a code of conduct approved by a supervisory authority in the European Union
21. Access to your personal information
You have the following rights with respect to your personal information.
21.1. At any time you may review or update personally identifiable information that we hold about you.
21.2. To obtain a copy of your information that we store.
21.3. To ask us to dispose of your personal data.
21.4. To ask us to stop processing or using your personal data.
You may make any of these requests by contacting us at info@clairglobal.com. After receiving a request from you, we will tell you when we expect to comply with your request.
22. Removal of your information
If you wish us to remove personally identifiable information from our records, you may contact us at info@clairglobal.com.
This may limit the service we can provide to you.
23. Verification of your identity
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
24. Children & COPPA (Children Online Privacy Protection Act)
24.1. We do not sell products or provide services for purchase by children, nor do we specifically market to and it is not our intention to collect data from children under the age of 13 years old.
24.2. If you are under 18, you may use our website only with consent from a parent or guardian
24.3. We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.
24.4. Such child users and visitors will inevitably visit other parts of the site and will be subject to whatever on-site marketing they find, wherever they visit.
25. Protection of your information
We implement a variety of security measures including firewalls, encryption, and passwords, when a user enters, submits, or accesses their information to maintain the safety of your personal information.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive information you supply is encrypted via Secure Socket Layer (SSL) technology. We do not use vulnerability scanning and/or scanning to PCI standards. We do not use Malware Scanning. Telephone calls and e-mails to us are not encrypted.
26. How you can file a concern
26.1. If you have a concern with our privacy policy, contact us by email at info@clairglobal.com
26.2. If a dispute is not settled, we will ask you to agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
26.3. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with regulatory agencies.
27. Retention period for personal data
Except as otherwise mentioned in this privacy policy, we keep your personal information only for as long as required by us:
27.1. to provide you with the services you have requested;
27.2. to comply with other law, including for the period demanded by our tax
authorities;
27.3. to support a claim or defense in court.
28. Compliance with the law
Our privacy policy has been compiled to comply with the law of every country or legal jurisdiction in which we aim to do business. If you believe it fails to satisfy the law of your jurisdiction, please contact us.
29. Review of this privacy policy
We may update this privacy policy from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
If you have any question regarding our privacy policy, please contact us.
