Table of Contents
As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.
The Collection of Information
Our principal goals in collecting information are to provide and improve our Site, Application, services, features and content, to administer your use of the Site and Application (collectively, the “Service”) and to enable users to enjoy and easily navigate the Site and Application. The types of information that we collect include:
Information you provide to us
Personal Information: You may browse the Site and Application without providing any personal information that may be used to identify you personally. However, when you register for and use the Service, access certain content or features, or directly contact the Site or Application, we may ask you to provide information, including:
your name, phone number, mobile phone number, email address and postal address;
your username, password, and account setting preferences;
your credit card number, billing address and other billing related information.
(collectively, “Personal Information”) Information automatically collected When you visit and interact on the Site or Application, certain information is collected automatically, including:
Non-Identifying Information: We collect other non-identifying information you provide as part of the registration, administration and personalization of your Prox Account profile (e.g. account preferences) (“Non-Identifying Information”). We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other Prox Users (defined below) to attempt to provide you with a better experience, to improve the quality and value of the Site, Application and Service and to analyze and understand how our Site, Application 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.
Log Data: When you visit the Site and Application, whether as a Member or a non-registered user (any of these, a “Prox User”), 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, browser type or the webpage you were visiting before you came to our Site and Application, pages of our Site and Application that you visit, the time spent on those pages, information you search for on our Site and Application, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site, Application and the Service and for the Site and Application’s technical administration, to increase our Site and Application’s functionality and user-friendliness, and to better tailor our Site and Application to our visitors’ needs. 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.
Web Beacons: Our Site and Application may contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our Site and Application are used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our Member communications and marketing campaigns.
(c) Information collected from other sources
We may access information about you from third-party sources and platforms. You can register to use the Service by logging into online accounts you may have with third party service providers (“TPSP”)(e.g. Facebook, Twitter or LinkedIn); each such account, a “Third Party Account”, via our Site or Application as described below. As part of the functionality of the Site, Service and Application, you may link your Prox Account with Third Party Accounts, by either: (i) providing your Third Party Account login information to Prox through the Site, Service or Application; or (ii) allowing Prox to access your Third Party Account, as is permitted under the applicable terms and conditions that govern your use of each Third Party Account. You represent that you are entitled to disclose your Third Party Account login information to Prox and/or grant Prox access to your Third Party Account for use for the purposes described herein without breach by you of any of the terms and conditions that govern your use of the applicable Third Party Account and without obligating Prox to pay any fees or making Prox subject to any usage limitations imposed by the applicable TPSP.
If you register by logging into a Third Party Account via our Site or Application, we will obtain the Personal Information you have provided to the applicable TPSP (such as your true name, email address, profile picture, names of TPSP friends, names of TPSP groups to which you belong, other information you make publicly available via the applicable TPSP and/or other information you authorize Prox to access by authorizing the TPSP to provide such information) from your Third Party Accounts and use that information to create your Prox Account and Prox Account profile page. Depending on the Third Party Accounts you choose and subject to the privacy settings that you have set in such Third Party Accounts, you understand that by granting us access to the Third Party Accounts, we will access, make available and store (if applicable and as permitted by the TPSP and authorized by you) the information in your Third Party Accounts so that it is available on and through your Prox Account on the Site, Service and Application. If there is information about your “friends” or people with whom you are associated in your Third Party Account, the information we obtain about those “friends” or people with whom you are associated, may also depend on the privacy settings such people have with the applicable TPSP.
Use of Your Information
Mobile Communications: With your consent, we may use your mobile phone number to send you information, notifications and updates regarding the Site, Application or Service.
Profile Information: We use the information we collect at registration to create your Prox Account and Prox Account profile page. Your Prox Account profile page will include, among other things, your first and last name, your profile picture and your location. You can select the other items of Personal Information that you wish to be included in your Prox Account profile page – including, but not limited to, a list of the TPSP groups to which you belong, a list of any of your TPSP friends or connections who are also Members of Prox, connections you have established between your Prox Account and any TPSPs, and a biography and links to your Listings, if applicable (together, your “Profile Information”). We will display your Profile Information in your Prox Account profile page publicly via the Site and Application, and, with your prior permission, on third party sites. Any information you choose to provide as part of your Profile Information will be publicly visible to all Prox Users and consequently should reflect how much you want other Prox Users to know about you. We recommend that you guard your anonymity and sensitive information and we encourage Members to exercise caution regarding the information disclosed in their Prox Account profile page. You can review and edit your Profile Information at any time.
Listings: If you create a Listing, we may publish, use, share or otherwise disclose the Content of that Listing publicly via the Site and Application and may enable third parties to publish the Listing on their websites.
Prox Marketing: We may also use your Personal Information to contact you with Prox newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of these marketing related notifications at any time by accessing the “Manage Notifications” section of your Prox Account. Please note that we may also use your Personal Information to contact you with information related to your use of the Service; you may not opt out of these notifications.
Request Fulfillment: We may use the information that we collect to fulfill your requests for products, services and information. For example, we may use your information to respond to your customer service requests.
Data Analysis: In order to learn more about how our Site, Application and Service are used, we aggregate and analyze the data we collect. We may use the information, for example, to monitor and analyze use of the Site, Application and Service, to improve the functionality of same and to better tailor our content and design to suit our visitors’ needs.
Testimonials: Prox posts testimonials on the Site and Application. With your consent, we may post your testimonial on the Site and Application along with your name. To have your testimonial removed, please contact us at email@example.com.
Information Sharing and Disclosure
Analysis: 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 industry analysis, demographic profiling, payment processing, customer service and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.
Service Delivery: We may employ third party companies and individuals to perform Site-related services, including maintenance services, database management, web analytics, data processing and email and text message distribution. These third parties have access to your information only to perform these tasks on our behalf.
Investigations: We may share information about you to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety or other rights and interests of any person, violations of Prox’s Terms of Service, or as otherwise required by law.
Compliance with Laws: We may share information about you to respond to subpoenas, search warrants, judicial proceedings, court orders, legal process, or other law enforcement measures, to establish or exercise our legal rights, or to defend against legal claims.
Third Party Services
To customize your experience on the Site and Application and to simplify our registration process, we provide you with the opportunity to access or interact with TPSPs, such as Facebook, Twitter and LinkedIn. When you connect to the Site or Application through these TPSPs, we may share information about you with these third-party service providers and they may share data about you with us.
When you allow us to access your data through a third-party service to create a Site account, we may use this data for several purposes, including:
Creating relationships automatically within our system. For example, if you connect to us via a service with a public friend list, like Twitter, we may check to see if any people you follow on Twitter are also Site members. If web find a match, we will replicate your Twitter relationship with those members, setting them to be fans, followers, or friends on our Site.
Populating a list of potential friends to whom you can send service-specific messages. For example, we may use friend lists from a TPSP to create a list of contacts to whom you may choose to share your Prox Account profile page.
To enhance and personalize your experience on the Site. When you are connected via a TPSP, we may access certain account information, such as your profile picture, in order to enhance and personalize your experience on the Site.
Please remember that we do not control the privacy practices of these third-party services. We encourage you to read the privacy policies of all TPSP websites.
Updating and Deleting your Personal Information
All Members may review, update, correct or delete the Personal Information in their registration profile by contacting us at firstname.lastname@example.org or editing their profile. If you would like us to deactivate your Prox Account, please contact us or select the “Cancel Account” feature of the Service and we will attempt to accommodate your request if we do not have any legal obligation or a legitimate business reason to retain the information contained in your Prox Account. Please note that, if you cancel your Prox Account, any of your Member Content on the Site and Application will remain publicly viewable via the Site and Application. Please see below for privacy contact information
Security and Data Retention
To protect your privacy and information, Prox uses multiple security procedures and practices to protect from unauthorized access, destruction, use, modification and disclosure of Personal Information of users.
When you enter Personal Information on our Site and Application, we encrypt that information using secure socket layer technology (SSL). SSL creates a secured connection between our web servers and your browser, which protects against unauthorized access to transmitted data and supports data being sent only to intended recipients.
Your Personal Information is password protected and our main servers are locked and hosted by a leading provider of Internet access to enterprises with mission-critical Internet application requirements. Access to the host environment is secure.
Identity theft and the practice currently known as “phishing” are of great concern to Prox. 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 Prox Account ID, login password, or national identification numbers in a non-secure or unsolicited email or telephone communication.
We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site and Application, you can contact us at email@example.com.
Note that 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 the Site and Application 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.
Sharing personal email addresses, phone numbers, Skype/IM usernames or any other personal contact details.
All communications, information and files exchanged should be performed exclusively using Prox’s messaging system. The main reason this it is required is to keep communications and transactions on Prox is for your safety. The internet industry has traditionally been inundated with risk and uncertainty. Prox is a new form of communications. For this community to thrive, security and trust must be maintained for all users. This is only possible through maintaining initial conversations within the Prox application. Protecting our users’ privacy is of critical concern for everyone on the Prox team. To protect our users’ privacy, personal information should be kept anonymous. Requesting or providing email addresses, skype/IM usernames or other personal contact details (other than your name) are strictly prohibited. Prox’s Call Back service and User Inboxes are designed to enable communication between all users.
Prox and its third party partners to whom we disclose information under this policy may perform activities outside of the United States and potentially collect, transfer, store, and process your personal information in other countries. As a result, your information may be subject to the laws of those countries or other jurisdictions. These laws may not be equivalent to the privacy and data protection laws in your jurisdiction. Information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in these countries. By using the Site, Application or providing us with your information, you consent to the potential collection, transfer, storage, and processing of information in other countries.
We will make available to you any of your personal information that we have collected, used or disclosed upon request. Please contact us at support@cl arity.fm.
Updates to This Policy
Addressing Your Concerns
Data Rights and Protection
Proximity Team, Inc., has the utmost respect for our customers’ privacy and information protection. Given the ever changing regulatory environment, we strive to stay ahead of the curve. In our mission to ethically and lawfully serve our customers we have the following policies in place in order to adhere to international and domestic law:
Proximity Team, Inc. wrote our terms of service to make it as understandable and straightforward as possible. Our valued customers are able to give and rescind consent at any time. If at any time you wish to remove consent, please email our Data Protection Officer at firstname.lastname@example.org. Additional details are provided below in our “Data Protection Officer” description.
Timely Breach Notification
In the event of a data breach, Proximity Team, Inc. will notify our associated data controllers and customers within 72 hours. In addition to outlining the nature of the breach, the breadth, and actions involved to remedy the situation will be detailed.
Right to Data Access
If at any time a customer wishes to access his or her existing data profile, Proximity Team, Inc. will provide a free electronic copy of the data we collected about that customer. This report will also include the various ways the information has been used.
Right to Be Forgotten
If at any time a customer discontinues their relationship with Proximity Team, Inc., the customer can request that his or her personal data is wholly erased from our records.
This gives users rights to their own data. Customers will be able to obtain their data from Proximity Team, Inc. in an electronic report and reuse that same data in different environments outside of ours.
Privacy by Design
Proximity Team, Inc. has a full and detailed map of our data collection process and the various parties privy to that data. Proximity Team, Inc. has specifically designed its systems and trained its staff to maintain customer privacy. We strive to continue to improve and adapt this design to be forward looking.
Data Protection Officer
Proximity Team, Inc. has appointed a Data Protection Officer who can be reached at email@example.com, Inc.. This internal officer will be able to rescind customer consent as requested, alert stakeholders of a data breach, provide access to data reports, ensure the right to be forgotten, establish data portability as requested, and oversee privacy by design with a fiduciary responsibility.