ClearTrack Privacy Policy

This privacy policy explains how ClearTrack Information Network uses and protects personal data collected through:

• Its websites
• Its Supplier Portals
• Its Service Provider Portals
• Its services (Clarity™ Global Trade Management Platform & Modules; Mobile Inspection Management, Load Tender x-Change, Ocean Freight Quote Management applications), with respect to:
• Collection and use
• Sharing
• Retention
• Location
• Privacy rights

“Personal data” means any information relating to an identified or identifiable individual, such as name, an identification number or location data.

Information Collected Through the Website

The website uses cookies to help ClearTrack better understand how visitors use the site so we can maintain and improve it.  The information cookies collect includes use of the site, such as pages visited, links clicked, text entered and mouse movements; location data and IP addresses; referring URL, browser, operating system and Internet Service Provider.

The personal data collected through cookies is only used to recognize the user’s computer, to assist the user in navigating the website and to capture usage trends.

Visitors to the website are informed up front that they can opt out of the cookies through their web browser settings. The ClearTrack Website Privacy Statement applies regardless of the “Do Not Track” setting on the user’s browser.

With the user’s consent, we collect the personal data users provide us when they choose to interact with our website. This includes the user’s name, email address, username and/or password when filling out an online form or creating an account. This information is used to contact the user to provide services requested, or for account authentication purposes.

Children

The ClearTrack website is intended for a general audience and does not knowingly collect personal data from anyone under the age of 13.

Privacy Practices of other Websites

ClearTrack has no control over the privacy policies of websites to which it links.  To protect the integrity of its website, it encourages and welcomes feedback about linked sites (including if a specific link does not work).

Data Collected through the Supplier Portals and Service Provider Portals

In the course of its business activities, ClearTrack collects information that individuals provide during assessment of supply chains, with respect to due diligence procedures. This includes information that enables ClearTrack to perform services for its clients, such as questionnaire or survey responses, as well as the business contact information for the individual providing the responses. The individuals providing this information are responding to an inquiry by a particular client of ClearTrack, to whom they are a supplier or service provider. ClearTrack’s clients are responsible for ensuring the validity of consent from individuals providing responses to the questionnaires and surveys.

Data may be made available to other ClearTrack customers through the Supplier Portals or Service Provider Portals, in aggregate form, for the purposes of maximizing use and re-use of data in anonymized form.  ClearTrack will never share personal data without consent.

Data Collected Through ClearTrack Services

ClearTrack’s web-based software and services collect personal data via email, SMS, telephone, web-based forms or other means of communication individuals choose to interact with ClearTrack. The information collected includes, as necessary, name, email address, username and password, IP addresses, location data, use of the service, usage data in relation to the services and other information relevant for the purpose of providing the services, specifically to:

• Process transactions with ClearTrack.
• Send emails about ClearTrack’s services or respond to inquiries.
• Send emails and updates about ClearTrack services, including newsletters.
• Provide support for ClearTrack services.
• Enhance or improve ClearTrack services.
• Monitor data and user activity to ensure compliance with contractual requirements.
• Perform any other function reasonably necessary to protect the security or proper functioning of ClearTrack services.

With express consent, ClearTrack may post personal testimonials in addition to other endorsements. If a registered user of the service has supplied their email address, ClearTrack may occasionally send an email to promote new features, solicit feedback or keep the user up to date with ClearTrack and its products.

Sharing of Personal Data

Whether collected through the website, the Supplier Portals, Service Provider Portals or ClearTrack services, personal data is never sold or disclosed without consent, except in the rare cases where it is required to do so by law. However, in the course of business, ClearTrack may hire third party individuals or organizations to help deliver our services. ClearTrack may also hire third parties to operate, maintain, repair, or otherwise improve or preserve files or systems.

In those cases, the third parties only process personal data collected by ClearTrack, on ClearTrack’s behalf, under ClearTrack’s written instructions, and/or under contractual arrangements containing specific clauses that demand the same level of security and protection of the personal data shared with them, as provided for by ClearTrack. All third parties engaged by ClearTrack are subject to this policy and to compliance monitoring in that regard.

Where ClearTrack is required by law to disclose personal data, the disclosure will only be done upon demonstrated lawful authority to do so and on the basis of legal advice. As permitted by law, ClearTrack may also access or disclose personal data when it is reasonable to believe that it is necessary to (i) enforce applicable terms of service, including investigation of potential violations; (ii) detect, prevent, or otherwise address fraud, security or technical issues; or (iii) protect the rights, property or safety of users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Right To Access, Edit and Remove Your Data

Individuals may access, edit or remove their personal data by contacting ClearTrack directly at [email protected].

ClearTrack will ensure the accuracy of personal data and allow individuals the opportunity to correct their personal data upon request and as necessary. ClearTrack will also delete, upon request, any inaccurate personal data or personal data for which consent has been withdrawn.

An access request cannot be accepted if it puts the privacy of others at risk.

Access, correction, and deletion of personal data are provided for free, except where the request requires disproportionate technical effort (such as developing a new system or fundamentally changing an existing practice), or would be extremely impractical (for instance, requests concerning information residing on backup systems). In such cases, ClearTrack will charge a fee corresponding to administrative costs and provide justification for the fee.

If the access request relates to personal data stored by a client of ClearTrack, the request will be redirected to that client to respond to the individual.

While we will seek to address any request and resolve any complaint regarding this policy, other complaint mechanisms exist. ClearTrack informs individuals of those resources as relevant.

Security Measures for all Personal Data

ClearTrack applies necessary physical, technological and administrative measures to protect personal data at the level appropriate to its sensitivity. These include:

• Entry-exit registration of visitors.
• Secure areas for the protection of servers and devices.
• Use of SSL Certificates to protect users against unauthorized access.
• Policies governing the management and protection of personal data, made easily accessible and distributed to staff for implementation.
• Risk management plans, threat identification and mitigation measures.

Location of Data

ClearTrack stores and processes personal data on computers located in the United States. This means United States privacy laws apply according to where the information is stored. Wherever it stores personal data, ClearTrack ensures, through contractual clauses, that the information will be protected with a comparable level of safeguards.

Changes

This privacy policy is updated as necessary to reflect ClearTrack activities that may entail collection and use of personal data, as well as the measures developed to protect it.

Addressing Questions or Concerns

ClearTrack addresses questions and concerns through its privacy office. All queries regarding privacy at ClearTrack are directed to the data protection executive via email at [email protected] or via postal mail at:

ClearTrack Information Network, Inc.

Attn: Data Protection Executive

5301 Virginia Way, Ste. 110

Brentwood, TN 37027

ClearTrack makes every effort to respond in a timely and satisfactory manner.