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Privacy Policy

Cluen is committed to protecting the privacy and security of your visits to www.cluen.com. It is our general policy not to make personal information available to anyone other than our employees, staff and agents. While this web site does not collect email addresses, if you have received email from us and would like to be removed, please contact us.

Browser Information & Cookies

We log IP addresses, which are the locations of computers or networks on the Internet. We also collect aggregate numbers of page hits in order to improve the value of our site. We do not gather, request, record, require, collect or track any Internet users' personal information through these processes. A cookie is a "crumb" of data stored by a user's browser that helps a web site/service recognize a unique computer; you can remove or block cookies by changing the settings of your browser.

Security

We maintain a variety of physical, electronic and procedural safeguards to protect your personal information—we use commercially reasonable tools and techniques to protect against unauthorized access to our systems. We may have links to outside web sites that we do not control; we are not responsible for the content or privacy policies of these sites (users should check those policies).

Privacy Shield

The Cluen Corporation complies with the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. The Cluen Corporation has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms 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, please visit https://www.privacyshield.gov.

In compliance with the Privacy Shield Principles, The Cluen Corporation commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Private Shield policy should first contact The Cluen Corporation at:

The Cluen Corporation
7 West 22nd Street, 5th Floor
New York, NY 10010 USA
privacy@cluen.com

Other than through any data controller that may have referred you to our systems and who would retain control over your submission(s), Cluen does not disclose your personal information to third parties without your consent. As an individual you may access your personal data or learn about the choices and means for limiting the use of your personal data by contacting the applicable data controller. Cluen is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Cluen may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Cluen may be responsible for continued protection of your data in cases of onward transfers to third parties not authorized by you or the applicable data controller. You may invoke binding arbitration to resolve issues of Cluen's conduct under this policy.

The Cluen Corporation has further committed to refer unresolved Privacy Shield complaints to ICDR/AAA Privacy Shield Program, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.icdr.org/icdr/faces/icdrservices/safeharbor for more information or to file a complaint. The services of ICDR/AAA Privacy Shield Program are provided at no cost to you.

Human Resources Data

Cluen has further committed to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs or Swiss FDPIC for more information or to file a complaint. The services of EU DPAs and the Swiss FDPIC are provided at no cost to you.

Policy Updates

We reserve the right to revise this policy at any time. You should refer back to this page often for the latest information and the effective date of any changes. If you have questions about this policy, please let us know.

Updated June 12, 2017

The Cluen Corporation 7 West 22nd Street, 5th Floor New York, NY 10010 USA

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