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ClearCaptions Privacy Policy

Last Updated: November 6, 2025

Updates to ClearCaptions Privacy Policy

ClearCaptions provides this summary of recent changes pursuant to its right to change its Privacy Policy. If you do not object to the changes within 30 days, you will be deemed to have accepted the changes.

We have consolidated the privacy policies provided by the different ClearCaptions entities, to simplify our notices and to clearly describe our data practices and your privacy rights under different consumer privacy laws.
In doing so, we have changed the structure of our privacy policy to clarify how personal information is collected or disclosed, and the purposes for which we use it.
We have added language describing your privacy rights under applicable laws, to account for recent developments in the law and regulations.
We have added language regarding our use of targeted advertising on our websites in order to provide you with meaningful choices.

1. INTRODUCTION

This Privacy Policy (the “Policy”) explains how ClearCaptions LLC and its affiliates, including but not limited to ClearWellness, LLC (together, “ClearCaptions” or “we”/ “our”/ “us”) collect, use, share, and otherwise process the personal information we collect about consumers. This Policy details what information we collect, how we use it, and the choices and rights you have regarding its use. Our aim is to give you the necessary insights to make informed decisions about your interactions with us, including online. By using our websites, mobile applications, or other products and services (“Services”) and providing your personal information to us, you give us permission to process your personal information as described in this Policy. If you do not agree with the data collection practices described in this Policy, do not access or use our Services.

2. SCOPE OF THIS POLICY

This Policy describes the various contexts and circumstances in which we collect personal information, including through our Services. It applies to data collected via the following:

Our Websites: Any that link to this Policy, including www.clearcaptions.com, www.captions.com, and www.clearwellness.com.
Social Media and Affiliates: Interactions on our social media pages.
Other Digital Platforms: Including interactions such as clicking on our ads on third-party sites and subscribing to our electronic communications.
Customer Services: Including communications with our service representatives or features via chat functions, email, text, or phone.
Additionally, for Customers of the ClearCaptions Captioned Services:
- Our Internet Protocol Captioned Telephone Service (“IP CTS”): Information we collect during the application, registration, or use of our IP CTS services.
Additionally, for ClearWellness Customers:
- Our Mobile Applications: Including the ClearWellness App.
- Connected Devices: ClearWellness utilizes smart devices to take measurements about subscribers of our Wellness Services (“Members”). The smart devices include our smartwatch, body scale, and sleep mat.
- Wellness Coach Interactions: Our Wellness Coaches use collected information about Members to provide the Wellness Services.
- Wellness Hub Interactions: Our Wellness Hub, made available to Members, provides an interface for Members to view their personal data.
- Other Member-Related Interactions: If we collect personal data about Members in other contexts, such as through a family member, representative, or other third party, our use of it will be described here.
- This Policy also applies to personal data we collect in the context of transactions (e.g., purchases, subscriptions, etc.) with us. To learn how ClearWellness processes Consumer Health Data, please review our Consumer Health Data Privacy Notice, which supplements this Policy and explains ClearWellness’ collection, use, and disclosure of personal information that may identify Members’ past, present, or future physical or mental health status ("Consumer Health Data").

For questions about the scope of this Policy, please contact us as set forth in the Contact Information section.

3. HOW WE OBTAIN INFORMATION

We obtain the information we collect about you through various means and sources, including:

Direct Interactions. We collect personal information when you provide it directly to us, such as when you provide payment information, submit forms, or otherwise provide us with information via phone, email, or online communications. The information collected online may be entered into our systems and combined with other information we collect about you directly or from third parties. We may also share this data with our service providers, affiliates, advertising and marketing partners, and others. Please see below for more information about how we share your personal information.
Automatically, Including Using Data Collecting Tools. We use various data collecting tools, including cookies, scripts, and pixels, to collect certain information about your use of our Services. These tools can help us improve site performance, account for usage, understand how our services are being accessed and used, and provide customized content and advertising to you. We provide you options regarding your use of non-essential data collecting technologies via our Services.
Third-Party Sources. We collect personal information from third parties, including social media platforms, advertising companies, e-commerce affiliates, public forums and databases, and other relevant parties based on your interactions with us. This information may be combined with other data we collect about you to enhance our Services, serve you with targeted ads, and tailor our interactions with you.

4. INFORMATION COLLECTED AND HOW WE USE IT

We collect and use personal information for several purposes, including to provide our Services and continually improve them. The personal information we collect, and how that information is used, depends on how you interact with us, the choices you make when engaging with us, and the Services you use. Please note, we share personal information for targeted advertising purposes, and we allow users to exercise their privacy rights with respect to this sharing.

This section provides an overview of the types of personal information we may collect about you and the general purposes for which they are used in particular contexts. Please note that the actual information collected, and its use, may vary depending on your interactions with us and the Services you use.

4.1. Personal Information We Collect Directly From You

This section describes the personal information we collect about you when you provide it directly to us through our Services, or in an electronic or other communication.

4.1.1. What We Collect or Process

Contact Information and Other Identifiers. We collect your name, email address, telephone number, physical address, age, and any other personal identifier you provide in a form or other communication, for example, to sign up, register, or subscribe for our Services.
Payment Information. This information includes credit or debit card numbers.
Commercial Activity. We keep track of the products or services you have purchased or considered.
For ClearCaptions IP CTS Customers:
- Profile and Eligibility Information. This includes name, date of birth, last four digits of your social security number, address, phone number, and self-certification regarding hearing disabilities.
- Customer Proprietary Network Information (“CPNI”). This includes information which relates to the quantity, technical configuration, type, destination, location, and amount of use of the IP CTS services.
For ClearWellness Customers:
- Measurement Data. Our Connected Devices take measurements and other recordings about those who use them, including the following:
  - Sleep-Related Measurements such as heart rate, time asleep, number of sleep interruptions, time in REM sleep, and sleeping state (e.g., "light" or "deep" sleep).
  - Bodily Measurements such as weight, body mass index ("BMI"), body fat measurements, bodily water measurements, bone weight, and muscle weight.
  - Activity Measurements, such as activity type, pulse, heart rate (including variability), and respiration rate.
- Wellness Information. Data related to a Member’s wellness status and history, such as:
  - Physical or Mental Health Condition, including information about Member’s health conditions, history, status, diagnoses, prescriptions, testing, or treatments.
  - Wellness Goals, Assessments, & Trends, which considers a Member’s and others’ input, Measurement Data, and other information.
  - Calculated or Inferred Data. Calculations or inferences related to a Member, such as sleep patterns/phases, activity levels, BMI, readiness, and similar calculations and inferences.
- Member-Provided Activity and Context. Information provided by a Member and recorded by ClearWellness, such as Wellness Coach interactions notes, activities, comments, feedback, and other information.
- Data Provided by Others. Personal data about a Member that we collect from third parties, such as caregivers, family members, personal representatives, and others.
- Please note that some of the personal data we process, including any data concerning Member’s health, is considered special or sensitive personal data. Under applicable law, such data is processed only if consent has been given for processing. If a Member accesses or uses a Connected Device that has location-based services, such as GPS-based activity tracking, ClearWellness may process the approximate or precise location of the connected device while it is active. Location-based tracking may not be disabled in all instances, so please contact ClearWellness about concerns regarding the use of location-based tracking in connection with a Connected Device.

4.1.2. How We Use It

To Communicate With You. We will use your personal information to facilitate our communications with you. For example, we will use your email address to respond to your email requests. The length of time we maintain your contact information and your communications varies depending on the context.
Service Fulfillment. We use your personal information to perform a variety of services essential to the customer experience or our business, such as account setup, maintenance, and support, transaction processing and fulfillment, billing and payment processing, and customer service across multiple channels.
Business Operations. We use personal information to perform business operations, such as document management and record keeping, training and development, generating business intelligence reports, strategic decision making, auditing and compliance, maintaining the security and integrity of our Services and offline operations, including protection against fraudulent or illegal activities. This includes validating your identity as necessary.
Quality Assurance and Improvement. We use personal information to maintain and improve the quality and safety of our Services.
Customization. To enhance your experience with our Services, we may use your data to personalize features, content, and recommendations, in line with applicable laws and your preferences.
For ClearCaptions IP CTS Customers: ClearCaptions may use or disclose your CPNI without further authorization from you under the following circumstances:
- To provide you with captioned relay services and phones;
- To process 911 calls;
- For installation, maintenance and repair of our products and services, including through the help of third parties;
- To offer you additional caption features and services of the type you already registered for with ClearCaptions;
- In response to legal requirements such as subpoena or court order;
- Upon request from the Federal Communications Commission’s (“FCC”) Telecommunications Relay Service (“TRS”) Fund, and for TRS program administration purposes; and
- To prevent fraud, abuse, or misuse of the service(s) and to protect the rights and property of ClearCaptions.
For ClearWellness Customers:
- Wellness Coaching. Our Wellness Coaches use the personal data to provide the Members with personalized wellness plans, including to set goals, make recommendations, monitor progress, and spot trends.
- To Provide our Wellness Services. In addition to use by a Wellness Coach, we use Member personal data to perform a variety of services essential to the Member experience and our business, such as account setup, maintenance, and support, transaction processing and fulfillment, billing and payment processing, and customer service across multiple channels.
- Third-Party Interactions. We may share Member personal data with Authorized Recipients (defined below).
Privacy Preservation. We may process personal data in order to implement privacy protecting measures, such as deidentification, aggregations, or anonymization. When information is aggregated or anonymized, it is no longer personal data.
Additional Uses Described. In any other way we may describe when you provide the information or any other purposes for which you provide your consent.

4.2. Personal information Collected Using Online Data Collecting Tools

We collect, use, and disclose personal information gathered in connection with your online interactions with us, including your use of our websites and their features. We also collect personal information in connection with electronic communication services like email and electronic messaging, and our social media pages (though not the platforms on which they are maintained). When you use our Services, we collect some information automatically and combine it with other information we collect about you. In many cases we utilize third parties to assist with this collection. In such cases, your personal information is made available to other entities for processing on our behalf or at our direction or to serve you with targeted advertisements.

Some of this information is collected and logged because of your access to our servers, by various technologies such as cookies, web beacons, scripts, tags, and other software code that store and transmit personal and other information (collectively “data collecting technologies”). Some of these data collecting technologies are used by third parties to collect or receive information from our Services and elsewhere on the Internet and use that information to provide measurement services and target ads.

4.2.1. What We Collect or Process Using Data Collecting Technologies

Identifiers and Contact Information. We collect identifiers associated with you or the device you are using to access our Services, such as IP addresses, cookie IDs, and other similar identifiers.
Device and Browser Data. We collect information about your device and the software and systems you use to access our Services, such as your browser type/version, screen size/resolution, and other information contained in your browser’s communication with our website.
For ClearWellness Customers:
- Data Related to Use of Wellness Portal. When a Member accesses and uses our Wellness Portal, whether through a mobile or web app, we log interactions with the Wellness Portal. Some of this information is collected and logged automatically by various technologies such as cookies, web beacons, scripts, tags, and other software code that store and transmit personal and other information. Some of these data collecting technologies are provided by third parties.
User Interaction Data. We collect data about how you navigate to/from our Services (such as the URLs that referred you to our website), browsing activity on our Services (such as the web pages you viewed and buttons you clicked), and other metrics associated with your access and use of our Services.
Electronic Communication Records. We collect records related to your electronic communications with us, including online chat transcripts, email records, call records and recordings/logs, and other electronic messages and communications.
User Preferences. We record your online preferences, such as communication preferences, language, time/zone, and general location information, and privacy choices and configurations. We do this to facilitate such preferences.
Advertising Metrics. We collect information about your interaction with our content and marketing materials. For example, we may gather information about our advertisements you have viewed on our website or elsewhere. We use third parties to do this.

4.2.2. How We Use It

To Provide Our Services in a safe and secure manner, such as to present our website, mobile apps, and products to you, to communicate with you about changes to our Services, to validate your identity as necessary to ensure the security of our services and systems, and to maintain and improve the security and performance of our Services.
Communications and Support, such as to review and respond to your requests or inquiries, provide updates, notices, and requested communications, send you important transactional information, request feedback, or as necessary to fulfill our obligations to you.
For Our Legitimate Business Operations, such as to make strategic decisions concerning our business operations, enforce, and review compliance with, the legal terms that govern our offerings, comply with our legal obligations, protect the rights, safety, and property of the Services, our users, and third parties, and anonymize, aggregate, or de-identify your personal information (so it can no longer identify you) in furtherance of conducting research and analysis.
To Send You Promotional Materials, such as updates, newsletters, surveys, or other information regarding contests, events, and/or other ClearCaptions products or services that may be of interest to you based upon information you have provided to us. Promotional materials may be conveyed in emails or, if you have provided your consent, by SMS/text message.
Advertising. We use personal information to serve you with targeted advertisements and this information is shared with third parties in order to facilitate our advertising objectives.
Analytics/Personalization. We use personal information to conduct research and analytics, including to improve our Services. We also use your personal information to personalize your experience, and to understand how you interact with our websites, advertisements, and communications with you.
Data Aggregation. We may aggregate your personal information with that of other users for analytical and reporting purposes. This aggregated data is anonymized or deidentified and does not identify you personally. Aggregated data may be used for various purposes, including statistical analysis, without further notice to you and without obtaining additional consent.
With Your Consent: We use information about you where you have given us consent to do so for a specific purpose not listed above.

4.2.3. Third Parties Who Provide Services

We may use third-party services for various purposes, including but not limited to analytics, advertising, and customer support. Below are some specific third parties that we may use. To learn more about the types of entities who deploy cookies and online tracking technologies on our websites, please review “Disclosure of Personal information.”

Content Providers. Various third parties assist us in providing content and features, including video content, on our Services. Because these services send the content to your browser on our behalf, they typically have access to information about your device and browser, including your IP address, the URL of the pages you visit, and information about your device. They use this information to ensure that the content is delivered to you in the correct format and size.
Functionality Providers. Third parties assist us in providing various online functionality, such as our accessibility tools, online chat tools, and consent management tools.
Web Hosting Providers. Our website hosting and infrastructure providers will receive personal information about your device, including your IP address, device, and browser information, as well as your activity on our websites, in order to provide the hosting services.
Analytics and Advertising Providers. We allow third-party partners and service providers (such as advertising networks, analytics providers and social media platforms and networks), including but not limited to those listed below, to gather data when you interact with our Services for our analytics and marketing purposes, including to help manage and display advertisements, to tailor advertisements to your interests, and target you on other websites (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our websites or on other websites.
- Google Analytics: We employ Google Analytics for detailed user interaction analysis. This service collects data such as your originating location, visit frequency, viewed pages, and actions taken within our Services. Google Analytics uses cookies to collect this information. The use and sharing of this data by Google are subject to the Google Analytics Terms of Service. For options to opt-out of Google Analytics tracking, you may disable cookies on your browser or follow these specific instructions provided by Google.
- Other Google Services. We utilize various Google services like Google Ads and Google Dynamic Remarketing for purposes such as analytics, advertising, and user experience optimization. These services deploy their own cookies and may collect information like your IP address, user preferences, and online behaviors, which Google uses for its own purposes. For further information and to manage your Google privacy settings, consult Google’s Privacy Policy and Terms of Service, or visit your Google Account.
- Personalized Ads. We use various tools, including the Meta Pixel, which collect information about your device and how it interacts with our Services. These third-party services may use cookies, web beacons, and other storage technologies to collect or receive information about you or your device from our website and elsewhere on the Internet and use that information to provide measurement services, target and deliver ads. You can opt-out of the collection and use of your information for ad targeting purposes by Meta by visiting http://www.aboutads.info/choices.

4.2.4. Your Privacy Choices Regarding Tracking Technologies

To the extent these data gathering technologies are deemed to be a “sale” / “sharing” (which includes targeted advertising, as defined under the applicable laws) under applicable U.S. state laws, you can opt-out of these online tracking technologies by submitting a request using our cookie management tool (for cookies and other data collecting technologies), our privacy request form, or using the contact information provided below. Please note, some features of our websites may not be available to you as a result.

Cookies. You can manage how your web browser interacts with cookies. While most browsers are configured to accept cookies by default, you can modify this behavior through your browser's “Privacy” or “Security” settings. However, if you remove or reject our Cookies, it could affect how the website works for you. Please note you must separately opt out in each browser and on each device. You can also tailor your cookie preferences using our cookie consent manager.
Changing Mobile Device Privacy Settings. Your mobile device may collect and share device-level information to facilitate targeted advertising. This is independent of our Services but can affect your overall privacy experience. To better understand and manage these settings, you may refer to the privacy resources provided by your device's operating system. For your convenience, we've included links to informational pages for Google’s Android and Apple’s iOS platforms.
Limiting Interest-Based Advertising. You have the option to limit the interest-based advertising you receive. Various organizations and platforms offer opt-out features that allow you to have more control over your online advertising experience. For example, the Digital Advertising Alliance (DAA) provides a consumer choice tool that lets you opt out of interest-based advertising from participating companies. You can access this tool at the DAA Opt-Out Page. Similarly, the Network Advertising Initiative (NAI) offers an opt-out tool for participating members. You can access this tool at the NAI Opt-Out Page. Please note that participation in the DAA and NAI opt-out programs is entirely optional. These are third-party services and opting out through these platforms is not a requirement for using our Services. We are not responsible for the effectiveness of any such opt-out options. Opting out of interest-based advertising does not mean you will no longer see advertisements; it simply means that the advertisements you do see will not be tailored to your interests.
“Do Not Track” Signals. Do Not Track (“DNT”) is a privacy preference that you can set in your web browsers, which allows you to opt out of tracking by websites and Services. Like many websites, we do not currently respond to ‘Do Not Track’ browser settings or signals. For more information about DNT, please see eff.org/issues/do-not-track.
“Global Privacy Control.” Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including the “sharing” of your personal information. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting.

4.3. Data Collected from Other Parties

We obtain information from businesses which assist us in providing our business and Services, such as our data analytics providers, marketing or advertising service providers, fraud prevention service providers, vendors that provide services on our behalf, and publicly available sources. We also create information based on our analysis of the information we have collected from you. We use this information for our business operations purposes, including offering and improving our services, providing customer support, measuring the effectiveness of our Services, accounting and transaction purposes, and to enforce our terms and policies. Please see “Disclosure of Your Personal information” to learn more about how we process personal information via our business services providers.

4.4. Other Purposes for Processing Personal information

While less frequent, there are other scenarios where we may use or disclose your personal information:

Audits Involving External Entities: Sharing data with external organizations, including those we collaborate with or those that evaluate our business operations, to ensure compliance with industry standards, certifications, or legal obligations.
Legal Obligations: Fulfilling legal obligations such as responding to subpoenas, court orders, or other binding government requests, or as required by applicable law or regulation. In the rare event of litigation, we may use your data to establish, exercise, or defend legal claims.
Reorganization: In the event of a business transaction such as a sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, your personal information may be shared or transferred. This also includes any subsequent integration activities post-transaction.
Business Transfers: In the event of a divestiture, investment, or other asset transfer that is not part of a broader business transaction like a merger or acquisition, your personal information may be shared or transferred.
With Your Consent: We use information about you where you have given us consent to do so for a specific purpose not listed above.

5. DISCLOSURE OF YOUR PERSONAL INFORMATION

We may disclose the above information to the following types of parties:

Other ClearCaptions Group Entities (Affiliates). We may share personal information between the ClearCaptions group entities that are related by common ownership or control. We share personal information for our routine business purposes and to develop new and improve existing services.
For ClearWellness Customers:
- Wellness Coaches. Our Wellness Coaches receive access to Members’ personal data, including sensitive personal data like health data, as part of the Services.
- Care Facilities and Medical Providers. We share the personal data of Members with the care facilities, doctors, trainers, specialists, or other professionals authorized by the Member or their legal representative to receive it. Once the personal data of Members is shared with such persons or entities, they become the controllers of such data, and are responsible for processing it in accordance with the laws applicable to them.
- Authorized Representatives. We may disclose Member’s personal data, including sensitive health data, to authorized recipients (each an “Authorized Representative”), including through the CareGiver App. Authorized Representatives may include a Member’s family members, care facility personnel, in-home care personnel, or healthcare providers. A Member (or legal guardian) may revoke an existing Authorized Representative’s access at any time by sending a written notice to Compliance@clearwellness.com or via in-app settings. Revocation is effective when processed and does not affect disclosures already made.
For ClearCaptions IP CTS Users:
- Authorized Representatives. We may disclose your personal data to authorized recipients, legal guardians, or caretakers with whom we interact on your behalf during service registration, setup, or fulfillment.
- Installation Partners. We may disclose your personal data to third parties who assist us in the installation, setup, or repair of our IP CTS products and services.
- TRS Program Administration. We may disclose your personal data in accordance with applicable laws and regulations, including the FCC’s rules applicable to TRS providers, and as needed for TRS program and fund administration.
Business Services Providers. These are persons or entities with whom we have a relationship to provide business operations services and support to ClearCaptions. These providers may include the following:
Marketing and Advertising Providers. These include advertising, direct marketing, and lead generation providers, affiliate marketing program providers, retargeting platforms, data brokers, ad networks, marketing consultants, and similar services providers.
Law Enforcement/Government Agencies. Persons to whom we are required by law to provide information, such as pursuant to a subpoena or a court order.
Corporate Transaction Disclosures. Persons involved in the consideration, negotiation, completion of a business transaction, including the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration.
Authorized Disclosures. To any party when authorized by the individual to whom it pertains to share it.

6. DATA RETENTION

We retain your personal information only as long as needed to fulfill the purposes we collected it for, including satisfying legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider (i) the amount, nature, and sensitivity of the personal information; (ii) the potential risk of harm from unauthorized use or disclosure of your personal information; (iii) the purposes for which we process your personal information and whether we can achieve those purposes through other means; and (iv) the applicable legal requirements related to our processing activities. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. If you have any questions about the specific retention periods for different types of your personal information, please feel free to contact us using the Contact Information provided below.

7. YOUR PRIVACY CHOICES

You can control the collection and use of personal information for some of our processing activities. Below are the avenues through which you can manage the types of communications you receive from us:

Email: To opt out of promotional emails, you may follow the ‘unsubscribe’ instructions located at the bottom of each email. Alternatively, you may contact us directly using the information provided in the Contact Information section. Please be advised that opting out of promotional communications will not preclude you from receiving transactional emails, such as those related to purchases or account activity.
Text Messages: To discontinue receiving automated text notifications, simply reply ‘STOP’, ‘CANCEL’,’STOPALL’,UNSUBSCRIBE,END, or QUIT to any of our messages, email us at sms-unsubscribe@clearcaptions.com, or call us at 866-992-2192.
Mail Promotions: Should you wish to be removed from our mailing list for physical promotions and solicitations, please send a written request to our customer service department using the address provided in the Contact Information section of this Policy. Ensure your full name and mailing address are included in your correspondence.
For ClearCaptions IP CTS Customers: We may use or disclose CPNI to third parties to offer you products and services that may be different from the types of services you already use. ClearCaptions asks for your consent to do this during your registration process. You may withdraw consent for this use of your CPNI for marketing purposes at any time. If you wish to restrict ClearCaptions’ use of your CPNI for such marketing purposes, you may do any of the following:
- Log in to your account at portal.clearcaptions.com, go to the “CPNI Opt In” section of your user profile (Profile), and uncheck the “CPNI Opt-in” checkbox;
- On the ClearCaptions Phone (excluding the Ensemble) navigate to the ‘My Account’ section in Settings, log in, and uncheck or toggle off “CPNI” from the CPNI section; or
- Call ClearCaptions Customer Support at +1 (866) 868-8695.

8. YOUR PRIVACY RIGHTS

8.1. Description of Your Privacy Rights

Depending on your location and applicable laws and regulations, you may also have data privacy rights regarding ClearCaptions’ processing of your personal information. Based on the legal requirements applicable to your jurisdiction, and subject to any legal restrictions or exceptions, you may have the choices and rights described below.

Right to Access. You may request access to the personal information we hold about you. This may include the right to be informed about the categories and specific pieces of personal information we have collected, the sources from which we collected it, the purposes for collecting it, and the third parties with whom we have shared it.
Right to Correct. You may request that we correct any inaccurate personal information relating to you without undue delay. In this context, taking into account the purposes of the processing, you may also have the right to request the completion of incomplete personal information.
Right to Delete. You may request the deletion of your personal information, subject to certain exceptions. In certain circumstances, it may not be possible for us to accept your request, for example, when the processing is necessary to comply with a legal obligation, or if the processing is necessary for the performance of a contract.
Right to Portability. You may request that we provide you with a copy of your personal information in a structured, commonly used, and machine-readable format. You also have the right to request that we transfer this information to another data controller, where technically feasible.
Right to Opt Out of Sale. You may direct us not to sell or share your personal information with third parties.
Right to Opt Out of Targeted Advertising. You may request that we not disclose, disseminate, or transfer your personal information to a third party for targeted advertising (also known as “cross-context behavioral advertising”). You may opt out of this activity by clicking “Your Privacy Choices” in the website footer and opting out of targeted advertising cookies.
Right to Restriction of Processing. You may request that we restrict processing of your personal information. In certain circumstances, it may not be possible for us to accept your request, for example, when the processing is necessary to comply with a legal obligation, or if we can demonstrate compelling legitimate grounds otherwise.
Right to Opt Out of Certain Data Processing. You may withdraw your consent that you have previously provided for ClearCaptions’ collection, use or disclosure of your personal information, subject to reasonable notice and any contractual or legal exceptions. Note that this will not affect the lawfulness of our processing of your personal information based on consent before its withdrawal.
Right to Opt Out of Automated Individual Decision-Making. You may have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Note that this right shall not apply if such a decision is necessary as part of a contract we have with or want to conclude with you, we have your consent, or we are permitted by law to engage in such automated decision making. In these cases, we will implement measures to safeguard your rights and freedoms and legitimate interests, and you may contest the decision by contacting us as set forth below.
Right Against Discrimination. You have the right not to be discriminated against for exercising any of your data protection rights. This means that we will not deny you goods or services, charge you different prices or rates, or provide you with a different level or quality of goods or services based solely on your exercise of these rights.
Right to Appeal. Depending on your residency, you may have the right to appeal if we decline to act regarding your privacy request. To do so, please follow the instructions for exercising your privacy rights below, or use the contact information provided in this Policy.

Residents of California may also have additional rights pertaining to their personal information, as described in "California Privacy Rights.”

8.2. Exercising Your Privacy Rights

To exercise any of the rights outlined above, please visit our web form.

To ensure the security and confidentiality of your personal information, we have established verification measures that must be completed prior to fulfilling certain requests to exercise your data rights. These measures may involve confirming your identity through a series of questions or requiring documentation that substantiates your identity or authority to make the request. Should we be unable to verify your identity or authority adequately, we reserve the right to decline the request and will provide an explanation for our decision. Upon receiving a verified request to exercise your data rights, where applicable, we will acknowledge receipt of the request. We will aim to respond substantively to your request within time permitted under the applicable law. If we require more time to process your request, we will inform you of the reason and extend the period by the notified number of days.

Please note that not all requests will be granted. Certain legal exceptions may apply, such as if we are unable to verify your identity, or if there are legal or contractual reasons that prevent us from fulfilling a deletion request. Regardless of the outcome, you will receive a written response that either details the actions we took or explains why no action was possible. If you are dissatisfied with our initial response, you may seek further review.

To initiate an appeal, please contact us within 30 days of receiving our initial response using the method provided in the response. You should include a copy of your original request, our response, and a detailed explanation of why you are seeking reconsideration. You may also attach any additional supporting information and documents that you believe are relevant. We will review your appeal and provide a final determination within 60 days.

9. SECURITY

We implement recognized physical, technical, and organizational safeguards tailored to protect the confidentiality, integrity, and availability of personal data we collect and process. These safeguards are designed to prevent unauthorized or unlawful access, destruction, loss, alteration, or disclosure of personal data. However, despite our best efforts, no security measures can provide absolute protection against all security threats, and we cannot guarantee that unauthorized access or loss will never occur. We have procedures in place to deal with any suspected data security breach. We will notify the appropriate person and/or any applicable regulator of a suspected data security breach where we are legally required to do so.

10. CHILDREN’S PRIVACY

Our websites are not directed to children and are intended for use by individuals who have reached the age of majority in their jurisdiction, or the age of digital consent where applicable. We do not knowingly collect personal information from children without the appropriate consent required by law. We may offer certain services that can be used by children. In those cases, a parent or legal guardian must provide any required consent before a child may use the service. We collect, use, and disclose a child’s information only as permitted by applicable law, including any limits on targeted advertising, profiling, and data sharing.

If you are a parent or guardian and believe we have collected personal information from your child without the required consent, contact us at compliance@clearcaptions.com . We will take reasonable steps to verify your request and delete the information unless we are required to retain it for legal, safety, or security reasons.

California residents: we do not sell or share personal information of consumers under 16 years of age without the required opt in. United States residents: when a service is intended for use by children under 13, we obtain verifiable parental consent consistent with the Children’s Online Privacy Protection Act.

11. UPDATES TO THIS PRIVACY POLICY

We reserve the right to modify this Policy at any time to reflect changes in our practices, services, or legal obligations. Any modifications will be effective upon the date specified in the updated Policy. If we make material changes to this Policy that significantly affect your rights or the way we use your personal information, we will notify you through the most appropriate channels. Generally, this will be done by updating the date at the top of this page. However, other notification methods may include sending an email to the address you have provided, posting a notice on our Services, or other methods as required by law. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.

We will indicate the date of the last revision at the top of this Policy. We encourage you to periodically review this Policy to stay informed about how we are protecting your personal information.

12. CALIFORNIA PRIVACY RIGHTS

This section is tailored to meet the specific requirements imposed by California law. While this section outlines state-specific rights for California residents, the preceding sections of this Policy also apply to them.

12.1. Additional Notice to California Residents

California law requires us to disclose the following additional information with respect to our privacy practices. If you are a California resident, this section applies to you in addition to the rest of the Policy.


Description of Information Practices Regarding CCPA-Defined Categories of Personal Information
Category	Examples	Collected	Disclosed for a Business Purpose	Shared for Cross-Context Behavioral Advertising
Identifiers	A real name, alias, postal address, unique personal identifier (e.g., employee ID), online identifier, Internet Protocol address, email address, driver's license number, passport number or other similar identifiers.	✔	✔	✔
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, Social Security number, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	✔	✔
Protected classification characteristics under California or federal law	Age (40 years or older), citizenship, marital status.	✔	✔
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	✔	✔
Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Internet or other similar network activity	Browsing history, information on a consumer's interaction with a website, application, or advertisement.	✔	✔	✔
Geolocation data	Physical location or movement.	✔	✔	✔
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	✔	✔
Professional or employment-related information	Current or past job history or performance evaluations.
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Inferences drawn from other personal information	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	✔	✔	✔
Sensitive Information	Government identifiers (social security, driver's license, state identification card, or passport number); complete account access credentials (usernames, account numbers, or card numbers combined with required access/security code or password); precise geolocation; racial or ethnic origin; mail, email, or text message contents; genetic data; data concerning health, sex life or sexual orientation.	✔	✔

For a comprehensive understanding of the types of personal information we collect, the sources from which we collect it, and the purposes for which we use it, please refer to the “Information Collected and How We Use It” section of this Policy.

Notice of Financial Incentive. We may offer our customers loyalty and other incentive programs that provide certain benefits, such as rewards and exclusive offers. We may also provide other promotional campaigns, such as sweepstakes, contests, or limited-time promotions (collectively, the “Programs”). When you sign up for one of these Programs, we typically ask you to provide your name and contact information (such as email address and/or telephone number). Because our Programs involve the collection of personal information, they might be interpreted as a “financial incentive” program under the CCPA. The value of your personal information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the applicable Program, less the expense related to offering those products, services, and benefits to Program participants. Participation in a Program is governed by the applicable terms and conditions (including the Official Rules for any sweepstakes or contest or the promotional terms for any short-term promotion), which will also describe the financial incentives associated with the promotion and how to participate. You are not obligated to participate in any contest, sweepstakes, or short-term promotion and may terminate your participation at any time (as described in the Program terms and conditions). You may withdraw from participating in a Program at any time by contacting us using the designated method set forth in the applicable Program terms and conditions.
Shine the Light Disclosure. California Civil Code Section § 1798.83, also known as the “Shine the Light” law, permits California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for direct marketing purposes in the preceding calendar year, as well as the type of personal information disclosed. To make such a request, please send an email with the subject “Shine the Light Request” to the email address in our Contact Information.

12.2. California-specific Privacy Rights

California law grants specific rights to California consumers regarding their personal information. Note that these may be duplicative of the rights described above in “Your Privacy Rights”. They are as follows:

Right to Know. You can request, up to two times each year, that we disclose the categories and/or specific pieces of personal information that we collect, use, disclose, and may sell, the sources from which we collected it, the purposes for collecting, selling, or sharing it, as applicable, and the categories of third parties to whom we have disclosed it.
Right to Correction of Personal Information. You have the right to have inaccurate personal information corrected.
Right to Deletion of Personal Information. You can ask us to delete the personal information that we have collected from you, subject to certain exceptions such as to complete a transaction for you, to exercise our rights, or to comply with a legal obligation.
Right to Opt out of Sales of Personal Information. You have the right opt out of the sale of your personal information to third parties. In the preceding twelve (12) months, ClearCaptions has not “sold” personal information as this term is defined in the CCPA. Therefore, we do not offer such a right.
Right to Opt Out of Sharing of Personal Information. The CCPA defines “sharing” as disclosing or making a consumer’s personal information available to a third party for cross-context behavioral advertising. In the preceding twelve (12) months, ClearCaptions has shared certain categories of personal information (identified in the above table) with third-party advertisers to tailor ads to consumers’ interests. You have the right to opt out of your personal information being shared for targeted advertising, and you may exercise this right by clicking “Cookie Settings” in the website footer and opting out of Targeted Advertising Cookies.
Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to direct us to limit our use of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer. ClearCaptions does not use sensitive personal information beyond the CCPA’s permissible purposes.
Right against Discrimination. You are entitled to exercise the rights described above free from retaliation as prohibited by the CCPA.
Right to Appeal. If we deny your request to exercise a right, you have the right to appeal our decision.

To exercise your California privacy rights, please visit this web form or use the contact methods described below. We may request specific information from you to help us confirm your identity and your rights. We will respond to your request within a reasonable period (if properly submitted) and in accordance with applicable law. If we need more time to verify your identity, process and respond to your request, we will notify you of that fact along with the reason for the delay. If we decline to act regarding your request, we will inform you of our decision and the reason for it, and, if applicable, with instructions on how you may appeal our decision.

You have the option to designate an authorized agent to submit requests on your behalf for exercising your data rights. An authorized agent can be either a person or a business entity that you have formally authorized to act on your behalf.

To use an authorized agent:

Signed Authorization: You must provide the authorized agent with a signed written authorization to act on your behalf. This document should clearly indicate that you grant them the authority to submit requests for you.
Agent Submission: The authorized agent can then submit a request via the methods outlined above. The agent should attach a copy of the written authorization you provided.
Identity Verification: We may contact you directly to confirm that you have authorized the agent to act on your behalf. This is a security measure designed to protect your personal information.

Please note that we reserve the right to deny requests from agents who do not provide proof of authorization or if we cannot verify the agent’s identity.

13. CONTACT INFORMATION

If you have any questions or concerns about this Policy or our data practices, you can reach out to us through the following means:

Email: compliance@clearcaptions.com

Mail: ClearCaptions Compliance/Legal Department, 3026 Owen Drive, Suite 111, Antioch, TN 37013

Submit Your Privacy Rights Request: https://clearcaptions.com/data-requests/

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