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.
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.
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.
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.
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.
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.
Cleanlist shall take reasonable steps to ensure that Private Information is accurate, complete, current, and reliable for its intended and declared use only.
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.
If a complaint or dispute cannot be resolved through internal process, Cleanlist agrees to dispute resolution via a third party.
Information Subject to Other Policies
Questions regarding this statement should be directed to the Privacy Officer at Cleanlist and Interact Direct Marketing, Inc. (firstname.lastname@example.org).
Cleanlist.ca, a division of Interact Direct Marketing, Inc.
787 Industrial Road
London, Ontario, Canada