Privacy Policy

The privacy and security of personal information is very important to Clearline Technologies Inc. and its affiliates (“Clearline”). It is Clearline’s policy to protect and respect the privacy of personal information in accordance with applicable privacy laws. This Privacy Policy explains Clearline’s privacy and security practices with respect to all personal information in the possession and control of Clearline, and may be supplemented by specific policies, procedures, and practices.

 

Note to Residents of the European Union and California: In order to comply with the requirements of applicable privacy laws, this Privacy Policy outlines the legal basis on which Clearline processes your personal data (also referred to as personal information herein). Please see the relevant sections below for additional information as required by applicable laws.

Why does Clearline collect personal information?

Clearline may collect personal information from individuals (such as from customers, staff, sub-contractors, and suppliers) for the following purposes:

  • To administer, plan, and manage the relationship with individuals and to communicate with individuals;
  • To provide individuals with requested information, products, and/or services;
  • To better understand how Clearline may improve its products and services, to develop and conduct its business and operations, and for other internal business purposes;
  • To provide individuals with information on current and future products and services or other developments with respect to Clearline and its affiliates and partners (in accordance with applicable laws such as Canada’s Anti-Spam Legislation – see below); and
  • To comply with applicable legal and regulatory requirements or to protect Clearline’s legal rights and property;

(collectively, the “Authorized Purposes”).

The type of information that Clearline may collect from individuals includes, for example, name, email address, address, phone number, age, gender, technological devices and brand, financial information, and other information individuals choose to provide.

Clearline may collect personal information for other purposes where it has a legal duty or right to do so or where Clearline has a good faith belief that it is necessary to protect the property or rights of Clearline.

Clearline does not collect personal information for any other purposes, unless it has the consent of the individual to whom it relates.

How does Clearline collect personal information?

Clearline only collects personal information about an individual with the individual’s knowledge and consent. Generally, this means that Clearline collects personal information directly from the individual to whom it relates, whether via Clearline’s website, mobile app, social media accounts, chat or other features, e-mail, telephone, fax, or in person. Occasionally, Clearline may collect personal information from third party sources, but only with the knowledge and consent of the individual or where otherwise authorized by law.

 

Visitors to Clearline’s website, mobile app, social media, or other portions of Clearline’s platform (the “Platform”) should also be aware that anonymous technical information may be collected by Clearline as a result of a visit to Clearline’s Platform. For example, this information may include the visitor’s IP address, browser type, operating system, domain name, access times and referring website addresses. Clearline uses this anonymous technical information for purposes such as diagnosing problems with Clearline’s servers, improving the operation and content of Clearline’s Platform and compiling aggregate and statistical information.

 

Clearline will not attempt to link or match such anonymous technical information with any personally-identifiable information unless Clearline has an individual’s consent, Clearline (or its service providers) have detected or reasonably suspect any unlawful use of Clearline’s services or a security breach, or Clearline has a legal duty or right to do so.

Clearline may use “cookies” on its website. “Cookies” are small text files placed on computers that can collect and store a variety of information. Permanent cookies are stored indefinitely on a user’s hard drive unless manually deleted, while temporary cookies are automatically deleted from the user’s browser upon logging out of a website. Web browsers typically allow users to disable permanent and/or temporary cookies.

Please note that we use the following analytics services providers on the Platform:

  • Google Analytics. There is more information about how Google collects, uses, and processes data at http://www.google.com/policies/privacy/partners/.
  • Hubspot. There is more information about how Hubspot collects, uses, and processes data at https://legal.hubspot.com/privacy-policy.
  • SEMRush. There is more information about how SEMrush collects, uses, and processes data at https://www.semrush.com/company/legal/privacy-policy/. 
  • Social Media Site Analytics. Please see the Privacy Policy of the Social Media Site you are visiting for more information about how the Social Media Site you are visiting collects, uses, and processes data (e.g. for Facebook, please see https://www.facebook.com/policy.php).

Please note that Clearline’s website contains links to other websites. Clearline is not responsible for the privacy practices used or followed by other websites. You are encouraged to be aware of when you leave Clearline’s website, and to read the privacy statements of each and every website you may visit that may collect personal information from you.

When does Clearline use or disclose personal information?

Clearline only uses or discloses personal information as reasonably required to facilitate the Authorized Purposes listed above.

In some cases, Clearline may share personal information with third party service providers performing functions on Clearline’s behalf, including, for example, vendors that provide information technology services or provide analytics or assessment services.

Clearline may share information with other sites with your permission (e.g. CloudTalk and Rescue by LogMeIn).

Clearline does not otherwise use or disclose personal information unless Clearline has an individual’s consent, Clearline has a good faith belief that disclosure of the information is necessary to protect the rights or property of Clearline, or Clearline has a legal duty or right to do so.

Clearline does not rent, sell or trade customer lists or other personal information.  

Consent – Is there a choice?

Individuals provide their consent to the collection, use, and disclosure of personal information by Clearline when they provide their information to Clearline or use its products or services.

Individuals can deny or withdraw their consent to Clearline’s collection, use and disclosure of their personal information at any time upon reasonable notice, subject to any legal or contractual requirements. However, if consent is denied or withdrawn, Clearline may not be able to provide certain products or services.

Clearline and its affiliates may use personal information to inform individuals of current and/or new products or services or other developments that Clearline or its affiliates or partners believe will be of interest to individuals in accordance with applicable laws including Canada’s Anti-Spam Legislation. Such communications may be made by way of telephone, text message, direct messaging, e-mail, fax or regular mail. Individuals provide their consent to Clearline and its affiliates and partners contacting them in this manner when they use Clearline’s products or services. Individuals may opt-out of receiving such communications by contacting Clearline at the address below.

How does Clearline protect the security of personal information?

Clearline has in place reasonable policies, procedures and safeguards (including physical, technological and organizational measures) designed to protect the security of personal information under its control.

The protection of personal information is of paramount concern to Clearline, and Clearline is prepared to take appropriate and timely steps in the event of any incidents involving personal information in accordance with applicable privacy laws.

Clearline makes every reasonable effort to ensure that personal information is accurate and complete. This may involve requesting further information or updates from individuals. Clearline relies on individuals to notify Clearline if there is a change to their personal information that may affect their relationship with Clearline.

Clearline retains personal information only as long as is reasonable to fulfill the purposes for which the information was collected, or for legal or business purposes.

Does Clearline provide access to personal information?

Clearline will provide individuals with access to the personal information Clearline holds about them in accordance with applicable laws. Clearline reserves the right to require that any request for access to personal information be made in writing. Generally, there is no cost for such access. However, Clearline reserves the right to charge such costs on a case by case basis in accordance with applicable laws. The individual will be notified in advance if charges apply.

Clearline will correct or amend the personal information in its files where it can be shown that the information is incorrect or incomplete.

Storage and Processing

Clearline will store the personal information on its internal servers and/or with its services providers.

Clearline’s service providers may store and/or process personal information outside of Canada (including in the United States of America). When information is stored or processed outside of Canada, it may be subject to the laws of and be accessible by legal authorities in such other jurisdictions. Clearline has taken appropriate technical, organizational, and legal steps to secure this information.

Contact Clearline

For further information about Clearline’s privacy practices, to make a request for access to personal information to exercise any other rights outlined in this Privacy Policy, please contact Clearline’s Privacy Officer at the following address:

 

Clearline Privacy Officer

1205 Sherwin Rd

Winnipeg, MB  R3H 0V1

info@mygenie.rocks

The foregoing policy is effective as of January 13, 2021. Clearline reserves the right to change this Privacy Policy at any time in accordance with applicable laws – please check our website for updates to this Privacy Policy.

 

Additional Information For Residents of European Union

The European General Data Protection Regulation (GDPR) sets out obligations and rights with respect to the personal data of residents of the European Union. Clearline is committed to ensuring that it complies with the requirements of the GDPR. As such, this section outlines additional information relevant to residents of the European Union only. Please see the remainder of Clearline’s Privacy Policy for more information on our privacy practices.

Your Rights relating to your Personal Data

Subject to some exceptions, the GDPR provides you with the following rights:

  1. Right of access: You have the right to information about whether and why we process your personal data and related information (for example, what personal data we are processing).
  2. Right of rectification: You have the right to correct any inaccurate or incomplete personal data that we hold about you.
  3. Right to erasure: You have the right to ask us to delete personal data that we hold about you.
  4. Right to restrict or object to processing: You have the right to ask us to limit or stop our processing of your personal data in certain cases (for example, if the personal data we are processing about you is inaccurate or is for direct marketing purposes).
  5. Right to data portability: You have the right to ask us for a copy of personal data we hold about you and to transfer such data to another entity.
  6. Right to complain: We encourage you to contact us at the contact information above if you have any questions or concerns with our personal data practices. However, you also have the right to complain to regulatory authorities in your jurisdiction. Please contact us at the contact information above if you need information about the appropriate authority.

 

You may exercise these rights or find out more about these rights by contacting Clearline at the contact information listed above.

Retention and Storage of Personal Data

Clearline is based in Canada and processes personal data in Canada. The European Commission recognizes Canada as providing an adequate level of protection for personal data. Clearline’s service providers may process your personal information outside of Canada (please see above). When your information is processed outside of the European Union, it may be subject to the laws of and be accessible by legal authorities in such other jurisdictions. Clearline has taken appropriate technical, organizational, and legal steps to secure this information.

 

Additional Information For Residents of California

 

The California Consumer Protection Act of 2018 (CCPA) sets out obligations and rights with respect to the personal information of California consumers. Clearline is committed to ensuring that it complies with the requirements of the CCPA. As such, this section outlines additional information relevant only to individual’s accessing our services in California. Please see the remainder of Clearline’s Privacy Policy for more information on our privacy practices.

Your Rights relating to personal information

Subject to some exceptions, the CCPA provides you with the following rights:

  1. The right to know: You have the right to request that Clearline disclose what personal information is collected, used, shared or sold, both as to the categories and specific pieces of personal information.
  2. The right to opt-out: You have the right to say “no” to the sale of your personal information. Please note that Clearline does not sell or trade personal information.
  3. The right to delete: You have the right to request the deletion of your personal information held by Clearline and by extension Clearline’s service providers.
  4. The right to non-discrimination: Clearline is prohibited from discriminating against you in terms of price or service if you choose to exercise a privacy right under the CCPA.

 

Categories of personal information Clearline collects or discloses

 

Clearline may have collected and/or disclosed the following categories of personal information in the last twelve (12) months:

 

Category

Examples

Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifier.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Protected classification characteristics under California or federal law

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Biometric information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Internet or other electronic activity information

Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.

Geolocation data

Physical location, generally.

Sensory data

Audio, electronic, visual, thermal, olfactory or similar information.

Professional or employment-related information

Current or past job history or performance evaluations.

Education information

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Inferences drawn from other personal information

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

Categories of personal information Clearline has sold

 

Clearline does not sell personal information.