PRIVACY POLICY
Last updated: November 14, 2023
CLNSD LLC (referred to herein as “CLNSD” “Company” “us” and “we”) understands the importance of privacy to our visitors (“you”) and presents this Privacy Policy to help explain how we collect, use, and disclose your personal information. This Privacy Policy also explains your options and rights with respect to your personal information along with the ways in which you can express your communication preferences.
This Privacy Policy describes the privacy practices of CLNSD for personal information that we collect:
• through websites and software operated by us from which you are accessing this Privacy Policy, including our mobile applications, www.CLNSD.com and other websites owned or controlled by CLNSD (collectively, the “Platform”);
• through your interaction with our Platform for the purchase of our products and services (our “Services”);
• through email messages that we send you that link to this Privacy Policy and through your communications with us online, over the phone, through email, or in person;
• through our social media pages that we control (collectively, our “Social Media Pages”);
• from third parties such as our clients, analytics providers such as Google Analytics, Affiliates, and Business Services Providers.
Collectively, we refer to the Platform, our Social Media Pages, and electronic communications as the “Online Services.”
This Privacy Policy does not apply to:
• Third-Party Sites. Platform, apps, videos (embedded or direct links), or other content (each a “Linked Site”) to which we link that are not operated by us. Linked Sites have their own personal information collection and use practices, and we are not responsible those practices. We encourage you to read each Linked Site’s privacy disclosures to understand how your personal information is processed.
• Non-Personal Information. Our processing of information that cannot be linked to an identifiable or identified individual. We may process this data for any legitimate business purpose.
Collection of Your Personal Information
Online Services
We and our third-party partners may use certain web technologies such as cookies, web beacons, clear GIF, pixels, internet tags, and other similar tracking technologies (collectively, “tracking technologies”) to gather information when you interact with our Platform and email communications. We use some of these tracking technologies help us optimize and maintain the security of our Platform and your account. We may also use them for compatible purposes like save your preferences, fixing errors, and ensuring consistent service of our Platform.
We may permit third parties to use tracking technologies on our Platform for analytics and remarketing advertising, including to help manage and display advertisements, to tailor advertisements to your interests, and provide metrics on advertising effectiveness. The third parties use their technology to provide advertising about products and services tailored to your interests which may appear either on our Platform or on other websites.
The information we collect using these technologies includes:
• Device and Browser Identifiers. For example, an assigned user ID, IP address, or similar identifier that can be used to identify your device.
• Coarse and Precise Location Information. We may gain a general approximation of your location that is not based on global position system (GPS) information. We may collect your precise location when you enable us to collect it via your device. You can use your device’s settings to restrict access to precise location.
• Browsing and Search History. Information about the content you view and searches you make on our Site(s).
• Platform Log and Usage Data. Information related to our pages you viewed, the services and features you used or interacted with, your browser type and details about any links or communications with which you interacted.
• Advertising Metrics. Information about the advertisements you have viewed on our Platform.
• Web Interactions. We may collect certain categories of personal information from you when you contact us online by, for example, emailing us directly, through online form submissions, or through automated chat modules. By interacting with any of our online contact methods, you consent to our collection practices and understand and acknowledge that we may use this data to provide functionality to our Platform and improve our Services.
• Google Analytics. We may collect data through Google Analytics, which use cookies and technologies to collect and analyze data about use of the Online Services. These services also collect data regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/ and opt out by downloading the Google Analytics opt out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
• Google Ads. We may use Google Ads for marketing purposes wherein Google makes use of pixel tracking technologies and cookies to provide analytics regarding traffic sources. If you wish to modify your ad tracking preferences or opt out of tracking you may do so by visiting: https://www.google.com/settings/ads/onweb#display_optout. You may learn more about Google’s privacy practices by visiting: www.google.com/policies/privacy/partners.
• Do Not Track. Because the “Do Not Track” browser-based standard signal has yet to gain widespread acceptance, our Platform(s) currently does not respond to those signals. To learn more about your options with respect to tracking technologies, please see the Your Privacy Preferences section, below.
Platform Services
When you interact with us in connection with our Platform Services and Platform we may collect and process certain information about you. This information includes:
• Your Personal Details. These include your first and last name, email address, phone number, mailing and billing address, and other contact information you may provide.
• Financial Information. This includes credit and debit card number or other payment data.
• Survey data. We may contact some individuals to request participation in a survey or other general research. If you choose to take part in these, you may provide personal information, in or along with your survey responses, or in any other feedback or comments you give us.
• Messages and email data. We collect information about you when you send, receive, open, read or otherwise engage with messages, email, online forms, chat modules, or other communications in connection with our Platform and Services, including whether you have opened or acted on those communications.
• Social Media Content. For example, interactions with our Social Media Pages and content you post on them. This information may include your social media handle, account ID, publicly available photos and other data made public by you on your social media.
• Other Personal Information You Provide. If you provide us personal information other than that described above, we will collect it and use it for the purposes for which you provide it or other consistent purposes.
• Inferences. In certain instances, we may infer personal information about you based on the information you have provided to us or that we have collected about you.
We collect this information when you sign up or otherwise agree to receive marketing communications from a CLNSD; interact with CLNSD’ workforce members; engage with us on social media; participate in a promotion, contest, or sweepstakes that we may offer; contact our customer services teams; or submit it to us online or in-person.
Other Sources
We obtain the personal information described above from third parties including:
• Affiliates. We share personal information with other entities associated with or under common ownership with CLNSD.
• Clients. Our clients that we work with may share personal information with us to operate the Platform and Services and provide you with opportunities to, for example, be featuredin connection with our client’s social media pages.
• Business Services Providers. These are those persons or entities with whom we have a relationship to provide business operations services and support to Company. These providers may include the following:
o IT Operations Providers. These include cloud computing service providers, internet service providers, data backup and security providers, functionality and infrastructure providers, and similar service providers.
o Operations Providers. These include service provider with whom we partner to provide day-to-day business operations, including vendors such as payment processors, security vendors, business software service providers, banks, and security providers.
• Marketing and Advertising Providers. These include advertising, direct marketing, and lead generation providers, affiliate marketing program providers, retargeting Platform, data brokers, ad networks, marketing consultants, and similar services providers.
• Publicly Available Sources. These include public databases, marketing partners, and event sponsors.
Use of Your Personal Information
We may use your personal information for a variety of reasons. Depending on how you interact with our Services, these include using personal information:
• Delivering Our Platform and Services to you and to provide the related customer support, communication, and security.
• Customer Service to provide customer service, maintain, improve, and service products and accounts, provide training for quality purposes, and perform similar activities.
• Processing Transactions to process or fulfill orders and transactions, verify customer information, process payments, confirm eligibility promotional benefits, and perform similar activities.
• Policy Enforcement including enforcing our terms of stay and service, acceptable use policies, anti-spam policies, and similar policies.
• Advertising & Marketing to send advertisements and marketing material via physical and electronic mail or through other online communication methods relating to product specials and other promotional events or offers, perform marketing research and data analytics, and perform similar activities.
• Contextual and Behavioral Targeting to provide contextual customization of ads and remarketing shown as part of an interaction with our Platform or application, using tracking technologies like cookies and pixels.
• Counting Ad Impressions & Platform Interactions to audit interactions with our Platform, applications, or advertisements, count ad impressions to unique visitors, verify position and quality of ad impressions, and perform similar activities.
• Fraud Prevention to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to prosecute those responsible for that activity.
• Defending Against Claims & Litigation to defend against or respond to potential or actual claims and litigation.
Disclosure of Personal Information
We may share your personal information with the following:
• Affiliates. Including companies under common control and individuals having a fiduciary capacity within our business(s).
• Clients. Including businesses that we work with in connection with the Platform and Services such as clients who provide promotional social media campaigns wherein you may be featured.
• Business Services Providers. Including entities with whom we have a relationship to provide business operations services and support to Company.
• Marketing and Advertising Providers. Including advertising, direct marketing, and lead generation providers, affiliate marketing program providers, retargeting Platform, data brokers, ad networks, marketing consultants, and similar services providers.
• Professional Advisors. These include lawyers, accountants, consultants, security professionals, and other similar parties when disclosure is reasonably necessary to comply with our legal and contractual obligations, prevent or respond to fraud or abuse, defend ourselves against attacks, or protect the rights, property, and safety of us, our customers, and the public.
• Legally Required Parties/Governmental Entities. Persons to whom we are required by law to provide information, such as pursuant to a subpoena or a court order.
• Reorganization. Persons involved in the consideration, negotiation, completion of a business transaction, including the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration.
• Authorized Disclosures. To any party when authorized by the individual to whom it pertains to share it.
Data Retention
We will retain your personal information only for so long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; and the applicable legal requirements. In some circumstances, you may ask us to delete your information. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Data Security
We make reasonable efforts to implement and maintain security procedures and practices, appropriate to the nature of the information, to protect your personal information from unauthorized access, destruction, use, modification, or disclosure. However, no security measure is perfect, so we cannot guarantee the security of your personal information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contact Us” section, below.
Your Privacy Preferences
You can control the collection and use of personal information for some of our processing activities. This includes:
Adjusting Communication Preferences
Emails From CLNSD: During the registration for use of the Platform Services or to login to our Platform, you should be presented with an opt-in to receive email communications. If you wish to no longer receive email communications, you can click on the “unsubscribe” link located at the bottom of the email or send an email to CLNSD at info@clnsd.com to let us know, and we will remove you as soon as possible. Opting out of marketing emails will not opt-you out of all emails—we may need to send you transactional or similar emails related to your CLNSDpurchases, legal or contractual updates, or similar topics. You are not able to opt-out of any such emails that we may need to send based on legal or contractual requirements.
Opting Out of Cookies
There are several ways to opt-out of cookies. If, however, you do not accept any cookies, you may experience some inconvenience in your use of the Online Services as they are used to provide certain functionality to our Platform and Platform Services. For example, we will not be able to recognize your computer, and you will need to log in every time you visit.
Browser settings: You can opt out of cookies on your browser. Every browser is different so please check the instructions provided by your browser.
Children’s Privacy
Our Services are not intended for persons under 16 years of age. We do not knowingly collect or process the personal information of individuals under the age of 16. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us their Personal Information, please contact us at info@clnsd.com.
Changes to this Notice
We may update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our Platform homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access our Services or otherwise interact with us to stay informed about our information practices and the choices available to you.
Contact Us
If you have questions or comments about this Privacy Policy or complaints and our privacy practices, please contact us at:
CLNSD LLC
Email: info@clnsd.com