Website Privacy and Security Policy

Last modified: January 28th, 2010

If you have any questions about this Website Privacy and Security Policy, please contact us at feedback@clearrisk.com.

1. Protecting Your Privacy

(1) ClearRisk Inc. respects your privacy and is committed to protecting it in accordance with this Website Privacy and Security Policy. This policy explains ClearRisk Inc.’s treatment of your personally identifiable information collected in connection with your activities on, or related to, ClearRisk Inc.’s website and all services made available thereon. This policy also explains how you can ask questions and make suggestions about ClearRisk Inc.’s privacy practices and review and update your personal information.

(2) ClearRisk Inc. urges you to read this Website Privacy and Security Policy carefully and to check back periodically, as this policy may change from time to time. Please note that this policy does not apply to practices of companies or websites which are not owned or controlled by ClearRisk Inc.

2. Information Collected

(1) In the course of operating the website, ClearRisk Inc. may collect two types of information about you: Personal Information and Non-Personal Information.

(2) “Personal Information” is personally identifiable information, such as your name, address, telephone number, e-mail address and credit card information. Personal Information is collected by ClearRisk Inc. when you choose to subscribe to the website or download content. In addition, if you choose to contact any of Clear Risk Inc.’s service representatives, a record of that correspondence may be kept so as to fully address the subject matter. ClearRisk Inc. may also receive Personal Information from its business partners and other third parties, provided that such third parties confirm that you have permitted them to share such information.

(3) “Non-Personal Information” is information of an anonymous nature, such as an internet protocol address (“IP address”), the domain used to access ClearRisk Inc.’s website, and the type and version of browser or operating system being used. Aggregate information, such as demographic statistics of users, number of visitors and average time spent on the website, is also considered Non-Personal Information.

(4) Non-Personal Information is collected or derived by ClearRisk Inc. in the course of operating its website. Non-Personal Information is used by ClearRisk Inc. as described here:

(a) Cookies: When you visit ClearRisk Inc.’s website, one or more cookies – a small file containing a string of characters – is sent to your computer that uniquely identifies your browser. ClearRisk Inc. uses cookies to improve quality of service by storing user preferences and tracking user trends, such as how people search.

(b) Log information: When you visit ClearRisk Inc.’s website, servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, IP address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser. ClearRisk Inc. uses this information to improve the provision of its website services.

(c) Links: ClearRisk Inc. may present links in a format that enables it to keep track of whether these links have been followed. ClearRisk Inc. uses this information to improve the quality of its search technology, customized content and advertising.

3. Use of Personal Information

Personal information may be used by ClearRisk Inc. for the following purposes:

(a) Providing you with the services and information you have requested from Clear Risk Inc., including your use of the ClearRisk Inc. website, and maintenance and improvement of that use. ClearRisk Inc. may from time to time use your Personal Information to contact you about changes, enhancements, products, partner offerings, blog posts or similar notices related to the website.

(b) If you indicated that you were interested in receiving offers or information from ClearRisk Inc. or certain of our selected sponsors or advertisers, Clear Risk Inc. or such sponsors or advertisers may send you e-mail materials and other mailings about products and services that may be of interest to you. If at any time you would like to end your subscriptions to any such e-mail materials, follow the directions posted at the bottom of the e-mail material;

(c) If you enter a contest or other promotion offered on the ClearRisk Inc. website, ClearRisk Inc. may, under the rules of the promotion, use your name and certain other information to administer the promotion, such as contacting, announcing and promoting the winners of the promotion;

(d) ClearRisk Inc. may also use Personal Information if it has reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law or in order to protect or defend a legal interest.

4. Disclosure of Personal Information

ClearRisk Inc. will not sell or rent your Personal Information to anyone. ClearRisk Inc. will only disclose your Personal Information to third parties:

(a) where you have specifically given us your consent to disclose your Personal Information for a designated purpose;

(b) who are acting on behalf of ClearRisk Inc. as agents, suppliers or service providers, solely to enable ClearRisk Inc. to more efficiently provide you with the website services and information. Such entities act under strict contractual controls, requiring them to maintain the confidentiality of all such Personal Information and to use such information solely for purposes related to the provision of the website services and information.

(c) as may be set out in the Website Terms and Conditions;

(d) as required by law, including by an order of any court, institution or body with jurisdiction or authority to compel the production of information, or in order to protect or defend a legal interest; or

(e) in connection with a corporate reorganization of ClearRisk Inc., merger or amalgamation with another entity, or a sale of all or a substantial portion of the assets of ClearRisk Inc.

5. Links to Other Sites and Advertisements

The ClearRisk Inc. website may contain links to other websites and services. While ClearRisk Inc. tries to link only to sites and services that share its high standards and respect for privacy, please understand that ClearRisk Inc. is not responsible for the content of, or the privacy practices employed by, other companies or websites. This Website Privacy and Security Policy applies only to the ClearRisk Inc. website.

6. Security

(1) The security of your Personal Information is important to ClearRisk Inc. ClearRisk Inc. takes technical, contractual, administrative and physical security steps to protect Personal Information that you provide to us. Clear Risk Inc. takes various security measures, including the use of secured networks, to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, your Personal Information. These measures also include internal reviews of ClearRisk Inc.’s data collection, storage and processing practices. ClearRisk Inc. instructs its employees with access to your Personal Information that it is to be used only in adherence with the principles set forth in this Website Privacy and Security Policy and the laws applicable to each specific business.

(2) You can help protect the security of your Personal Information as well. For instance, never give out your password, since this is what is used to access your account or registration information. Also, remember to log out of your account and close your browser window when you finish using the ClearRisk Inc. website or surfing the Web, so that other people using the same computer will not have access to your information. You must notify ClearRisk Inc. immediately of any unauthorized use of your password or account, or of any other breach of security. ClearRisk Inc. is not liable for any loss or damage arising from your failure to protect your password or account information.

7. Accessing and Changing Account Information

ClearRisk Inc. provides you with the means to access your Personal Information and either correct this data if it is inaccurate or delete such data that is not otherwise required to be retained by law or for a legitimate business purpose. ClearRisk Inc. requires that you identify yourself and the information requested to be accessed, corrected or removed before processing your request. ClearRisk Inc. may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or that would be extremely impractical to satisfy (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required.

8. Changes to this Website Privacy and Security Policy

ClearRisk Inc. may from time to time change its Website Privacy and Security Policy. Changes will be effective when notice of such change is posted on the ClearRisk Inc. website. Please check this policy regularly for updates by checking the date of “Last Modified” at the top of this document.

9. Questions, Comments or Suggestions

If you have any questions, comments or suggestions about this Website Privacy and Security Policy or ClearRisk Inc.’s privacy practices that were not answered here, please contact us at feedback@clearrisk.com.

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