Last updated July 2021
Data processed by Clearstream can be classified in two ways:
- Data that has been collected by us for our own purposes; and
- 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.
How We Collect Personal Information
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 email@example.com
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.
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.
- For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050
- For the Internet Explorer web browser, please visit this page from Microsoft: http://support.microsoft.com/kb/278835
- For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
- For the Safari web browser, please visit this page from Apple: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
- For any other web browser, please visit your web browser’s official web pages.
You can learn more about cookies from the following third-party websites:
- AllAboutCookies: http://www.allaboutcookies.org/
- Network Advertising Initiative: http://www.networkadvertising.org/
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
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
Your information is not shared with or sold to other organizations for commercial purposes.
Retention of Data
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.
Disclosure of Data
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 firstname.lastname@example.org.
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 email@example.com or +1 (917) 818-4557.
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.
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.
All daily is backed up daily, and securely stored remotely.
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.
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 firstname.lastname@example.org, 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
- 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 email@example.com. Once you have made a request and we have verified it, we will respond within 45 days.
Right to Correction
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
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 firstname.lastname@example.org.
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
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
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 email@example.com] 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.
Links to Other Sites
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.
Please send any privacy-related concerns to firstname.lastname@example.org.
Or by mail:
13 Palafox Place
Pensacola, Florida 32502
You can also call us at: +1 (917) 818-4557