We collect the e-mail addresses of those who communicate with us via e-mail, aggregate information on what pages consumers access or visit, and information volunteered by the consumer (such as survey information and/or site registrations). The information we collect is used to improve the content of our Web pages and the quality of our service, and is not shared with or sold to other organizations for commercial purposes, except to provide products or services you’ve requested, when we have your permission. Such exceptions apply only to ClearTouch clients and would be shared only with ClearTouch partners handling Data Management or Accessibility options, or ClearTouch clients or potential clients looking for references on services, etc. In such case, your permission will be obtained prior to making your information available.
If you are a ClearTouch client wishing to port telephony services off of the ClearTouch platform, we would need to confirm your information with the Telephony service provider(s) you have engaged to take over the applicable service, incorrect validation information would not be confirmed.
Additionally, your information may be shared under the following circumstances:
It is necessary to provide information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Terms of Service of the specific application, or as otherwise required by law.
ClearTouch is subject to the investigative and enforcement authority of the United States Federal Trade Commission (FTC).
INFORMATION GATHERING AND USAGE
We do not collect personally identifiable information from our visitors other than what is supplied to us on a voluntary basis. When you register voluntarily to be contacted via our Contact Us link or to receive a Demo for any ClearTouch product we ask for information such as your name, company name, email address, etc.
ClearTouch uses collected information for the following general purposes: products and services provision, billing, identification and authentication, services improvement, contact, and research. ClearTouch does not share your personal information with non-agent third parties, unless explicitly approved by you. Please see DATA STORAGE & THIRD PARTY TRANSFER information below for use by ClearTouch’s agents under normal operations. ClearTouch processes telecommunications data on behalf of the owners of such data from the countries they reside. Such information is confidential and provided only to its owners. If you use the Site without registration, the only information we collect will be non-personal information related to your IP address, web browser and operating system.
ClearTouch recognizes an individual’s right to access their own data. Individuals wishing to review, correct, delete, or otherwise amend their personal information may do so by following the steps listed below under Privacy Complaints by European Union Citizens, or Privacy Complaints by Swiss Citizens, respectfully.
DATA STORAGE & THIRD PARTY TRANSFER
ClearTouch uses primarily its own equipment and hosting, but for certain services, it uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run our services. Although ClearTouch owns the code, databases, and all rights to ClearTouch hosted applications, you retain all rights to your data. ClearTouch is potentially liable for onward transfers to third parties of personal data of EU or Swiss individuals received pursuant to Privacy Shield. ClearTouch only shares data with agent partners in providing contracted services for clients. ClearTouch does not share information with non-agent partners and does not expect to do so in the future. In the event that this changes individuals will be given an option for opting out of the sharing of their information with third parties.
ClearTouch may disclose personally identifiable information under special circumstances, such as to comply with subpoenas or when your actions violate the Terms of Service of any of our applications. We 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. ClearTouch allows individuals to limit the use or disclosure of personal information by emailing us at firstname.lastname@example.org or through written correspondence to ClearTouch’s corporate offices.
CHANGES & ACCEPTANCE OF CLEARTOUCH WEB SITE POLICY TERMS AND CONDITIONS
EU-US PRIVACY SHIELD & SWISS-US PRIVACY SHIELD
Although ClearTouch does not require any specific piece of personal information beyond a phone number in the normal course of business, our clients will often utilize additional points of reference, including (but not limited to): names, addresses, additional contact information, and basic information regarding accounts or credit, like account numbers or balances. ClearTouch does not share nor make this information available to any other clients, groups, or individuals, except as noted in the disclosure statement, above.
PRIVACY COMPLAINTS BY EUROPEAN UNION AND SWISS CITIZENS
ClearTouch has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to 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 www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Please note, if a complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.