Privacy Policy - Canada's Largest Customer Data Company

PRIVACY

Cleanlist provides organizations of all types and sizes with access to the specialized software and databases necessary to clean, organize and enhance their contact data.

This privacy policy outlines Cleanlist’s general policy and practices for implementing Privacy Principles, including the types of information to be gathered, how that information will be used, and the notice and choice affected individuals have regarding that use of and their ability to correct that information. This privacy policy applies to all Private Information received by Cleanlist whether in electronic, paper, or verbal format.

Definitions

Private Information shall mean information that:

Can be used to uniquely identify a specific individual,
Can be used to uniquely describe a specific individual,
Is recorded in any form.

Principles

Notice

Cleanlist shall inform an individual of the purpose for which it collects and uses the Private Information and the types of non-agent third parties to which Cleanlist discloses or may disclose that Information. Cleanlist will provide the individual with the choice and means for limiting the use and disclosure of their Private Information. Notice will be provided in clear language when individuals are first asked to provide Private Information to Cleanlist, or as soon thereafter as is reasonable. In all circumstances, this notice will be given prior to Cleanlist’s use or disclosure of the Information for a purpose other than for which it was originally collected.

Choice

Cleanlist will provide to individuals the occasion to opt out should their Private Information be:

Disclosed to a third party or,
Used for a purpose other than the purpose for which it was originally collected.

For Sensitive Private Information, Cleanlist will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the one for which it was originally collected or subsequently authorized by the individual. Cleanlist will treat Sensitive Private Information received from an individual the same as the individual would treat and identify it as Sensitive Private Information.

Data Security

Cleanlist will take reasonable steps to protect Private Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction including undergoing an external audit as required under its CSAE3416 and SOC2 certifications. Cleanlist has implemented appropriate physical, electronic, and managerial processes to secure Private Information from loss, misuse, unauthorized access or disclosure, alteration, or destruction. Cleanlist cannot guarantee the security of Private Information on or transmitted via third-party electronic networks such as the Internet.

Onward Transfers

Before disclosing Private Information to a third party, Cleanlist will notify the individual and allow them to opt out of the disclosure. Cleanlist shall ensure that any third party to which Private Information may be disclosed subscribes to the same Privacy Principles or is subject to law providing the same level of privacy protection as is required by the Privacy Principles and agrees in writing to provide an adequate level of privacy protection.

Data Integrity

Cleanlist shall take reasonable steps to ensure that Private Information is accurate, complete, current, and reliable for its intended and declared use only.

Access

Cleanlist shall allow an individual to access their Private Information and permit the individual to correct, amend, or delete inaccurate information, unless the cost of providing access would be disproportionate to the risks to the privacy of the individual in the case in question, or where the rights of other persons would be violated by permitting access to such information.

Enforcement

Cleanlist uses a self-assessment approach to ensure compliance with this Privacy Policy and verifies periodically that the policy is accurate and comprehensive for the information intended to be covered, prominently displayed, completely implemented, and accessible and in conformity with the Privacy Principles. Cleanlist encourages interested parties to contact us with any concerns using the contact information provided. Cleanlist will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Private Information in accordance with the Privacy Principles.

If a complaint or dispute cannot be resolved through internal process, Cleanlist agrees to dispute resolution via a third party.

Amendments

This Privacy Policy may be amended from time to time. Cleanlist will post any revised policy on this website.

Information Subject to Other Policies

Cleanlist is committed to following the Privacy Principles for all Private Information. However, certain information is subject to policies of Cleanlist that may differ in some respects from the general policies set forth in this privacy policy.

Questions

Questions regarding this statement should be directed to the Privacy Officer at Cleanlist and Interact Direct Marketing, Inc.