This Privacy Statement is effective January 1, 2020

At ClearCycle, we recognize the importance of protecting your personal information and are committed to processing it responsibly and in compliance with applicable data protection laws in all geographies in which we operate. This privacy statement describes how ClearCycle collects, uses, stores, shares or processes Personal Data acquired by or provided to ClearCycle. This includes visitors of ClearCycle websites, employment candidates, consumers of ClearCycle products and services, or any other individuals for which ClearCycle acquires Personal Data. We may provide additional or more specific information on the collection or use of personal information on websites or related to a specific product or service

In this context, Personal Data is defined as information, both individually and if aggregated with other information, that allows the identification of an individual, either directly or indirectly.

Information We Collect

We collect the following categories of Personal Data about website visitors, candidates, marketing targets, and individuals registering for or using ClearCycle services.

• System data: Internet Protocol (IP) address of devices, type of browser software, operating system, or mobile device in use, associated region or location data, Internet domain and service provider used, and referring/exit pages from which you linked to a ClearCycle site
• Candidate data: Data provided by candidates in connection with employment opportunities Contact data: Name, title, organization, phone numbers, mailing address, and email address
• Registration data: ClearCycle information and marketing requests and event/seminar registrations
• Marketing data: Participation in events and seminars, opt-in marketing selection, and document or resource download references
• Customer data: Data received from customers in support of services provided to or on behalf of our customers
• Identification data: Government or national identifiers, identification documents such as passports or licenses, and dates of birth.

Why and how we collect and use your personal information

The purposes for which we process Personal Data include the following:

• Website Improvement: Enhancing our web sites requires us to use system and device data. Improving the use, layout, and content of our sites for our visitors is in our legitimate interests.
• System Security and Protection: Protecting the security and availability of ClearCycle information systems and assets requires the use of system and device data. It is in our legitimate interest to monitor our systems and assets to help detect and prevent misuse, tampering, or unauthorized access.
• Responding to your request for information: When you contact us (online or offline) in connection with a request for information, to order a product or service, to provide you with support, or to participate in a forum or other social computing tool, we collect information necessary to fulfill your request, to grant you access to the product or service, to provide you with support and to be able to contact you. For instance, we collect your name and contact information, details about your request and your agreement with us and the fulfillment, delivery and invoicing of your order and we may include client satisfaction survey information. We retain such information for administrative purposes, defending our rights, and in connection with our relationship with you
• Recruitment: Considering candidates for job opportunities with ClearCycle requires us to use job candidate data, contact data, and identification data for processing applications and complying with legal obligations which we are subject to
• Compliance: Addressing compliance and legal obligations require us to use contact data, identification data, customer data, and system and device data to ensure we comply with our legal obligations
• Sales and Marketing: Providing marketing information requires us to use contact data, marketing data, registration data, and system and device data. This includes newsletters, company announcements, conferences and networking opportunities, online resources, services, and ClearCycle job opportunities.
• Customer Relationship: Providing services and managing our relationships with our customers requires us to use contact data, registration data, and customer data in order to fulfill our contractual obligations to our customers and clients
• Business Operations: Managing our business operations requires us to use contact data, registration data, customer data, marketing data and system and device data to support our contractual obligations and legal requirements for business processes including financial, resource, and supplier management.
• Visitor information: We register individuals visiting our sites and locations (name, identification, and business contact information) and use camera supervision for reasons of security and safety of persons and belongings, as well as for regulatory purposes.

Sharing Personal Data

As a Healthcare IT organization offering a wide range of products and services, with business processes, management structures and technical systems that cross borders, ClearCycle has implemented global policies, along with standards and procedures, for consistent protection of personal information. Due to the nature of our business, we may share information about you with our subsidiaries and business partners in accordance with this Privacy Statement. Between ClearCycle controlled subsidiaries we only grant access to personal information on a need-to-know basis, necessary for the purposes for which such access is granted. ClearCycle may also share your personal information with selected partners to help us provide you, or the company you work for, products or services, or to fulfill your requests, or with your consent. When selecting our suppliers and partners, we take into account their data handling processes and ensure all Business Associate Agreements are in place for privacy and information security.

Under certain circumstances, personal information may be subject to disclosure to government agencies pursuant to judicial proceeding, court order, or legal process. We may also share your personal information to protect the rights or property of ClearCycle, our business partners, suppliers or clients, and others when we have reasonable grounds to believe that such rights or property have been or could be affected.

How Long We Keep Personal Data

We retain Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or allowed by law or otherwise fulfill a legal obligation.

Data Security and Protection

We are committed to protect your personal information and to maintain its accuracy. ClearCycle implements reasonable physical, administrative and technical safeguards to protect your personal information from unauthorized access, use and disclosure. We also require that our suppliers protect such information from unauthorized access, use and disclosure. While we are committed to protecting your Personal Data, we cannot ensure or warrant the security of any information you transmit to us.

Dispute Resolution

If you have a question or complaint regarding the data collected or have questions regarding this privacy statement or other privacy matters, please contact ClearCycle at the following address:

Privacy and Security Officer

ClearCycle Corporation

7345 164th Ave NE Ste 145 #187,

Redmond, WA 98052