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Privacy Statement

By accessing ClearStar Website (“Website”), you are indicating your agreement to ClearStar’s Privacy Statement (hereinafter referred to as “Policy” or “Statement”). This policy applies to all users of ClearStar Website. In addition, ClearStar has a separate privacy policy that applies to personal information pertaining to an identified or identifiable individual that is received by ClearStar from: (i) the European Union, called the European Union Safe Harbor Privacy Policy, and (ii) from Switzerland, called the Switzerland Safe Harbor Privacy Policy, which are further explained below.

ClearStar may revise this online privacy policy from time to time. If ClearStar makes any material changes, ClearStar will notify you by posting a prominent announcement on the Website. If ClearStar is going to use your personally identifiable information (“PII”) in a manner different from that stated at the time of collection, ClearStar will notify you via email if an email address has been provided and is available. You will have a choice as to whether or not to allow ClearStar to use your information in such a different manner.

Data Protection Officer

ClearStar Data Protection Officer for the United States, Canada, European Union and Switzerland is ClearStar’s General Counsel, Nicolas Dufour

To request information or receive help with data protection issues, contact ClearStar’s Data Protection Officer at:

nicolasd@clearstar.net
Toll free: 1 (877) 796-2559
Direct: (678) 999-8048

ClearStar Website

Welcome to ClearStar’s Website. Please carefully read ClearStar’s privacy policy to understand how ClearStar will treat the information you provide while visiting this Website. As previously stated, this policy may change from time to time. Please check the policy each time you use ClearStar Website for the most current information. This policy only applies to ClearStar and its affiliated entities. This Website is not intended for children and ClearStar does not knowingly collect any information about children. Nevertheless, ClearStar is committed to complying with applicable laws and requirements, such as the United States’ Children’s Online Privacy Protection Act(“COPPA”).

ClearStar also applies this privacy policy in the offline context in those limited cases where ClearStar requires a consumer to provide his/her PII in order for the consumer to order an information product by mail or telephone.

ClearStar Website may contain links to unrelated third party websites. ClearStar assumes no responsibility for the content or the privacy policies and practices on those websites. ClearStar encourages all users to read the privacy statements of those sites; their privacy practices may differ from those of ClearStar.

ClearStar is a leading provider of web technology services and risk mitigation and business solutions. ClearStar offers clients a comprehensive portfolio of products, services and tools to help them make informed decisions in a timely manner. ClearStar recognizes that it has an obligation to protect the privacy and confidentiality of PII that it may obtain about individuals through ClearStar Website. Safeguarding the privacy of information ClearStar may receive on its Website is a top priority for ClearStar, its clients and consumers.

How ClearStar Collects and Use Information on its Website 

ClearStar follows the below privacy principles when you visit its Website. In general, you can visit ClearStar Website on the World Wide Web without telling ClearStar who you are or revealing any information about yourself. ClearStar Web servers automatically collect the domain names, not the e-mail addresses, of visitors. This information is used to measure the number of visits, average time spent on the site, pages viewed and similar information. ClearStar uses this information to measure the use of its Website and to develop ideas to improve the content of its Website.

1. PII

This Website only collects PII from you if you choose to provide this information to ClearStar. PII collected with your consent may include name, mailing address, e-mail address, telephone number, date of birth, credit card number, social security number, driver’s license number, user name and password, any response you provide to survey questions, information relating to any orders you place, or any inquires you may make through our web site. Also, ClearStar may request this type of information if you place an order by mail or telephone.

2. Cookies

“Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. This site uses first and third party cookies, however personally identifiable information is not collected through the use of cookies. Cookies allow ClearStar to store your User ID during your visit to keep track of reports you have ordered or any updates to those reports. Cookies also help ClearStar detects potential fraud or misuse of its system.

While most browsers are set to accept cookies by default, you can set yours to refuse cookies or to alert you before accepting them. Your browser manufacturer has information on changing the default setting for your specific browser. However, be aware that if you do not accept cookies from this Website, you will not be able to use some of the features of this Website, such as those for ordering reports.

3. Non-personally-identifiable information

This Website also collects non-personally-identifiable information. For example, as you browse this Website, ClearStar may collect information about your visit, but not about you personally. Via web server logs, for example, ClearStar may monitor statistics such as: the number of people that visit its Website, which page(s) are visited on its Website, from which domain visitors come (e.g., aol.com, hotmail.com, etc.), and which browsers people use to visit this Website (e.g., Google Chrome, Microsoft Internet Explorer, etc.). This Website may use an outsourcing program to assist ClearStar in analyzing this data to better tailor ClearStar Website.

Information Use and Consumer Choice

The information collected by this Website is used only for responding to your inquiries and otherwise corresponding with you, for processing transactions your request, maintaining your account (if you have one), and for the administration, review and/or improving the content of ClearStar Website. ClearStar does not share, sell, rent or trade PII with third parties for their promotional/marketing purposes.

ClearStar may contact you in response to your comments or inquiries, as part of the maintenance of your account with us (if you have one), or in order to complete a transaction that you requested.

ClearStar may also contact you to inform you of other products or services ClearStar believes may be of interest to you, but ClearStar always offer you an opportunity to opt not to receive such communications.

If you decide that you do not want to receive further e-mails regarding your inquiry from ClearStar, you can e-mail ClearStar Data Privacy Officer at nicolasd@clearstar.net or email service@clearstar.net with a request that ClearStar does not continue to e-mail you. ClearStar does not use outside data sources to enrich marketing data obtained online.

ClearStar website users have the option to request that ClearStar not use information previously provided, correct information previously provided, or remove information previously provided to ClearStar. Those that would like to correct or suppress information they have provided to ClearStar should contact ClearStar Consumer Advocacy Group at service@clearstar.net. The inquiries should include the individual’s name, address, and other relevant contact information (phone number, email address), as well as the nature of the request. Except as required by law, ClearStar is free to deny such requests. If ClearStar decides to grant such a request, it will use all reasonable efforts to honor such requests as soon as practicable.

Onward Transfer 

ClearStar may disclose information you provide to ClearStar to third parties in order to complete a transaction that you requested. For example, it may be necessary to disclose information you provide about yourself or third parties in order to obtain the information product you requested. In such cases, however, ClearStar requires that the companies acting on ClearStar’s behalf abide by ClearStar privacy policy and institute safeguards to protect the confidentiality of your information.

Finally, please note that ClearStar may disclose personal information when required by law or in the good faith belief that such action is necessary in order to conform with the law or to comply with a legal process.

Access and Correction

As an information service company, ClearStar understands the importance of accurate data. ClearStar will provide you (whether you are a consumer or a client) with access to PII you provide through this Website for as long as ClearStar maintains that information in a readily accessible format. Similarly, ClearStar permits and encourages you to correct inaccuracies in the information you submit to ClearStar through this Website.

If you wish to access information that you have submitted through ClearStar Website or to request the correction of any inaccurate information you have submitted through this Website, please use the mechanisms provided by the Website, or send an e-mail to service@clearstar.net.

The access and correction provisions of this online privacy policy only apply to PII collected from you through this Website. Individuals that are interested in information about how to access and/or request the correction of personal information ClearStar maintains about them for potential inclusion in information products and services can contact service@clearstar.net.

Security 

ClearStar takes steps to protect against the loss, misuse, or unauthorized alteration of PII collected through this Website and otherwise subject to this policy. ClearStar recognizes the importance of security for all PII collected on its Website. Once ClearStar receives PII, ClearStar takes steps to protect its security on its systems. In the event ClearStar requests or transmits sensitive information, such as credit card information or Social Security Numbers through this Website, ClearStar uses industry standard, secure socket layer (SSL) encryption.

ClearStar limits access to PII to those employees who need access in order to carry out their job responsibilities.

When ClearStar disposes of PII collected through this Website, ClearStar uses procedures to dispose of personal information by means such as shredding documents and erasure of electronic media that information cannot be practicably read or reconstructed.

How ClearStar Uses and Collects Information in its Businesses  

A number of services offered by ClearStar are Consumer Reports (“Consumer Reports”), as the term is defined under the federal Fair Credit Reporting Act (“FCRA”), and when providing Consumer Reports to its Clients, ClearStar acts as a Consumer Reporting Agency (“CRA”) as the term is defined under the FCRA, operating in accordance with the requirements of the FCRA. The FCRA establishes the following principles for all CRAs:
Privacy: Information about you may only be furnished to third parties that have a permissible purpose to request such information. In general, these deal with credit, employment, insurance, rental or banking transactions initiated by you, or where the object is to make a firm offer to you. CRAs must credential their clients to make certain that they have a permissible purpose to receive the requested information.

Access: Consumers may receive a copy of information the CRA maintains about them. Such reports can be obtained free of charge once per year or for a reasonable fee for additional disclosures. Please contact ClearStar at service@clearstar.net or call toll free 1-877-275-7099.

Accuracy: CRAs must follow reasonable procedures to assure accuracy of the information they maintain and/or furnish. When you obtain a copy of your information, you have a right to dispute and have the information reinvestigated and corrected in the CRAs database.

Fairness: Information is obtained from various sources including public records sources. However, certain information over a specified time period may not be reported.

Accountability: The Federal Trade Commission is in charges with overseeing the operations of CRAs that provide consumer reports for employment and residential screening purposes and enforcing the FCRA requirements.

When ClearStar provides Consumer Reports, it is subject to the FCRA and operates within FCRA framework. If you would like to obtain a report about the information ClearStar maintains about you, please call toll free 1-877-275-7099or email service@clearstar.net.

For credit reports from the credit bureaus, please visit:

https://www.annualcreditreport.com/cra/index.jsp

Privacy Notice: Preparation and Processing of Investigative Consumer Reports  

This notice is provided to California residents. Under California law, an “investigative consumer report” is a consumer report containing information on a consumer’s character, general reputation, personal characteristics, or mode of living. ClearStar may provide investigative consumer reports about individuals and in such case, it provides them to business for employment screening, resident screening, and similar purposes.

Personal Information Disclosure: United States or Overseas – In connection with its preparation and processing of investigative consumer reports, ClearStar may transfer personal information about you to ClearStar authorized service providers and affiliates outside the United States and its territories. In such case, the transfer will be conducted in accordance with all applicable laws and regulations.

To obtain additional information about the privacy practices and policies of ClearStar in connection with its preparation and processing of investigative consumer reports, please contact:

ClearStar
Nicolas Dufour
General Counsel
United States
+1-877-796-2559
nicolasd@ ClearStar.net

For additional information about privacy or consumer reporting, visit the following websites:

Federal Trade Commission: www.ftc.gov
Consumer Financial Protection Bureau: http://www.consumerfinance.gov/
Consumer Data Industry Association: www.cdiaonline.org
Experian: www.experian.com/consumer/credit_education.html
Equifax: https://www.econsumer.equifax.com/consumer/landing.ehtml?^start=&companyName=PSHP1_hpg
TransUnion: http://www.transunion.com/corporate/personal/personal.page
California Office of Privacy Protection: www.privacy.ca.gov

Privacy Vision 

ClearStar is committed to the responsible use of information and protecting individual privacy rights.  ClearStar strives to provide services to mitigate risk, facilitate more informed decisions, and make the world safer, in ways that protect consumer privacy.  ClearStar aspires to protect consumer privacy through the design of its processes, by credentialing, monitoring, and/or auditing its clients as appropriate, and through other information security safeguards.  ClearStar also strives to promote transparency through appropriate opportunities for consumer choice, access, and correction with respect to personal information about the consumer.

EUROPEAN UNION SAFE HARBOR PRIVACY POLICY

ClearStar respects the privacy of its visitors and clients. It is ClearStar policy to maintain the confidentiality and privacy of any personal data voluntarily submitted to ClearStar in writing, submitted electronically via ClearStar Website, or submitted to ClearStar by its clients in connection with employment background screening, credential verification, investigations, residential screening and other services.

Scope 

This Safe Harbor Privacy Policy (“Policy”) applies to personal information pertaining to an identified or identifiable individual that is received by ClearStar from the European Union or other personal information that ClearStar acquires pursuant to its performance of services for its clients or other third parties to which ClearStar has contractually agreed to apply this privacy policy (“EU Personal Data”). This Policy does not apply to: (a) data collected and used by ClearStar which is not EU Personal Data; (b) ClearStar’s affiliated entities that do not receive or process EU Personal Data or; (c) data collected on any other ClearStar’s affiliated entities not reasonably calculated to capture EU Personal Data. Those entities websites reasonably calculated to capture EU Personal Data contain a link to this Safe Harbor Privacy Policy.

In the event of a conflict between this Policy and ClearStar’s obligations under the Fair Credit Reporting Act, 15 U.S.C. Sec. 1681 et. seq., other statutes, regulations, or case law, or to the extent necessary to meet national security, public interest or law enforcement requirements, adherence to this Policy may be limited.

Provisions of ClearStar Safe Harbor Privacy Policy

ClearStar receives certain EU Personal Data at the request of clients and other third parties for investigative, credential verification, employment and residential related purposes. ClearStar has joined the U.S. Department of Commerce’s “Safe Harbor” program with respect to EU Personal Data and utilizes such information in accordance with the Safe Harbor principles. The Safe Harbor principles and ClearStar Safe Harbor certification can be found at www.export.gov/safeharbor. ClearStar Policy addresses each of the Safe Harbor Privacy Principles, as described below.

1. Notice

Where ClearStar collects EU Personal Data from individuals, individuals are informed about the purposes for which it collects and uses EU Personal Data about them, how to contact ClearStar with any inquiries or complaints, the types of third parties to which it discloses the information and the choices and means ClearStar offers individuals for limiting its use and disclosure. Notice is provided in clear and conspicuous language either when individuals are first asked to provide EU Personal Data or as soon thereafter as is practicable, but in any event before ClearStar uses such information for a purpose other than that for which it was originally collected or processed by the transferring organization or discloses it for the first time to a third party (other than agents acting under our instructions). Information about how ClearStar collects and uses EU Personal Data also follows below.

ClearStar gathers consumer and other data which it provides to employers or their agents (such as recruiters or staffing firms) for use in making employment-related decisions, such as who to hire, retain, promote, or re-assign. ClearStar also gathers consumer and other data which it provides to entities including landlords. Below is an illustrative list of common ways in which employers use the data provided by this service:

Performance of applicant and employee background checks

Verification of the credentials of job applicants and current employees

Investigation into a suspicion of work-related misconduct or wrongdoing

Investigation into matters of employee compliance with employer policies, or

Investigation into matters of employee compliance with Federal, State, or local laws and regulations

The scope of this notice covers consumer report data that ClearStar has obtained on behalf of employers and other businesses by manually or electronically contacting the appropriate sources of the data (court records, references, licensing bureaus, etc.). ClearStar also performs services related to corporate litigation and investigative services as requested by ClearStar clients.

More information regarding the nature and scope of consumer data inquiries is available by contacting ClearStar in writing or by e-mail at the addresses listed on the Contact Us page or by writing to the contacts listed below.

2. Choice

ClearStar offers individuals the opportunity to choose (opt-out) whether their EU Personal Data will be disclosed to a third party (not including ClearStar agents) or be used for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized by the individual. With respect to sensitive information, however, an individual must “opt-in” to the disclosure of the information to a non-agent third party or to the use of this information for a purpose other than its original purpose or that purpose authorized subsequently by the individual. ClearStar will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.

3. Onward Transfer (Transfers to Third Parties)

With respect to the transfer of EU Personal Data to third parties (other than ClearStar agents), the principles of “Notice” and “Choice” apply. Accordingly, EU Personal Data is only provided to third parties for purposes described in the “Notice” section or otherwise disclosed to consumers, and will not be disseminated to a third party where a consumer has “opted-out” or, in the case of sensitive information, failed to “opt-in.”

ClearStar may disclose EU Personal Data clients and third parties, which may include employers or their agents, landlords or their agents, who certify that they subscribe to the Safe Harbor Principles or the EU Data Protection Directive or a law subject to an adequacy finding by the EU. ClearStar also may disclose EU Personal Data to employer clients, other types of clients or their agents who enter into a written agreement with ClearStar, in which the third party agrees to comply with the FCRA, if applicable, and to provide at least the same level of privacy protection as is required by the seven Safe Harbor Principles (in the instance where EU Personal Data is requested).

4. Access

A consumer may request, in writing, access to all EU Personal Data collected and maintained about him or her. ClearStar affords the consumer a reasonable opportunity to correct, amend, or delete information that is inaccurate or incomplete, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated.  In cases where the information is subject to the FCRA, ClearStar complies with the FCRA’s requirements regarding access and correction rights of consumers.

ClearStar reserves the right to engage in reasonable efforts to confirm the identity of the individual requesting EU Personal Data to ensure the information is provided only to the subject of the data.

To request information relating to his or her EU Personal Data, a consumer may contact ClearStar by fax, or by e-mail at the following email address, service@clearstar.net or by fax 678-807-2913. In addition, the consumer will be asked to provide sufficient evidence of his or her identity so we may ensure that information is being released to the correct individual. If we are unable to provide the consumer with access to his or her EU Personal Data or to correct the data, we will notify the consumer.

5. Security

ClearStar takes reasonable procedures to protect EU Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.

6. Data Integrity

ClearStar collects EU Personal Data that is relevant for the purposes for which it is to be used, consistent with the Safe Harbor Principles.  ClearStar processes EU Personal Data in ways that are compatible with the purposes for which it has been collected (as identified in the Notice section above) or subsequently authorized by the individual.  To the extent necessary for those purposes, ClearStar takes reasonable steps to ensure that EU Personal Data collected is accurate, complete, current, and reliable for its intended use.

7. Enforcement

ClearStar will verify adherence to the EU Safe Harbor Policy via in-house verification and internal policies and procedures implemented by the management of our company. ClearStar also will cooperate with an independent third party as a means of providing consumers a readily available and affordable recourse mechanism by which individual consumer complaints and disputes, if any, can be investigated and remedied.

8. Amendments

From time to time, this Privacy Policy may be amended to reflect new products and services, or as necessary to reflect a new business practice.  Consistent with the Safe Harbor requirements, ClearStar will post any revised policy on this Website.

Contact information 

To request information relating to your EU Personal Data, please contact: service@clearstar.net.

If you have questions regarding our Safe Harbor Privacy Policy contact:

ClearStar
Nicolas Dufour
EVP and General Counsel
United States
+1-678-999-8048
nicolasd@clearstar.net

SWITZERLAND SAFE HARBOR PRIVACY POLICY

ClearStar respects the privacy of its visitors and clients. It is ClearStar policy to maintain the confidentiality and privacy of any personal data voluntarily submitted to ClearStar in writing, submitted electronically via ClearStar Website, or submitted to ClearStar by its clients in connection with employment background screening, credential verification, investigations, residential screening and other services.

Scope 

This Safe Harbor Privacy Policy (“Policy”) applies to personal information pertaining to an identified or identifiable individual that is received by ClearStar from the Switzerland or other personal information that ClearStar acquires pursuant to its performance of services for its clients or other third parties to which ClearStar has contractually agreed to apply this privacy policy (“Switzerland Personal Data”). This Policy does not apply to: (a) data collected and used by ClearStar which is not Switzerland Personal Data; (b) ClearStar’s affiliated entities that do not receive or process Switzerland Personal Data or; (c) data collected on any other ClearStar’s affiliated entities not reasonably calculated to capture Switzerland Personal Data. Those entities websites reasonably calculated to capture Switzerland Personal Data contain a link to this Safe Harbor Privacy Policy.

In the event of a conflict between this Policy and ClearStar’s obligations under the Fair Credit Reporting Act, 15 U.S.C. Sec. 1681 et. seq., other statutes, regulations, or case law, or to the extent necessary to meet national security, public interest or law enforcement requirements, adherence to this Policy may be limited.

Provisions of ClearStar Safe Harbor Privacy Policy

ClearStar receives certain Switzerland Personal Data at the request of clients and other third parties for investigative, credential verification, employment and residential related purposes. ClearStar has joined the U.S. Department of Commerce’s “Safe Harbor” program with respect to Switzerland Personal Data and utilizes such information in accordance with the Safe Harbor principles. The Safe Harbor principles and ClearStar Safe Harbor certification can be found at www.export.gov/safeharbor. ClearStar Policy addresses each of the Safe Harbor Privacy Principles, as described below.

1. Notice

Where ClearStar collects Switzerland Personal Data from individuals, individuals are informed about the purposes for which it collects and uses Switzerland Personal Data about them, how to contact ClearStar with any inquiries or complaints, the types of third parties to which it discloses the information and the choices and means ClearStar offers individuals for limiting its use and disclosure. Notice is provided in clear and conspicuous language either when individuals are first asked to provide Switzerland Personal Data or as soon thereafter as is practicable, but in any event before ClearStar uses such information for a purpose other than that for which it was originally collected or processed by the transferring organization or discloses it for the first time to a third party (other than agents acting under our instructions). Information about how ClearStar collects and uses Switzerland Personal Data also follows below.

ClearStar gathers consumer and other data which it provides to employers or their agents (such as recruiters or staffing firms) for use in making employment-related decisions, such as who to hire, retain, promote, or re-assign. ClearStar also gathers consumer and other data which it provides to entities including landlords. Below is an illustrative list of common ways in which employers use the data provided by this service:

Performance of applicant and employee background checks

Verification of the credentials of job applicants and current employees

Investigation into a suspicion of work-related misconduct or wrongdoing

Investigation into matters of employee compliance with employer policies, or

Investigation into matters of employee compliance with Federal, State, or local laws and regulations

The scope of this notice covers consumer report data that ClearStar has obtained on behalf of employers and other businesses by manually or electronically contacting the appropriate sources of the data (court records, references, licensing bureaus, etc.). ClearStar also performs services related to corporate litigation and investigative services as requested by ClearStar clients.

More information regarding the nature and scope of consumer data inquiries is available by contacting ClearStar in writing or by e-mail at the addresses listed on the Contact Us page or by writing to the contacts listed below.

2. Choice

ClearStar offers individuals the opportunity to choose (opt-out) whether their Switzerland Personal Data will be disclosed to a third party (not including ClearStar agents) or be used for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized by the individual. With respect to sensitive information, however, an individual must “opt-in” to the disclosure of the information to a non-agent third party or to the use of this information for a purpose other than its original purpose or that purpose authorized subsequently by the individual. ClearStar will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.

3. Onward Transfer (Transfers to Third Parties)

With respect to the transfer of Switzerland Personal Data to third parties (other than ClearStar agents), the principles of “Notice” and “Choice” apply. Accordingly, Switzerland Personal Data is only provided to third parties for purposes described in the “Notice” section or otherwise disclosed to consumers, and will not be disseminated to a third party where a consumer has “opted-out” or, in the case of sensitive information, failed to “opt-in.”

ClearStar may disclose Switzerland Personal Data clients and third parties, which may include employers or their agents, landlords or their agents, who certify that they subscribe to the Safe Harbor Principles or the Switzerland Data Protection Directive or a law subject to an adequacy finding by the Switzerland. ClearStar also may disclose Switzerland Personal Data to employer clients, other types of clients or their agents who enter into a written agreement with ClearStar, in which the third party agrees to comply with the FCRA, if applicable, and to provide at least the same level of privacy protection as is required by the seven Safe Harbor Principles (in the instance where Switzerland Personal Data is requested).

4. Access

A consumer may request, in writing, access to all Switzerland Personal Data collected and maintained about him or her. ClearStar affords the consumer a reasonable opportunity to correct, amend, or delete information that is inaccurate or incomplete, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated.  In cases where the information is subject to the FCRA, ClearStar complies with the FCRA’s requirements regarding access and correction rights of consumers.

ClearStar reserves the right to engage in reasonable efforts to confirm the identity of the individual requesting Switzerland Personal Data to ensure the information is provided only to the subject of the data.

To request information relating to his or her Switzerland Personal Data, a consumer may contact ClearStar in writing or by e-mail at the following email address, service@clearstar.net or by writing to the contacts listed below. In addition, the consumer will be asked to provide sufficient evidence of his or her identity so we may ensure that information is being released to the correct individual. If we are unable to provide the consumer with access to his or her Switzerland Personal Data or to correct the data, we will notify the consumer.

5. Security

ClearStar takes reasonable procedures to protect Switzerland Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.

6. Data Integrity

ClearStar collects Switzerland Personal Data that is relevant for the purposes for which it is to be used, consistent with the Safe Harbor Principles.  ClearStar processes Switzerland Personal Data in ways that are compatible with the purposes for which it has been collected (as identified in the Notice section above) or subsequently authorized by the individual.  To the extent necessary for those purposes, ClearStar takes reasonable steps to ensure that Switzerland Personal Data collected is accurate, complete, current, and reliable for its intended use.

7. Enforcement

ClearStar will verify adherence to the Switzerland Safe Harbor Policy via in-house verification and internal policies and procedures implemented by the management of our company. ClearStar also will cooperate with an independent third party as a means of providing consumers a readily available and affordable recourse mechanism by which individual consumer complaints and disputes, if any, can be investigated and remedied.

8. Amendments

From time to time, this Privacy Policy may be amended to reflect new products and services, or as necessary to reflect a new business practice.  Consistent with the Safe Harbor requirements, ClearStar will post any revised policy on this Website.

Contact information 

To request information relating to your Switzerland Personal Data, please contact: service@clearstar.net.

If you have questions regarding our Safe Harbor Privacy Policy contact:

ClearStar
Nicolas Dufour
EVP and General Counsel
United States
+1-678-999-8048
nicolasd@clearstar.net

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1/22/2015
SingleSource Is Now a Service Offering of ClearStar, Inc.
10/14/2014
October 12-14 Single Source at National HCAOA Conference, Kansas City
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OneChurch - Conway, AR
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