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CLEARSALE PRIVACY POLICY

We are committed to communicating with you in a professional manner and protecting your confidential information. We use the information you provide (e.g. name, address, phone number, email, etc.) to contact you to share information about our (products/services). We will not share your information with any third party outside of our organization, other than as necessary to fulfill your request. This company does not sell, trade or rent your personal information to others. See below for further information.

CLEARSALE SOLUTION PRIVACY POLICY
WEBSITE PRIVACY POLICY

CLEARSALE SOLUTION PRIVACY POLICY


ClearSale Services

ClearSale LLC (“us,” “we,” “ClearSale,” or “our”) offers a fully outsourced fraud management solution that provides merchants (“Merchant”) with a recommendation to either “approve” or “deny” online transactions, in order to prevent fraudulent online transactions (“Fraud Prevention,” “Service”).

Merchants integrate our Fraud Prevention on their eCommerce websites, mobile apps, or Mail Order Telephone Order (MOTO) operations (“Sales Platform”), where consumers like you place orders. After you place an order, the Sales Platform may request that we process your personal data to provide our services.

This Privacy Policy (“Policy”) explains the privacy practices of ClearSale LLC, on behalf of ourselves and for the benefit of our affiliates (“ClearSale,” “we,” “our,” or “us”) for our Fraud Prevention service. It describes how we collect, use, and share personal information, and the rights and options available to you with respect to your information.

You are not obligated by law to provide us with your personal data, but the Sales Platform may require that you provide us with your personal data to enable the processing of orders you place. Please note that this Policy does not cover the practices or policies of Merchants, the Sales Platform, or other parties.


Information Collection and Use

We collect information regarding your transactions, including data about your device, geolocation, cross-referenced data, and other analytical points. We use the information first and foremost to analyze whether a transaction is fraudulent.

As a Data Controller, we rely on our legitimate interests to process your information, including the use of our third-party service providers assisting us to deliver the Fraud Prevention. We may also receive your explicit consent through the Sales Platform. The Sales Platform relies on its valid legal basis for processing your information, which may be in the form of consent, legitimate interest, or execution of a contract.

The Sales Platform may, at its discretion, use ClearSale’s fraud assessment to make a decision on whether to accept or decline your order. It may do so if you have given your consent, if needed, to enter into or perform a contract, or if authorized by law.

We also use the information we collect for the following purposes:

  • Improving and enhancing Fraud Prevention and developing new services;
  • Statistical analyses of consumers’ activities;
  • Handling your requests and complaints;
  • Enforcing this Policy and preventing misuse of the Fraud Prevention; and
  • Any other action that may be mandated by law or undertaken to protect our legal rights and property and/or those of third parties.

Types of Data Collected

When you place an order with the Sales Platform, we collect various data regarding your transaction, which may include personal information such as your name, e-mail, address, the items you purchased, price paid, shipping information, and (if you have one) basic information from your account on the Sales Platform. We also collect basic information about your payment and billing method. We do not collect or keep your complete credit card number.

We may also collect information about how the Sales Platform is accessed and used (“Usage Data”). This Usage Data may include, but is not limited to, information such as your computer’s Internet Protocol (IP) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, location data, and other diagnostic data.

If you have provided a Merchant or the Sales Platform with access to information on third-party platforms (including social networks), then we may also receive the same access permissions to the information that you made public. In some circumstances, we may combine your information with information acquired from publicly available data sources or contract with third parties for cross-referencing. Some of these third-party providers may use the data we share with them for their own purposes, in accordance with their own terms and conditions.

If you contact us for questions or complaints, or if we contact you to confirm any transactional data, we will collect the information related to your inquiry and verify your identity. This may include, but is not limited to, your name, e-mail address, postal address, telephone number, and other contact information.


Transfer of Data

We may share elements of your personal data with the Merchant with whom your transaction was made. This information sharing will be for the purpose of reviews and audits.

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

ClearSale LLC will take all steps reasonably necessary to ensure that your data are treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data to an organization or a country will take place unless adequate controls are in place, including the security of your data and other personal information.


Your Data Protection Rights

You may request access to your personal information and/or seek to have such information updated, corrected, or deleted, if the law provides you those rights. If you wish to be informed of what Personal Data we store about you and if you want it to be removed from our systems, please contact us. However, we will continue retaining, using, and sharing certain information if it is associated with fraudulent activity or to comply with legal obligations.

You may also ask for our confirmation as to whether or not we process your personal data.

Several of our data sources are companies operating in countries outside of your local territory, in legal environments that may not be adequate by US or EU data protection standards. You may opt out of having your personal data shared with those data sources. However, opting out may prevent us from providing Fraud Prevention services and, as a result, may prevent you from using the Sales Platform. Irrespective of requests to opt out, if your personal data are associated with fraudulent activity we may continue to retain, use, and share certain information in order to prevent unlawful practices.


If you are from the European Economic Area (EEA), ClearSale LLC’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

ClearSale LLC may process your Personal Data because:

  • We need to perform a contract with you.
  • You have given us permission to do so.
  • The processing is in our legitimate interests and it is not overridden by your rights.
  • To comply with the law.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. ClearSale LLC aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed of what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update, or to delete the information we have on you. Whenever made possible, you can access, update, or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where ClearSale LLC relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local Data Protection Authority in the EEA.


 

Our Privacy Policy may change from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we may provide a more prominent notice (including, for certain services, email notification of privacy policy changes). The actual Privacy Policy for your review is placed on: https://www.clear.sale/privacypolicy/


Disclosure of Data
Disclosure for Law Enforcement

Under certain circumstances, ClearSale LLC may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency). ClearSale will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (e.g., if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Legal Requirements

ClearSale LLC may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation.
  • To protect and defend the rights or property of ClearSale.
  • To prevent or investigate possible wrongdoing in connection with the Service.
  • To protect the personal safety of users of the Service or the public.
  • To protect against legal liability.

Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.


Data Sharing with Corporate Group Entities or in a Business Transfer

We may share personally identifiable information with our corporate group entities, but their use of such information must comply with the Policy. Your data may also be shared if the operation of the Fraud Prevention service is organized within a different framework or through another legal structure or entity, such as due to a merger or acquisition.


Children’s Privacy

Our Service does not address anyone under the age of 16 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.


Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via e-mail and/or a prominent notice on our Service, prior to the change becoming effective, and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.


Governing Law

This Privacy Policy shall be exclusively governed by and construed in all respects under the laws of the State of Florida, without giving effect to any choice-of-law or conflict-of-law provisions. Any and all legal claims, suits, or actions that arise in connection with this Privacy Policy or with breach of this Privacy Policy shall be submitted to the personal jurisdiction of the courts located in the Miami-Dade County, FL.


Contact Us

If you have any questions about this Privacy Policy, please contact us:

By e-mail: contact@clear.sale

By phone number: +1 (786) 888-4584

WEBSITE PRIVACY POLICY

ClearSale LLC (“us,” “we,” or “our”) operates the www.clear.sale website (the “Service”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have that are associated with that data.

We are committed to communicating with you in a professional manner and protecting your confidential information. We use the information you provide (name, address, phone number, e-mail, etc.) to contact you to share information about our products/services. We will not share your information with any third party outside of our organization, other than as necessary to fulfill your request. This company does not sell, trade, or rent your personal information to others.

By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from ‘www.clear.sale’.


Definitions

Service: Service is the www.clear.sale website operated by ClearSale LLC

Personal Data: Personal Data means data about a living individual who can be identified from those data (or from data and other information either in our possession or likely to come into our possession).

Usage Data: Usage Data are automatically collected data either generated by the use of the Service or from the Service infrastructure itself (e.g., the duration of a page visit).

Cookies: Cookies are small pieces of data stored on your device (computer or mobile device).

Data Controller: Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information is, or is to be, processed. For the purpose of this Privacy Policy, we are the Data Controller of your Personal Data.

Data Processors (or Service Providers): Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User): A Data Subject is any living individual who uses our Service and is the subject of Personal Data.


Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.


Types of Data Collected

Personal Data: While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • E-mail address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any e-mail we send.

Usage Data: We may also collect information concerning how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your device’s Internet Protocol (IP) address, browser type, and browser version, as well as the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Location Data: We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide and enhance features of our Service and to improve and customize our Service.

You can enable or disable Location Services through your device settings when you use our Service at any time.

Tracking & Cookie Data

We use cookies and similar tracking technologies to track the activity on our Service and store certain information.

Cookies are files with small amounts of data that may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies We Use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

Use of Data

ClearSale LLC uses the collected data for various purposes:

  • To provide and maintain our Service.
  • To notify you about changes to our Service.
  • To allow you to participate in interactive features of our Service when you choose to do so.
  • To provide customer support.
  • To gather analysis or valuable information so that we can improve our Service.
  • To monitor the usage of our Service.
  • To detect, prevent, and address technical issues.
  • To provide you with news, special offers, and general information about other goods, services, and events that we offer and that are similar to those you have already purchased or enquired about unless you have opted not to receive such information.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdictional area.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

ClearSale LLC will take all steps reasonably necessary to ensure that your data are treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data to an organization or a country will take place unless adequate controls are in place, including the security of your data and other personal information.


Disclosure of Data

Disclosure for Law Enforcement: Under certain circumstances, ClearSale LLC may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Legal Requirements: ClearSale LLC may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation.
  • To protect and defend the rights or property of ClearSale LLC.
  • To prevent or investigate possible wrongdoing in connection with the Service.
  • To protect the personal safety of users of the Service or the public.
  • To protect against legal liability.

Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee their absolute security.


“Do Not Track” Signals Under the California Online Privacy Protection Act (CalOPPA)

We do not support Do Not Track (DNT). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.


Retention of Data

ClearSale LLC will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (e.g., if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

ClearSale LLC will also retain Usage Data for internal analysis purposes. Usage Data are generally retained for a shorter period of time, except when the data are used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.


If you are from the European Economic Area (EEA), ClearSale LLC’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

ClearSale LLC may process your Personal Data because:

  • We need to perform a contract with you.
  • You have given us permission to do so.
  • The processing is in our legitimate interests and it is not overridden by your rights.
  • To comply with the law.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. ClearSale LLC aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed of what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update, or to delete the information we have on you. Whenever made possible, you can access, update, or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where ClearSale LLC relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local Data Protection Authority in the EEA.


Service Providers

We may employ third-party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services, or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

For the purpose of providing and operating the Service, we may share non-PII (Personally identifiable information) information with trusted third-party partners for the purpose of providing Site-related services to us. We will require that these third parties comply with this Privacy Policy or with privacy policies at least as protective as this Privacy Policy.

We may also request your permission to use your information in other ways. Such use is subject to your consent.

Any data processing performed by these third parties will, if and when required by law, be governed by a data processing agreement in the form required by law preserving your statutory data protection rights.


Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data are shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its advertising network.

You can opt out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visit activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en.

Behavioral Remarketing: ClearSale LLC uses remarketing services to advertise on third-party websites to you after you have visited our Service. We and our third-party vendors use cookies to inform, optimize, and serve ads based on your past visits to our Service.

Google AdWords: Google AdWords remarketing service is provided by Google Inc.

You can opt out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads.

Google also recommends installing the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout) for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en.

Facebook: Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950.

To opt out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217.

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt out of Facebook and other participating companies through the Digital Advertising Alliance in the USA (http://www.aboutads.info/choices/), the Digital Advertising Alliance of Canada in Canada (http://youradchoices.ca/), or the European Interactive Digital Advertising Alliance in Europe (http://www.youronlinechoices.eu/), or opt out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation.


Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policies of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.


E-mail Communications

You have the ability to opt out of receiving marketing communications from ClearSale at any time. You can opt out by either changing your e-mail preferences or using the link provided at the bottom of each e-mail message. You may not opt out of administrative e-mails (e.g., e-mails about your transactions or policy changes) while you are a registered user.

We do not send e-mails to anyone without permission and we do not sell or rent e-mail addresses to any unauthorized third party. If you believe that you have received an unsolicited e-mail from us, please contact us at contact@clear.sale and we will investigate.


Children’s Privacy

Our Service does not address anyone under the age of 16 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.


Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via e-mail and/or a prominent notice on our Service, prior to the change becoming effective, and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.


Governing Law

This Privacy Policy shall be exclusively governed by and construed in all respects under the laws of the State of Florida, without giving effect to any choice-of-law or conflict-of-law provisions. Any and all legal claims, suits, or actions that arise in connection with this Privacy Policy or with breach of this Privacy Policy shall be submitted to the personal jurisdiction of the courts located in Miami-Dade County, FL.


Contact Us

If you have any questions about this Privacy Policy, please contact us:

By e-mail: contact@clear.sale

By phone number: +1 (786) 888-4584


Disclaimer

The information contained on www.clear.sale (the “Service”) is for general information purposes only. ClearSale LLC assumes no responsibility for errors or omissions in the contents on the Service. In no event shall ClearSale LLC be liable for any special, direct, indirect, consequential, or incidental damages or any damages whatsoever, whether in an action of contract, negligence, or other tort, arising out of or in connection with the use of the Service or the contents of the Service. ClearSale LLC reserves the right to make additions, deletions, or modification to the contents on the Service at any time without prior notice.

ClearSale LLC does not warrant that the Service is free of viruses or other harmful components.