Introduction

Your privacy is important to CLEAResult Consulting Inc. and its corporate affiliates (Collectively, “CLEAResult”). This Privacy Policy explains how CLEAResult collects, uses, discloses and retains personal information, including information collected through the CLEAResult website.

 

Table of Contents

  1. Application
  2. Your Consent
  3. Personal Information
  4. How CLEAResult Collects Personal Information
  5. How CLEAResult Uses Personal Information
  6. How CLEAResult Discloses Personal Information
  7. Your Right to Withdraw Consent
  8. Location of Personal Information
  9. Retention of Personal Information
  10. Protection of Personal Information
  11. Accuracy and Access to Personal Information
  12. Non-Personal Information
  13. Other Websites and Businesses
  14. Social Media
  15. Children and Personal Information
  16. Other Matters
  17. Contacting CLEAResult

 

1.     Application

This Privacy Policy applies if you are a customer who uses our products and services, a user who visits our website, or a job applicant who applies for a career opportunity with us.

In some cases, at the time of collection of your personal information, we may provide you with additional information regarding the processing of your personal information. We may also obtain your specific consent in certain circumstances to use or share your personal information, including where required by law.

2.     Your Consent

By providing CLEAResult with your personal information, you consent to the collection, use, disclosure and retention of that information by CLEAResult in accordance with this Privacy Policy and as otherwise permitted by applicable law. You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to CLEAResult, but then you might not be able to proceed with your intended interactions or transactions with CLEAResult or otherwise receive the full benefit of CLEAResult’s products and services.

Please refer to Section 7 of this Privacy Policy to learn about your options for withdrawing your consent.

3.     Personal Information

In this Privacy Policy, “personal information” means information about an identifiable individual (a natural person), but does not include (to the extent permitted by applicable law) information that is publicly available in a telephone directory, business contact information that enables an individual to be contacted at a place of business, and other kinds of information that are not subject to regulation by Canadian personal information protection or privacy laws.

4.     How CLEAResult Collects Personal Information

(a)    Information You Provide

You may be asked to voluntarily give your personal information to CLEAResult when you interact with CLEAResult, including when you subscribe to receive marketing offers from us, request information or use a product or service provided by CLEAResult. In those circumstances, you can choose not to provide certain requested personal information, but then you might not be able to proceed with your intended interaction or transaction with CLEAResult or otherwise receive the full benefit of the desired service.

For example, CLEAResult may collect:

  • contact information (such as name, email address, postal address and phone number) and any other option information you provide when you make an inquiry or contact us;
  • contact information when you use a product or service from us;
  • contact information, employment information (such as education and employment history) and government-issued identification (such as social security number, passport number, and driver’s license information) when you apply for an employment opportunity with CLEAResult; and
  • contact information, communications preferences and correspondence you send to us.

In those circumstances, you can choose not to provide certain requested personal information, but then you may not be able to purchase products or services or access or use certain features of the CLEAResult website, or otherwise receive the full benefit of CLEAResult’s products and services.

If you give CLEAResult the personal information of another individual, then you are solely responsible for complying with all applicable laws, including obtaining the individual’s valid consent, regarding your collection and disclosure of the personal information to CLEAResult and to CLEAResult’s use, disclosure and retention of the personal information.

(b)    Automated Collection

CLEAResult may use technologies to automatically collect certain information regarding your use of the CLEAResult website or online services, such as the dates and times that you access a CLEAResult website or an online service, general geographic location, the browsers, operating systems, software, devices and networks that you use to access the website or online service and details of your use of the website or online service.

CLEAResult’s website, online services, email messages, and advertisements may also use technologies (e.g. cookies, web beacons, tokens, pixels or tags) to automatically collect information that assists CLEAResult to improve its products, services, customer communications and advertising and to prevent fraud.

Some of the information automatically collected by technological means is non-personal information (because the information does not identify you), and CLEAResult will deal with that non-personal information as explained below in this Privacy Policy unless applicable law requires otherwise.

(c)    Information from Other Sources

CLEAResult may collect personal information from various third party sources (including providers that perform background checks on job applicants) and from publicly available sources (including criminal and educational history).

5.     How CLEAResult Uses Personal Information

(a)    General

CLEAResult may use your personal information for various purposes in connection with its relationship and transactions with you and as otherwise set out in this Privacy Policy or permitted by applicable law, including:

  • to contact and correspond with you regarding your transactions and your use of CLEAResult’s website, products and services and to provide you with customer care services;
  • to facilitate your interactions and transactions with CLEAResult;
  • to provide products and services to you;
  • to process and respond to your inquiries, requests and other communications (including to process your job application);
  • to provide you with information (including by email and other electronic messages) regarding CLEAResult and its products and services and the products and services offered by other businesses,
  • to the extent permitted by applicable law;
  • to maintain, protect and improve CLEAResult’s website, products and services and to develop new websites, products and services;
  • to develop, deliver and improve CLEAResult’s advertising and marketing;
  • to determine whether you are eligible to participate in certain programs and to track and report your participation accordingly; and
  • to protect and enforce CLEAResult’s legal rights, interests and remedies and to protect the business, operations and customers of CLEAResult or other persons.

CLEAResult may transfer your personal information to its suppliers and service providers to assist CLEAResult in the provision of website, products and services to you, to provide services to CLEAResult, to assist CLEAResult to use your personal information (e.g. providing marketing campaigns, analytic services, and data hosting) as set out in this Privacy Policy and as otherwise permitted by applicable law.

CLEAResult may combine your personal information collected by CLEAResult through various sources.

CLEAResult may use your personal information to create non-personal information, and CLEAResult may then use, disclose, transfer and retain the non-personal information as set out below in this Privacy Policy.

(b)    Information Collected by Technological Means

CLEAResult may use information collected by technological means to recognize you as a user of CLEAResult’s website, to facilitate and improve your use of CLEAResult’s website and online services, to confirm that messages have been delivered to and opened by you and to provide you with targeted advertisements. CLEAResult may use web beacons, pixels or gif tags and action tags to confirm that email messages have been delivered and opened. You may opt out of receiving emails or other commercial electronic messages in accordance with this Privacy Policy.

Information provided by cookies may be collected and processed by CLEAResult or by its third party service providers, including Google.

You may choose to decline or disable cookies if your web browser or device permits, but doing so may affect your ability to access or use certain features of a website. Information about how Google uses cookies and how you can limit or disable certain kinds of cookies on your personal computer or mobile device is available here: https://www.google.com/policies/privacy/partners/ and https://www.google.com/policies/technologies/ads/.

(c)    Interest-Based Advertising

CLEAResult may use interest-based advertising services (sometimes called “remarketing” or “retargeting”) provided by third party vendors (such as Google) to display advertisements on third party websites and social media sites visited by users of CLEAResult’s website or online services. Advertising vendors (such as Google) use cookies, pixels or tokens – unique identifiers of a web browser on a specific computer that are installed on the computer when it accesses CLEAResult’s website and online services – to display ads based on the computer’s past access to CLEAResult’s website and online services. You can opt-out of Google’s use of cookies as indicated in section 4(b) of this Privacy Policy. You can also opt out of a remarketing vendor’s use of cookies by visiting the Network Advertising Initiative’s consumer opt-out page (https://optout.networkadvertising.org/?c=1).

(d)    Do Not Track

CLEAResult does not respond to do not track signals.

6.     How CLEAResult Discloses Personal Information

(a)    General

CLEAResult discloses your personal information for purposes relating to or arising from your relationship and transactions with CLEAResult and as otherwise set out in this Privacy Policy or permitted by applicable law.

(b)    Specific Consents

CLEAResult may disclose your personal information in accordance with express or implied consents that you give during your interactions and transactions with CLEAResult.

(c)    Affiliates

CLEAResult Consulting Inc. and its corporate affiliates may share your personal information with each other and use it in the provision of website, products and services to you, in accordance with this Privacy Policy.

(d)    Business Partners and Other Third Parties

In some circumstances, CLEAResult may share your personal information with its business partners, such as business partners who provide certain programs that may be of interest to you, and other third parties. CLEAResult will only disclose your personal information to a third party if CLEAResult has your consent to do so, if you have provided your consent to the third party, or if CLEAResult is legally required or permitted to do so.

(e)    Law Enforcement/Legal Disclosures

CLEAResult may disclose your personal information as required or authorized by applicable law, including to comply with a subpoena, warrant or court or arbitral order or litigation disclosure obligation. CLEAResult may disclose your personal information to law enforcement agencies or other independent organizations if CLEAResult reasonably believes the disclosure is necessary or appropriate in connection with national security, law enforcement or other issues of public importance, or if CLEAResult reasonably believes the disclosure is necessary or appropriate to protect and enforce CLEAResult’s legal rights, interests and remedies or to protect the rights, interests, business, operations or customers of CLEAResult or other persons (including to detect and prevent fraud and other illegal activities, to enforce any of the terms of use, terms of service or other agreements that govern access to or use of any of CLEAResult’s websites, products and services). The use, disclosure and retention of the disclosed information by those agencies, independent organizations or other persons is not subject to this Privacy Policy.

(f)    Business Transactions

CLEAResult may disclose your personal information in connection with a proposed or actual business transaction in which CLEAResult is involved (e.g. a corporate amalgamation, reorganization, merger or acquisition, or the sale or transfer of some or all of CLEAResult’s business or assets), but CLEAResult will require the information recipient to agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy and applicable law.

CLEAResult has no control over, or responsibility or liability for, the use, disclosure or retention of your personal information by the persons and organizations to whom CLEAResult discloses your personal information as set out above.

7.     Your Right to Withdraw Consent

You may withdraw your consent to CLEAResult’s collection, use, disclosure and retention of your personal information as set out in this Privacy Policy at any time, subject to legal or contractual restrictions and reasonable notice. To withdraw your consent, you may contact us at the contact information set out at the end of this Privacy Policy.

If you withdraw your consent to the collection, use, disclosure and retention of your personal information for purposes that are integral to the provision of CLEAResult’s website, products and services, then you might not be able to proceed with your intended interactions or transactions with CLEAResult or otherwise receive the full benefit of CLEAResult’s website, products and services.

If you withdraw your consent to the collection, use, disclosure and retention of your personal information for additional purposes that are not integral to the provision of CLEAResult’s products and services (e.g., to send advertising and marketing messages to you, and to administer and facilitate your participation in promotions) then withdrawing your consent for those purposes will not affect the provision of CLEAResult’s website, products and services to you.

8.     Location of Personal Information

CLEAResult and its service providers may process, store and use your personal information at facilities in Canada, and the United States and other countries. The personal information protection laws of those other countries might be different from the laws of the jurisdiction in which you reside, and might permit courts, government, law enforcement agencies, regulatory agencies and security authorities to access your personal information without notice. By providing your personal information to CLEAResult, you consent to the transfer of the personal information to facilities located in other countries and the processing and storage of the personal information at those facilities.

9.     Retention of Personal Information

CLEAResult will retain your personal information for the period reasonably necessary for the purposes set out or referenced in this Privacy Policy and to comply with CLEAResult’s legal obligations or enforce or protect CLEAResult’s legal rights, or a longer period required or permitted by applicable law. CLEAResult will delete or dispose of your personal information, or anonymize the information, when CLEAResult is no longer reasonably required to retain the information for the purposes set out or referenced in this Privacy Policy.

10.     Protection of Personal Information

CLEAResult uses reasonable safeguards – including administrative, physical and technical security and safeguarding measures – appropriate to the sensitivity of the personal information in CLEAResult’s possession or under CLEAResult’s control to help protect the information from unauthorized access, collection, use, disclosure, deletion or similar risks. Nevertheless, security risks cannot be eliminated and CLEAResult cannot guarantee that your personal information will not be accessed, used, disclosed or deleted in ways not otherwise described in this Privacy Policy. CLEAResult implements a combination of measures to protect your personal information, including:

  • Internal policies and procedures that define the roles and responsibilities of our employees throughout the information life cycle and limits their access to such information on a “need-to-know” basis;
  • If information is collected or stored in electronic format, technical safeguards such as encryption, firewalls, passwords, antivirus software and similar measures;
  • A designated Privacy Officer to monitor CLEAResult’s compliance with applicable privacy laws;
  • Employee privacy and data security training;
  • Procedures for receiving, investigating and responding to complaints or inquiries regarding CLEAResult’s information handling practices; and
  • Framework governing the retention and destruction of personal information.

[NTD: Under the amended Quebec’s Private Sector Act, CLEAResult will be required to make available on its website “detailed information” about its data governance policies and practices. This amendment comes into force on September 22nd, 2023. While there is some uncertainty regarding the level of detail that must be provided, the section above illustrates the types of information that could be required in order to comply with this new requirement.]

11.     Accuracy and Access to Personal Information

CLEAResult will rely on you to ensure that the personal information you provide to CLEAResult is as accurate, complete and up to date as necessary for the purposes for which CLEAResult uses the personal information. You will promptly notify CLEAResult of any changes to the personal information you provide to CLEAResult using the procedures made available for that purpose by CLEAResult or by contacting CLEAResult’s Privacy Officer using the contact information noted below.

You may reasonably request access to your personal information collected by CLEAResult and information about CLEAResult’s use, disclosure and retention of the personal information by submitting a written request to CLEAResult’s Privacy Officer using the contact information noted below. Subject to applicable exceptions and limitations prescribed by applicable law, you will be given reasonable access to your personal information and you will be entitled to verify the accuracy and completeness of your personal information and have the information corrected as appropriate. You may be required to pay a reasonable fee for access to your personal information. CLEAResult may decline to process an access request that is unreasonably repetitive, frivolous, vexatious or impracticable, or if CLEAResult reasonably believes that the requested access would infringe or jeopardize the privacy of other persons, or violate any applicable law or legal requirement, or for other reasons permitted by applicable law.

Depending on the jurisdiction where you reside, you may also be entitled to request the rectification of your personal information if our collection, disclosure or retention of such information is not authorized by law.

12.     Non-Personal Information

CLEAResult may use your personal information to create and collect non-personal information (information that is not about an identifiable individual), including personal information that has been aggregated or otherwise anonymized so that the information no longer relates to an identifiable individual. CLEAResult may use, disclose, transfer and retain non-personal information for any purpose and in any manner whatsoever. If non-personal information is combined with personal information, then CLEAResult will treat the combined non-personal information as personal information for the purposes of this Privacy Policy for as long as the non-personal information is combined with the personal information.

13.     Other Websites and Businesses

The CLEAResult website and correspondence (including emails and messages) may include advertisements for products and services offered by independent businesses or links to websites operated by independent businesses. CLEAResult has no responsibility or liability for, or control over, those other independent businesses, their websites, products or services, or their collection, use, disclosure or retention of your personal information. This Privacy Policy does not apply to the collection, use, disclosure and retention of your personal information by independent businesses or through independent websites or online services. If you have questions about how those independent businesses or their websites or online services collect, use, disclose or retain personal information, please contact the owner or operator of the independent businesses, websites and services.

14.     Social Media

When you use certain aspects of the CLEAResult website or other services to post information to social media sites the personal information that you post or share in connection with the social media sites is visible to other persons and can be read, collected, used and disclosed by other persons, including to send unsolicited messages. Any information provided to a social media sites and other sites is governed by their own privacy policies. You are solely responsible for the personal information that you choose to post or share in those situations. CLEAResult has no control over, or responsibility or liability for, the use, disclosure, and retention of the personal information that you disclose in those situations, and the use, disclosure, and retention of the disclosed information is not subject to this Privacy Policy.

15.     Children and Personal Information

CLEAResult does not knowingly collect personal information from children under 13 years of age without the consent of a legal guardian. If CLEAResult learns that CLEAResult has collected or received personal information from a child where parental or guardian consent was required, CLEAResult will delete that information unless the parent or guardian provide the required consent. If you believe CLEAResult might have any information from or about a child where parental or guardian consent was required, please contact CLEAResult’s Privacy Officer using the contact information set out at the end of this Privacy Policy.

16.     Other Matters

(a)     Disclaimers, Liability Exclusions/Limitations and Disputes: The agreements (including any website terms of use, terms of service or other agreements) that you accept when you apply, register for, order or use CLEAResult’s website, products and services contain important provisions, including provisions disclaiming, limiting or excluding the liability of CLEAResult and other persons (including service providers) and provisions determining the applicable law and jurisdiction for the resolution of disputes. To the extent permitted by applicable law, each of those provisions applies to any dispute that may arise in relation to this Privacy Policy or CLEAResult’s collection, use, disclosure and retention of your personal information, and are of the same force and effect as if they were reproduced directly in this Privacy Policy. Nothing in this Privacy Policy amends any of those other agreements.

Changes to this Privacy Policy:  CLEAResult may change this Privacy Policy from time to time by posting a new version of this Privacy Policy on the CLEAResult website. CLEAResult’s collection, use, disclosure and retention of your personal information will be governed by the version of this Privacy Policy in effect at that time. Your continued dealings with CLEAResult after any change to this Privacy Policy will signify your consent to the collection, use, disclosure and retention of your personal information by CLEAResult as set out in the changed Privacy Policy. Accordingly, you should check the “Last Updated” date of this Privacy Policy (at the top of this Privacy Policy) and review any changes since the last version.

(b)     English Language: You and CLEAResult have each expressly requested and required that this Privacy Policy and all other related documents be drawn up in the English language. Les parties conviennent et exigent expressément que cette Politique de confidentialité et tous les documents qui s’y rapportent soient rédigés en anglais.

(c)     Notices to You: You consent to CLEAResult sending you emails (to the email addresses you provide to CLEAResult) regarding this Privacy Policy and related matters and as otherwise permitted by applicable law.

17.     Contacting CLEAResult

If you have any comments or questions about this Privacy Policy or how CLEAResult handles your personal information, please contact CLEAResult’s Privacy Officer by email at: <[email protected]>.

                                                                                              ________________________________________________________________________