Privacy Policy

Last modified: April 11, 2015

This Privacy Policy applies to all of the products, services and websites offered by Clear Talk Mastery Inc. or its subsidiaries or affiliated companies. Sometimes, we may post product specific privacy notices or materials to explain our products in more detail.

For brevity, Clear Talk Mastery, Inc. is abbreviated as CTM in the rest of this Privacy Policy.

If you have any questions about this Privacy Policy, please feel free to contact us through our website or write to us at
Privacy Matters
c/o Clear Talk Mastery, Inc.
1800 30th St., Suite 220 D
Boulder, CO 80301
USA

Information we collect and how we use it

We may collect the following types of information:

• Information you provide – When you sign up for a CTM Student Account or make a purchase from our website, we ask you for personal information. “Personal information” is information that you provide to us which personally identifies you, such as your name, email address or billing information, or other data which can be reasonably linked to such information by CTM.
• We may combine the information you submit under your account with information from other CTM services or third parties in order to provide you with a better experience and to improve the quality of our services. For certain services, we may give you the opportunity to opt out of combining such information.
• Browser Cookies – When you visit CTM, we send one or more browser cookies to your computer or other device. We use cookies to improve the quality of our service, including for storing user preferences, improving search results and ad selection, and tracking user trends, such as how people search. CTM also uses cookies in its advertising services to help advertisers and publishers serve and manage ads across the web and on CTM services.
• Log information – When you access CTM services via a browser, application or other client our servers automatically record certain information. These server logs may include information such as your web request, your interaction with a service, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser or your account.
• User communications – When you send email or other communications to CTM, we may retain those communications in order to process your inquiries, respond to your requests and improve our services. When you send and receive SMS messages to or from one of our services that provides SMS functionality, we may collect and maintain information associated with those messages, such as the phone number, the wireless carrier associated with the phone number, the content of the message, and the date and time of the transaction. We may use your email address to communicate with you about our services.
• Affiliated CTM Services on other sites – We may offer some of our services on or through other web sites. Personal information that you provide to those sites may be sent to CTM in order to deliver the service. We process such information under this Privacy Policy.
• Third Party Applications – CTM may make available third party applications, such as gadgets or extensions, through its services. The information collected by CTM when you enable a third party application is processed under this Privacy Policy. Information collected by the third party application provider is governed by their privacy policies.
• Location data – CTM may offer location-enabled services. If you use these services, CTM may receive information about your actual location (such as GPS signals sent by a mobile device) or information that can be used to approximate a location (such as a cell ID).
• Application environment  – Certain services, such as the CTM assessment Windows application, may send information about your installation (e.g., operating system type, version number, language, CPU, memory) may be sent to CTM in order to help us facilitate the running of the software and to improve it in the future.
• Other sites – This Privacy Policy applies to CTM services only. We do not exercise control over any other site, including links from within our various services. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you.

In addition to the above, we may use the information we collect to:

• Provide, maintain, protect, and improve our services (including advertising services) and develop new services; and
• Protect the rights or property of CTM or our users.

If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use.
CTM processes personal information on our servers in the United States of America.  We may have servers in other countries in the future as well. In some cases, we process personal information outside your own country.

Choices

Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some CTM features and services may not function properly if your cookies are disabled.

Information sharing

CTM only shares personal information with other companies or individuals outside of CTM in the following limited circumstances:

• We have your consent. We require opt-in consent for the sharing of any sensitive personal information.
• We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
• We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of CTM, its users or the public as required or permitted by law.

If CTM becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will ensure the confidentiality of any personal information involved in such transactions and provide notice before personal information is transferred and becomes subject to a different privacy policy.

Information security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data.

We restrict access to personal information to CTM employees, contractors and agents who need to know that information in order to process it on our behalf. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Accessing and updating personal information

When you use CTM services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way we maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

Third Parties

Third party vendors, including Google, show our ads on sites on the internet.

Third party vendors, including Google, use browser cookies to serve ads based on your prior visits to this website.

• You have the option to opt out of Google’s use of browser cookies by visiting the Google advertising opt-out page. http://www.google.com/privacy_ads.html

• Alternatively you can opt-out of most third party browser cookies by visiting the Network Advertising Initiative opt-out page. http://www.networkadvertising.org/managing/opt_out.asp

CTM Clients

There are some additional privacy issues specifically for CTM clients.

• All information collected via questionnaires, tests, assessments, audio recordings or other means will not be shared with anyone in a format which allows client identification other than the client, the client’s sponsor, and authorized staff at CTM, except by express permission of the client or the client’s sponsor.
• Information collected via questionnaires, tests, assessments, audio recordings, or other means may be shared in an aggregate fashion with third parties to facilitate CTM advertising or other goals. Such information will never be shared with client identification information included.
• CTM may contact former clients from time to time unless specifically requested to stop.
• CTM may use data, including audio recordings, from our interaction with our clients for improving CTM products, or other research efforts.

Enforcement

CTM regularly reviews its compliance with this Privacy Policy. When we receive formal written complaints, it is CTM’s policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between CTM and an individual.

Changes to this Privacy Policy

Please note that this Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.