Clora's Privacy Policy
This "Privacy Policy" describes the privacy practices of Clora and our subsidiaries and affiliates (collectively, "Company", "we", "us", or "our"). This Privacy Policy describes how we collect, use, disclose and otherwise process personal information in connection with our websites, mobile apps, and other services, and explains the rights and choices available to individuals with respect to their information. For convenience, our websites and mobile apps are collectively referred to as the "Services," and, together with our other services, collectively referred to as the "Services." This Privacy Policy governs any of the Services on which the Privacy Policy is posted.
Individuals located in the European Union should be sure to read the important information provided here.
Table of Content
- Personal Information We Collect
- Sensitive Personal Data
- Cookies and Similiar Technologies
- How We Use Your Personal Information
- How We Share Your Personal Information
- Your Choices
- Choosing Not to Share Your Personal Information
- Security
- Children
- International Transfer
- Other Sites and Services
- User Generated Content
- Changes to this Privacy Policy
- Contact Us
- Additional Information for European Union Users
Personal Information We Collect
Clora offers a technology platform facilitates the relationship between a client (“Client”) and consultants (“Consultants”).
We collect personal information about you in the following ways:
Information you give us
Personal information that you may provide through the Services or otherwise communicate with us includes:
- Personal and Business Contact information, such as your first name, last name, postal address, email adress, telephone number, job title, employer name, resume information, education, and biographical information;
- Profile information, such as your username and password, industry, interests and preferences or any other information you subnmit to your Profile (as defined below);
- Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with the Services, receive customer support or otherwise correspond with us;
- Transaction information, such details about consulting work arranged through the Services, registrations you make through the Services, and billing details;
- Usage information, such as information about how you use the Services and interact with us;
- Marketing information, such as your preferences for receiving marketing communications and details about how you engage with them;
User Profiles
You may have the opportunity to create a profile, which consists of information about you, and may include personal information, photographs, examples of your work, information on work previously performed via the Service and outside the Service, skills, tests taken, test scores, hourly pay rates and earnings information and other information, including your username (“Profile”). The information in your Profile may be visible to other Registered Users (as defined below). You may edit certain information in your Profile via your account. Individual Client Registered Users may also have the opportunity to create an organization Profile. If, in any case, you believe that an unauthorized profile has been created about you, you can request for it to be removed by contacting us at privacy@clora.com.
Information from Social Networking Sites
Our Services include interfaces that allow you to connect with social networking sites (each a "SNS"). If you connect to a SNS through our Services you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Notice. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.
Information We Get from Others
We may also get information about you from other sources, for example professional organizations and groups advertising skills and experiences, and we may add this to information we get from our Site or the Services.
In addition, if you are matched with a Client, we may receive information from the Client related to your performance of services for the Client.
We may combine other publicly available information, such as information related to the organization for which you work, with the personal information that you provide to us through our Services.
Information Automatically Collected
We may automatically log information about you and your computer or mobile device when you access our Services. For example, we may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Sites, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Services. We collect this information about you using cookies. Please refer to the Cookies and Similar Technologies section for more details.
Changes to Your Personal Information
It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us by updating your registration profile or emailing us at hello@clora.com.
Sensitive Personal Data
We ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
If you send or disclose any sensitive personal data to us when you use the Services, you must consent to our processing and use of such sensitive personal data in accordance with this Notice. If you do not consent to our processing and use of such sensitive personal data, you must not submit such sensitive personal data to our Services.
Cookies and Similar Technologies
What are cookies?
We may collect information using "cookies." Cookies are small data files stored on the hard drive of your computer or mobile device 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 or mobile device until you delete them) to provide you with a more personal and interactive experience on our Services.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Services; and (2) third party cookies, which are served by service providers on our Services, and can be used by such service providers to recognise your computer or mobile device when it visits other websites.
Cookies We Use
Our Services uses the following types of cookies for the purposes set out below:
| Type of Cookie | Purpose |
|---|---|
| Essential Cookies | These cookies are essential to provide you with services available through our Services and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services. |
| Functionality Cookies | These cookies allow our Services to remember choices you make when you use our Services. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-select your preferences every time you visit our Services. |
| Analytics and Performance Cookies | These cookies are used to collect information about traffic to our Services and how users use our Services. The information gathered may include the number of visitors to our Services, the websites that referred them to our Services, the pages they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Services works. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Services by downloading and installing the browser plugin available here. |
| Social Media Cookies | These cookies are used when you share information using a social media sharing button or you link your account or engage with our content on or through a social networking website such as LinkedIn or Twitter. The social network will record that you have done this. |
| Targeted and advertising cookies | These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show advertisements which we think will be relevant to your interests while you are on third party websites. You can disable certain cookies which remember your browsing habits and target advertising at you by visiting this site. If you choose to remove targeted or advertising cookies, you will still see advertisements but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioural advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed. |
Disabling Cookies
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the "settings," "help" "tools" or "edit" facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.
If you do not accept our cookies, you may experience some inconvenience in your use of our Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Services.
Flash Technology
We may use Flash cookies (which are also known as Flash Local Shared Object ("LSOs")) on our Services to collect and store information about your use of our Site. Unlike other cookies, Flash cookies cannot be removed or rejected via your browser settings. If you do not want Flash cookies stored on your computer or mobile device, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel at this website. You can also control Flash LSOs by going to the Global Storage Settings Panel at this website and following the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our Services.
Pixel Tags
We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Services to track the actions of users on our Services. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Services, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal data.
Do Not Track Signals
Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not currently respond to do not track signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.
How We Use Your Personal Information
To Provide Our Services
If you have an account with Clora(each, a "Registered User") or use our Services, we use your personal information to:
- operate, maintain, administer and improve the Services, including providing Registered Users' personal information to other Registered Users to facilitate a connection between a Consultant and Client vis the Services;
- enable you to create a Profile to be displayed within the Services that may be searchable or viewable by a Registered User,
- manage and communicate with you regarding your Clora account, if you have one, including by sending you service announcements, technical notices, updates, security alerts, and support and administrative messages;
- process and manage registrations you make through the Services, including to track and administer trainings you have registered for and attended;
- better understand your needs and interests, and personalize your experience with the Services; and
- provide support and maintenance for the Services and our services;
- respond to your service-related requests, questions and feedback.
Transactional SMS text message notifications will be sent to users if they provide their mobile phone numbers for the corresponding purposes. Users can opt-out by texting STOP to any transactional SMS text message notification or by logging in and updating their user settings. By opting out, users will continue to receive relevant communication via email.
To Communicate with You
If you request information from us, register on the Services, or participate in our surveys, promotions or events, we may send you Clora-related marketing communications as permitted by law. You will have the ability to opt out of such communications.
To Comply with Law
We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
With Your Consent
We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Services, you instruct us to take a specific action with respect to your personal information, or you opt into third party marketing communications.
To Create Anonymous Data for Analytics
We may create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information that makes the data personally identifiable to you, and use that anonymous data for our lawful business purposes.
For Compliance, Fraud Prevention and Safety
We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
How We Share your Personal Information
Except as described in this Privacy Policy, we do not share the personal information that you provide to us with other organizations. We disclose personal information to third parties under the following circumstances:
- Affliates. We may disclose your personal information to our subsidiaries and corporate affiliates for purposes consistent with this Privacy Policy.
- Service Providers. We may employ third party companies and individuals to administer and provide the Services on our behalf (such as training, customer support, hosting, email delivery and database management services). These third parties may use your information only as directed by Clora and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.
- Information about Consultants shared with Client. We may share information regarding Consultants to Client in order to facilitate a relationship between Client and Consultant, including but not limited to information contained in your Profile.
- Information about Client shared with Consultant. We may share information contained in the Client’s Profile with Consultant to facilitate a relationship between the Client and Consultant. In addition, if you have entered into a services agreement and/or statements of work between the Client, Clora and/or the Consultant, Clora may share certain information about you to the Consultant in order to complete any transactions or to facilitate the resolution of a claim or dispute.
- Professional Providers. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
- Compliance with Laws and Law Enforcement; Protection and Safety. Clora may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Service; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
- Business Transfers. Clora may sell, transfer or otherwise share some or all of its business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.
Your Choices
Access, Update, Correct or Delete Your Information
All Clora account holders may request to review, update, correct or delete the personal information in their registration profile by logging into their account. Clora account holders may also contact us at privacy@clora.com to accomplish the foregoing or if you have additional requests or questions.
Marketing Communications
You may opt out of marketing-related emails by logging in and changing your account settings, by clicking on a link at the bottom of each such email, or by contacting us at privacy@clora.com. You may continue to receive service-related and other non-marketing emails.
Testimonials
If you gave us consent to post a testimonial on our Services, but wish to update or delete it, please contact us.
Choosing Not to Share Your Personal Information
Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services and may need to close your account. We will tell you what information you must provide to receive the Services by designating it as required in the Services or through other appropriate means.
Security
The security of your personal information important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.
Children
Our Services is not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable.
International Transfer
Company is headquartered in the United States and has affiliates and service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.
Other Sites and Services
The Services may contain links to other websites and services. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.
User Generated Content
We may make available on our Services, or link to, features that allow you to share information online (e.g., on message boards, in chat areas, in file uploads, through events, etc.). Please be aware that whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage or dissemination of such publicly-disclosed personal information. By posting personal information online in public forums, you may receive unsolicited messages from other parties.
Changes to Privacy Policy
We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy you will be notified via e-mail (if you have an account where we have your contact information) or another manner through the Service that we believe reasonably likely to reach you (which may include posting a new privacy policy on our Site – or a specific announcement on this page or on our blog).
Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.
Contact Us
If you have any questions or concerns at all about our Privacy Policy, please feel free to email us at privacy@clora.com.
Additional Information for European Union Users
Personal Information
References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.
Controller and Data Protection Officer
Company is the controller of your personal information for purposes of European data protection legislation. To the extent that Client and Consultants communication with each other through the Service, such Client will also be a controller with respect to such communication. See the Contact Us section above for contact details.
Legal bases for processing
We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how we process your personal information, contact us at privacy@clora.com.
| Processing purpose (click link for details) | Legal basis |
|---|---|
| To provide the Services | Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services. |
| To communitcate with you | These processing activities constitute our legitimate interests. |
| To create anonymous data for analytics | We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. |
| For compliance, fraud prevention and safety | We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). |
| To comply with law | Processing is necessary to comply with our legal obligations. |
| With your consent | Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at privacy@clora.com. |
User for new purposes
We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collect it. If we need to use yur personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.
Retention
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
Your rights
European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to your reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You can submit these requests by email to privacy@clora.com. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described above or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.