Clearleaf Crossing PRIVACY POLICY
Last updated: 8 December 2021
This Clearleaf Crossing Privacy Policy explains in detail how we collect, use, disclose, and protect your personal data. It also informs you about the choices that you have with respect to your personal data.
Please read this document carefully before submitting your personal data to us.
- GENERAL INFORMATION
- WHAT DATA DO WE COLLECT THROUGH THE WEBSITE?
- HOW LONG DO WE STORE YOUR DATA?
- HOW DO WE DISCLOSE YOUR DATA?
- HOW DO WE PROTECT YOUR DATA?
- HOW CAN YOU ACCESS AND MANAGE YOUR PERSONAL DATA?
- COOKIES
- CONTACT
1. GENERAL INFORMATION
Here you can find some general information about us and the Website.
1.1 What does this Privacy Policy cover? This inMotion Real Estate privacy policy (the “Privacy Policy”) governs the processing of personal data collected from individual users (“you” and “your”) through the website https://www.clearleafcrossingapts.com and the related domain names (collectively, the “Website”). The Privacy Policy does not cover any other websites, applications or software that integrate with the Website or any other third-party products and services (for example, our social media service providers that are linked to from the Website).
1.2 Who is the data controller? The Website is owned and operated by Clearleaf Crossing having an address at PO Box 504, Portsmouth, NH 03801, the United States (“we,” “us,” and “our”).
1.3 What is the Website about? The Website features information about the digital marketing and software development services provided by us and allows you to contact us.
1.4 Children. The Website is not intended for use by persons under the age of 18. Therefore, we do not knowingly collect children’s personal data. If you become aware that a child has provided us with his or her personal data and you are a parent or a legal guardian of the child, please contact us immediately and we will remove the child’s personal data from our systems.
1.5 Term and termination. This Privacy Policy enters into force on the date indicated at the top of the Privacy Policy (“Last updated”) and remains in effect until terminated or updated by us.
1.6 Amendments. We reserve the right to change this Privacy Policy from time to time. It may be necessary to address the changes in our business practices, functionalities of the Website, applicable laws, regulations, and industry standards. The amended version of the Privacy Policy will be posted on this page and, if we have your email address, we will send you a notification about the changes implemented by us. We encourage you to review our Privacy Policy regularly to stay informed. For significant material changes in the Privacy Policy or, where required by the applicable law, we may seek your consent.
2. WHAT DATA DO WE COLLECT THROUGH THE WEBSITE?
Here we explain in detail what personal data we collect from you, for what purposes we use it, what technical data is collected automatically when you use The Website, and how we communicate with you.
2.1 From what sources do we get your personal data? We obtain your personal data from the following sources:
Directly from you: for example, if you submit your personal data when you contact us;
Directly or indirectly through your activity on the Website: when you use the Website, we automatically collect technical information about your use of the Website; and
From third parties: we may receive information about you from third parties to whom you have previously provided your personal data, if those third parties have a legal basis for disclosing your personal data to us (for example, for payment processing purposes).
2.2 What personal data do we collect? We comply with data minimisation principles. This means that we collect only a minimal amount of personal data that is necessary for your use of the Website. We use your personal data for limited, specified and legitimate purposes explicitly mentioned in this Privacy Policy. In general, your personal data is used for the purposes of providing you with access to the Website, maintaining and improving the Website, replying to your enquiries, and pursuing our legitimate interests. We do not re-purpose your personal data. This means that we do not use it for any purposes that are different from the purposes for which your personal data was provided. Below, you can find an overview of the types of personal data that we collect, the purposes for which we use it, and the legal bases on which we rely when processing it.
Enquiries. When you contact us by email, we collect your name, email address, and any information that you decide to disclose in your message. When you contact us by using the ‘Contact Us’ functionality available on the Website, we collect your name, email address, company name, phone number, and any information that you decide to include in your message. We use such data to respond to your enquiries and provide you with the requested information. The legal bases on which we rely are ‘pursuing our legitimate interests’ (i.e., to maintain and grow the Website) and ‘your consent’ (for optional personal data). We will store this data until you stop communicating with us.
Cookies. When you browse the Website, we or our third-party analytics service provider (as explained in below) collect your location and cookie-related data. We use such information to analyse the technical aspects of your use of the Website, prevent fraud and abuse, and ensure the security of the Website. For more information on our use of cookies, please refer to section 7 “Cookies”. The legal bases on which we rely are ‘pursuing our legitimate interests’ (i.e., to analyse our content and protect the Website) and ‘your consent’. We will store this data as long as analytics records are necessary for our activities or you withdraw your consent (if you have provided one).
2.2 Do we collect sensitive data? We do not collect or use any special categories of personal data (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data refers to your health, religious and political beliefs, racial origins, membership of a professional or trade association, or sexual orientation.
2.3 What happens if you refuse to provide your personal data? If you decide not to provide us with your personal data when we ask for it, we may not be able to perform the requested operation (for example, reply to you) and you may not be able to use the full functionality of the Website. Please notify us immediately if you think that any personal data that we collect is excessive or not necessary for its intended purpose.
2.4 Do we collect analytics data? Yes. When you browse the Website, we collect or have access to certain technical analytics data collected from you. Such data includes the following information:
- Your activity on the Website (time of visit, pages visited, products viewed, time spent on each page, clicks, scroll depth, interaction with widgets);
- URL addresses from which you access the Website;
- Your browser type and version;
- Your operating system;
- Your device details;
- Information about your orders; Your other online behaviour; and
- Cookies-related data, as explained in section 7 “Cookies”.
2.5 For what purposes do we use analytics data? We use your analytics data to analyse what kind of users access and use the Website, measure your engagement with the Website, see which products are interesting to you, improve our content, develop new products and services, and investigate and prevent security issues and abuse. In most cases, such analytics data is non-personal and it does not allow us to identify you as a natural person. However, some of such data like your IP address may be considered personal data and we will make sure that we have the necessary legal basis for processing such data. When we process your analytics data that is personal data, we rely on the ‘legitimate interest’ (i.e., to analyse and improve the Website) and ‘your consent’ bases.
2.6 Do we keep your feedback? If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and the response. Where possible, we will de-identify your personal data (i.e., we will remove all personal data that is not necessary for keeping such records).
2.7 What happens if we aggregate or de-identify your data? In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you as an individual, we will handle such aggregated data as personal data. If your personal data is de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any legitimate purpose.
2.8 When will you receive our commercial communication? We send you our commercial communication only if submit the “Contact Us” form available on the Website or subscribe to our newsletter. In such cases, you will receive information about our services, features of the Website, and special offers. The legal bases on which we rely are ‘your consent’ or ‘pursuing our legitimate interests’ (i.e., to grow the Website). At any time, you can opt-out from receiving our commercial communication free of charge by clicking on the “unsubscribe” link included in our newsletters or by contacting us directly.
3. HOW LONG DO WE STORE YOUR DATA?
Here we explain for how long we keep your data in our systems and how we delete it.
3.1 For how long do we store your personal data? We and our data processors listed in section 4 below store your personal data only for as long as such personal data is required for the purposes described in this Privacy Policy or until you request us to update or delete your personal data, whichever comes first. For more details about the period for which each type of personal data is stored, please refer to section 2.2. After your personal data is no longer necessary for its purposes and we do not have other legal basis for storing it, we will immediately securely delete your personal data from our systems. We do not store any personal data longer than strictly necessary.
3.2 For how long do we store your non-personal data? We retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include storing non-personal data for the period of time needed for us to examine our business activities, fulfil our contractual obligations, pursue our legitimate interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
3.3 When are we obliged by law to store your personal data? In very rare cases when we are obliged by law to store your personal data for a certain period of time, we will store your personal data for the time period stipulated by the applicable law and securely delete the personal data as soon as the required retention period expires.
4. HOW DO WE DISCLOSE YOUR DATA?
Here you can find information about third parties that may have access to your personal data.
4.1 When do we disclose your personal data? We keep your personal data in strict confidentiality. However, if necessary for the intended purpose of your personal data, we will disclose your personal data to entities that provide services on our behalf or support us in our business (our data processors). Your personal data may be shared with entities that provide technical support services to us, such as hosting, analytics, and email distribution services. We do not sell your personal data to third parties and do not intend to do so in the future. The disclosure of your personal data is limited to the situations when it is required for the following purposes:
- Ensuring the proper operation of the Website;
- Responding to your enquiries;
- Pursuing our legitimate interests;
- Enforcing our rights, preventing fraud, and security purposes;
- Carrying out our contractual obligations;
- Law enforcement purposes; or
- If you provide your prior consent to such a disclosure.
- 4.2 Who has access to your personal data? We choose our data processors carefully and make sure that they ensure an adequate level of protection of personal data that is consistent with this Privacy Policy and the applicable data protection laws. The data processors that will have access to your personal data are:
- Our hosting service provider MediaTemple located in the United States;
- Our cloud storage service provider Digital Ocean located in the United States;
- Our newsletter service provider ActiveCampaign located in the United States;
- Our analytics service provider Google Analytics located in the United States; and
- Our independent contractors and consultants.
4.3 Do we transfer your personal data outside the EEA? Some of our data processors are based outside the European Economic Area (EEA). If you are a resident of a country belonging to the EEA, we may need to transfer your personal data outside your country. In case it is necessary to make such a transfer, we will make sure that the country in which our data processor is located guarantees an adequate level of protection for your personal data or we conclude an agreement with it that ensures such protection (e.g., a data processing agreement based pre-approved standard contractual clauses).
4.4 Do we disclose your non-personal data? Your non-personal data may be disclosed to third parties for any purpose as it does not identify you as a natural person. For example, we may share it with prospects or partners for business or research purposes, for improving the Website, responding to lawful requests from public authorities or developing new products and services.
4.5 What happens if we receive a legal request? If requested by a public authority, we will disclose information about the users of the Website to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.
5. HOW DO WE PROTECT YOUR DATA?
Here you can find information on how we protect your data against breaches.
5.1 What security measures do we use? We implement technical and organisational information security measures that protect your personal data from loss, misuse, unauthorised access and disclosure. The security measures taken by us include secured networks, SSL certificate, strong passwords, limited access to your personal data by our staff, anonymisation of personal data (when possible), regular updates, and carefully selected data processors.
5.2 What happens if a security breach occurs? Although we put our best efforts to protect your personal data, given the nature of communication and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.
6. HOW CAN YOU ACCESS AND MANAGE YOUR PERSONAL DATA?
Here you can find detailed information about the rights that you have with regard to your personal data and how to exercise those rights.
6.1 What rights do you have? You have the right to control how we process your personal data. Subject to any exemptions provided by law, you have the following rights:
- Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;
- Right to rectification: you can rectify inaccurate personal data that we hold about you;
- Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our systems;
- Right to restriction: you can ask us to restrict the processing of your personal data;
- Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor;
- Right to object: you can ask us to stop processing your personal data;
- Right to withdraw consent: you have the right to withdraw your consent, if you have provided one; or
- Right to complaint: you can submit your complaint regarding our processing of your personal data.
6.2 How to exercise your rights? If you would like to exercise any of your legitimate rights, please contact us by using our contact details available at the end of the Privacy Policy and explain in detail your request. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information, so that we can identify you in our system. We will answer your request within a reasonable time frame but no later than 30 days.
6.3 Launching an official complaint? If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible (no later than 30 days). If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
7. COOKIES
7.1 What should you know about cookies? A cookie is a small piece of data typically consisting of letters and numbers. When you visit a website, that website may send a cookie to your browser. As a result, the browser may store the cookie on your computer or mobile device for some time (cookie expiration date depends on its type). Cookies are used to recognise your device and collect certain information about your use of websites. Thus, over time, cookies allow websites to “remember” your actions and preferences. There are several types of cookies: (i) persistent cookies that remain valid until deleted by you, (ii) cookies that remain valid until their expiration date, and (iii) session cookies that are stored on a web browser and remain valid until the moment the browser is closed. Cookies may also be (i) first-party cookies (set by the original website itself) and (ii) third-party cookies (placed by third-party websites).
7.2 What cookies do we use on the Website? You can find the list of our cookies below. We use different types of cookies on the Website, including:
- Essential technical cookies that are strictly necessary to ensure the correct functioning of the Website and provide the services requested by you. You cannot decline such cookies; and
- Statistics cookies that allow us to generate statistical reports about how you use the Website.
7.3 Do you need to provide your consent? When you visit the Website, you may be presented with a cookie consent banner (for example, if we see that you are based in the EU). In the banner, we will ask you to provide us with your consent to our use of all cookies. If you do not provide your opt-in consent for all our cookies, we will serve you our essential technical cookies only. Please note that we may not be able to provide you with the best possible user experience on the Website if not all cookies are enabled.
7.4 How to disable cookies? When we ask you to provide your consent to our use of non-essential cookies, you have the freedom not to provide such consent. If you would like to refuse our use of non-essential cookies later, you can do it at any time by declining cookies in your browser or device. For more information, you can consult the cookie management instructions of your browser:
- Apple Safari: https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac
- Google Chrome: https://support.google.com/chrome/answer/95647
- Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- Opera: https://blogs.opera.com/news/2015/08/how-to-manage-cookies-in-opera/
- Microsoft Edge: https://support.microsoft.com/en-us/help/4468242/microsoft-edge-browsing-data-and-privacy-microsoft-privacy
7.5 Google Analytics. We use Google Analytics, a web analytics service provided by Google LLC, registered at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google generates statistical information by means of cookies and creates reports about your use of the Website. The cookies served by Google are anonymous first-party cookies that do not allow us to identify you in any manner. The information generated by cookies will be transmitted to and stored by Google on servers in the United States. To ensure your privacy, your IP address will be anonymised and Google will not combine your IP address with other information Google holds about you. Thus, Google will not be able to identify you. In certain cases (e.g., when required by law or when third parties conduct services on behalf of Google), Google may transfer the information to third parties. For more information about Google Analytics’ privacy practices, please visit https://support.google.com/analytics/answer/6004245. If you would like to opt out from Google Analytics, you can do so by installing a Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout?hl=en.
7.6 Targeted advertising. You may encounter targeted interest-based advertising based on your use of the Website and other websites on the Internet. Where necessary, we will seek your consent. You can control how such advertising is shown to you or opt-out from targeted advertising by consulting the guide powered by the Digital Advertising Alliance available at https://youradchoices.com. For more information on opting-out from advertising features on your device, please visit https://www.networkadvertising.org .
8.CONTACT
If you have any questions about this Privacy Policy, your rights, or our data protection practices, please contact us by using the following contact details:
Our contact form: https://www.clearleafcrossingapts.com/contact-us
Postal address: Clearleaf Crossing, 501 Silkwood Dr, Bryan, TX 77803, the United States