Clue Digital Website Privacy Policy

Intent

Protecting the privacy and confidentiality of personal information is an important aspect of the way that Clue Digital conducts its business. Collecting, using, and disclosing personal information in an appropriate, responsible, and ethical manner is fundamental to Clue Digital’s daily operations.

Clue Digital strives to protect and respect the personal information of its customers, employees, business partners, etc. in accordance with all applicable regional and federal laws. Each staff member of Clue Digital must abide by this organization’s procedures and practices when handling personal information.

This Website Privacy Policy informs everyone of Clue Digital’s commitment to privacy and establishes the methods by which privacy is ensured. This Website Privacy Policy applies to all personal information within Clue Digital’s possession and control.

Definitions

Personal information is defined as any identifying information about an individual or group of individuals, including name, date of birth, address, phone number, e-mail address, social insurance/security number, nationality, gender, health history, financial data, credit card numbers, bank account numbers, assets, debts, liabilities, payment records, credit records, loan records, opinions, and personal views.

Business information refers to: Clue Digital, business address, business telephone number, name(s) of owner(s), executive officer(s), and director(s), job titles, business registration numbers, and financial status. Business information is treated and handled with the same level of confidentiality, privacy, and respect as personal information.

Consent occurs and is obtained when an individual signs an application or other form containing personal information, thereby authorizing Clue Digital to collect, use, and disclose the individual’s personal information for the purposes stated on the form or in the Appropriate Use section of this policy.

Implied consent is granted by the individual when he/she signs an application, form or agrees to the terms of use on a website. This allows Clue Digital to obtain or verify information from third parties (such as banks, credit bureaus, lenders, or insurance companies) in the process of assessing the eligibility of an individual, customer, client, job applicant, or business partner.

Guidelines

Clue Digital collects and uses personal information solely for the purpose of conducting business and developing an understanding of its customers. Clue Digital hereby asserts that personal information will only be used for the following purposes:

Prospective Employee Recruiting
Inbound Sales Leads
Digital Advertising Retargeting

Clue Digital assumes full accountability for the personal information within its possession and control. This organization has appointed Clue Digital’s Legal Team (legal@cluedigital.com) as custodian of all privacy matters and legal compliance with privacy laws.
Clue Digital obtains personal information directly from the individual to whom the information belongs. Individuals are entitled to know how Clue Digital uses personal information and this organization will limit the use of any personal information collected only to what is needed for those stated purposes. Clue Digital will obtain individual consent if personal information is to be used for any other purpose. Clue Digital will not use that information without the consent of the individual.
Under no circumstances will Clue Digital sell, distribute, or otherwise disclose personal information or contact lists to third parties. However, limited disclosure may be required as part of Clue Digital fulfilling its stated business duties and day-to-day operations. This may include consultants, suppliers, or business partners of Clue Digital, but only with the understanding that these parties obey and abide by this Website Privacy Policy, to the extent necessary for fulfilling their own business duties and day-to-day operations.
Clue Digital will retain personal information only for the duration it is needed for conducting business. Once personal information is no longer required, it will be destroyed in a safe and secure manner. However, certain laws may require that certain personal information be kept for a specified amount of time. Where this is the case, the law will supersede this policy.
Clue Digital vows to protect personal information with the appropriate security measures, physical safeguards, and electronic precautions. Clue Digital maintains personal information through a combination of paper and electronic files. Where required by law or disaster recovery/business continuity policies, older records may be stored in a secure, offsite location.
Access to personal information will be authorized only for the employees and other agents of Clue who require the information to perform their job duties, and to those otherwise authorized by law.
Clue Digital’s computer and network systems are secured by complex passwords. Only authorized individuals may access secure systems and databases.
Routers and servers connected to the Internet are protected by a firewall, and are further protected by virus attacks or “snooping” by sufficient software solutions.
Personal information is not transferred to volunteers, summer students, interns, or other non-paid staff by e-mail or any other electronic format.

Website Privacy Procedures

Clue Digital’s website will include our privacy policy and disclose our personal information practices. Individuals inputting data into the website will be notified of:
Personally identifiable information about the individual that is collected from the website or through affiliate sites.
Information about the organization collecting the data.
How the data will be used.
With whom the data may or may not be disclosed.
The options available to the individual regarding the collection, use, and disclosure of personal information.
The information technology security procedures in place that protect against the destruction, loss, theft, alteration, or misuse of personal information under Clue Digital’s possession and control.
How an individual may access and correct any inaccuracies in his/her personal information.
Clue Digital does not collect personally identifiable information from any individual known to be under the age of thirteen (13).
Clue Digital may share compiled demographic information with its business partners and/or advertisers, but no personal information that can identify any individual person shall be disclosed.
This website may contain links to other sites, but Clue Digital is not responsible for the privacy practices of other organizations’ sites.
While IP addresses will be logged in order to administer the site, track visitor movement, and gather demographic information, these IP addresses will not be linked to any personally identifiable information.
Any registration or order form asking site visitors to enter personal or financial information will be protected by SSL encryption.
Site visitors are given the choice to opt out of having their personal information used at the point where the information is gathered.
In most instances, Clue Digital will grant individuals access to their personal information upon presentation of a written request and satisfactory identification. If an individual finds errors of fact with his/her personal information, the individual should notify Clue Digital as soon as possible to make the appropriate corrections. Should Clue Digital deny an individual’s request for access to his/her personal information, Clue Digital will advise in writing of the reason for such a refusal. The individual may then challenge the decision.
Clue Digital may use personal information without the individual’s consent under particular circumstances. These situations include, but are not limited to:
Clue Digital is under obligation by law to disclose personal information in order to adhere to the requirements of an investigation of the contravention of a regional or federal law, under the purview of the appropriate authorities.
An emergency exists that threatens an individual’s life, health, or personal security.
The personal information is for in-house statistical study or research.
The personal information is already publicly available.
Disclosure is required to investigate a breach of contract.

Any questions or concerns regarding this Website Privacy Policy can be addressed by contacting Clue at legal@cluedigital.com. Clue Digital will investigate and respond to concerns about any aspect of the handling of personal information. This organization will address concerns to the best of its abilities.