Clearview Social Inc. (“Clearview Social”, “we”, “us”) respects your privacy and has instituted this Privacy Policy to protect you (the “User”).

This Privacy Policy applies to any website, application, service, or tool provided by Clearview Social, unless stated otherwise. “Services” shall mean the provision, maintenance, and operation of Clearview Social’s website, and all services attendant thereto that are under direct Clearview Social control. This Privacy Policy governs your use of the Services.

Capitalized terms are defined herein.

Clearview Social provides a customizable subscription service that allows its members to access and share web-based content via a user’s designated social media platforms. Any organization, employee, or affiliate that successfully registers with Clearview Social shall be considered a “User(s)” of our Services.

If you have any questions about our Privacy Policy, please contact our customer support team by navigating to https://clearviewsocial.com/contact/ and completing the “Contact Support” form.

This Privacy Policy is effective as of January 11, 2022.

I. Your Rights under This Policy

A. Compliance with the General Data Protection Regulation

With respect to residents or citizens of the European Union, and to the extent that we are required to comply with the General Data Protection Regulation (“GDPR”), the following rights are intended to mirror those provided under GDPR. Accordingly, these rights are coterminous with those provided in GDPR, and Clearview Social does not grant any right in excess of those provided thereunder or in excess of the jurisdiction of the GDPR. If applicable to you, you may exercise any of the following rights by navigating to https://clearviewsocial.com/contact/ and completing the “Contact Support” form.

1. The Right of Access

You have the right to access and obtain certain data we collect from you, such as your “Personal Data”, which shall mean any information that can be used to identify and contact you. Accordingly, upon request, we will provide you with a copy of the data we have collected from you within one (1) month of our receipt of your request. If we receive complex or significant numbers of requests from users seeking copies of their data, we will have up to two (2) months to respond to a request. We reserve the right to charge a reasonable fee for repetitive requests or further copies.

Our lawful basis under the GDPR for collecting Personal Data is either (i) in fulfillment of contract, with respect to any data we collect pursuant to contracts with customers; (ii) pursuant to the User’s consent, with respect to any data that we collect from persons that is outside the terms of a customer contract; or (iii) our legitimate interest of maintaining and improving our Services, with respect to any data that we collect only for our internal use. Our bases for processing your Personal Data and any other information in this manner under the GDPR are our legitimate interests of marketing our Services, fraud prevention, and information technology security.

2. The Right of Rectification

You have the right to rectify any inaccurate or incomplete Personal Data that we have collected from you. If you believe any data that we have about you is incorrect, you can request rectification by contacting customer support at the email address identified in this Privacy Policy and identifying what information you believe to be incorrect. We agree to correct any such inaccurate or incomplete Personal Data. We reserve the right to request supporting evidence, and the right to not rectify any information that we reasonably believe to be correct.

3. The Right to Deletion

You have the right to have Clearview Social erase all of the Personal Data we have collected from you under the following circumstances:

i. The Personal Data is no longer needed for its original purpose and no new lawful purpose exists;

ii. The lawful basis for the processing is subject to your consent, and you have since withdrawn consent, and no other lawful ground exists;

iii. You have exercised your right to object, and we have no overriding grounds for continued processing of that Personal Data;

iv. The Personal Data was processed unlawfully; or

v. Deletion is otherwise necessary to comply with European Union law or regulations.

4. The Right to Restrict Data Processing

You have the right to restrict our processing of your Personal Data under the following circumstances:

i. You contest the accuracy of your Personal Data;

ii. The processing of your Personal Data was unlawful;

iii. We no longer need your Personal Data for our original purpose, but we still require that Personal Data to establish, exercise, or defend our legal rights; or

iv. Verification of overriding grounds is pending, as in the context of a user’s erasure request.

5. The Right to Be Notified

You have the right to be notified about how we collect data about you, to whom we disclose such data, and how we use such data.

Should you exercise your rights of rectification, erasure, or cessation of processing, we are required to notify any relevant third party that you have exercised these rights unless doing so would be impossible for us or require disproportionate effort.

6. The Right of Portability

Your right of portability permits you to:

i. Receive a copy of your Personal Data in a commonly used, machine-readable format;

ii. Transfer your Personal Data from Clearview Social to a third party;

iii. Store your Personal Data for your further use on a private device; or

iv. Have your Personal Data transmitted from Clearview Social to a third party.

We are not required to retain Personal Data for longer than otherwise necessary in order to comply with this right of portability.

7. The Right to Object to Processing

If we deny your request that we cease processing your Personal Data, you have the right to object on grounds relating to your particular circumstances. We must grant your request to cease processing your Personal Data unless:

i. We can demonstrate compelling, legitimate grounds for processing your Personal Data which override your interests, rights, and freedoms; or

ii. We require the Personal Data to establish, exercise, or defend our legal rights.

You also have the right to object to processing of your Personal Data for direct marketing purposes or scientific, historical, or statistical purposes.

8. The Right to Reject Automated Individual Decision-Making

You have the right to reject automated processing of your Personal Data to make decisions about you—for example, profiling—if such processing produces a legal effect that significantly affects you. This processing shall be permitted if it is necessary for performance of the contact, is authorized by law, or you have explicitly consented to this use and appropriate safeguards are in place.

B. Compliance with the California Privacy Statutes

With respect to residents of the State of California, and to the extent that we are required to comply with the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”), the following rights are intended to mirror those provided under the CCPA and CPRA. Accordingly, these rights are coterminous with those provided in the CCPA, and CCRA, as applicable, and we do not grant any right in excess of those provided thereunder or in excess of the jurisdiction of the CCPA and CPRA. If applicable to you, you may exercise any of the following rights by navigating to https://clearviewsocial.com/contact/ and completing the “Contact Support” form or by using the contact information identified in Section I(C) below.

Pursuant to the CCPA and CPRA, “Personal Information” shall mean “information that relates to describes, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) with a particular consumer or household.” With respect to California residents, we are only permitted to collect Personal Information for limited purposes; that is, the collection of Personal Information must be “reasonably necessary and proportionate to achieve the purposes” for which it is being collected.

1. Right to Know

At or before the moment that we begin collecting Personal Information from you, we must advise you (i) what categories of Personal Information we are collecting and (ii) for what purpose we are collecting it; and (iii) for how long we plan to retain such Personal Information.

Details regarding the categories of Personal Information we collect, why such collection is necessary for our business, the parties with whom we share your Personal Data, and how you can opt out of the collection of your Personal Information are detailed in this Privacy Policy.

2. Right to Access

You have the right to request from us the following information collected by us on or after January 1, 2022:

i. The categories of Personal Information collected;

ii. The categories of sources from which Personal Information is collected;

iii. Our business or commercial purpose of collecting or sharing the Personal Information;

iv. The categories of third parties, including service providers and independent contractors, if any, with whom we share Personal Information;

v. The specific Personal Information we retain from you; and

vi. The categories of Personal Information, if any, that we sell to or share with third parties.

We reserve the right to deny a request that exceeds a twelve (12)-month lookback period if such request would be impossible for us to fulfill or requires a disproportionate effort. We further reserve the right to deny right to know requests that are excessive, repetitive, or harassing in nature.

Please know that privileged materials, such as communications with our in-house or outside counsel shall be exempt from right to know requests, unless otherwise agreed upon by the parties.

3. Right to Request Deletion

You have the right to request that we delete the Personal Information that we have collected from you if we no longer need it. If you submit such a request, we will also notify any and all relevant third parties who have received or bought any of your Personal Information, if applicable, to delete the same.

Please note that the CCPA does not require us to delete Personal Information that we have collected from you in connection with diagnosing cybersecurity issues, protecting or defending against legal claims, exercising our First Amendment rights, and for our own internal uses, as discussed in Section II(4) below.

4. Right to Opt-Out

You have the right at any time to request that we do not share or sell your Personal Information to a third party for any reason. You will be able to opt out by emailing support@clearviewsocial.com.

If you are a minor under the laws of the State of California, you have the right to opt in to the sale of your Personal Information to third parties if you are between the ages of 13 and 16. If you are below the age of 13, your parent or guardian has the right to opt in on your behalf.

5. Right to Fair Treatment

Regardless of whether you assert your rights under the CCPA and CPRA, you have the right to equal services and prices in using our Services. We do not penalize or discriminate against users who opt out of the sale of their Personal Information.

6. Right to Correction

You have the right to correct any inaccurate Personal Information that we have collected from you. If you believe any data that we have about you is incorrect, you can request correction by contacting customer support at the email address identified in this Privacy Policy and identifying what information you believe to be incorrect.

We agree to correct any such inaccurate or incomplete Personal Data. We reserve the right to request supporting evidence, and the right to not rectify any information that we reasonably believe to be correct. We will require any third parties (including service providers and independent contractors) with whom we have shared your Personal Information, if any, to correct the same.

7. Right to Limit Use and Disclosure of Sensitive Personal Information

Pursuant to the CPRA, “Sensitive Personal Information” shall mean Personal Information that reveals an individual’s:

i. Social Security Number;

ii. Driver’s License or State Identification Card;

iii. Passport number;

iv. Account login, financial account information, debit card, or credit card number in combination with any required security or access code, password, or credentials that allow access to an account;

v. Precise geolocation;

vi. Racial or ethnic origin;

vii. Religious or philosophical beliefs;

viii. Union membership;

ix. Mail, email, or text message content (unless we are the intended recipient of such communication;

x. Genetic data; and

xi. Biometric information.

At present, we do not collect any Sensitive Personal Information from our Users. However, in the event that we begin collecting Sensitive Personal Information from our Users, we will (i) update this Privacy Policy; and (ii) you will have the right to instruct us to limit our use of your Sensitive Personal Information to narrowly prescribed purposes—for example, “as necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods and services.”

8. Right to Access Information about Automatic Decision-Making

You have the right to request and access information about the way that we use automated decision-making technology. At present, we do not use automatic decision-making to deliver the Services. However, in the event that we begin using automatic decision-making, we will (i) update this Privacy Policy; and (ii) you will have the right to access information about the way in which we are using it. You are further entitled to opt-out of any automatic decision-making by submitting a written request pursuant to the processes set forth in this Privacy Policy.

9. Right to Data Portability

You have the right to request that we transfer your Personal Information to another entity, to the extent that this is feasible. To exercise this right, please submit a written request pursuant to the processes set forth in this Privacy Policy.

C. Processing Requests for Information

To request information about the Personal Data we collect from our Users or any other aspect of this Privacy Policy, please feel free to contact us at any time using the following methods:

i. Website: https://clearviewsocial.com/contact/

ii. Email address: info@clearviewsocial.com

iii. Toll-free phone number: 1-800-845-6735

iv. Mail: Clearview Social, 77 Goodell Street, Suite 430, Buffalo, New York 14203

Before we can process your request for information, we must verify the identity of the individual making such request. Unless mandated by statute, regulation, or court order, we will not release any requested information about the Personal Data we collect from you to any party other than the individual data subject.

We are not required to provide the same requested information to the same user more than once in a twelve (12) month period.

II. When, How, and WHY Do WE Collect Personal Data?

1. Registration

At the time you create your user account, we will ask for certain Personal Data including, but not limited to, the full name, mobile telephone number, and email address of the individual creating the account.

Clearview Social will also ask your permission to access to your social media accounts, such as LinkedIn, Twitter, and Facebook. Granting permission to access at least one of your social media accounts is a central component of using our Services. Such permission allows Clearview Social to post content to your third-party social media accounts on your behalf.

During registration, you may opt to provide additional information about yourself—such as your gender or age—but you are not required to do so.

When you create a user account, we ask for your honest responses to our questions concerning your Personal Data. By continuing to use the Services, you represent and warrant that the information you provided us is correct and accurate.

2. Collection and Storage of Personal Data

Notwithstanding the Personal Data you provide Clearview Social when you create an account, Clearview Social does not collect additional Personal Data from its users. We also reserve the right to collect the IP address and location data of the individual creating the account.

Such data will be stored securely on servers located in the United States or in the cloud using Amazon Web Services.

3. Sharing of Personal Data

We will not sell or rent your Personal Data to any third party.

However, if your subscription to Clearview Social was provided by your employer, we may be contractually obligated to share with your employer certain non-sensitive information that we have collected from you, such as the number of clicks, engagement, shares, and views.

Pursuant to CCPA requirements, we can confirm that we have not disclosed or sold any users’ Personal Data to third parties in the past twelve (12) months.

4. Use of Personal Data

We use your Personal Data to manage your account and to deliver the Services. We reserve the right to collect and use certain data collected from users, in the aggregate only, to diagnose problems with the Services, to improve the Services, or to resolve technical issues.

We shall take all commercially reasonable steps to ensure that Personal Data is used only for its intended use. At Clearview Social, we limit our employees’ and contractors’ access to users’ Personal Data to those individuals (i) who need access to such data to perform their duties and (ii) who have an obligation to safeguard the confidentiality of such data. Any Clearview Social employee or contractor who fails to abide by these requirements shall be subject to disciplinary action, up to and including termination.

5. User Activity

We collect certain data with respect to your use of the Services. This data may include, but is not limited to, your answers to surveys, comments, ideas, and suggestions. Such data is non-personally identifiable information and is not considered Personal Data.

Except as otherwise provided by applicable contracts with Clearview Social users or third parties, we are free to disclose and use such non-personally identifiable data.

Should you contact us with an inquiry, we will use the information you provided us to respond but will not share such information with any third party.

We reserve the right to contact you by email to notify you of specials, new products or services, or changes to this privacy policy. You will have the option to unsubscribe from such emails.

Unless otherwise specified, the only User data we store is (i) Users’ names and (ii) Users’ email addresses. Such data will be stored securely on servers located in the United States or in the cloud using Amazon Web Services.

III. Use of Cookies

1. By Clearview Social

We use cookies in order to provide (i) our users with data regarding the effectiveness of Clearview Social posts and (ii) streamlined access to our Services.

When you use Clearview Social to generate a social media post, such post may include a link that, when clicked by a third party, downloads cookies that tracks the third party’s activity. Such cookies help us provide our users with data regarding the effectiveness of their Clearview Social posts. It does not provide Clearview Social with any personally identifiable information about the party who clicks on the link.

We reserve the right to use Session Cookies and Short-term Persistent Cookies with our Services. “Session Cookies” shall mean cookies that allow users to be recognized by the Clearview Social website as User navigates from webpage to webpage and are erased when User closes the web browser. “Short-Term Persistent Cookies” shall mean cookies that track a User’s activity on the site and are stored in the web browser even after the web browser is closed. We use Session Cookies and Short-term Persistent Cookies to keep you logged into our Services over short periods of time so that you do not have to repeatedly re-enter your login information.

Should you decide that you want to limit Clearview Social’s use of cookies when you use our Services, please contact us by navigating to https://clearviewsocial.com/contact/ and completing the “Contact Support” form. Please note that an organization may opt to utilize cookies for “tagging” and “tracking” purposes; an individual User that is a member of such organization would not be able to opt out of this use of cookies.

2. By Clearview Social Business Partners

Some of our business partners, such as advertisers, use cookies on our website and may collect the following information from Users: (i) App ID; (ii) Internet browser information; (iii) the user ID; (iv) name; and (v) email address.

If you would like to read more about some of our business partners’ privacy policies, please feel free to access the resources available on their respective websites:

· Amplitude: https://amplitude.com/blog/2018/04/24/amplitude-gdpr

· Intercom: https://www.intercom.com/help/pricing-privacy-and-terms/data-protection/how-intercom-complies-with-gdpr

3. By Third-Party Content

Third-party content that you share using the Services may use cookies. Clearview Social has no access to or control of these cookies. We can make no warranties regarding the information these cookies store.

4. “Do Not Track” Signals

In your web browser settings, you can opt to send a “Do Not Track” signal to the Clearview Social website requesting that we do not track your activity on our website. Upon receipt of this signal, we shall cease our use of any tracking cookies within forty-eight (48) hours.

Please note, however, that our business partners may use cookies in connection with our website. Clearview Social make no warranties regarding how such business partners respond to “Do Not Track” signals.

IV. Surveys & Contests

From time to time, Clearview Social requests information via surveys or contests. Participation in these surveys or contests is completely voluntary. You may choose whether to participate and thereby disclose the solicited information.

Requested information may include contact information—such as a mailing address—and demographic information—such as age. Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the Services or user satisfaction.

V. Security

We value your trust in providing us with your information and strive to use commercially acceptable means of protecting it. However, we caution that no method of transmission over the internet or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

All Personal Data and other sensitive data we collect from users—such as credit card information—is encrypted and securely transmitted. You can verify that the website’s connection to the server is encrypted by looking for (i) a lock icon in the address bar and (ii) “https” at the beginning of the address of the webpage. If you do not see both of these items on a Clearview Social webpage where Personal Data or other sensitive information is to be entered, please contact us immediately. We ask that you refrain from transmitting Personal Data or other sensitive information via our website until we have responded to your inquiry.

In addition to using encryption, we also take steps to protect your information internally. Only those Clearview Social employees who need the information to perform a specific job function—for example, billing or customer service—are granted access to users’ Personal Data.

In the event that we experience any security breach, we will notify you within the first seventy-two (72) hours that we become aware of the qualifying event. We will contact you by telephone and/or by email and provide as much relevant information to you as possible, including the nature of the breach and an estimate of the number of users affected. This communication will include our contact information for users seeking additional customer support or technical assistance.

VI. Consent to Privacy Policy

By accessing or using the Services, you hereby agree to comply with and be bound by the Privacy Policy as detailed herein.

We reserve the right, in our sole discretion, to modify this Privacy Policy from time to time without notice to you. The amended Privacy Policy shall automatically be effective five (5) days after it is posted to our website. Your continued use of the services after the effective date of any posted change constitutes your acceptance of the amended Privacy Policy as modified by the posted changes.

Any Further Questions?

If there is anything else we can assist you with or to obtain a PDF copy of this policy, you can contact Clearview Social Support either by emailing support@clearviewsocial.com or through the Intercom chat button in the bottom right of the site.

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