Last Updated: October 26, 2017
Clintra is committed to protecting the privacy and security of all individuals who use our site. Our goal is to provide an internet experience that delivers the information, resources, and services that are most relevant and helpful to you. In order to achieve this goal, from time to time we may collect information during your visits. This Privacy Policy is designed to help you learn more about the personal information we collect, who we might share it with, and how we protect it. Your use of our website is subject to this Privacy Policy and the applicable Terms of Service. By using our website, you are accepting the practices set out in this privacy statement and the applicable Terms of Service.
EU-U.S. Privacy Shield Framework
Clintra complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Clintra has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/ In compliance with the EU-US Privacy Shield Principles, Clintra commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Clintra at: Compliance Office Zonopact, Inc. [email protected] Clintra has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. Clintra is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
US-Swiss Safe Harbor Framework
Clintra complies with the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. Clintra has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. If there is any conflict between the policies in this privacy policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern. To learn more about the US-Swiss Safe Harbor and to view our certification page, please visit http://www.export.gov/safeharbor/ In compliance with the US-Swiss Safe Harbor Principles, Clintra commits to resolve complaints about your privacy and our collection or use of your personal information. Swiss citizens with inquiries or complaints regarding this privacy policy should first contact Clintra at: Compliance Office Zonopact, Inc. [email protected] Clintra has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint. Information We Collect Clintra collects personal information supplied: • by our users; • from information collected through web server logs; • when you interact with third party services available through Clintra like surveys, polls or other third party research undertaken with your consent; and • through cookies.
Information Supplied by Our Users
Clintra collects personal information, such as your e-mail address, name, home or work address and telephone number. Clintra may also collect demographic information, such as your ZIP code, age and gender. Clintra does not collect any of this unique information about you except when you specifically and knowingly provide such information.
Information from Web Server Logs
Clintra records and saves information about you from our web server logs such as your Internet [Protocol] (IP) address, the time day you visited and your browser type. This information is used to verify our records and to provide better services to you.
Information from Cookies
In order to offer and provide you with personalized services, Clintra may use “cookies” to store and help track your information. A cookie is a piece of data that identifies you as a unique user. Clintra will not disclose its cookies to third parties except as required by a valid legal process such as a search warrant, subpoena, statute, or court order.
Information from Mobile Devices
Clintra may collect information from mobile devices used to access this site, such as operating system and version information and IP address.
Information That Will Be Shared On Clintra
Information about yourself that you share. This is the information that your connections, other professionals, and companies see about you. This includes your profile and your contributions to discussions on Clintra, or other community features Clintra may offer which, if you opt-in by completing the on-boarding in the welcome email,
Information That Will Not Be Shared
Private Activity. We also provide tools that you can use privately on Clintra (for example, searching, or adding notes to your connections information.) These actions and information are private and we don’t share or distribute them to others on the website. Use or Disclosure of your Personal Information to Third Parties and Co-Brand Partners The services provided on Clintra’s website and mobile app may be provided by various companies and organizations Certain Clintra services and content may be co-branded with another company. If you register for or use such services, both Clintra and the other company may receive information collected in conjunction with the co-branded services. In such cases, either a joint privacy statement or a link to the other company’s privacy statement will be provided, which will provide you with information about how the other company will use the information and how you can contact the other company with requests to access the information or other inquiries. We do not sell, rent, or otherwise provide personally identifiable information to third parties without your consent except where it is necessary to carry out your instructions (to process your payment information, for example) or to share information with Clintra Platform’s or affiliates that provide services. We also provide you with the means to control whether or not your contact information is viewable to other Users through your profile. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Clintra is potentially liable.
Compliance with Legal Process
We may disclose personal information if we are required to do so by law or we in good faith believe that such action is necessary to: (1) comply with the law or with legal process; (2) protect and defend our rights and property; (3) protect against misuse or unauthorized use of our web sites; or (4) protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions). Clintra also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
Content Submitted Or Made Available For Inclusion On The Service
With respect to content you submit or make available for inclusion on publicly accessible areas of the Service, this information will be made public on the Internet. “Publicly accessible” areas of the Service are those areas of the Clintra network of properties that are intended by Clintra to be available to the general public. By way of example, publicly accessible areas of the Service would include message boards, and Blogs.
Access
Clintra acknowledges the right of EU individuals to access their personal data. Individuals can access data to review, edit, correct, or delete it by contacting us at [email protected]
Our Commitment to Data Security
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
Protecting Your Information
While Clintra is committed to protecting your personal information, no data transmission over the Internet can be guaranteed to be 100% secure. You are solely responsible for maintaining the secrecy of any passwords you set up and/or any account information.
Links to Other Sites
Clintra encourages you to review the privacy statements of Web sites you choose to visit from Clintra so that you can understand how those Web sites collect, use and share your information. Clintra is not responsible for the privacy statements or other content on Web sites outside of the Clintra site.
Children’s Privacy
Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our website from those we actually know are under 13, and no part of our website is structured to attract anyone under 13.
Correcting Inaccuracies
When you sign up for Clintra’s products and service, we may send you an e-mail confirming your new account. The message will be sent to the address that you supplied to us at the time of sign-up and will describe ways for you to change or delete the account information provided. Remember to keep the confirmation e-mail as it will also contain information that will help you in case you run into problems accessing our services. We welcome your comments or questions. Send us an email to [email protected].