Data that we collect
MyClearStep collects data to operate effectively and provide you the best experiences with the Service. You provide some of this data directly, such as when you create a MyClearStep account, input data into your profile, or contact us for support. We get some of it by recording how you interact with the Service by, for example, using technologies like cookies, and receiving error reports or usage data from software running on your device. We may also obtain data from third parties (including other companies). For example, we may supplement the data we collect by purchasing demographic data from other companies. We also use services from other companies to help us determine a location based on your IP address in order to customize the Service to your location, or to help us process payments. The data we collect depends on the features and aspects of the Service you use, and includes the following. Name and contact data. We collect your first and last name, email address, postal address, phone number, and other similar contact data. Credentials. We collect passwords, password hints, and similar security information used for authentication and account access. Demographic data. We collect data about you such as your age, gender, country and preferred language. Interests and behaviors. In addition to those you explicitly provide, your interests and behaviors may also be inferred or derived from other data we collect. Payment data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. Usage data. We collect data about how you and your device interact with the Service. This includes data, such as the features you use, the items you purchase, the web pages you visit, and the search terms you enter. This also includes data about your device and the network you use to connect to the Service, including IP address, device identifiers (such as the IMEI number for phones), regional and language settings. It includes information about the operating systems and other software installed on your device, including product keys. And it includes data about the performance of the Service and any problems you experience with it. Contacts and relationships. Location data. We collect data about your location, which can be either precise or imprecise. Precise location data can be Global Position System (GPS) data, as well as data identifying nearby cell towers and Wi-Fi hotspots, we collect when you enable location-based services or features. Imprecise location data includes, for example, a location derived from your IP address or data that indicates where you are located with less precision, such as at a city or postal code level. Content. We collect the content of your files and communications when necessary to provide you with the Service. For example, we collect any photos, content or posts you upload to your MyClearStep account. We also collect the content of messages you send to us, such as feedback and product reviews you write, or questions and information you provide for customer support. When you contact us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded. You have choices about the data we collect. When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary to provide the Service, you may not be able to use some features or the Service itself.
How we use your data
MyClearStep uses the data we collect for three basic purposes, described in more detail below: (1) to operate our business and provide (including improving and personalizing) the Service we offer, (2) to send communications, including promotional communications, and (3) to display advertising.
Providing and improving our services. We use data to provide and improve the Service we offer and perform essential business operations. This includes operating the Service, maintaining and improving the performance of the Service, including developing new features, research, and providing customer support. Examples of such uses include the following.
Providing the Services. We use data to carry out your transactions with us and to provide the Service to you. The Service includes personalized features and recommendations intended to enhance your lifestyle and enjoyment, and tailor your Service experiences based on your activities, behaviors, interests and location.
a) Customer support. We use data to diagnose Service problems, repair customers’ devices, and provide other customer care and support services.
b) Product activation. We use data – including device and application type, location, and unique device, application, network and subscription identifiers – in order to activate software and devices that require activation.
c) Service Improvement. We use data to continually improve our Service, including adding new features or capabilities.
d) Security, Safety and Dispute Resolution. We use data to protect the security and safety of our Service and our customers, to detect and prevent fraud, to confirm the validity of software licenses, to resolve disputes and enforce our agreements.
e) Business Operations. We use data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business.
Information Collection and Use
Our primary goals in collecting information are to provide and improve our Site, services, features and content, to administer your membership (together, the “Service”) and to enable users to enjoy and easily navigate the Site.
Personally Identifiable Information
- When you register with us through the Site, we will ask you for personally identifiable information. This refers to information about you that can be used to contact or identify you (“Personal Information”). Personal Information includes, but is not limited to your name and email address. We will use your Personal Information to create a MyClearStep account (“Account”) and you will become a member of MyClearStep (“Member”). We use your Personal Information mainly to provide the Service and to administer your Account and inquiries.
- We also collect the other information that you provide as part of registration and the administration of your Account (e.g., without limitation, zip code (on its own), city and state and individual preferences) (“Non-Identifying Information”).
- We may publicly display on the Site certain Healthcare and Financial Information that is Non-Identifying Information, including, but not limited to, the names and contact information of doctors and names and prices for medical procedures.
- We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) mainly to provide the Service and administer your inquiries.
- Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your preferences). We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other MyClearStep Members to attempt to provide you with a better experience, to improve the quality and value of the Service and to analyze and understand how our Site and Service are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.
- We also use your Personal Information to contact you with MyClearStep newsletters, marketing or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or update your preferences via the “Settings” section of the Site. (See “Changing or Deleting Information,” below.)
When you visit the Site, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, pages of our Site that you visit, the time spent on those pages, information you search for on our Site, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site and the Service and for the Site’s technical administration, to increase our Site’s functionality and user-friendliness, and to better tailor it to our visitors’ needs. We also use this information to verify that visitors to the Site meet the criteria required to process their requests. We do not treat Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
From time to time we may provide you the opportunity to participate in surveys, contests or sweepstakes (collectively, “Promotions”) on our Site. If you decide to participate, we will request certain Personal Information from you. Participation in these Promotions is completely voluntary and you have a choice whether or not to disclose this information. We use this information to administer your participation in each Promotion.
Identity theft and the practice currently known as “phishing” are of great concern to MyClearStep. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your login information or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
Information Sharing and Disclosure
Please note that MyClearStep does not sell, rent or trade Personal Information with third parties for such third parties’ promotional or marketing purposes.
Aggregate Information and Non-Identifying Information. We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for enhancement of features of the Service, industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.
Service Providers. We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Site-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Site’s features) or to assist us in analyzing how our Site and Service are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Compliance with Laws and Law Enforcement. MyClearStep cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of MyClearStep or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
Business Transfers. MyClearStep may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
Changing or Deleting Your Information and Data Retention
All Members may review, update, correct or delete the Personal Information in their Account by contacting us or by making edits via the “profile” section of the Site. If you completely delete all such information, then your Account may become deactivated.
We will retain your information, including Personal Information, for as long as your Account is active or as needed to provide you the Service. If you would like us to delete your record in our system, please contact us at Support@myclearstep.com with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.
MyClearStep is very concerned with safeguarding your information. The security of your personal information is important to us. But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. When you enter sensitive information or otherwise provide MyClearStep with access to sensitive information (such as login information and Personal Information), we encrypt that information using secure socket layer technology (SSL). In some cases, we also encrypt sensitive information where it is stored on our systems. MyClearStep has been verified by Verisign for its use of SSL encryption technologies. In addition, MyClearStep tests the Site daily for any failure points that would allow hacking.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on this Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
MyClearStep Offers and Links to other Websites
Our Site contains links to other websites and offers for third party products or services that may be complementary to your use of the Site. If you click on a third party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
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Our Policy Toward Children
This Site is not directed to individuals under 18. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at Support@myclearstep.com. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.