PRIVACY POLICY

This Privacy Policy identifies and describes the way Clarity uses and protects the information we collect about Customers and Users. All use of Clarity’s products and services, as well as visits to our websites, are subject to this Privacy Policy.

The Information We Collect, How We Collect It, And How We Use It

We may collect different types of personal and other information based on your use of our products and services and our business relationship with you. Some examples include:

  • Contact Information that allows us to communicate with you – including your name, address, telephone number, and e-mail address;
  • Billing information related to your financial relationship with us — including your payment data, credit history, credit card number, Social Security numbers, security codes, and service history;
  • Equipment, Performance, Clarity’s Website Usage, Viewing and other Technical Information about your use of our network, services, products or websites.

We collect information in three primary ways:

  • You give it to us when you purchase or interact with us about a product or service we offer or provide;
  • We collect it automatically when you visit our websites or use our products and services;
  • We obtain it from other sources, such as credit agencies.

We may use the information we collect in a variety of ways, including to:

  • Provide you with the best customer experience possible;
  • Provide the services you purchase, and to respond to your questions;
  • Communicate with you regarding service updates, offers, and promotions;
  • Deliver customized content and advertising that may be of interest to you;
  • Address network integrity and security issues;
  • Investigate, prevent or take action regarding illegal activities, violations of our Terms and Conditions or Acceptable Use Policies; and
  • Provide local directory and directory assistance.

Information Sharing

With Clarity Companies: Subject to applicable legal restrictions, such as those Federal Communications Commission rules, orders and regulations that exist for Customer Proprietary Network Information (“CPNI”), the Clarity companies may share your Personal Information with each other to make sure your experience is as seamless as possible, and you have the full benefit of what Clarity has to offer.

With Non- Clarity Companies: We share your Personal Information only with non- Clarity companies that perform services on our behalf, and only as necessary for them to perform those services.

  • We require those non-Clarity companies to protect any Personal Information they may receive in a manner consistent with this policy.
  • We do not provide Personal Information to non-Clarity companies for the marketing of their own products and services without your consent.

In Franchisor-Franchisee Relationships: In situations where there exists a Franchisor-Franchisee relationship and Clarity is providing services to the Franchisee, Clarity may disclose the Franchisee’s personal calling data to the Franchisor under the following circumstances:

  • When instructed to by the Franchisee customer of Clarity;
  • When required by Franchisor pursuant to contract between Franchisee and a Franchisor when such contract provision is disclosed to Clarity and Franchisee has not otherwise objected to such disclosure in writing to Clarity prior to activation of the service; and/or
  • When the calling data provided by Clarity is in aggregate form and is only being used to identify geographic or durational patterns that can assist with planning or optimizing Clarity’s network.

In Other Circumstances: We may provide Personal Information to non-Clarity companies or other third parties for purposes such as:

  • Responding to 911 calls and other emergencies;
  • Complying with court orders and other legal process;
  • To assist with identity verification, and to prevent fraud and identity theft;
  • Enforcing our agreements and property rights; and
  • Obtaining payment for products and services that appear on your Clarity billing statements, including the transfer or sale of delinquent accounts to third parties for collection

Anonymous & Aggregate Information

  • We collect some information on an anonymous basis. We also may anonymize the personal information we collect about you.
  • We obtain aggregate data by combining anonymous data that meet certain criteria into groups.
  • When we employ non- Clarity companies to anonymize or aggregate data on our behalf, the requirements for sharing Personal Information with non- companies apply.
  • We may share aggregate or anonymous information in various formats with trusted non- Clarity entities, and may work with those entities to do research and provide products and services.

Safeguarding Your Information: Our Policy on Data Protection and Security

  • We do not sell your Personal Information to anyone for any purpose. Period.
  • We maintain information about you in our business records while you are a customer, or until it is no longer needed for business, tax, or legal purposes.
  • We have implemented encryption or other appropriate security controls to protect Personal Information when stored or transmitted by Clarity.
  • We require non- Clarity companies acting on our behalf to protect any Personal Information they may receive in a manner consistent with this Policy. We do not allow them to use such information for any other purpose.

Customer Privacy Controls and Choices

  • You can review and correct your Personal Information collected by us.
  • You can limit certain types of solicitation communications from Clarity, including marketing contacts made via telephone, e-mail and text messaging.
  • We will provide you with notice of changes to this policy.

Privacy when using Clarity Office Anywhere and other Clarity Apps

Clarity processes and in certain situations collects personal information as needed to deliver its Products and Services and manage its business. When collecting personal information, Clarity does so in a reasonable and lawful manner.

The types of information and the purposes for which Clarity collects or processes personal information may include: Indirect End User Phone Contact Information (Personal Identifiable Information).

Clarity acts as a data processor with regard to indirect end user personal identifiable information and our Clients act as the data controller of such data. In the course of Clarity’s processing and protection of such data, all use will be in conformity with the data controller’s instructions.

Specifically, only when enabled via system permission on Clarity Office Anywhere Android and Clarity Office Anywhere iOS, Clarity shows personal contacts within the respective application. When the user sends an SMS message to one of his/her phone contacts, or when the user initiates a call to one of his/her phone contacts, the phone number is sent securely through Clarity’s API. Clarity does not store this number with any other personally identifiable information, and it cannot be directly or indirectly attributed to any person or persons; Clarity stores only the phone number and pertinent metadata so as to be compliant with all applicable state and federal laws, and Clarity does not share this data with any advertisers or third parties under any circumstances. A user can revoke phone contact access on his/her mobile device at any time, and his/her app experience is not hindered or interrupted.

Clarity Office Anywhere Android and iOS also uses Gravatar, only when enabled via Settings and UIConfigs, which is a service that provides avatar images linked to the MD5 hash of the user’s email address. This means that, only when Gravatar use is enabled, we hash each contact’s email address and send it to Gravatar to try and retrieve an avatar image. MD5 hashes cannot be directly or indirectly attributed to any person or persons, and we only send the MD5 hash to Gravatar, never the email address in plain text. As with phone contacts, a user can revoke Gravatar access at any time in Settings or via UIConfig, and his/her app experience is not hindered or interrupted.

Collection of Images

The Clarity Voice applications collect images information only if a user allows it (by using the app to send or receive an image) and the only information collected is file name, file size, and file type. This information is stored in memory only so the user can see their images inside a chat (inside the app) and this information is never sent from the device. The only information we share is a base64 String representation of the image and it is only shared with our API in order to keep an accurate conversation history.

Your California Privacy Rights

California Civil Code Section 1798.83 entitles California customers to request information concerning whether a business has disclosed Personal Information to any third parties for the third parties’ direct marketing purposes. As stated in this Privacy Policy, Clarity will not sell or share your Personal Information with non-Clarity companies for their direct marketing purposes without your consent. California customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices and policies may contact us at 800-786-6160, option 4.