- September 30, 2021
- Posted by: Clearport Team
- Category: General
Privacy Statement and
User Consent to Data Storage and Processing
Effective: May 2021.
At Clearport, 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 Canada and/or countries in which Clearport operates.
This Privacy Statement describes Clearport’s general privacy practices that apply to personal information we collect, use, and share about our members and clients, with allies, business partners, suppliers, and other organizations (such as Schools, the Government of Canada, or others).
This Privacy Statement does not apply to the extent Clearport processes personal information on behalf of clients for their benefit and under their control (as a “processor”), such as Cloud Services or applications (“apps”). It may apply to collection of information related to authorized users of such services to the extent Clearport processes this information for its own interests (as “controller”).
Clearport’s website stores cookies on your computer. These cookies are used to collect information about how you interact with our website and allow us to remember you. We use this information in order to improve and customize your browsing experience and for analytics and metrics about our visitors, both on this website and other media.
Why and how we collect and use your personal information
We may collect your personal information as an individual for various purposes, such as the following:
- Access and use of websites or other online service (including “apps”).
When entering one of our websites or allied third-party connected platforms, or when using a related online service or third-party platform (where references to online services include desktop or mobile applications or “apps”), we will record information necessary to provide you with access, for the operation of the websites or allied third-party connected platforms and for us to comply with security and legal requirements relating to operating these sites, such as passwords, IP address and browser settings.
We also collect information about your activities during your visit to personalize your online experience, such as recording your preferences and settings, and to collect statistics to help us improve and further develop our websites, related third-party online platforms, products, and services.
- Responding to your request for information, order, or support.
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. When you provide your name and contact information to register in connection with such a request, the registration may serve to identify you when you visit our websites. For ordering of most services and products, we require you to have registered as a Clearport Member. Registration may also allow you to customize and control your privacy settings.
- Your use of Clearport Cloud services.
- Contacting employees of our clients, prospects, partners, and suppliers.
Relating to the services we provide directly or through a third party, our clients or prospects (whether students, candidate workers, business/investors, employers), partners, suppliers, institutions and applicable Government offices all provide us with business contact information (such as name, contact details, position or title of their employees, contractors, advisors and authorized users) for purposes such as contract management, fulfillment, delivery of products and services, provision of support, invoicing and management of the services or the relationship.
- Visitor information.
We may register individuals visiting our websites (name, identification, and business contact information); completion of an online profile with Clearport might also ask from certain clients to supply photographs and/or Government-issued photograph ID as required by -and only as needed in their applications to- Educational Institutions, Assessment Partners or Government authorities. We may also register individuals visiting physical locations (name, identification, and business contact information) for reasons of security and safety of persons and belongings, as well as for regulatory purposes.
Most information we collect about you comes from our direct interactions with you. When you register online as a Clearport Member and complete an online Profile with us, or register for an event, we may collect information (online or offline) relating to your type of application (for example and without limitation, to study, work, invest in or immigrate to Canada), or for the event organization and your participation during an event, such as webinars, online sessions, assessments, interviews, and surveys.
We combine the personal information we collect to develop aggregate analysis and business intelligence for conducting our business and for marketing purposes. You can choose to receive information by email or telephone about our products and services. When visiting our websites or third-party platforms, or when using our services, we may provide you with personalized information.
Where we reference that we use your personal information in connection with a request, order, transaction, or agreement (or preparing for the same), or to provide you with services that you requested (such as an application or registration for it via a website or a third-party application), we do this because it is necessary for the performance of an agreement with you.
Where we reference that we use your personal information relating to marketing, improvement or development of our products or services, for reasons of safety and security, or regulatory requirements other than in connection with your agreement or request, we do this based on our or a third party’s legitimate interests, or with your consent. When we collect and use your personal information subject to the EU Privacy Legislation, this may have consequences for your rights.
Sharing of Personal Information
As a Canadian organization offering globally a wide range of products and services, with business processes, management structures, and technical systems that cross borders, Clearport has implemented global policies, along with standards and procedures, for consistent protection of personal information.
As a Canadian organization with a global service offering, we may share information about you with third parties and/or our subsidiaries world-wide and transfer it to countries in the world where we do business in accordance with this Privacy Statement. Between Clearport 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.
In some cases, Clearport may use third-party alliances and suppliers located in various countries to collect, use, analyze, and otherwise process personal information on its behalf. Where appropriate, Clearport may share your personal information with selected partners to help us provide you (or the organization you work for) products or services, or to fulfill your requests, or with your consent. When selecting our third-party allies, suppliers, and partners, we consider their data handling processes.
If Clearport decides to sell, buy, merge, or otherwise reorganize businesses in some countries, such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of such information from sellers.
It is Clearport’s practice to require appropriate protection for personal information in these types of transactions. Please be aware that in certain circumstances, personal information may be subject to disclosure to government agencies pursuant to a judicial proceeding, court order, or legal process. We may also share your personal information to protect the rights or property of Clearport, our third-party allies, 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.
The international footprint of Clearport can potentially involve transfers of personal information between different subsidiaries, as well as to third parties located in the countries where we do business. Some countries have implemented transfer restrictions for personal information, in connection with which Clearport takes various measures, including that, where required, Clearport implements PIPEDA (in Canada) or other standard contractual clauses (i.e., approved by the EU Commission), or similar contractual clauses in other jurisdictions. This includes transfers to suppliers or other third parties.
Information Security and Accuracy.
We intend to protect your personal information and to maintain its accuracy. Clearport implements reasonable physical, administrative, and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. For example, we (or our third-party providers) encrypt certain sensitive personal information such as credit card information when we (or our third-party providers) transmit such information over the Internet. We also require that our third-party allies and suppliers protect such information from unauthorized access, use and disclosure.
We will not retain personal information longer than necessary to fulfill the purposes for which it is processed, including complying with legal and regulatory obligations (e.g., audit, accounting, and statutory retention terms), handling disputes, the security of our processing, and for the establishment, exercise, or defense of legal claims in the countries where we do business. Because the circumstances may vary depending on the context and the services, the information provided in this Privacy Statement, or provided in a specific notice, may supply more detailed information on applicable retention terms.
How to contact us.
If you have a question related to this Privacy Statement, please contact us by using the Contact Form provided here. Your message will be forwarded to the appropriate member of Clearport’s Data Privacy Team, such as its Privacy Officer. Where this is relevant, the controller of your personal information is Clearport International Inc., Suite 205-279 Midpark Way SE, Calgary AB, T2X 1M2, Canada, unless indicated otherwise. Clearport is not the controller in situations such as:
- Personal information processed in connection with a contractual relationship, or when entering into a contractual relationship with a specific Clearport Client subsidiary, vendor, or third-party provider. In this case, the controller of personal information is the Clearport contracting company, which is the legal entity with which you or your employer have, or will have, the contract.
- Personal information collected on the physical site or location of a Clearport subsidiary. In this case, that subsidiary is the controller of the personal information.
You can request to access, update, or correct, and in certain circumstances, to delete your personal information. You also have the right to object to direct marketing. If you have any such request, please submit it using the Contact Form provided here. You may have additional rights pursuant to your local law applicable to the processing of data.
Right to Lodge a Complaint.
In the event you consider our processing of your personal information not to be compliant with the applicable data protection laws, you can lodge a complaint:
- Directly with Clearport by using the Contact Form provided here.
Changes to our Privacy Statement.
We may update this Privacy Statement from time to time to reflect changes to our data governance practices. The revised Privacy Statement will be posted here with an updated revision date. We encourage you to check back periodically for any changes or updates.
If we make a material change to our Privacy Statement, we will post a notice at the top of this page for 30 days. By continuing to use our websites and/or third-party online platforms after such revision takes effect, we consider that you have read and understand the changes.
Information Access, Privacy and Opt-Out Contact Form
For any of these purposes, please submit your request using the Contact Form provided here.
Other relevant information: