Introduction
Clareo and its affiliated entities (collectively, “Clareo” or “we” or “us”) respect your personal information and privacy. This Privacy Policy applies to the websites, tradenames, mobile websites, applications and other online and digital services to which this Privacy Policy is posted (collectively, the “Digital Services”), including, but not limited to, www.clareo.com and “Clareo” and “Clareo Partners” trademarks. Please read our Privacy Policy carefully to be sure you understand how we collect and use information and under what circumstances we share information about you. By visiting the Digital Services or by submitting information to us in a manner governed by this Privacy Policy, you agree to the terms of this Privacy Policy. Your continued use of the Digital Services following the posting of changes to this Privacy Policy will be deemed your acceptance of those changes. If you do not agree to this Privacy Policy, do not use the Digital Services.
Collection and Use of Information
Personal Information
Clareo may collect personally identification information (“PII”) from you on or through the Digital Services, but only if you voluntarily submit such information to us. For example, we may collect PII when you respond to a survey, fill out a contact form, apply for employment, or in connection with other activities, services, features or resources we make available on or through the Digital Services. PII that may be collected includes, but isn’t limited to, your name, mailing address, email address, title or occupation, employer, and telephone number. Additional types of PII that may be collected on or through the Digital Services include, without limitation:
- Your user name and password, work authorization status, contact information, employment history and preferences, educational background, salary history and requirements, information necessary to conduct pre-employment screening, and any other information you submit in connection with your application or include on the resume and other materials you upload to the Digital Services.
- Content shared by you, such as a job description.
- Any data or other content that you store in the context of utilizing any of the Digital Services, and any PII contained in, associated with, or related to such data.
You may refuse to supply PII, but this may prevent you from engaging in certain activities available on the Digital Services.
PII is used for the purpose for which it was collected and for administrative and analytical purposes. For example, Clareo may use your PII for the following purposes:
- To provide the services or information you have requested.
- To run a survey or other feature of the Digital Services.
- To create and manage any accounts you may have with us and respond to your inquiries.
- To recruit candidates for employment opportunities.
- To operate, evaluate and improve our business (including developing new products and services; managing our communications; determining the effectiveness of and optimizing our advertising; analyzing our products, services, websites, mobile applications and any other digital assets; facilitating the functionality of our websites, mobile applications and any other digital assets; and performing accounting, auditing, billing, reconciliation and collection activities).
- To send you information and communications you have agreed to receive.
- To comply with industry standards and our policies.
- To monitor and analyze trends, usage, and activities in connection with the Digital Services and for marketing or advertising purposes.
- To investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities.
- To personalize the Digital Services, including by providing features or advertisements that match your interests and preferences.
- For other purposes for which we obtain your consent.
In addition, when you opt not to receive advertising and promotional emails from us, we collect and store certain information, such as your email address, in order to comply with your preferences regarding such materials. You may withdraw your consent to receipt of advertising or promotional emails at any time by clicking unsubscribe within the email or contacting us.
Information from Children
The Digital Services are meant for adults. We do not knowingly collect PII from children under 18. If you are under the age of 18, you should not use the Digital Services and should not submit any information to us. If you are a parent or legal guardian and think your child under the age of 18 has given us PII, you can contact us.
Other Information
“Other Information” is any information that does not reveal a person’s specific identity or does not directly relate to an identifiable individual, such as:
- Browser and device information
- App usage data
- Information collected through cookies, pixel tags and other technologies
- Demographic information and other information provided by you that does not reveal a person’s specific identity
- Information that has been aggregated in a manner that it no longer reveals a person’s specific identity
- Survey responses and similar information which reveals views and preferences, but which does not reveal a person’s specific identity.
If we are required to treat Other Information as PII under applicable law, then we may use and disclose it for the purposes for which we use and disclose PII as detailed in this Privacy Policy.
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
- Through a browser or device: Certain information is collected by most browsers or automatically through devices, such as a Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Digital Services (such as the App) being used. We use this information to ensure that the Digital Services function properly.
- Using cookies: Cookies are pieces of information stored directly on the computer being used. Cookies allow us to collect information such as browser type, time spent on the Digital Services, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize the user’s experience. We also gather statistical information about use of the Digital Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them. We do not currently respond to browser do-not-track signals.
Most browsers allow individuals to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. Please refer to http://www.allaboutcookies.org/manage-cookies/index.html for more information. Declining cookies may cause certain parts of the Digital Services to cease working. - Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Digital Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Digital Services and response rates.
- Analytics: We may use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Digital Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/ partners/__ We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Digital Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also go to the Global Storage Settings Panel and follow the instructions (which may explain, for example, how to delete existing Flash LSOs (referred to as “information”), how to prevent Flash LSOs from being placed on your computer without your being asked, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.
Accessing and Updating PII
Some Digital Services may allow you to set up an account and access and update your PII by logging into your account and going to the appropriate section of your account. You may contact us to modify your PII.
Opt-Out Choices
Emails
You can opt out of receiving future promotional email communications from us by following the unsubscribe procedure indicated within each promotional email you may receive from us or by contacting us. Even if you opt out of receiving promotional emails from Clareo, we may send you transaction emails and respond to questions from you.
Interest-Based Behavioral Advertising
Clareo does not currently engage in interest-based behavioral advertising on the Digital Services or use web beacons or similar technologies to collect information about your online activities over time and across third party websites.
How we protect your information
We maintain safeguards designed to protect the PII you provide, although we cannot guarantee such information will be secure from intrusion or breach. We urge you to use caution when online. This includes not sharing your passwords. If you wish to cancel a password, or if you become aware of any loss, theft or unauthorized use of a password, please promptly contact us.
Sharing your personal information
We do not sell, trade or rent your PII to third parties for their marketing purposes, although we may share your PII with our subsidiaries and affiliates who may use it for their marketing purposes. We do not share with others your PII collected through the Digital Services except with your consent or as outlined in this Privacy Policy. We may disclose your PII to others for the following purposes:
- Affiliates. Clareo may transfer PII to its subsidiaries and corporate affiliates, including future subsidiaries and affiliates.
- Service Providers. Clareo may disclose PII to third party consultants and service providers to help us operate our business and the Digital Services, including, but not limited to, providers of hosting, support, maintenance and repair services, employee recruitment, screening and processing services, email delivery services, survey services, evaluation data analysis, data cleansing, promotion administration and fulfillment, advertising, marketing and promotional activities, fraud protection and risk reduction.
- Enforcement of Rights/Security. We reserve the right to release PII (i) when we are under legal compulsion to do so (e.g. we have received a subpoena) or we otherwise believe that the law requires us to do so, (ii) when we believe it is necessary to protect and/or enforce the rights, property interests or safety of Clareo, our Digital Services users, clients or others, or (iii) we deem necessary to resolve disputes, troubleshoot problems, prevent fraud and otherwise enforce the Privacy Policy.
- Reorganization or Sale of the Company. In the event that Clareo or any of its affiliates is merged with or becomes part of another organization, or in the event that Clareo or any of its affiliates is sold or sells all or substantially all of its assets or is otherwise reorganized, the PII we collect may be one of the transferred assets to the acquiring or reorganized entity.
- As Otherwise Allowed by Law. We may transfer PII to third parties where we are expressly authorized by applicable law to do so. In addition, we may share anonymous aggregated information not linked to PII with our business partners, affiliates, clients, advertisers and others.
Your California Privacy Rights
Under California’s “Shine the Light” law, California residents who provide PII in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the PII we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of PII and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2013 will receive information regarding 2012 sharing activities). To obtain this information, please contact us with a request for your California privacy information and provide your name, street address and email address. We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the “Shine the Light” law and only information on covered sharing, if any, will be included in our response.
Third Party Services
This Privacy Policy does not address, and we are not responsible for, the privacy information or other practices of any third parties, including any third party operating any website or service to which any of the Digital Services may link. The inclusion of a link does not imply endorsement of the linked site or service by us or our affiliates.
Retention Period
We will retain PII for as long as it is needed or permitted in light of the purposes for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Consent of Data Transfer of Non-U.S. Residents
If you reside in a country other than the United States, upon providing your PII to Clareo, you have explicitly consented that the PII you have provided may be transferred to, processed, and stored in the United States.
Changes to this privacy policy
Clareo reserves the right to modify this Privacy Policy at any time. When we do, we will revise the Effective Date at the top of this Privacy Policy. We encourage you to review this Privacy Policy each time you use the Digital Services to stay informed about how we are helping to protect the PII we collect. You acknowledge and agree that it is your responsibility to review this Privacy Policy and become aware of modifications.
Contact us
If you have any questions about this Privacy Policy or your experience on the Digital Services, please contact us at: privacy@clareo.com
Clareo, 20 N Wacker Dr, Suite 2230, Chicago, IL 60606