Last Revised: February 1, 2023
Claire Holdings, Inc. (“we” or “us”) created this Privacy Policy to describe our data collection, use, and disclosure practices with respect to information that identifies or may reasonably identify you (“Personal Information” or “PI”). This Privacy Policy applies to our website (“Website”) and all communications with you.
By using this Website, you affirm that you have read this Privacy Policy and our Terms of Use and that you understand, agree to be bound by, and acknowledge all the terms contained herein. If you do not agree to be bound by the terms of this Privacy Policy or our Terms of Use, you should discontinue your use of the Website.
Children
Our Website is not directed at children and we do not knowingly collect or solicit Personal Information online from children under the age of 18 or knowingly allow such persons to use our Website. If you are aware that a child has provided us with Personal Information online, please contact us using the contact information below.
Types of Personal Information we Collect From Users
TYPES OF PERSONAL INFORMATION WE COLLECT FROM USERS
We collect the following Personal Information about you:
- Information You Submit. This includes information you provide to us, such as when you sign up to our email alerts by providing your email address. This also includes any information you may submit in connection with a job application or a consulting engagement, including any government identifiers for a background check. We also may collect the visible Personal Information about you when you interact with our social media pages or participate in our promotion campaigns.
- Information from Third Parties. We may receive contact information about you from third-party partners.
- Geolocation. We automatically collect your geolocation when you use the Website. This is information that identifies your location.
- Technological Information. We automatically collect your IP address, unique online identifier, device ID and/or hardware model, mobile operating system, and Wi-Fi or mobile network. We use this for a number of reasons, including tracking how you engage with our Website and monitoring user traffic on our Website to ensure the security and integrity of our systems.
- Internet Activity. This includes browsing history, search history, and information regarding your interactions with other applications, advertisements, or websites (including the websites you came from before you visited our website and the website you visit when you leave our website). This information is collected via cookies and pixels. We may use this information to serve you with tailored advertising content if permissible and in accordance with law. For more information about our advertising practices, which includes targeted advertising, please see the sections below.
How we use your information
We may share your Personal Information in the following ways:
- On our Website or Social Media Pages. For example, we may display or repost Personal Information that you post in our social media forums.
- With Our Service Providers. We may share your Personal Information with third parties who perform services on our behalf. For example, this may include companies that send emails on our behalf or other operating systems or Websites that help us run our Services or Website. This also may include vendors that perform background checks or exclusion list screening.
- With Data Analytics Providers for Targeted Advertising. Third-party data analytics providers may collect Personal Information about users over time and across different websites, applications, and devices for the purposes of targeted advertising. Third-party data analytics providers may also collect Personal Information in this way on our website. For more information about your choices related to these communications, see Choices Regarding Your Information.
- Choices Regarding Your Information. For example, this may include a company that co-sponsors a promotion.
- With Any Successors to All or Part of Our Business or One of Our Brands. For example, if we assess or actually merge with, acquire or are acquired by, or sell a brand or part of its business to another business entity. This may include an asset sale, corporate reorganization, or other change of control, potentially involving the bankruptcy process. We may transfer our customer information, which may include your Personal Information, as part of such a transaction or as a stand-alone asset. You hereby consent to such transfers and we may assign and transfer all of the rights, benefits, duties, and obligations of this Privacy Policy, under the circumstances described in this paragraph.
- To Comply with the Law or To Protect Ourselves. For example, this could include responding to a court order or subpoena. It could also include sharing Personal Information if requested by a government agency or investigatory body. We might share Personal Information within the context of protecting or assessing our own legal rights, such as with third-party accountants or outside legal counsel. We might share Personal Information in order to protect the rights, privacy, safety, or property of ourselves, our employees and personnel associated with us, our business partners, or you.
Choices regarding your information
You have certain choices about how we use your Personal Information. Certain choices you make are specific to your browser and/or device.
Marketing Communications:
You can opt-out of receiving our marketing communications. Note that you will still receive transactional messages from us, including information about your account and responses to your inquiries. To opt-out of receiving our marketing communications, you can follow the instructions included with the communication.
Cookies & Other Tracking Technologies:
Cookies are small text files that websites place on your device as you are browsing, which are stored by your web browser. By storing data, cookies serve crucial functions for websites. If you prefer not to share data, you can disable them. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Website. Your browser may give you the ability to control cookies or other tracking tools. How you do so depends on the type of tool. If you do not want information, which may include Personal Information, collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a website. To learn more about cookies and how to manage them, you may find the following link helpful: aboutcookies.org/how-to-control-cookies.
Rights regarding personal information
You may have the following rights (“Data Subject Rights”) in relation to the Personal Information that we collect or process about you. These rights differ depending on where you live, but we will endeavor to respect these rights regardless of your country or state of residence. Please note that we reserve the right to honor your Data Subject Rights as required by applicable law.
- Right to Access and Obtain a Copy: If you ask us, we may confirm whether we are processing your Personal Information and, if so, provide you with a copy of all Personal Information you are lawfully entitled to receive along with certain other details. In addition, you may request to know the types of third parties with whom we share your Personal Information, and the categories of Personal Information we share with them.
- Right to Amend: If you believe your Personal Information is inaccurate or incomplete, you may request that we correct or complete it. If you ask us, and where possible and lawful to do so, we may tell you with whom we shared your Personal Information so you can contact them directly.
- Right to Delete: You may request that we delete or remove your Personal Information. If we shared your Personal Information with others, we will tell them about the erasure as required by law.
- Right to Restrict Processing: You may ask us to restrict or “block” the processing of your Personal Information in certain circumstances, such if we process Personal Information that is considered “sensitive” under applicable state laws or engage in automated decision-making.
- Right to Opt Out of Targeted Advertising: Targeted advertising is the practice of serving you tailored advertisements based your Personal Information gathered across other businesses, websites, applications, or services. You may request that we opt out of this practice.
- Right to Non-discrimination: We will not discriminate against you for exercising these rights, but we may charge a reasonable fee as permitted by law in fulfilling these rights, such as if you request multiple copies of your Personal Information.
If you or your authorized agent wish to exercise any of these Data Subject Rights, please contact us via at the information provided in How To Contact Us. Before responding to your request to exercise Data Subject Rights, we may require additional information (potentially including Personal Information) from you to verify your identity or clarify your specific request. We will try to comply with your request as soon as reasonably practicable and in compliance with applicable law. Where appropriate, we will work with third parties in order to fulfil your request.
Security and Retention
We have enabled reasonable administrative, physical, and technical safeguards for the protection of the Personal Information in our custody or control. Unfortunately, no data transmission or storage system is guaranteed to be 100% secure. 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 How To Contact Us.
As our operations are conducted from the United States, all Personal Information that we collect is used and stored in the US, is subject to US laws, and may be subject to disclosure to US governments, courts, law enforcement, or regulatory agencies pursuant to those laws. If you are using our Website, including accessing this website, from or in another country, please note that your Personal Information will be transmitted to our servers in the US as necessary to provide you with the information that you requested, administer our Services to you, or as otherwise disclosed in this Privacy Policy.
Links
This Privacy Policy does not address, and we are not responsible for, the privacy or other information practices of any third parties, including any third party operating any site or service to which the Website links. The inclusion of a link on the Website does not imply endorsement of the linked site or service by us. In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as an app developer, app provider, exclusion list screening provider, social media provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Services.
How to contact us
If you have any questions, comments, or concerns with respect to our privacy practices or this Policy, wish to update your information, or would like to exercise your Data Subject Rights, please feel free to contact us at compliance@claire.health
You may also write to us at the following address:
- Claire Holdings, Inc.
- 530 7th Avenue Floor M1
- New York, NY 10018
If you disagree with our determination regarding your Data Subject Rights, you may appeal the decision by contacting us at compliance@claire.health. Please include confirmation of your original decision in the email.
Changes in Policy
From time to time, we may change our Privacy Policy. We will notify you of any material changes to our Privacy Policy as required by law. We will also post an updated copy on our website. This Privacy Policy is current as of the “last revised” date which appears at the top of this page.
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