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). If you have a The Cluen Corporation ("Cluen") account and wish to delete it, then email accounting@cluen.com with your desired effective termination date for processing.

Access to Your Google and Microsoft Accounts

If you grant the Encore Max application access to your other accounts (Google, Microsoft, etc.), then selected data will be accessed and potentially stored in your Encore Max data file in accordance with your preference setting (each user within your organization can control their access preference).

It is our general policy not to make personal information available to anyone other than our employees, staff and agents.

What information do we collect? We may collect your HTTP header information. And with your consent, for storage in your private Encore Max database only, you may instruct our systems to collect your emails, schedules, documents.

How do we use your information? The collected information would be used by you in Encore Max to improve your user experience, and to allow you to share with your designated colleagues in the system. No humans outside of you or such colleagues read such data without your consent in each incident.

What information do we share? Cluen will not share your organization’s data outside of your organization unless requested by your organization.

Data Privacy Framework (DPF)

Cluen complies with the EU-US Data Privacy Framework (EU-US DPF) and the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF) as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, United Kingdom, and Switzerland to the United States. Cluen has certified to the Department of Commerce that it adheres to the DPF Principles. If there is any conflict between the terms in this privacy policy and the DPF Principles, the DPF Principles shall govern. To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

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

The Cluen Corporation
149 East 23rd Street, #2045
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.

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.

Business transfers. We may share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.

Legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, health, safety, and security of Cluen, our affiliates, users, or the public.

With your consent or at your direction. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction.

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. Cluen has further committed to refer unresolved DPF complaints to ICDR/AAA DPF 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://go.adr.org/dpf_irm.html for more information or to file a complaint. The services of ICDR/AAA DPF Program are provided at no cost to you.

Human Resources Data

In compliance with the EU-US DPF and the UK Extension to the EU-US DPF and the Swiss-US DPF, Cluen commits to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner's Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-US DPF and the Swiss-US DPF in the context of the employment relationship.

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 14, 2024