CLEAREDGEPARTNERS.COM PRIVACY POLICY

Last revised and effective as of: October 15, 2021

This Privacy Policy applies to information collected online and offline by ClearEdge Partners Inc. (“ClearEdge”, "us", "we" or "our"), including through your use of the ClearEdge website at http://www.clearedgepartners.com  and any subdomains thereof (the “Site”) and the services, features, and information available on the Site and/or any mobile applications we may offer (together with the Site, along with associated and successor websites, applications, features, information, and services, or any part thereof, the “Service”).

By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. As used in this Privacy Policy (a) “GDPR” means the General Data Protection Regulation (EU) 2016/679; (b) “UK Data Protection Laws” means data protection laws enacted under the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 (“UK GDPR”) and the UK Data Protection Act 2018 (“UK DPA 2018”); and (c) “European Data Protection Laws” means the GDPR and/or UK Data Protection Laws, in each case to the extent applicable.

 

To the extent that the Service is available to individuals located in the European Economic Area or the United Kingdom, this Privacy Policy sets out our practices and obligations under the European Data Protection Laws, to the extent applicable. If an organization with which you are associated (an “Organization”) signs up to use our Service, we may receive personally identifiable information about you in connection with our provision of the Service to your Organization. To the extent we process (as defined below) that personally identifiable information solely in order to provide the Service to your Organization, under the European Data Protection Laws, to the extent applicable, we will act as a processor (as defined in the European Data Protection Laws) on behalf of your Organization in respect of that personally identifiable information; this Privacy Policy will not apply to the processing of that personally identifiable information and your Organization will act as a controller (as defined in the European Data Protection Laws) in respect of that personally identifiable information  and is responsible for obtaining all necessary consents and providing you with all requisite information as required by applicable law. To the extent we process your personally identifiable information for any other lawful business purpose of ours, under the European Data Protection Laws, to the extent applicable, we will act as a controller of such personally identifiable information and this Privacy Policy will apply to the processing of such personally identifiable information.

As used in this Privacy Policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within ClearEdge or among our affiliates within the United States or internationally.

 

Information Collection And Use 

We collect several different types of information for various purposes to provide and improve our Service to you. 

 

Types of Data Collected 

 

Personal Data 

While using our Service or in order to take advantage of certain features of the Service, we may ask you to provide us with certain personally identifiable information in order to create an account, which information may be used to contact or identify you ("Personal Data"). Personally identifiable information amounts to ‘personal data’ for the purposes of and as defined in the European Data Protection Laws (to the extent applicable). All references to “Personal Data” in this Privacy Policy include ‘personal data’ as defined and used in the European Data Protection Laws (to the extent applicable). Personal Data may include, but is not limited to: 

  • Email address 

  • First name and last name 

  • Phone number

  • User name

  • Password

  • Any personally identifiable information that you choose to share by completing a “Contact Us” form or by posting a “Message” on the Portal page of the Service.

  • Any information you provide in a communication you choose to conduct through the Service, such as if you submit a request or contact our support team. 

  • Cookies and Usage Data 

We may also collect additional information about you from third-party sources such as ZoomInfo and LinkedIn and publicly available sources, such as your:

 

  • Job title 

  • Job function

  • Address 

  • Company name 

  • Phone number

  • Zoominfo contact profile URL 

  • LinkedIn contact profile URL
     

Usage Data 

We may also collect information about how the Service is accessed and used ("Usage Data"). This may include information such as your computer's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, documents you access, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. 

 

Tracking & Cookies Data 

We use cookies and similar tracking technologies to monitor the activity on our Service and collect certain information. 

 

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags and scripts to collect and track information and to improve and analyze our Service. 

 

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. 

 

Examples of Cookies We Use: 

  • Session Cookies. We use Session Cookies to operate our Service. 

  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings. 

  • Security Cookies. We use Security Cookies for security purposes. 

The Service uses third-party service platforms (including to help analyze how users use the Service).  These third-party service platforms may place cookies on your computer or mobile device.  If you would like to disable "third party" cookies, you may be able to turn them off by going to the third party's website.

Here are links to the main third-party platforms we use:

https://www.google.com/policies/privacy/

https://help.salesforce.com/s/articleView?id=sf.networks_cookies.htm&type=5

https://www.salesforce.com/company/privacy/

https://help.salesforce.com/s/articleView?id=sf.pardot_basics_cookies.htm&type=5

https://www.zoominfo.com/about-cookies

https://www.linkedin.com/legal/cookie-policy

 
No Information From Children Under 13 Years Of Age

We are committed to protecting the privacy of children. The Service is not designed for or directed to children under the age of 13. We do not collect Personal Data from any person we actually know is under the age of 13.

Use of Data 

 

ClearEdge uses the Personal Data for various purposes: 

  • To provide and maintain the Service 

  • To notify you about changes to our Service 

  • To allow you to participate in interactive features of our Service when you choose to do so 

  • To provide customer care and support 

  • To provide analysis or valuable information so that we can improve the Service 

  • To monitor the usage of the Service 

  • To detect, prevent and address technical issues 

  • Unless you opt out, to the extent permitted by applicable law, so that we and third parties can contact you about products and services that may be of interest to you.

 

​Furthermore, we will only use your Personal Data to the extent that the law allows us to do so. Pursuant to the European Data Protection Laws, legal bases for our processing your Personal Data may include (without limitation):

  • Where you have given consent to the processing, which consent may be withdrawn at any time without affecting the lawfulness of processing based on consent prior to withdrawal;

  • Where it is necessary to perform the contract we have entered into or are about to enter into with you (whether in relation to the provision of the Service or otherwise);

  • Where it is necessary for us to comply with a legal obligation to which we are subject; and/or

  • Where it is necessary for the purposes of our legitimate interests (or those of a third party) in providing or marketing the Service and your interests or fundamental rights and freedoms do not override those legitimate interests.

 

Transfer of Data 

 

Your information, including Personal Data, may be transferred to from time to time to our offices or personnel, or to third parties, located throughout the world, and the Service may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such information. By using the Service and submitting such information on it, you voluntarily consent to the trans-border transfer and hosting of such information. Without  limitation of the foregoing, you hereby expressly grant consent to the ClearEdge to: (a) process and disclose such information in accordance with this Privacy Policy; (b) transfer such information throughout the world, including to the United States or other countries that do not ensure adequate protection for personally identifiable information (as determined by the European Commission or the UK Information Commissioner’s Office, as applicable, each, an "Inadequate Jurisdiction") and/or countries that may not have laws of general applicability regulating the use and transfer of such information; and (c) disclose such information to comply with lawful requests by public authorities, including to meet national security or law enforcement requirements.  To the extent required by applicable law: whenever we transfer your personal data (as defined in the European Data Protection Laws) to third parties (as described in this Privacy Policy) located in an Inadequate Jurisdiction, we ensure a similar degree of protection is afforded to it; we may use specific contracts approved by the European Commission or the UK Information Commissioner’s Office, as applicable, which give personal data the same protection it has in the European Economic Area or the United Kingdom, as applicable, under the European Data Protection Laws; and if we rely on another basis to transfer your personal data to an Inadequate Jurisdiction, we will keep you updated or contact you if required. Please contact us if you want further information on the specific mechanisms used by us when transferring your personal data to an Inadequate Jurisdiction.  If you are a user accessing the Service from a jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from those of the United States, please be advised that all aspects of the Service are governed by the internal laws of the United States and the Commonwealth of Massachusetts, USA, regardless of your location.

 

Disclosure Of Data 

 

Legal Requirements 

ClearEdge may disclose your Personal Data in the good faith belief that such action is necessary to: 

  • To comply with a legal obligation including lawful requests by public authorities, including to meet national security or law enforcement requirements  

  • To protect and defend the rights or property of ClearEdge

  • To prevent or investigate possible wrongdoing in connection with the Service 

  • To protect the personal safety of users of the Service or the public 

  • To protect against legal liability 

Sale of Business

We reserve the right to transfer information to a third party in connection with a sale, merger or other transfer of all or substantially all of the assets of ClearEdge or any of its Corporate Affiliates (as defined below), or that portion of ClearEdge or any of its Corporate Affiliates to which the Service relates, or in connection with a strategic investment by a third party in ClearEdge, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding.

 

Affiliates

We may disclose information (including personally identifiable information) about you to our Corporate Affiliates. For purposes of this Privacy Policy: "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under common control with ClearEdge, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.

Outside Contractors

 

See “Service Providers” section below.

Security Of Data 

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. 

 

Retention of Data

We will only retain your personally identifiable information for as long as necessary to fulfill the purposes for which we collected it or as otherwise permitted by applicable law.

To determine the appropriate retention period for personally identifiable information, we consider the amount, nature, and sensitivity of that information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personally identifiable information and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

Service Providers 

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. 

 

These third parties have access to your Personal Data only to perform these tasks on our behalf and we use reasonable efforts to ensure that these third parties are capable of protecting the security of your Personal Data and to obligate them not to use it for any other purpose. 

 

Analytics 

We may use third-party Service Providers to monitor and analyze the use of our Service. 

 

Google Analytics 

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. 

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. 

 

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page.

 

Your Choices Regarding Your Personal Data

We generally use Personal Data as described in this Privacy Policy or as authorized by you or as otherwise disclosed at the time we request such information from you. You generally must "opt in" and give us permission to use your Personal Data for any other purpose. You may also change your preference and "opt out" of receiving certain marketing communications from us by following the directions provided in association with the communication or such other directions we may provide or by contacting info@clearedgepartners.com.

Under certain circumstances and in compliance with the European Data Protection Laws, you may have the right to:

Request access to your Personal Data (commonly known as ‘subject access request’). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it;

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;

Request erasure of your Personal Data. This enables you to ask us to delete or remove your Personal Data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove all of your Personal Data in certain circumstances;

Object to processing of your Personal Data where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground;

Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data, for example, if you want us to establish its accuracy or the reason for processing it;

Request the transfer of your Personal Data to another party; and

Lodge a complaint with the relevant supervisory authority (as defined in the European Data Protection Laws). If you have any complaints about the way we process your Personal Data, please do contact us. Alternatively, you may lodge a complaint with the supervisory authority which is established in your country.

If you want to review, verify, correct, or request erasure of your Personal Data, object to the processing of your Personal Data, or request that we transfer a copy of your Personal Data to another party, please contact info@clearedgepartners.com  

Such updates, corrections, changes, and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

You should be aware that it may not be technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your Personal Data may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, all Personal Data stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.

Do Not Track

The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.

 

 

Links To Other Sites or Services 

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. 

 

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services. A link to a third-party website does not constitute or imply endorsement by us.  This Privacy Policy applies solely to information collected by us through the Service.

 

 

Changes To This Privacy Policy 

 

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. 

 

We will let you know via email and/or a prominent notice on our Service, when the change becomes effective and update the "effective date" at the top of this Privacy Policy. 

 

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. 

Contact Us 

If you have any questions about this Privacy Policy, please contact us. You can reach us by submitting information at the “Contact Us” form at the foregoing link or through the following ways:

By e-mail:

info@clearedgepartners.com

By postal mail or courier:

Attn: Privacy
ClearEdge Partners, Inc.

254 Second Ave, Suite 140

Needham, MA 02494