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Last Updated: September 7, 2016
NOTE THE CHANGE IN THE INTERNATIONAL COLLECTION & CROSS-BORDER TRANSFER OF PERSONAL INFORMATION SECTION. THE EU-US PRIVACY SHIELD POLICY HAS BEEN ADDED. THE SWITZERLAND SAFE HARBOR PRIVACY POLICY HAS BEEN UPDATED.

The following explains what personal data is collected by ClearStar, Inc. (“ClearStar”) and how it is used. This includes information provided on a ClearStar Website (“Website”), and information collected from third parties and other sources associated with ClearStar’s services such as employment, tenant, or occupational health screening.

For a discussion of how ClearStar handles personal information sent or obtained from outside of the United States, view the section on INTERNATIONAL COLLECTION & CROSS-BORDER TRANSFER OF PERSONAL INFORMATION. ClearStar has separate privacy policy statements that apply to personal information pertaining to an identified or identifiable individual that is received by ClearStar from: (i) the European Union (“EU”), called the EU-U.S. Privacy Shield Policy, and (ii) from Switzerland, called the Switzerland Safe Harbor Privacy Policy, which are further explained below.

The use of ClearStar Websites indicates your agreement to ClearStar’s privacy policy. 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 this 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.

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.

Data Protection Officer
The ClearStar Data Protection Officer for the United States, Canada, European Union and Switzerland is Kerstin Bagus, Director of Global Initiatives.

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

Privacy@ClearStar.net
Direct: (770) 416-1900 x872

ClearStar Website
Please carefully read ClearStar’s privacy policy to understand how ClearStar will treat the information you provide while visiting our Websites. As previously stated, this policy may change from time to time. Please check the policy each time you use a ClearStar Website for the most current information. This policy only applies to ClearStar and its affiliated entities. ClearStar’s Websites are 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’s Websites 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’s Websites. Safeguarding the privacy of information ClearStar may receive on its Websites is a top priority for ClearStar, its clients and consumers.

How ClearStar Collects and Use Information on its Websites
ClearStar follows the below privacy principles when you visit its Websites. In general, you can visit a 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.

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.

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 our Websites, you will not be able to use some of the features of the Websites, such as those for ordering reports.

Non-personally-identifiable information
ClearStar Websites also collect 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 our Websites is used only for responding to your inquiries and otherwise corresponding with you, for processing transactions you request, maintaining your account (if you have one), and for the administration, review and/or improving the content of ClearStar Websites. 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’s Data Privacy Office at Privacy@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. Individuals who would like to correct or suppress information provided to ClearStar should contact the 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. ClearStar may engage third parties in processing services requested by customers, such as screening for employment, tenant, and occupational health. ClearStar enters into service agreements with these third parties and 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 our Websites 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 submitted to ClearStar through this Website.

If you wish to access information held on you by ClearStar or request the correction of information you feel is inaccurate, 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 ClearStar Websites. 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 or service providers who need access in order to carry out their job responsibilities.

When ClearStar disposes of PII collected through our Websites, 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 nationally free of charge once per 12 months, twice in some states, or for a reasonable fee for additional disclosures. Please contact ClearStar at Service@ClearStar.net or call toll free 1-877-275-7099 if you need more information.

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 charge 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 on U.S. residents, 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 1-877-275-7099 or 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:

Kerstin Bagus
Director of Global Initiatives
United States
+1-770-416-1900 ext. 872
Privacy@ClearStar.net

For additional information about privacy or consumer reporting, visit the following websites:
Federal Trade Commission: www.ftc.gov
Consumer Financial Protection Bureau: www.consumerfinance.gov
Consumer Data Industry Association: www.cdiaonline.org
Experian: www.experian.com/consumer/credit_education.html
Equifax: www.econsumer.equifax.com/consumer/landing.ehtml?^start=&companyName=PSHP1_hpg
California Office of Privacy Protection: www.privacy.ca.gov

INTERNATIONAL COLLECTION & CROSS-BORDER TRANSFER OF PERSONAL INFORMATION

ClearStar may transfer your personally identifiable information to other countries outside of your home country, including to the United States (“U.S.”), by whatever means is determined to be appropriate in order to perform a background check that you authorized. Your information may also be processed and stored in other countries where ClearStar’s service providers are located. Your information may be subject to U.S. or other laws for disclosure and may be accessible to foreign law enforcement, national security agencies, or courts. Note that the laws regarding personal information in some of the jurisdictions involved may be different or less stringent than the laws of the country in which you reside. Please be aware that ClearStar may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

ClearStar utilizes a variety of methods to transfer personal information across country borders. This can include consent, contractual methods, and/or regulatory authority certifications. ClearStar maintains appropriate contracts in place with service providers who may view your personal information. ClearStar abides by the EU-US Privacy Shield Framework (“Privacy Shield”) developed by the U.S. Department of Commerce and the European Union and the Swiss–US Safe Harbor Framework (“Safe Harbor”).

CLEARSTAR’S EU AND SWISS PRIVACY STATEMENTS

ClearStar’s compliance with these Frameworks apply to personal information pertaining to an identified or identifiable individual that is received by ClearStar from the European Union or 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. This Policy does not apply to: (a) data collected and used by ClearStar which is not EU or Swiss 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 entity’s websites reasonably calculated to capture EU or Swiss Data contain a link to the policies listed below.

If you have questions regarding our EU-US Privacy Shield or Swiss Safe Harbor Privacy Policy contact:

Kerstin Bagus
Director of Global Initiatives
United States
+1-770-416-1900 ext. 872
Privacy@ClearStar.net

EU-U.S. PRIVACY SHIELD POLICY

The EU-U.S. Privacy Shield Policy applies to personal information ClearStar receives from the European Union.

ClearStar processes EU Personal Data at the request of clients and other third parties, and with the written consent of the data subject, for investigative, verification, employment and residential screening related purposes. This includes but is not limited to, identifying information about the data subject, employment and educational history, credit and insolvency reports, driving records, court records, criminal history checks, and other checks contracted by ClearStar’s client or by the data subject themselves. ClearStar uses this information to fulfill background screening requests by customers, which may be employers, other background screening companies, housing providers, and the data subject. ClearStar’s client is required to have obtained written consent from the data subject for this collection. ClearStar maintains written agreements for services with its clients.

ClearStar complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. ClearStar has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

1. Notice
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.

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

ClearStar customers who are processing EU Personal Data are contractually required to provide a legally compliant Notice to their data subjects, prior to submitting screening requests to ClearStar.

More information regarding the nature and scope of ClearStar’s data processing 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 contact listed below.

2. Choice
The information obtained by ClearStar is only used for the original purpose to which the data subject has consented, unless a new consent is obtained.A data subject may request ClearStar stop the processing of data they had previously consented to by contacting ClearStar directly. In such case, ClearStar will make every attempt to stop the processing as quickly as possible.

3. Accountability for Onward Transfer
ClearStar may engage third parties to perform functions on our behalf, in order to provide services requested by customers or data subjects. ClearStar enters into service agreements with these third parties and requires that the companies acting on ClearStar’s behalf abide by the ClearStar privacy policy and institute safeguards to protect the confidentiality of your information. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, ClearStar is potentially liable.

ClearStar 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. These ClearStar customers are contractually required to provide a legally compliant Notice to their data subjects prior to submitting screening requests to ClearStar.

Please be aware that ClearStar may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

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

5. Data Integrity and Purpose Limitation
The information obtained by ClearStar is only used for the original purpose to which the data subject has consented, unless a new consent is obtained. 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.

6. Access
A data subject, whose information is or was processed by ClearStar under the Privacy Shield, has the right to access all personal data collected and maintained about him or her by contacting us directly at Privacy@ClearStar.net. ClearStar affords the data subject 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 Fair Credit Reporting Act (“FCRA”), ClearStar complies with the FCRA’s requirements regarding access and correction rights of data subject.

ClearStar reserves the right to engage in reasonable efforts to confirm the identity of the individual requesting their personal data. This is done to ensure the information is provided only to the subject of the data. If we are unable to provide the individual with access to his or her EU Personal Data or to correct the data, we will notify the individual.To request information relating to his or her personal data, or to request processing be halted, a data subject may contact ClearStar at:

Fax: +1-678-623-3274
Email: Privacy@ClearStar.net

7. Recourse, Enforcement, and Liability
ClearStar is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and the Consumer Financial Protection Bureau (“CFPB”).

In compliance with the EU-US Privacy Shield Principles, ClearStar commits to answer questions and resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy or the processing of their personal information should first contact ClearStar at:

Kerstin Bagus
Director, Global Initiatives
United States
+1-770-416-1900 ext. 872
Privacy@ClearStar.net

ClearStar has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

ClearStar will cooperate with the EU Data Protection Authorities and comply with the advice of such authorities with respect to Human Resources data transferred from the European Economic Area in context of the employment relationship.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

SWITZERLAND SAFE HARBOR PRIVACY POLICY

The Switzerland Safe Harbor Privacy Policy applies to personal information ClearStar receives from Switzerland.

ClearStar complies with the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. ClearStar has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. If there is any conflict between the policies in this privacy policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern. To learn more about the US-Swiss Safe Harbor and to view our certification page, please visit http://www.export.gov/safeharbor/.

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.

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
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.

Information about how ClearStar collects and uses Swiss 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

ClearStar customers who are processing Swiss Personal Data are contractually required to provide a legally compliant Notice to their data subjects, prior to submitting screening requests to ClearStar.

More information regarding the nature and scope of ClearStar’s data processing 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 contact listed below.

2. Choice
The information obtained by ClearStar is only used for the original purpose to which the data subject has consented, unless a new consent is obtained.

A data subject may request ClearStar stop the processing of data they had previously consented to by contacting ClearStar directly. In such case, ClearStar will make every attempt to stop the processing as quickly as possible.

3. Onward Transfer (Transfers to Third Parties)
ClearStar may engage third parties to perform functions on our behalf, in order to provide services requested by customers or data subjects. ClearStar enters into service agreements with these third parties and requires that the companies acting on ClearStar’s behalf abide by the ClearStar privacy policy and institute safeguards to protect the confidentiality of your information.

ClearStar may disclose Swiss 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. These ClearStar customers are contractually required to provide a legally compliant Notice to their data subjects prior to submitting screening requests to ClearStar.

Please be aware that ClearStar may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

4. Access
A data subject, whose information is or was processed by ClearStar under the Privacy Shield, has the right to access all personal data collected and maintained about him or her by contacting us directly at Privacy@ClearStar.net. ClearStar affords the data subject 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 Fair Credit Reporting Act (“FCRA”), ClearStar complies with the FCRA’s requirements regarding access and correction rights of data subject.

ClearStar reserves the right to engage in reasonable efforts to confirm the identity of the individual requesting their personal data. This is done to ensure the information is provided only to the subject of the data. If we are unable to provide the individual with access to his or her EU Personal Data or to correct the data, we will notify the individual.

To request information relating to his or her personal data, or to request processing be halted, a data subject may contact ClearStar at:

Fax: +1-678-623-3274
Email: Privacy@ClearStar.net

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

6. Data Integrity
The information obtained by ClearStar is only used for the original purpose to which the data subject has consented, unless a new consent is obtained. ClearStar processes Swiss 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 Swiss 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.

In compliance with the US-Swiss Safe Harbor Principles, ClearStar commits to resolve complaints about your privacy and our collection or use of your personal information. Swiss citizens with inquiries or complaints regarding this privacy policy should first contact ClearStar at:

Kerstin Bagus
Director of Global Initiatives
United States
+1-770-416-1900 ext. 872
Privacy@ClearStar.net

ClearStar has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU Privacy Shield, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by ClearStar, please visit the BBB EU Privacy Shield web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

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: Privacy@ClearStar.net.