PRIVACY POLICY

Updated January 29, 2020

This Privacy Policy is issued by the Council on Licensure, Enforcement and Regulation (CLEAR) to inform you of the data relating to you that we collect and use in connection with this website, and its integrated third-party platforms. CLEAR is not responsible for the content or privacy practises of any linked sites. Unless indicated otherwise, the terms “you” and “your” refer to both you individually and to any entity on whose behalf you are accessing CLEAR’s website, and its integrated third-party platforms.

CLEAR headquarters is located at:

108 Wind Haven Drive, Suite A
Nicholasville, KY 40356
United States of America
Phone: (+1) 859-269-1289

If you have any questions or concerns related to this policy, please contact CLEAR at DPO@clearhq.org.

1.    CLEAR’s Internal Data Contact and Personal Data Supervisor

Our Data Protection Officer oversees how CLEAR collects, uses, shares and protects your information.

You can contact our Data Protection Officer at DPO@clearhq.org or by writing to them at CLEAR, 108 Wind Haven Drive, Suite A, Nicholasville, KY 40356, United States of America.

2.    Questions / Concerns

If you are a data subject in the European Union, you also have the right to make a complaint at any time to a supervisory authority.

If you are a data subject elsewhere and you believe that our website or app is not following our policy, you may contact us at the above address, or state or local chapters of the Better Business Bureau.

3.    Collecting personal data

CLEAR collects information as a way to further its purpose to:

a)  bring together individuals, agencies and organizations involved in or affected by professional and occupational regulation;

b)  encourage and provide for the exchange of information and ideas;

c)  provide education and training regarding professional and occupational regulation;

d)  improve functionality of CLEAR’s website;

e)  provide a central clearinghouse of information pertinent to professional and occupational regulation; and

f)  improve practices regarding professional and occupational regulation.

Your data may be collected from several collection points on CLEAR’s website, and its integrated third-party platforms. This data may include, but is not limited to: name, mailing address, telephone number, email address, employer, professional title, date of birth, username and password, photographs and education, payment information.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

CLEAR will also collect personal information when you request that we, or give permission for us to, contact you via e-mail, mail, or telephone. 

Website users from outside the United States are advised that their information may be accessed by individuals located in other jurisdictions, where the level of data protection may differ from their home jurisdiction. When providing CLEAR with your personal data, you consent to its use under this privacy policy, including its transfer across international boundaries to any location globally, as is permitted by law.

CLEAR uses session cookies and persistent cookies to offer a better user experience. Users of the CLEAR website must agree to the privacy policy before accessing the material. Details on cookies follow:

• Cookies are pieces of data sent to your browser when you visit a website, and stored on your hard drive. Information stored may include user preferences and other information, for example to allow you to quickly log-in.
  
• Session cookies enable the website to store information on your computer as you travel from one page to another. This information is deleted from your machine when you close your browser.
• A persistent cookie is kept even when you close your browser. You can manually delete these cookies using persistent command specific to your computer and browser.
  

CLEAR uses session cookies and persistent cookies to offer a better user experience. Users of the CLEAR website must agree to the privacy policy before accessing the material. Details on cookies follow:

Purpose/Activity	Type of Data	Lawful basis for processing including basis of legitimate interest	Retention Period
To register for an account with us or interact with our services	(a) Identity Data (b) Contact Data	(a) Performance of a contract with you (b) Necessary for our legitimate interests (for running our business)	3 years after we have ceased to provide you with goods or services
To communicate with you for the purpose of marketing	(a) Identity data (b) Contact data (c) Marketing data	The consent of the data subject	Until consent is withdrawn
To understand how you use our website and app	(a) Technical Data (b) Usage Data	Necessary for our legitimate interests (to keep our website and app updated and relevant, to develop our business and to inform our marketing strategy)	7 years after we have ceased to provide you with goods or services
Notifying you about changes to our privacy notice	(a) Identity Data (b) Contact Data	(a) Necessary to comply with a legal obligation	3 years after we have ceased to provide you with goods or services

5.    Children

CLEAR does not offer its services or promote its website or app to, nor does it intentionally collect or retain personal data from children who are younger than 18 years of age. 

6.    The retention periods for your personal data

CLEAR will retain your personal data only for as long as we need it for the purposes described in this Privacy Statement or to comply with our obligations under applicable law. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are set out in the table above.

7.    The recipients of your personal data
CLEAR may share your personal information with third parties in the following ways:

• We sometimes use agents and third-party service providers to process personal information on our behalf.
• Affiliated partners, including, but not limited to: event sponsors and exhibitors, who may receive attendance lists that indicate your full name, e-mail and mailing address, company name.
• We may release your personal information to others when you have given your consent to that release.
  

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes, outside of the marketing purposes contemplated herein, and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8.    The rights available to you in respect of the processing
Under the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), individuals in the EU are afforded specific rights with respect to their Personal Information, or “personal data” as defined under the GDPR.  For the purposes of this Policy, the Company operates as a data controller.  You may always withdraw your consent to our use of your personal data as described below. 

You can exercise any of the following rights by notifying us as described below:

• Access. You may email us at DPO@clearhq.org to request a copy of the personal data our Website databases currently contain.

• Correction or Rectification. You can correct what personal data our Website database currently contains by accessing your account directly, or by emailing us at DPO@clearhq.org to request that we correct or rectify any personal data that you have provided to us.  We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties.  Using the same email address associated with your Website account, simply type the words “Correction or Rectification” in the subject line of your email.

• Restrict Processing. When applicable, you may restrict the processing of your personal data by submitting a request via email to DPO@clearhq.org.  In your email, please explain how you wish us to restrict processing of your personal data.  When such restrictions are not possible, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.  Using the same email address associated with your Website account, simply type the words “Restrict Processing” in the subject line of your email.

• Object to Processing. When applicable, you have the right to object to the processing of your personal data by submitting a request via email to DPO@clearhq.org.  When such objections are not possible, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.  Using the same email address associated with your Website account, simply type the words “Object to Processing” in the subject line of your email.

• Portability. Upon request and when possible, we can provide you with copies of your personal data.  You may submit a request via email to DPO@clearhq.org.  When such a request cannot be honored, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent.  Where applicable, we will ensure such changes are shared with any trusted third parties. Using the same email address associated with your Website account, simply type the words “Portability / Personal Data” in the subject line of your email.

• Withdraw Consent. At any time, you may withdraw your consent to our processing of your personal data through this Website by notifying us via email at DPO@clearhq.org.  Using the same email address associated with your Website account, simply type the words “WITHDRAW CONSENT” in the subject line of your email.  Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your personal data.  Where applicable, we will ensure such changes are shared with trusted third parties.

• Erasure. If you should wish to cease use of our Website and have your personal data deleted from our Website, then you may submit a request by emailing us at DPO@clearhq.org.  Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your personal data has been deleted.  Where applicable, we will ensure such changes are shared with trusted third parties.  Using the same email address associated with your Website account, simply type the words “Erasure / Personal Data Deletion” in the subject line of your email.

• Submit Complaints or Questions. If you wish to raise a complaint on how we have handled your personal data, you can contact us by emailing us at DPO@clearhq.org. Using the same email address associated with your Website account, simply type the words “Complaints or Questions” in the subject line of your email. If you reside in a European Union member state, you may also lodge a complaint with the supervisory authority in your country.

9.    The right to lodge a complaint with a supervisory authority
You have a right to lodge a complaint with the data protection regulator in the country in which you reside, or where you believe any misuse of your data has taken place. 

10.    Update and revision

CLEAR may update this privacy policy and you should take time to review the document each time you visit the website, and its integrated third-party platforms.