Privacy Policy

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INTRODUCTION
COLLECTION OF INFORMATION
COOKIES
SECURITY
DISCLOSURE OF INFORMATION
SAFE HARBOR
SUMMARY
DISPUTE RESOLUTION

INTRODUCTION

ClearPoint Learning Systems, Inc. (“ClearPoint”) takes privacy seriously. In our modern technological world, we work to balance the importance of the free flow of information against the importance of an individual’s privacy rights. This Privacy Policy sets out the privacy practices used by ClearPoint in the collection, processing, and storage of personal information. This Privacy Policy covers www.clearpointlearning.com and the ClearPoint product portals (the “Web sites”).

ClearPoint is committed to complying with the EU Safe Harbor principles with respect to all personal data received from the EU.

ClearPoint agrees to cooperate with the EU Data Protection Authorities, and to participate in the dispute resolution program provided by the European Data Protection Authorities Panel. If you have questions or concerns regarding this statement, you should first contact the Legal Department of ClearPoint by email at .

Personal Information Received from the European Union:

We anticipate receiving personal information from European Union citizens, such as name and email address, for each visitor to our Web sites. Our Web server automatically recognizes the visitor’s domain name, browser type, operating system, entry page, exit page, resources accessed, and average time on the Web sites. This information is used to authenticate users to the sites and to help us improve our Web sites and better understand our customers’ needs.

COLLECTION OF INFORMATION

Our Web sites may log the user’s IP address, browser type and version, domain, and computer operating system when customers visit the sites. IP addresses may in some cases be linked to personally identifiable information (email addresses and contact information). We use the tracked information to help diagnose problems with our server and to administer our Web sites. IP addresses may also be used to gather broad demographic information (i.e., information that is not associated with any individual and is anonymous). The data are used for research, product development, and statistical analysis only in the aggregate and never disclose any individual’s identity. Our Web sites may contain links to other Web sites that are preapproved by our clients specific to their portals developed by ClearPoint. We have no control over the privacy practices of those other Web sites, nor should the links be considered an endorsement of the other Web sites’ privacy practices. We recommend that you read the privacy policies of those other Web sites.

COOKIES

We use session cookies as part of our login process for our customer portals. Session cookies are identifiers that can be sent from a Web site via your browser to be placed on your computer’s hard drive. Our session cookies store the user’s account information but are destroyed when the user logs out, when the user leaves the custom portal site, or when the browser window is closed. You may elect not to accept cookies by changing the designated settings on your Web browser. However, not utilizing cookies may prevent you from using certain functions and features of the Web sites. The information collected from the use of cookies is used to personalize the experience of our customers, provide support to customers, record visitor preferences, provide personalized and specialized content, record session information throughout the Web site and customize site content based on each user’s browser type, operating system, and preferences. By gathering such information to supplement our records, we learn things like what pages are most attractive to our visitors, and which of our products are most interesting to our customers. If you disable cookies, you may still use our corporate Web site; however, you may not be able to access certain custom portals developed by ClearPoint for our clients. ClearPoint does not have access to or control over cookies used by third parties accessed through links on ClearPoint sites. This privacy statement does not cover the use of cookies by any of those third parties.

SECURITY

We use security measures to protect against the loss, misuse, and alteration of the information under our control gathered from our Web sites. We have licensed the industry-standard Secure Sockets Layer (SSL) and Advanced Encryption Standard (AES) for data encryption technology, to be used at the request of the customer, that permits encryption of personally identifiable information such as user name and email. This will make your information unusable in the event of unauthorized third-party interception. Additionally, we are protected from hackers and DDoS attack (UDP flood). We have an extensive custom firewall rule and large mod_security rulesets and IDS protection that protect our servers. If we do experience heavy flooding, we will have our datacenters enable network-level flood protection. Our datacenters are all highly secure facilities with restricted access. We have appropriate security measures in place at our physical facilities to protect against the loss, misuse, or alteration of your personal information or customer data.

DISCLOSURE OF INFORMATION

We do not share, sell, trade, rent, or otherwise give to any other entity or organization the individual information our customers submit on our Web sites, except as noted in this privacy policy.

We may share your information with agents, contractors, or partners of ClearPoint in connection with services that these individuals or entities perform for, or with, ClearPoint. These agents, contractors, or partners are prohibited from using this data in any way other than to provide services for ClearPoint, or services for the collaboration in which they and ClearPoint are engaged (for example, some of our products are developed and marketed through joint agreements that are protected in compliance with ClearPoint corporate NDA with other companies).

Other than as stated above, if ClearPoint provides a third party with client information, it will be in the form of aggregate data and used for the purposes of product development, research, or statistical analysis. The information will remain anonymous, stripped of all personally identifiable data. Again, all identifiable individual information will be removed.

We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Web sites.

ClearPoint may release account information when it believes, in good faith, that such release is reasonably necessary to (i) comply with law; (ii) enforce or apply the terms of any of its user agreements; or (iii) protect the rights, property, or safety of ClearPoint, its users, or others. If you need to delete, update, or correct the personal information that you have provided to ClearPoint, please send an email to . You can expect a response to your request within 30 days.

SAFE HARBOR

ClearPoint complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. ClearPoint has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view ClearPoint’s certification, please visit http://www.export.gov/safeharbor/.

If you believe that we are not in compliance with the Safe Harbor principles, first contact us by any of the contact methods below. If for any reason, ClearPoint is unable to resolve your complaint or dispute to your satisfaction, we have agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities to resolve disputes pursuant to the Safe Harbor Privacy Principles, as well as to cooperate and comply with the Federal Data Protection and Information Commissioner of Switzerland.

SUMMARY

ClearPoint is committed to protecting our customers’ privacy. We use the information collected on our sites to improve our products and your experience. By using our Web sites, you consent to the collection and use of information by ClearPoint. We may from time to time change our privacy policy; we will post those changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it.

Because of the changing legal landscape and the evolving nature of technologies, we reserve the right to amend this privacy policy from time to time. You can determine when this privacy policy was last updated by looking at the “Last Updated” statement at the bottom of this Web page.

DISPUTE RESOLUTION