Ascendant Strategy Management Group d/b/a ClearPoint Strategy (“ClearPoint” or the “Company”) is committed to protecting the privacy of individuals who visit the Company’s Web sites (“Visitors”), individuals who register to use the Services as defined below (“Customers”), and individuals who register to attend the Company’s corporate events (“Attendees”). This Privacy Statement describes ClearPoint’s privacy practices in relation to the use of the Company’s Web sites and the related applications and services offered by ClearPoint Strategy (the “Services”). The related applications include, but are not limited to, ClearPoint, ClearPoint Sync, ClearPoint Data Loader, and the ClearPoint WordPress plugin.
1. Web sites covered
This Privacy Statement covers the information practices of Web sites that link to this Privacy Statement, including: https://www.clearpointstrategy.com and http://www.ascendantsmg.com (collectively referred to as “ClearPoint Strategy’s Web sites” or “the Company’s Web sites”).
ClearPoint Strategy’s Web sites may contain links to other Web sites. The information practices or the content of such other Web sites is governed by the privacy statements of such other Web sites. The Company encourages you to review the privacy statements of other Web sites to understand their information practices.
2. Information collected
When expressing an interest in obtaining additional information about the Services or registering to use the Services, ClearPoint Strategy requires you to provide the Company with personal contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”). When purchasing the Services, ClearPoint Strategy may require you to provide the Company with financial qualification and billing information, such as billing name and address, credit card number, and the number of employees within the organization that will be using the Services (“Billing Information”). ClearPoint Strategy may also ask you to provide additional information, such as company annual revenues, number of employees, or industry (“Optional Information”). Required Contact Information, Billing Information, and Optional Information about Customers are referred to collectively as “Data About ClearPoint Strategy Customers,” or in the case of Attendees, “Data About ClearPoint Strategy Attendees.”
As you navigate the Company’s Web sites, ClearPoint Strategy may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s Web sites (such as the Web pages viewed and the links clicked).
3. Use of information collected
The Company uses Data About ClearPoint Strategy Customers to perform the services requested. For example, if you fill out a “Contact Me” Web form, the Company will use the information provided to contact you about your interest in the Services.
The Company also uses Data About ClearPoint Strategy Attendees to plan and host corporate events, host online forums and social networks in which event attendees may participate, and to populate online profiles for Attendees on the Company’s Web sites. Additional information on the Company’s privacy practices with respect to Data About ClearPoint Strategy Attendees may be found in additional privacy statements on the event Web sites, as the case may be.
The Company may also use Data About ClearPoint Strategy Customers and Data About ClearPoint Strategy Attendees for marketing purposes. For example, the Company may use information you provide to contact you to further discuss your interest in the Services and to send you information regarding the Company, its affiliates, and its partners, such as information about promotions or events.
ClearPoint Strategy uses credit card information solely to check the financial qualifications and collect payment from prospective Customers and Attendees.
ClearPoint Strategy uses Web Site Navigational Information to operate and improve the Company’s Web sites. The Company may also use Web Site Navigational Information alone or in combination with Data About ClearPoint Strategy Customers and Data About ClearPoint Strategy Attendees to provide personalized information about the Company. For additional information about the use of Web Site Navigational Information, please see clause 5.
4. Data Retention
ClearPoint Strategy does not keep personal information for longer than is reasonably required, which will depend on the purposes for which it was received. Personal information will be retained as long as required by a relevant law (e.g. to ensure compliance with tax requirements); if required by any relevant contractual agreement; and for as long as is required to manage engagement with you.
5. Web Site Navigational Information
Cookies, Web Beacons and IP Addresses
ClearPoint Strategy uses commonly-used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Company’s Web sites (“Web Site Navigational Information”). This section describes the types of Web Site Navigational Information used on the Company’s Web sites and how this information may be used.
Targeting or Advertising cookies
Third parties, with whom the Company partners to provide certain features on our Web sites or to display advertising based upon your Web browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and manner in which data is stored.
ClearPoint Strategy uses Web beacons alone or in conjunction with cookies to compile information about Customers’ and Visitors’ usage of the Company’s Web sites and interaction with emails from the Company. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Web site tied to the Web beacon, and a description of a Web site tied to the Web beacon. For example, ClearPoint Strategy may place Web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s Web sites. ClearPoint Strategy uses Web beacons to operate and improve the Company’s Web sites and email communications.
When you visit ClearPoint Strategy’s Web sites, the Company collects your Internet Protocol (“IP”) addresses to track and aggregate non-personal information. For example, ClearPoint Strategy uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Web sites. ClearPoint Strategy also collects IP addresses from Customers when they log into the Services as part of the Company’s “Identity Confirmation” and “IP Range Restrictions” security features.
Do Not Track
Currently, various browsers – including Internet Explorer, Firefox, and Safari – offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Web sites visited by the user about the user’s browser DNT preference setting. ClearPoint Strategy does not currently commit to responding to browsers’ DNT signals with respect to the Company’s Web sites, in part because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. ClearPoint Strategy takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
6. Public forums, refer a friend, and customer testimonials
ClearPoint Strategy may provide bulletin boards, blogs, or chat rooms on the Company’s Web sites. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. ClearPoint Strategy is not responsible for the personal information you choose to submit in these forums.
Customers and Visitors may elect to use the Company’s referral program to inform friends about the Company’s Web sites. When using the referral program, the Company requests the friend’s name and email address. ClearPoint Strategy will automatically send the friend a one-time email inviting him or her to visit the Company’s Web sites. ClearPoint Strategy does not store this information.
ClearPoint Strategy posts a list of Customers and testimonials on the Company’s Web sites that contain information such as Customer names and titles. ClearPoint Strategy obtains the consent of each Customer prior to posting any information on such a list or posting testimonials.
7. Sharing of information collected
ClearPoint Strategy may share Data About ClearPoint Strategy Customers and Data About ClearPoint Strategy Attendees with the Company’s contracted service providers so that these service providers can provide services on our behalf. Without limiting the foregoing, ClearPoint Strategy may also share Data About ClearPoint Strategy Customers and Data About ClearPoint Strategy Attendees with the Company’s service providers to ensure the quality of information provided, and with third-party social networking and media Web sites, such as Facebook, for marketing and advertising on those Web sites. Unless described in this Privacy Statement, ClearPoint Strategy does not share, sell, rent, or trade any information with third parties for their promotional purposes.
ClearPoint Strategy Affiliates
The Company may share Data About ClearPoint Strategy Customers with other companies in order to work with them, including affiliates of the ClearPoint Strategy corporate group. For example, the Company may need to share Data About ClearPoint Strategy Customers for customer relationship management purposes.
From time to time, ClearPoint Strategy may partner with other companies to jointly offer products or services. If you purchase or specifically express interest in a jointly-offered product or service from ClearPoint Strategy, the Company may share Data About ClearPoint Strategy Customers collected in connection with your purchase or expression of interest with our joint promotion partner(s). ClearPoint Strategy does not control our business partners’ use of the Data About ClearPoint Strategy Customers we collect, and their use of the information will be in accordance with their own privacy policies. If you do not wish for your information to be shared in this manner, you may opt not to purchase or specifically express interest in a jointly offered product or service.
ClearPoint Strategy does not share Data About ClearPoint Strategy Attendees with business partners unless: (1) you specifically opt in to such sharing via an event registration form; or (2) you attend a Company event and have your attendee badge scanned by a business partner. If you do not wish for your information to be shared in this manner, you may choose not to opt in via event registration forms and elect not to have your badge scanned at Company events. If you choose to share your information with business partners in the manners described above, your information will be subject to the business partners’ respective privacy statements.
This Privacy Statement sets forth the information ClearPoint Strategy collects on the Company’s Web sites and the information we share with third parties. ClearPoint Strategy does not authorize the collection of personal information by third parties through advertising technologies deployed on the Company’s Web sites, nor do we share personal information with any third parties collected from the Company’s Web sites, except as provided in this Privacy Statement. Section 4 of this Privacy Statement, Web Site Navigational Information, specifically addresses the information we collect through cookies and web beacons, and how you can control cookies through your Web browsers.
ClearPoint Strategy uses a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on the Company’s behalf.
ClearPoint Strategy reserves the right to use or disclose information provided if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.
8. International transfer of information collected
The Company primarily stores Data About ClearPoint Strategy Customers and Data About ClearPoint Strategy Attendees in the United States. To facilitate ClearPoint Strategy’s global operations, the Company may transfer and access such information from around the world, including from other countries in which the Company has operations. This Privacy Statement shall apply even if ClearPoint Strategy transfers Data About ClearPoint Strategy Customers or Data About ClearPoint Strategy Attendees to other countries.
9. Communications preferences
ClearPoint Strategy offers Visitors, Customers, and Attendees who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of the Company’s marketing emails. Additionally, you may send a request specifying your communications preferences to email@example.com. Customers cannot opt out of receiving transactional emails related to their account with ClearPoint Strategy or the Services.
10. Correcting and updating your information
Customers may update or change their registration information by editing their user or organization record. To update a user profile, please login to https://app.clearpointstrategy.com with your ClearPoint Strategy username and password and click “My Profile.” To update Billing Information or have your registration information deleted, please email firstname.lastname@example.org or call +1 (866) 568-0590. To discontinue your account and to have information you maintained in the Services returned to you, please email email@example.com or call +1 (866) 568-0590.
11. Customer Data
ClearPoint Strategy Customers may electronically submit data or information to the Services for hosting and processing purposes (“Customer Data”). ClearPoint Strategy will not review, share, distribute, or reference any such Customer Data except as provided in the ClearPoint Strategy Master Subscription Agreement, or as may be required by law. In accordance with the ClearPoint Strategy Master Subscription Agreement, ClearPoint Strategy may access Customer Data only for the purpose of providing the Services or preventing or addressing service or technical problems or as may be required by law. Additional information about the Company’s privacy and security practices with respect to Customer Data is available upon request by contacting firstname.lastname@example.org.
ClearPoint Strategy uses robust security measures to protect Data About ClearPoint Strategy Customers and Data About ClearPoint Strategy Attendees. Because the Company uses the Services to maintain Data About ClearPoint Strategy Customers and Data About ClearPoint Strategy Attendees, this information, which is stored in the Services, is secured in the same manner as described here.
13. Changes to this Privacy Statement
ClearPoint Strategy reserves the right to change this Privacy Statement. ClearPoint Strategy will provide notification of the material changes to this Privacy Statement through the Company’s Web sites at least thirty (30) business days prior to the change taking effect.
14. Contacting us
Questions or complaints regarding this Privacy Statement or the information practices of the Company’s Web sites should be directed to ClearPoint Strategy Privacy by clicking here or by mailing ClearPoint Strategy Privacy, 75 Arlington Street, 5th Floor, Boston, MA 02116. If you are unsatisfied with how we address your complaint, you have the right to lodge a complaint with the relevant supervisory authority.