Privacy Policy

Last updated July 2021

This Privacy Policy outlines how Clearstream, LLC (“we” or “us”) collect and use our users’ (“you” or “your”) personal information, which we gather from our website and our web-based software and mobile app services (collectively referred to as “Clearstream”). We strive to ensure that any personal data we collect about you will be held and processed strictly in accordance with applicable data protection legislation, as set out in this notice.

This Privacy Policy also describes the choices you have regarding personal data we’ve collected about you. “Personal information” or “personal data” is any information that can be used to reasonably contact, link or identify someone.

Data processed by Clearstream can be classified in two ways: 

  1. Data that has been collected by us for our own purposes; and 
  2. Data collected by our users and used for their purposes. For example, your church may collect data about you and use this data to communicate with you.

This policy specifically covers data that is collected by us. We are not responsible for, nor do we have control over, the use of data that is collected by users of Clearstream.

By using Clearstream, you agree to the collection and use of your personal data in accordance with this policy. Terms used in this Privacy Policy have the same meanings as in our Terms of Services, which are incorporated herein by this reference.

How We Collect Personal Information

We collect several different types of personal data, which we use as described in this Privacy Policy (See “How We Use Personal Information,” below). For instance, we collect data:

During signup

When you sign up for Clearstream’s Services, we ask you to provide us with the following personal data: 

  • The name of the Organization (e.g., the church) you are affiliated with
  • Your email address
  • Your first name and last name
  • Your phone number
  • Cookies and Usage Data (discussed below)

We use this information for creating and administering your account, and in the ways described below. We also may use this information to contact you and send you email newsletters, marketing or promotional materials, or other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by clicking on the unsubscribe link in the emails, or by contacting our support team at help@clearstream.io

Automatically while you are using Clearstream

We also automatically collect information on how Clearstream is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of Clearstream that you use/visit, the time and date of your visit or use, the time spent on those pages or features of Clearstream, unique device identifiers and other diagnostic data. We use this data to analyze Clearstream’s performance and make our services more effective.

Through the use of Cookies 

We use cookies and similar tracking technologies to track the activity on Clearstream and we retain this information to provide and improve Clearstream.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse Clearstream

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of Clearstream.

Examples of Cookies we use:

  • Essential Cookies: These cookies are essential to provide you with Clearstream. For example, they allow you to log in.
  • Functionality Cookies: These cookies allow us to remember choices you make, or to provide certain features, such as enabling videos from third parties.
  • Analytics and Performance Cookies: These cookies are used to collect information about traffic to our Services and how users use our Services.

In addition to our own cookies, we may also use various third-party cookies to report usage statistics. For instance, we use Google Analytics only to improve Clearstream. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Please refer to Google’s Privacy Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on.

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.

You can learn more about cookies from the following third-party websites:

Through Carriers for Text Messaging Services

Clearstream’s Services include text messaging services. We share necessary personal information with the cell phone carriers to provide you with text messaging services. This may include data such as your affiliated organization, your first and last name, your specific carrier, and phone number. Additionally, the carriers may collect personal information data to support their business functions. This information is only used for the purposes for which it is provided.

When you choose to provide us with information

You may choose to provide us with personal information while interacting with us in various ways. For example, when you submit a request for help. This information is only used for the purposes for which it was provided.

How We Use Personal Information

We do not sell your personal data to others.

We use collected information for the following general purposes: 

  • To provide and maintain Clearstream
  • To notify you about changes to Clearstream
  • To allow you to participate in features of Clearstream
  • To provide customer support
  • To gather analysis or valuable information so that we can improve Clearstream
  • To detect, prevent and address technical issues
  • For billing purposes
  • To identify and authenticate users
  • To prevent fraud and spam
  • To provide you with products or services you have requested, such as newsletters
  • To communicate special offers and information that we think may be of interest to you, such as an offer for a free trial to a new feature of Clearstream

Service Providers

We share information with third parties who provide services on our behalf to help with our business activities and to provide Clearstream. These companies are authorized to use your personal information only for the sole purpose of providing services to us. These services include:

  • Processing payments
  • Providing customer service
  • Sending marketing communications
  • Fulfilling subscription services
  • Conducting research and analysis
  • Providing and maintaining a cloud computing environment 
  • Fixing bugs
  • Text messaging services

A list of these service providers and instructions on how to subscribe to updates to this list is available at https://clearstream.io/privacy-policy/.

Your information is not shared with or sold to other organizations for commercial purposes. 

Retention of Data

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. We will also retain Usage Data for internal analysis purposes. 

Transfer of Data

Your information, including personal data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including personal data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Disclosure of Data

Business Transaction

If we are involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

We may disclose your personal data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of our company
  • To prevent or investigate possible wrongdoing in connection with Clearstream
  • To protect the personal safety of users of Clearstream or the public
  • To protect against legal liability

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. If you have any questions about the security of your personal information, you can contact us at help@clearstream.io

If a breach of data occurs within Clearstream, we will inform you via a notification posted on Clearstream.io and via email at your last listed email address within 30 business days of discovering the breach. By using Clearstream, you acknowledge and agree that we may send you electronic notifications via email instead of notifications by mail. If you would still like to receive notifications by mail, you can let us know by contacting us at help@clearstream.io or +1 (917) 818-4557.

Application-Level Security

All code is reviewed by multiple developers and ran through a robust automated testing pipeline before it goes to production. Software dependencies are kept up-to-date, and code is periodically reviewed for potential vulnerabilities.

Data Encryption

All data sent to and from our servers is encrypted while in transit over HTTPS connections. Sensitive data is encrypted at rest when stored in our database. All passwords are filtered from our logs and one-way encrypted (salted and hashed), and rate-limiting is used to mitigate brute-force attacks.

Data Backup

All daily is backed up daily, and securely stored remotely.

Payment Processing

Our payment processor, Stripe, handles all credit card data storage and processing. No sensitive credit card information passes through our servers or is stored on our servers.

Your Rights

In General

Upon request, we will provide you with information about your personal data (such as the categories of personal information that we have collected about you, the specific pieces of personal data that we have collected about you, the categories of sources from which your personal information is collected, the purpose for collecting your personal information, and the categories of third parties with whom the business shares your personal information). You may request access, correct, request the deletion of, or object to our use of your personal information by contacting us at help@clearstream.io,  https://clearstream.io/contact/, or calling us at +1 (917) 818-4557. If you email us, please include “Personal Data Inquiry” as the subject line. Please note that we may ask you to verify your identity before responding to such requests. We will respond to your request within a reasonable timeframe and as set forth by the applicable laws. No users seeking to exercise these rights will be discriminated against in their use of Clearstream.

 In certain circumstances, we may be required by law to keep your personal information, or we may need to retain your personal information in order to continue providing Clearstream. Please note that we can only provide you with information about your personal data that we collect and use. We do not have control over, or information about, your personal data that other users collect or use. 

If we don’t resolve your concern in a reasonable time frame, you have the right to lodge a complaint with your local supervisory authorities.

Right to Know

You have the right to ask us:

  • What categories of personal information that have been collected
  • What categories of sources from which the personal information is collected
  • What the business or commercial purpose is for the collecting or selling of personal information (which is also explained in this Privacy Policy)
  • The categories of third parties that the business shares personal information with (which is also explained in this Privacy Policy)
  • The specific pieces of personal information that have been collected about you

You can ask us for this information and request access to your personal data by contacting us at https://clearstream.io/contact/, or help@clearstream.io. Once you have made a request and we have verified it, we will respond within 45 days.

Right to Correction 

You have the right to ask us to correct your personal data if it contains errors or inaccuracies. You may do so by https://clearstream.io/contact/, or help@clearstream.io.

Right to Opt Out of Automated Decision Making Technology & Access Information about Automated Decision Making Technology 

We currently do not use automated decision making technology with Clearstream. However, if we do in the future we will notify you via the email address we have on file, and post a notification on our website, clearstream.io.

Right to Restrict Sensitive Personal Data 

We currently do not collect government identifiers (such as Social Security numbers and driver’s licenses); financial account and login information (such as credit or debit card number together with login credentials); precise geolocation; race, ethnicity, religious or philosophical beliefs, or union membership; content of nonpublic communications (mail, email and text messages); genetic data; biometric or health information; and sex life or sexual orientation information. If we change this policy, we will update this paragraph accordingly and notify you of this change (pursuant to the notification process outlined in this Privacy Policy). 

Right to Data Portability

You may request that we provide your personal data to another entity (so long as it is technically feasible and legal for us to do so) in a commonly used and machine-readable format.

Selling Personal Information and The Right To Opt-Out

We do not sell (or trade, barter or exchange for money) your personal data to others. The use of your personal data is limited to the uses described above.  If we change our policy, we will send you notice to the email address listed in your account with us. We will also post the notice on our website, Clearstream.io, for seven days.

Additionally, in accordance with the California Consumer Privacy Act, if you are a California resident, you have the right to request information regarding the disclosure of your Personal Data to third parties. In order to make any such request, please contact us at https://clearstream.io/contact/, or help@clearstream.io.

If we do change our policy regarding the sale of your personal data, you have the right to request that we refrain from selling your personal data. If, in the future, we plan to sell any personal data, we will provide a mechanism where you can opt-out of the sale of your personal data.

Fair Information Practices 

If a breach of data occurs with our Service, we will notify you via a notification posted on the website Clearstream.io and via an email notification to the email you listed in your account with us within 30 business days of discovering the breach. By using Clearstream, you acknowledge and agree that we may send you electronic notifications via email for these notifications in lieu of notifications by mail. If you would still like to receive notifications by mail, you can let us know by contacting us.

Right to Request the Deletion of Personal Data

Pursuant to the California Consumer Privacy Act, California residents have a right to request that a business delete any personal data that has been collected from the consumer. In compliance with these provisions, upon a verifiable request we will delete the personal data you request that we delete. We will also notify third parties to delete any of your personal data, if we have provided them with your personal data.  However, we will not delete (or ask third parties to delete) personal data if it is necessary to maintain the information in order to: 

  • Complete the transaction for which the personal data was collected, provide a good or service you requested, or reasonably anticipated within the context of our ongoing business relationship, or otherwise perform a contract between us.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity. 
  • Debug to identify and repair errors that impact existing intended functionality. 
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided by law. 
  • Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code. 
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent. 
  • To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us. 
  • Comply with a legal obligation.
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Right to Equal Service

You have a right to equal service. This means that we will not deny you any goods or services, charge you a different price, or provide a different quality of service, if you decide to exercise any rights listed in this Privacy Policy or granted to you by law. 

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), our legal basis for collecting and using the personal information described in this Privacy Policy depends on the personal data we collect and the specific context in which we collect it.

We may process your personal data because:

  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it is not overridden by your rights
  • To comply with the law

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete or limit the use of your personal data. If you wish to be informed about what personal data we hold about you and if you want it to be removed from our systems, please contact us at [https://clearstream.io/contact/, or help@clearstream.io] or at +1 (917) 818-4557. If you email us, please include “Personal Data Inquiry” as the subject line.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your personal data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your personal data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Clearstream contains links to other sites that are not operated by us. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Use of Clearstream

We do not knowingly collect information from anyone under the age of 13. In order to use Clearstream, you must be old enough to consent to the collection of your personal data in your jurisdiction.

Amendments

We may periodically update this policy. We will notify our users about significant changes to this Privacy Policy by sending a notice to the user’s primary email address listed with us and by placing a prominent notice on our in our applications.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Questions

Please send any privacy-related concerns to help@clearstream.io.

Or by mail:

Clearstream

13 Palafox Place

Pensacola, Florida 32502

You can also call us at: +1 (917) 818-4557


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