LAST UPDATED: 1/27/2020
Particularly Important Information
Who we are: For the purpose of applicable data protection legislation, the data controller of your personal data is Intego Co. of 579 Broadway, 2C, New York, New York 10012. Clyde is an Intego Co. brand.
Changes to this Policy: We will post any modifications or changes to the Policy on our Apps. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will notify you via email and/or post a notice on our Apps prior to such changes(s) taking effect.
1. COLLECTING YOUR PERSONAL DATA
We collect information about you in the following ways:
Sources. We collect personal data from the following sources:
Types of Information. We collect the following types of information:
Information Automatically Collected. We, our service providers and third party partners may automatically log information about you, your computer or mobile device, and your activity over time on our Apps and other online services, such as:
Some of our automatic data collection is facilitated by cookies and similar technologies. Please see Section 2 for more information.
2. COOKIES AND OTHER TRACKING TECHNOLOGIES
What are cookies?
We may collect information using “cookies.” Cookies are small data files placed on your computer when you visit a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Apps.
In addition to cookies, our Apps and emails may use pixel tags (also known as web beacons and clear GIFs) to compile statistics about use of the Services, measure the success of our marketing campaigns, and indicate whether recipients of our emails open or click links within them.
Cookies we use
Our Apps use the following types of cookies for the purposes set out below:
Type of cookies & purpose
These cookies are necessary to allow the technical operation of our Apps (e.g., they enable you to move around on a website and to use its features).
These cookies enhance the performance and functionality of our Apps.
These cookies help us understand how our Apps are performing and being used. These cookies may work with web beacons included in emails we send to track which emails recipients open and which links recipients click. We use Google Analytics for this purpose. Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies and about how Google protects your data here: www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our Apps by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
These cookies are used by advertising companies to collect information about how you use our Apps and other websites over time. These companies use this information to show you ads they believe will be relevant to you within our Apps and elsewhere, and to measure how the ads perform.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com/uk, or our Online Tracking Opt-out Guide.
If you do not accept our cookies, you may experience some inconvenience in your use of our Apps. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Apps.
3. DO NOT TRACK SIGNALS
Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.
4. USING YOUR PERSONAL DATA
We may use your personal data as follows:
Research and development:
Compliance, fraud prevention and safety:
5. SHARING YOUR PERSONAL DATA
We may share your personal data as follows:
6. ANONYMOUS, AGGREGATED OR DE-IDENTIFIED DATA
We may create anonymous, aggregated or de-identified data from the personal data we receive about you and other individuals whose personal data we collect. We make personal data into anonymous, aggregated or de-identified data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous, aggregated or de-identified data for our lawful business purposes.
7. USER GENERATED CONTENT
We may make available on our Apps or through our Service, or link to, features that allow you to generate your own content or share information online (e.g., on our blog). Please do not embed personal information in the content you generate or share personal information online in public forums, because any such information can be collected and used by others. We have no control over, and take no responsibility for, the use, storage, dissemination or erasure of personal information embedded in user-generated content or shared on the Sites. By posting personal information online in public, you may receive unsolicited messages from other parties. If you provide feedback to us, in a public forum or otherwise, we may use and disclose such feedback on our Apps/Services and/or feature it in case studies and white papers we create, provided we do not publicly associate such feedback with your personal data. If you have provided your consent to do so, we may post your first and last name along with your feedback on our Apps/Services.
8. INTERNATIONAL DATA TRANSFER
Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us or our service providers outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. We will take steps designed to ensure that your data is treated securely and in accordance with this Policy. We rely on the Privacy Shield, as described below, for transfers of data from the EU and Switzerland to Clyde in the United States.
9. EU-U.S. PRIVACY SHIELD AND SWISS-U.S. PRIVACY SHIELD
Clyde complies with the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Clyde (as Intego Co.) has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
In compliance with the Privacy Shield Principles, Clyde commits to resolve complaints about our collection or use of your personal information. European individuals with inquiries or complaints regarding our Policy should first contact Clyde at firstname.lastname@example.org. Clyde has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. If neither Clyde nor JAMS resolves your complaint, you may have the ability to engage in binding arbitration through the Privacy Shield Panel. Additional information on the arbitration process is available on the Privacy Shield website at www.privacyshield.gov.
Clyde may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. The Federal Trade Commission has jurisdiction over Clyde’s compliance with the Privacy Shield. Clyde’s commitments under the Privacy Shield Principles are subject to the investigatory and enforcement powers of the Federal Trade Commission.
We seek to use reasonable organizational, technical and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely 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 any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in Section 15 below.
We will only retain your personal data as long as reasonably required for you to use the Apps and/or to provide you with the Services unless a longer retention period is required or permitted by law (for example for regulatory purposes).
12. SENSITIVE PERSONAL DATA
We do not collect sensitive personal data as that term is defined by the GDPR (with respect to European users) or other applicable law.
13. JOB APPLICANTS
When you visit the careers portion of our website, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics, and as otherwise necessary in connection with legal disclosures.
14. YOUR RIGHTS
Depending on the jurisdiction in which you are located, you may have the following rights with respect to your personal data:
If you wish to submit a request to exercise any of these rights, please contact us using the details in Section 17 below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. Applicable law may require or permit us to decline your request. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and except as otherwise permitted by law, within one month of your request. Please note that we may need to retain certain information for regulatory or record keeping purposes, to complete any transactions that you began prior to requesting such change or deletion, or to continue to provide our Services. Applicable law may also require or permit us to decline your request.
We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us using the details in Section 15 below. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention, however, if you are located in Europe and you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority. You can find your data protection regulator here.
16. LEGAL BASES FOR PROCESSING
Please note that this section applies only to individuals located in Europe.
We have listed in the table below our legal bases for processing the personal data described in this Policy.
Details regarding each processing purpose listed below are provided in the section above titled “Using Your Personal Data”.
Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for or otherwise engaging with the Services.
In other cases, these activities constitute our legitimate interests.
Marketing, Research and development, Compliance, fraud prevention and safety
These activities constitute our legitimate interests. We do not use your personal information for these activities where the impact on you would override our interests (unless we have your consent or are otherwise required or permitted to by law).
Processing is necessary to comply with our legal obligations.
Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Service.
17. CONTACT INFORMATION
We welcome your comments or questions about this Policy. You may contact us in writing at email@example.com or 579 Broadway, 2C, New York, New York 10012.
18. NOTICE TO CALIFORNIA RESIDENTS
We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their personal Information, and of the rights and choices we offer California residents regarding our handling of their personal information.
Under the CCPA, this Notice to California Residents and the privacy practices and rights it describes do not apply to the information we collect, use or disclose about our business contacts, including Merchants and Insurers (and representatives of Merchants and Insurers).
Privacy Practices. We do not sell personal information. As we explain in our Policy:
Here is a description of our relevant privacy practices:
Please note that we may also disclose personal information to our affiliates and third party service providers, in connection with corporate restructuring, to comply with law, or for compliance, fraud prevention and safety purposes, as further described in Section 5 of our Policy.
Privacy Rights. Except as excluded above, the CCPA grants California residents the following rights:
Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.
You are entitled to exercise the rights described above free from discrimination.
How to Submit a Request. To request access to or deletion of personal information:
Identity verification. The CCPA requires us to verify the identity of the individual submitting a request to access or delete personal information before providing a substantive response to the request.
Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.
Online Tracking Opt-Out Guide
Like many companies online, we use services provided by Google, Facebook and other companies that use tracking technology. These services rely on tracking technologies – such as cookies and web beacons – to collect directly from your device information about your browsing activities, your interactions with websites, and the device you are using to connect to the Internet. There are a number of ways to opt out of having your online activity and device data collected through these services, which we have summarized below:
Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt-out on every browser and device that you use.
An individual’s physiological, biological or behavioral characteristics, including an individual’s deoxyribonucleic acid (DNA), that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Personal information from an educational record, which could include: a student’s name, the names of the student’s parent or other family members, the address of a student or student’s family, a student’s personal identifier (e.g., SSN, student number), other indirect identifiers of the student (e.g., date of birth, place of birth, mother’s maiden name), other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty, or information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates.
Bank account number, debit or credit card numbers, insurance policy number, and other financial information.
Precise location, e.g., derived from GPS coordinates or telemetry data
Real name, alias, postal address, unique personal identifier, customer number, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
The derivation of information, data, assumptions, or conclusions from any other category of Personal Information to create a profile about a person reflecting the person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
Internet or Network Information
Browsing history, search history, and information regarding a person’s interaction with an Internet website, application, or advertisement.
Personal information about an individual’s health or healthcare, including health insurance information. Does not include (a) medical information governed by California’s Confidentiality of Medical Information Act, (b) protected health information that is collected by a covered entity or business associate governed by the Health Insurance Portability and Accountability Act of 1996 or (c) information collected as part of certain clinical trials.
An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device.
An individual’s physical characteristics or description (e.g., hair color, eye color, height, weight).
Professional or Employment Information
This term is not defined in the CCPA, but likely includes any information relating to a person's current, past or prospective employment or professional experience (e.g., job history, performance evaluations).
Protected Classification Characteristics
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).
Audio, electronic, visual, thermal, olfactory, or similar information.