Last Updated: June 10, 2022.
IF YOU ARE A NEVADA RESIDENT: If you are a resident of Nevada, please see the section titled Additional Information for Nevada Residents below, which will inform you in detail about our information collection practices and your specific rights.
Clockwork is a Delaware Corporation with the following contact information:
4357 Cedarhurst Circle
Los Angeles, CA 90027United States
If you have reason to believe that a child under the age of 16 has provided personal data to Clockwork through the Platform, please contact email@example.com and we will endeavor to delete that information from our databases.
What personal information we collect and process depends on a number of factors. As explained in more detail below, we process personal information that we receive directly from you when you provide it to us, such as when you sign up for our Services, or indirectly, such as through automated technologies (e.g., cookies) or from third parties. We also collect personal information for Executive Profiles in a variety of ways, as explained below.
We use the terms ‘controller’ and ‘processor’ or ‘service provider’ as they are commonly understood under applicable privacy laws. With respect to its collection and processing of personal information, Clockwork generally acts as a ‘data processor’ and ‘service provider’ when it collects and processes personal information on behalf of its Customers in order to provide the Services. We also act as a ‘data controller’ when we collect personal information on our own behalf and for our own commercial and business purposes, such as from Site Visitors or to register Customers, to improve our Services or send marketing.
You can generally visit our Site without having to submit any personal information. However, if you wish to use our Services, you will be asked to provide information about yourself.
If you contact us through our “Contact” form on the Site or otherwise send us an email, we process any personal information contained in those communications, including name, contact information, company and any other information that you submit to us.
If you sign up for our Services, whether as a Basic or Pro plan, we or our third party processors will collect personal information as follows:
If you are a Customer, we use PCI-compliant third-party processors, as explained in Payment Processing. Payment information is processed by our payment service providers, and we receive a confirmation of payment, which we then associate with your account and any relevant transactions.
Customer reviews may contain names, company names, photos and contact information. If you submit a Customer review, with your consent, it may be posted on the Site and publicly visible. We may also share it with strategic partners.
If you are browsing or interacting with the Site, we collect the same basic information that many other websites collect. Even if you do not have an account, we, or authorized third parties engaged by us, automatically collect information about your use of the Site, which consists of:
As a processor for our Customers, Clockwork processes information about individuals with whom it does not have a direct relationship on behalf of its Customers. We receive these Executive Profiles on behalf of our Customers from third parties. This information is provided to our Customers as part of the Services. Information that we collect and store to create Executive Profiles (“Executive Profile Data”) consists of business or professional information and includes personal and non-personal data.
Please contact the relevant Customer controller to access or have their Executive Profile Data updated, rectified or deleted.
We also use Hubspot on our Platform. You can read about Hubspot's use of personal data at https://legal.hubspot.com/product-privacy-policy.
We collect payments from Customers only and do not directly collect or store payment information. We use third-party, PCI-compliant, payment processors, which collect payment information on our behalf in order to complete transactions with our Customers. While our administrators are able to view and track actual transactions via the client portals of the payment processors, we do not have access to, or process, credit card information. We currently use Stripe to process certain payments and you can read more about Stripe’s collection of personal information at https://stripe.com/privacy.
We use your personal information for a number of different reasons, as further explained below.
In addition, for users located in the EEA and the U.K., we must have a valid legal basis in order to process your personal data. Generally speaking, the main legal bases under the European Union’s General Data Protection Regulation (GDPR) that justify our collection and use of your personal data are:
Below are the general purposes and corresponding legal bases (in italics) for which we may use your personal data:
We disclose your personal data as described below.
Clockwork discloses users’ information to our third party agents, contractors or service providers who are hired to perform services on our behalf. These companies do things to help us provide the Platform, and in some cases collect information directly, for example as explained in Payment Processing above. Below is an illustrative list of functions for which we may use third-party service providers:
Executive Profile Data is disclosed to our Customers that are the controllers of such personal data in connection with our Services. To exercise your rights with respect to personal information contained in your Executive Profile, please see the Executive Profile Data section above.
As we continue to grow, we may purchase websites, applications, subsidiaries, other businesses or business units. Alternatively, we may sell businesses or business units, merge with other entities and/or sell assets or stock, in some cases as part of a reorganization or liquidation in bankruptcy. In order to evaluate or as part of these transactions, we may transfer your personal information to a successor entity upon a merger, consolidation or other corporate reorganization in which Clockwork participates, or to a purchaser or acquirer of all or a portion of Clockwork’s assets, bankruptcy included.
We share aggregated, automatically-collected or otherwise non-personal information with third parties for various purposes, including (i) compliance with reporting obligations; (ii) for business or marketing purposes; (iii) to assist us and other parties in understanding our users’ interests, habits and usage patterns for certain programs, content, services, marketing and/or functionality available through the Platform. We do not share personal information about you in this case.
If we are required to disclose personal information by law, such as pursuant to a subpoena, warrant or other judicial or administrative order, our policy is to respond to requests that are properly issued by law enforcement within the United States or via mutual legal assistance mechanism (such as a treaty). However, if we receive information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person, we may provide information to law enforcement trying to prevent or mitigate the danger (if we have it), to be determined on a case-by-case basis.
We advertise our Platform by targeting (and measuring the performance of) ads to Site Visitors, Customers on other websites and platforms directly or through a variety of partners, including third party advertisers, ad server companies, social networks and ad networks (collectively, “External Ad Partners”). In order to advertise our Services, we or our External Ad Partners use the following information, whether separately or combined:
When we serve ads based on the foregoing information, it is referred to as “targeted advertising” because External Ad Partners track your activity on and off the Site in order to deliver targeted advertising based on your activity, such as one of your visits to the Site. In addition, as noted above, the information that External Ad Partners collect from our Services may be combined with other information from other sources and be used to build profiles on you and other individuals for the purposes of delivering targeted advertising.
In addition to advertising our Services, we use Customer data and content to market our Services, promote additional features or encourage Customers to share our Platform.
For more information about interest-based advertising, please visit the Network Advertising Initiative website and/or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising website. To learn more about interest-based advertising and to opt-out of this type of advertising by third parties that participate in the DAA’s AppChoices tool, please use this link. Please note that any opt-out choice you exercise through these programs will apply to interest-based advertising by the third parties you select, but will still allow the collection of data for other purposes, including research, analytics, and internal operations. You may also continue to receive advertising, but that advertising may be less relevant to your interests. You may have more options depending on your mobile device and operating system. For example, most device operating systems (e.g., iOS for Apple phones, Android for Android devices) provide their own instructions on how to limit or prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems to learn more about these features and how they apply to tailored in-app advertisements.
Please visit our Cookie Disclosure for more information on the types of cookies that are used by us and our External Ad Partners within the Services, as well as information on your choices and how to opt -out.
For users in the EEA and U.K., we provide opt-in mechanisms with respect to non-essential cookies. If you opt-in and subsequently change your mind, you may withdraw your consent at any time by contacting us or clicking 'COOKIE SETTINGS' at the bottom of any of our webpages.
Some browsers have incorporated Do Not Track (“DNT”) preferences. Most of these features, when turned on, send signals to the website you are visiting that you do not wish to have information about your online searching and browsing activities collected and used. As there is not yet a common agreement or industry standard about how to interpret DNT signals, Clockwork does not honor DNT signals from web browsers at this time. However, you may refuse or delete cookies as described above. For more information on DNT settings generally, please visit https://allaboutdnt.com.
To keep your information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update any information in our possession that you have previously submitted via the Platform. Note that you may also manage your communications preferences and the receipt of any commercial communication by clicking the “unsubscribe” link included at the bottom of all emails from Clockwork. You may also adjust your preferences through your account settings if you have a Clockwork account, or send an email to firstname.lastname@example.org.
You have choices about how to protect and limit the collection, use, and sharing of information about you. Note that in order to protect your privacy and security, we will also take reasonable steps to verify your identity before granting you access or enabling you to make corrections or delete your information.
You can access and change certain information through the Platform if you are a Customer, or by contacting us as email@example.com.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject first and third-party cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. For more information on controlling how cookies and similar technologies are used on the Site, see our Cookie Disclosure.
For users in the EEA and U.K., we provide opt-in mechanisms with respect to non-essential cookies. If you opt-in and subsequently change your mind, you may withdraw your consent at any time.
Some analytics providers we partner with may provide specific opt-out mechanisms. For example, you may manage the use and collection of certain information by Google Analytics via the Google Analytics Opt-out Browser Add-on.
You may also generally opt-out of receiving personalized advertisements from certain third-party advertisers and ad networks. To learn more about these advertisements or to opt-out, please visit the sites of the Digital Advertising Alliance and the Network Advertising Initiative, or if you are a user in the European Economic Area, Your Online Choices.
For users in the EEA and U.K., we provide opt-in mechanisms with respect to non-essential cookies. If you opt-in and subsequently change your mind, you may withdraw your consent at any time.
You may opt-out of receiving some or all categories of promotional communications from Clockwork by following the instructions/link contained in those communications or, if you are a Customer, by updating your email options in your account preferences. If you opt-out of promotional communications, we may still send you non-promotional communications, such as information about your account and/or transactions, or your use of the Services.
We use the following criteria to determine our retention periods: the amount, nature and sensitivity of your information, the reasons for which we collect and process your personal data, the length of time we have an ongoing relationship with you and provide you with access to our Platform, and applicable legal requirements. We will retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements). Additionally, we cannot delete information when it is needed for the establishment, exercise or defense of legal claims (also known as a “litigation hold”). In this case, the information must be retained as long as needed for exercising respective potential legal claims.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.
For any questions about data retention, please contact firstname.lastname@example.org.
In some instances, we may choose to anonymize your personal data instead of deleting it, for statistical use, for instance. When we choose to anonymize, we make sure that there is no way that the personal data can be linked back to you or any specific user.
We take steps that are reasonably necessary to securely provide our Platform. We have put in place reasonably appropriate security measures designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We limit access to personal data only to those employees, agents, contractors and the third parties who have a business need-to-know.
We also have procedures in place to deal with any suspected data security breach. If required, we will notify you and any applicable regulator of a suspected data security breach. We also require those parties to whom we transfer your personal information to provide acceptable standards of security.
Notwithstanding, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Platform may not be secure. Therefore, take special care in deciding what information you send to us via email. For any questions about the security of your information, please contact email@example.com.
We do not sell your personal information within the scope of, and according to the defined meaning of, a “sale” under NRS 603A.
We are located in the United States, and the personal information that we collect is stored on servers located in the United States. This means that your personal information will be collected, processed and stored in the United States, which may have data protection laws that are different from (and sometimes less protective than) the laws of your country or region, such as the GDPR.
Note: Customers are considered controllers of Executive Profile Data that they receive in connection with the Services and we are the processors of such Executive Profile Data. As such, for Customers that are not located in the EEA, the U.K or a third country deemed adequate by the European Union and that access and create a back-up copy of Executive Profile Data must enter into and adhere a data protection addendum with us.
If you are in the EEA or the U.K., please read this section for more information.
If you are in the EEA or the U.K., you have certain rights in relation to your personal data:
These rights are subject to certain rules around when you can exercise them.
If you are located in the EEA or the U.K. and wish to exercise any of the rights set out above, you may contact us at firstname.lastname@example.org. If you are in the EEA, you may contact our representative in the EU, as explained below.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request under those circumstances.
We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. If we cannot reasonably verify your identity, we will not be able to comply with your request(s).
We will respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated as required by law.
Sometimes, Clockwork acts as a ‘joint controller’ with certain third parties, namely certain social media sites, such as LinkedIn or Facebook. When Clockwork and a partner act as joint controllers, you (as a data subject) may exercise your rights against Clockwork and/or the third party. For a list of joint controller relationships, please contact us at email@example.com.
In order to market our Platform and stay in touch with users, we maintain a Facebook page (“Facebook Products”). With respect to our use of these Facebook Products, we are jointly responsible with Facebook Ireland for the processing activities (“Joint Processing”):
Facebook Ireland Ltd.,
4 Grand Canal Square, Grand Canal Harbor
Dublin 2, Ireland
Information about the personal data that is collected from you by Facebook, as well as how and why it is processed by Facebook, can be found at https://www.facebook.com/about/privacy.
It cannot be excluded that some processing by Facebook Ireland Ltd. will also take place in the United States by Facebook Inc.
With respect to our use of the “Page Insights”, we are joint controllers of your personal data with LinkedIn. You may find the joint controller addendum at https://legal.linkedin.com/pages-joint-controller-addendum.
General Data Protection Regulation (GDPR) – European Representative
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Clockwork ESE, Inc. has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU.[KEG4] [CS5] You can contact EDPO regarding matters pertaining to the GDPR by:
UK General Data Protection Regulation (GDPR) – UK Representative
Pursuant to Article 27 of the UK GDPR, Clockwork ESE, Inc. has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR by: