SAMPLE CONSENT DOCUMENT — Illustrative only. Final legal language will be provided by Clearvest Marketing Consultancy's counsel prior to any live transaction.
Clearvest Marketing Consultancy — Privacy Policy
Last Updated: [Last updated date]
This privacy policy ("Policy") describes how Clearvest Marketing Consultancy and its affiliated companies ("Company", "ClearVest Solutions", "we", "us") collect, use and share personal information of users of this website, [Website] (the "Site"), our borrower portal, and our demo booking page.
What We Collect
Information You Provide. We may collect your name, postal address, email address, phone number, username, password as well as other information you directly provide to us through the Site.
Information We Get From Others. We may get information about you from other sources. We may add this to information we get from the Site.
Information Automatically Collected. We automatically log information about you and your computer. For example, when visiting our Site, we log your computer operating system type, browser type, browser language, the website you visited before browsing to the Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site.
Where Applications Come From. [SAMPLE — ATTORNEY TO REVIEW] When you start an application, we record the campaign tags in the link you used (for example the campaign or partner name) and the name of the website that sent you, if any, to understand which channels bring applicants. We do not record your browsing history, and we do not place advertising or social-media tracking tools on our application or borrower portal pages.
Cookies. We may log information using "cookies." Cookies are small data files stored on your hard drive by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.
Financial and Identity Information for Funding Applications. [To be completed by counsel] When you apply for funding we may collect business details, ownership information, date of birth, Social Security Number, ITIN or EIN, bank statements and bank account data, tax documents, identification documents, credit reports, and verification results from our service providers.
Identity Verification and Biometric Information. [SAMPLE — ATTORNEY TO REVIEW] To confirm who owns the business, we use Persona Identities, Inc. ("Persona"), an identity verification service. With your written consent, given before you start, Persona collects photos of your government-issued photo ID and a selfie and creates a scan of your face geometry (biometric information) to check that the selfie matches the ID and that the ID is genuine. Persona processes this on our behalf only for identity verification and fraud prevention and keeps it under its retention policy. We receive the verification result and a copy of the front and back of your ID, which lenders reviewing your application may require; we never receive or keep your selfie or face scan. We keep the result and the ID copy for as long as your application and our record-keeping duties require [ATTORNEY TO CONFIRM: retention period], then delete them. We never sell, lease or trade biometric information. You can ask to verify your identity another way.
Fraud Prevention Checks. [SAMPLE — ATTORNEY TO REVIEW] To protect you and our lending partners from fraud and identity theft, we may send the email address and phone number you give us, and the network (IP) address you used when you applied, to fraud-prevention services that work on our behalf, such as SEON and IPQualityScore ("IPQS"). They tell us, for example, whether an email address or phone number appears to be real and whether it has been linked to fraud. We use these results only to prevent fraud and verify your application, never to decide your creditworthiness, and a person on our team reviews any warning before it affects your application. We do not send these services your Social Security number, date of birth, address or bank information. Some of these services may process information outside the United States.
Business Prospects and Demo Bookings. [SAMPLE — ATTORNEY TO REVIEW] When a business books a demo of our platform, we collect the contact person's first and last name, company name, work email, optional phone number, the time and time zone chosen, anything they tell us they would like to see, a record of the consent given (exact text, version and time), and a protected (hashed) form of the device's network address used only to prevent spam. We use this information only to schedule and hold the demo, send confirmations, calendar invites and reminders, answer questions, and follow up about our platform services. We do not sell it, and we do not use automated dialing, prerecorded voices or text messages for these contacts. Our email and calendar providers process it on our behalf. Demos use sample data only; no borrower information is shown. We will ask everyone's permission before recording a demo call. We keep booking records for [ATTORNEY TO CONFIRM: 24 months] after the demo and then delete them, unless the business becomes a client. You can cancel a booking with the link in the confirmation email, and you can ask us to delete this information or stop contacting you at any time using the Contact Information below.
Use of Personal Information
We use your personal information as follows:
- To operate, maintain, and improve our sites, products, and services.
- To respond to comments and questions and provide customer service.
- To send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
- To communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
- To provide and deliver products and services you request, including matching your application with lenders.
- As provided for in any agreement between you and ClearVest Solutions for services.
Sharing of Personal Information
We may share personal information as follows:
- With your consent. For example, you may let us share personal information with others for their own marketing uses. Those uses will be subject to their privacy policies.
- With lenders and financing partners to evaluate your application and present offers.
- With service providers who need it to do work for us or to deliver services you have requested (for example identity verification, fraud prevention, document processing, e-signature, and communications providers).
- When we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
- For legal, protection, and safety purposes: to comply with laws; to respond to lawful requests and legal processes; to protect the rights and property of Clearvest Marketing Consultancy, our agents, customers, and others, including enforcing our agreements, policies, and terms of use; and in an emergency, including protecting the safety of our employees and agents, our customers, or any person.
- Aggregated and/or anonymized data with others for their own uses.
- As provided for in any agreement between you and ClearVest Solutions for services.
Information Choices and Changes
Our marketing emails tell you how to "opt-out." If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you. You may opt out of text messages at any time by replying STOP.
You may send requests about personal information to our Contact Information below. You can request to change contact choices, opt-out of our sharing with others, and update your personal information.
You can typically remove and reject cookies from our Site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Site works for you.
Contact Information
We welcome your comments or questions about this privacy policy. You may contact us at:
Clearvest Marketing Consultancy Chan Compound, Bitoon, Dumanjug, Cebu 6035, Philippines support@clearvestsolutions.com · +639060838544
Changes to This Privacy Policy
We may change this privacy policy. If we make any changes, we will change the Last Updated date above.
