Privacy Policy
Last Updated: July 19, 2023
This Privacy Notice (“Notice”) explains how Clarus Direct, LLC (“Clarus Direct”, “our”, “us”, “we”), an consumer engagement company, collects, processes, and uses information that individuals (“users,” “you,” or “yours”) share with us, with our service providers, and other information we collect as you interact with our services.
We are committed to protecting the privacy of the information that you provide to us. This is your information that (i) you choose to provide to us directly; (ii) we gather when you visit our website at clarusdirect.com or other websites we own or manage (the “Site”); (iii) we gather when you interact with Clarus Direct directly (e.g., our website, mailboxes, points of entry offline); we possess and process; or (v) is provided to us by an affiliate network or service provider.
By accessing or using the Site, you signify your agreement to be bound by our Privacy Notice. If you do not agree to this privacy notice, you may not access or otherwise use our Site.
If you have any questions about this Notice, please email us at privacy@clarusdirect.com or call (860) 358-9198. Additional contact information is provided in the “Contacting Us” section below.
1.0 Information We Collect
1.1 Personally Identifiable Information (“PII”)
Clarus Direct may collect personally identifiable information, “PII”. This information may include, but is not limited to: your name, date of birth, marital status, mailing address, e-mail address, credit card information, telephone number, interests, online habits, your activity on the Site, geographical location, images, social posts, video, audio, and social media information. PII collected by an affiliate network will be used by the affiliate network in accordance with that particular network’s privacy policy.
In addition to the information you may provide directly, we may analyze your browsing behavior to draw inferences and create profiles about your personal preferences and behaviors. We may then use such information for the purposes described in this notice.
1.2 Personal information that is not PII.
Clarus Direct may also collect or generate non-personally identifiable information about your use of our services or use of an affiliate network. This information includes, but is not limited to, browser type and version, operating system, referral source, length of visit, page views, demographics, analytical data, receipts, images, social posts, video, audio, information collected by website visitor tracking tools such as “cookies,” “web beacons,” “pixels,” Internet tags and other navigational data. More information about our online activity tracking tools is provided below.
1.3 Website Visitor Tracking Tools That We Use
1.3.1 Cookies
“Cookies” are small pieces of information that are stored by your web browser on your device or temporarily in your device’s memory. The use of cookies is now an industry standard, and you will find them on most major websites.
Clarus Direct may place and store cookies on your device. We use cookies to help us remember, understand, and save your preferences for future visits, and compile aggregate data about Site traffic and Site interaction so that we can offer better Site experiences and tools in the future. The use of cookies provides benefits to you by saving your name, information supplied at registration, and other information that may make the use of our promotions easier. Although most web browsers are initially set up to accept cookies, if you prefer, you can decline the placement of a cookie on your device by using the appropriate setting(s) or feature(s) of your web browser software (if available) or device to block or delete the cookie.
Please note, however, that certain areas on the Site may not function properly if your web browser does not accept cookies. When you visit our Site, visit a link to a retailer, , or open an email you have received from us, we may place or recognize a unique cookie on your browser. These cookies enable us to provide our services, present you with relevant ads about our services, customize our services, gather insight analytics about our Site visitors, and honor preferences about advertising and communications made through the Site, a retailer, a vendor, or an affiliate network.
1.3.2 Web Beacons and Pixels
Additionally, emails we send to you may contain a bit of code known as a “web beacon” or “pixel.” This code helps us understand the time and date that you opened an email and when you used a link within the email to visit the Site, allowing us to collect analytics about our traffic, customize our services, and present you with relevant ads about our services. You can disable our web beacons by turning images “off” in your email client (e.g., Outlook, Apple Mail, or Gmail).
1.3.3 Third Party Tools
We make use of third party tools including fraud detection and prevention tools, web analytics tools, and tools capable of recording your interactions with the site. These tools are used to maintain site security, optimize site functionality and improve the user experience. Agreements are in place that limit how these third parties use your PII to the deliver the services provided by the third party.
2.0 How we Use the Information We Collect
Generally, we may use your information that we collect for: (i) analytical purposes, including the creation of recognition databases; creation of common event data databases; development and use of benchmarking, indexing, and analytics; product development, testing, analytics, modeling and algorithm development (e.g., machine learning, artificial intelligence, and fraud mitigation); (ii) delivering our services; and (iii) internal and third-party fraud detection, data matching, validation and recognition use, including, for example, use of PII for recognition database, matching to external services and augmentation with third party information. More information about how we use the information we collect is provided below.
2.1 To Operate Our Services and Personalize Your Experience
Our services may include features that personalize your experience. To that end, we may use your PII and non-personally identifiable information to operate and benchmark the services, including, without limitation, to process transactions with you and validate the information you provide. We may also use your email domain to determine your affiliation with a particular organization or industry or to personalize the content and experience you receive. We may use your IP address to serve you state or region-specific content, and to comply with relevant regulatory requirements.
2.2 For Development and Improvement of Our Services
We continually strive to improve our services to make them more engaging, secure, rewarding, and useful to you. We use the information we collect to better understand how Site visitors engage with the Site, to troubleshoot and to identify areas for improvement.
2.3 To Communicate With You About The Services
We use your PII to send transactional communications to you by email, text messages, mobile app messaging, and other means regarding our services. We also respond to your comments, questions and requests, provide customer support, and may send you notices, updates, and administrative messages using your PII. We also provide personalized communications based on your activity and interactions. For example, certain actions you take on a Site (such as downloading a white paper) may automatically trigger communications related to our services. If an opt-out is available, you will find that option within the communication itself. For more information about opting out, please see “Opting Out of Clarus Direct use of PII” and “Contacting Us” (Sections 6.0 and 7.0).
2.4 To Market, Promote, and Drive Engagement With The Services
We will use your information about how you engage with our Sites to send communications that may be of specific interest to you, including by email, and by displaying Clarus Direct ads on other companies’ websites and applications, as well as on platforms like Facebook and Google. These communications are aimed at driving engagement with our services and may include information about new programs and sites we think may be of interest to you. We may also communicate with you about new product and service offerings, promotions and contests. You can control how and whether you receive these communications as described below in “Opting Out of Clarus Direct use of PII” and “Contacting Us” (Sections 6.0 and 7.0).
2.5 Fraud Detection and Prevention; Safety and Security
We will use your information to detect and prevent fraud and as may be otherwise necessary to help ensure the integrity of our services and to identify violations of the Terms of Service or the policies of Clarus Direct or those of our service providers.
2.6 To Protect our Legitimate Business Interests and Legal Rights
Where required by law or where we believe it is necessary to protect the legal rights and interests of Clarus Direct, our clients, or others, we may use your PII in connection with legal claims, compliance, regulatory, and audit matters.
2.7 With Your Consent
We also use your PII where you have provided consent for Clarus Direct or service providers to do so for a specific purpose not listed above. For example, with your consent, we may post consumer reviews or other user generated content to the site or to social media platforms.
2.8 Customer Support
We use your PII and non-personally identifiable information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve our services.
2.9 Legal Bases for Processing (for EEA and UK Site Visitors)
If you are an individual in the European Economic Area (EEA) or the United Kingdom (UK), we collect and process your PII only where we have at least one legal basis for doing so under applicable EU or UK law. The legal bases depend on how you interact with Clarus Direct services. For example, how you contact us, or what services you request may impact which legal bases apply. This means we collect and use your PII only where:
– We need it to provide service, provide customer support and personalized features, help prevent fraud, and to protect the safety and security of our platforms and services;
– It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for our internal development of improved services, to market and promote our services, and to protect our legal rights and interests;
– You give us consent to do so for a specific purpose; or
– We need to process your PII to comply with a legal obligation or where the processing is necessary to the establishment, exercise or defense of legal claims.
If you consented to our use of your PII for a specific purpose, you have the right to change your mind at any time but note that this will not affect processing that has already taken place.
Where Clarus Direct is using your PII because Clarus Direct has a legitimate interest to do so, you have the right to object to that use although this may mean no longer participating in a service offering or opportunity. If we are unable to manage your relationship with Clarus Direct without the PII you provided (such as your registration information), you will no longer be able to access a service that requires that information. To learn how to opt-out of allowing use of your PII, please refer to “Opting Out of Clarus Direct use of PII” and “Contacting Us” (Sections 6.0 and 7.0).
3.0 THIRD PARTIES AND ADDITIONAL SERVICES
Clarus Direct may share or otherwise transfer your personally identifiable information (PII) to trusted third parties, such as service providers, affiliates or subsidiaries, who assist us in operating our Site, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
As we develop our business, we may transfer any information we have about you in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Clarus Direct or as part of a corporate reorganization or equity sale or other change in corporate control.
3.1 Third-party links
Hypertext links which redirect you to third-party websites may be encountered while browsing the Website. These hypertext links are maintained or operated by third parties, not Clarus Direct. These third-party websites are not under our control, and we are not responsible for the contents, links, or any changes or updates to these websites. Third-party sites linked on our Site may have separate and independent privacy policies. Further, the inclusion of any hypertext links on the Website does not imply endorsement by us of the related third-party website, that website’s contents or security, or any association or affiliation with its operators. Clarus Direct is not responsible for data and information collected by these third-party websites. Nonetheless, we seek to protect the integrity of our Site and welcome any feedback about these sites.
3.2 Third Party Identity Services
Third Party Identity Services
Clarus Direct may also offer sign-on services that allow you to interact with Clarus Direct, or our services, using a third-party identity service such as Facebook, Twitter, Instagram, YouTube, Google, Microsoft 365, etc. By using these services, we may share PII with that service about you and we may access the PII you make available through your third-party identity profile such as your name, age, gender, location, email address, and list of friends. This PII may be used by Clarus Direct to administer the technical and operational aspects of the Website or make your experience with our services more personal and social. Clarus Direct does not control the privacy practices of these (or any other) third-party services. We encourage you to read the privacy policies of these services before connecting to them.
4.0 Children’s Privacy
The Site is not directed or intended for children under thirteen (13) years of age. We do not knowingly collect Personal Information from individuals under thirteen (13) years of age. If you are under thirteen (13) years of age, you should not provide Personal Information on the Site or continue to use the Site.”
5.0 Security of PII
Although no computer network is invulnerable to attack, Clarus Direct uses reasonable physical, electronic, and procedural security measures designed to protect your PII from unauthorized disclosure, alteration or deletion.
6.0 Opting Out of Clarus Direct use of PII
In general, “opting out” means that you want Clarus Direct to limit the PII it collects and stores about you and to not present you with target marketing that is based on your interests or behavior, or inferences we may have drawn from your interests or behavior. Your opt out is applicable only to Clarus Direct marketing material and will not opt you out from platforms provided by any third-party. If you use multiple browsers, computers, or mobile devices, and wish to limit the PII Clarus Direct collects and stores or do not wish to receive Clarus Direct interest-based marketing on any of them, you must opt out from each browser, computer, and mobile device individually. Please note that if cookies are not enabled in your browser, or if you use certain ad-blocking tools, our opt-out mechanism may not work properly. Please also note that deleting your cookies does not opt you out. To opt-out of Clarus Direct using your PII, you need to contact us using the contact information provided below or by clicking on the “Do Not Sell or Share My Personal Information” link in the page footer.
6.1 Third Party Privacy Policies and opting out of Third Party use of PII
You should read the applicable third party’s privacy policy to learn how that client uses, discloses, and limits disclosure of your PII, as well as to understand your choices for opting out of its collection, amend it for accuracy, or have it deleted. Your desire to opt out of receiving marketing or other information from that third party will be handled in accordance with that particular third party’s privacy policy. Please note that opting out of a third party’s marketing program will not opt you out of Clarus Direct’s marketing programs. To learn how to opt out of Clarus Direct’s use of your PII, please see Section 6.0.
7.0 Contacting Us
It is Clarus Direct’s goal to keep all PII that you provide to us accurate. You may contact us to correct or update your PII, remove your PII or opt-out (if Clarus Direct is holding on to your PII as explained above), and to ask general questions regarding this Notice or any other privacy related issues. Clarus Direct’s privacy team can be reached at:
Clarus Commerce, LLC
500 Enterprise Drive
2nd Floor
Rocky Hill CT 06067
Phone: 860-358-9198
If you are based in the European Economic Area (“EEA”) or the United Kingdom (“UK”), you may contact our Data Protection Officer/Information Security Team at privacy@clarusdirect.com.
8.0 Terms of Use
Please also visit our Terms of Use section establishing the use, disclaimers, and limitations of liability governing the use of the Site at https://www.clarusdirect.com/terms-of-use/.
9.0 International Users
Clarus Direct is based in the United States, and, regardless of where you use Clarus Direct solutions or otherwise provide PII or other information, that information may be transferred to and maintained on servers located in the U.S.
10.0 CHANGES TO THIS NOTICE
This Notice was last updated on July 12, 2023. However, this Notice may change over time, for example to comply with legal requirements or to meet changing our business needs. The most up to date version can be found on the website. In case there is a change that we want to highlight to you, we will also inform you in another appropriate way (for example, via a pop-up notice or statement of changes on our website).
11.0 U.S. State Privacy Law Notices
11.1 State-specific Notices
11.1.1 California Resident Privacy Notice
This California Resident Privacy Notice disclosure (“Disclosure”) is provided pursuant to the California Consumer Privacy Act (“CCPA”) as amended and applies only to California residents. Any terms defined in the CCPA have the same meaning when used in this Disclosure. Terms defined in the Notice maintain the same meaning when used in this Disclosure.
This Disclosure is effective as of January 1, 2021.
The Personal Information (defined in Cal. Civ. Code §§ 1798.140(o)) that we collect and the manner we use it is covered in sections 1.0 and 2.0 above.
Your California Privacy Rights. Under California Civil Code sections 1798.83-1798.84, California residents are entitled to receive a notice describing what categories of personal customer information we share with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. This notice identifies the categories of information shared and includes a list of the third parties and affiliates with which it may be shared, along with their names and addresses. This notice appears below in the section entitled, “FreeShipping.com Personal Data Processing Disclosure”.
A California consumer may make the following requests as relates to their personal data collected on ClarusDirect.com under the rules of California Civil Code Section 1798.100 , using our Individual Rights Request process:
• Access: A consumer may request that Freeshipping.com disclose information collected about the consumer by Freeshipping.com
• Data Portability: A consumer may request that FreeShipping.com transfer any data it has collected and maintains about the consumer to the consumer for the purpose of transferring it to another entity.
• Correction: Once a consumer has access to their information, the consumer may request correction of their information maintained by Freeshipping.com
• Deletion: A consumer has a right to request deletion of personal information that Freeshipping.com collected from the consumer
An authorized Agent may make this request on your behalf. For your protection, where possible, we may verify the identity of the requestor and the nature of the request before completing the request.
11.1.2 Your Virginia Privacy Choices
Virginia residents are entitled to certain rights as relates to their personally identifiable information. Using our Individual Rights Request process, a Virginia consumer may make the following requests as relates to their personal data collected on ClarusDirect.com:
• Know: A consumer may request to know if ClarusDirect.com is processing their personal data
• Access: A consumer may request that ClarusDirect.com disclose information provided by the consumer to ClarusDirect.com
• Data Portability: A consumer may request that ClarusDirect.com provide a copy of any data it has collected and maintains about the consumer to the consumer.
• Correction: Once a consumer has access to their information, the consumer may request correction of their information maintained by ClarusDirect.com
• Deletion: A consumer has a right to request deletion of personal information that ClarusDirect.com has collected from or about the consumer
• Opt Out: A consumer may request that ClarusDirect.com not process the consumer’s personal data for (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling that may impact the opportunities the site provides to you.
An authorized Agent may make this request on your behalf. For the protection of our members, access to the inbox for to the member’s registered email address will be required to verify the request.
Please see the “Summary of Categories of Personal Information Processed” and “Summary: Categories of Personal Information Shared” charts below for a summary of the Personal Information that we collect in the course of providing you with services.
11.1.3 Your Connecticut Privacy Choices
Connecticut residents are entitled to certain rights as relates to their personally identifiable information.
Using our Individual Rights Request process, a Connecticut consumer may make the following requests as relates to their personal data collected on ClarusDirect.com:
• Access: A consumer may request to know what personal data ClarusDirect.com has collected about them.
• Data Portability: A consumer may request that ClarusDirect.com provide a copy of any data it has collected and maintains about the consumer to the consumer
• Correction: Once a consumer has access to their information, the consumer may request correction of their information maintained by ClarusDirect.com
• Deletion: A consumer has a right to request deletion of personal information that ClarusDirect.com has collected from or about the consumer
• Opt Out: A consumer may request that ClarusDirect.com not process the consumer’s personal data for (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling that may impact the opportunities the site provides to you.
An authorized Agent may make this request on your behalf. For the protection of our members, access to the inbox for to the member’s registered email address will be required to verify the request.
Please see the “Summary of Categories of Personal Information Processed” and “Summary: Categories of Personal Information Shared” charts below for a summary of the Personal Information that we collect in the course of providing you with services.
11.1.4 Your Colorado Privacy Choices
Your Colorado Privacy Choices. Colorado residents are entitled to certain rights as relates to their personally identifiable information.
Using our Individual Rights Request process, a Colorado consumer may make the following requests as relates to their personal data collected on ClarusDirect.com:
• Access: A consumer may request to know what personal data ClarusDirect.com has collected about them.
• Data Portability: A consumer may request that ClarusDirect.com provide a copy of any data it has collected and maintains about the consumer to the consumer
• Correction: Once a consumer has access to their information, the consumer may request correction of their information maintained by ClarusDirect.com
• Deletion: A consumer has a right to request deletion of personal information that ClarusDirect.com has collected from or about the consumer
• Opt Out: A consumer may request that ClarusDirect.com not process the consumer’s personal data for (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling that may impact the opportunities the site provides to you.
An authorized Agent may make this request on your behalf. For the protection of our members, access to the inbox for to the member’s registered email address will be required to verify the request.
Please see the “Categories of Personal Information Processed” and “Categories of Personal Information Shared” charts below for a summary of the Personal Information that we collect in the course of providing you with services.
11.2 Categories of Personal Information Processed
Below is a summary for the preceding 12 months of the categories of Personal Information we have processed in the course of providing services:
| Category | Examples | Processed by Clarus Direct |
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | Yes |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license, or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. | Yes |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | No |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Yes |
| E. 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. | No |
| F. Internet or similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | Yes |
| G. Geolocation data. | Physical location or movements. | Yes |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | No |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | No |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 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 codes. | No |
| K. Inferences drawn from other personal information. | Profile a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | Yes |
| L. Sensitive Personal Information (Cal. Civ. Code § 1798.140(ae)). | Social security number, precise geolocation, racial or ethnic origin, personal information collected and analyzed concerning health. | No |
11.3 Categories of Personal Information Shared
We may use or disclose Personal Information in the following categories in the course of providing services (the “Business Purpose Disclosures” in the table below).
| Category | Providing the Program Services, Security and Fraud Prevention | Sold | Shared with Third Parties | Used for Targeting Advertising | Used for Regulated Profiling |
| A. Identifiers. | Yes | No | Yes | No | No |
| B. Personal information categories listed in the California Customer Records statute | Yes | No | Yes | No | No |
| C. Protected classification characteristics under California or federal law. | Yes | No | No | No | No |
| D. Commercial information. | Yes | No | Yes | No | No |
| E. Biometric information. | No | No | No | No | No |
| F. Internet or similar network activity. | Yes | No | Yes | No | No |
| G. Geolocation data. | Yes | No | Yes | No | No |
| H. Sensory data. | No | No | No | No | No |
| I. Professional or employment-related information. | No | No | No | No | No |
| J. Non-public education information | No | No | No | No | No |
| K. Inferences drawn from other personal information. | No | No | Yes | No | No |
| L. Sensitive Personal Information (Cal. Civ. Code § 1798.140(ae)) | No | No | No | No | No |
11.4 No Sale
In the 12 months prior to the effective date of this Disclosure, Clarus Direct has not sold (as the term “sell” is defined in the CCPA) your Personal Information.
11.5 Requests Regarding Personal Information
You may have the right to request information about our collection of your Personal Information, to access it, or instruct us to delete it (subject to the exceptions below). To do so, please contact us using the information provided in “Contacting Us” (Section 7.0). Note that we may ask you to verify Personal Information we already have on file for you. If we cannot verify your identity based on the Personal Information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes. If we cannot comply with your request, we will provide you with an explanation.
11.5.1 Requests Regarding Personal Information
See below for the metrics required by Section 1798.185 of the California Civil Code (CCPA)
| Consumer Requests – ClarusDirect.com | |||||
| Reporting Period | Type | Number of Requests | Fulfuilled (%)* | Denied(%)** | Avg.Number of Days to Fulfill Requests |
|---|---|---|---|---|---|
| 2023 | Request to Know | 0 | N/A | N/A | N/A |
| Request to Opt-out † | 0 | N/A | N/A | N/A | |
| Request to Delete | 0 | N/A | N/A | N/A | |
| † : This site does not sell consumer data; this metric is included in this table as required by law. | |||||
| * : This site fulfills deletion requests through anonymization. | |||||
| ** :Requests may be denied for any of the reasons outlined in the CCPA, including but not limited to fraud prevention. | |||||
| These metrics are provided as required under Section 1798.185 of the California Civil Code. | |||||
11.6 Timing
We will use reasonable efforts to respond to your request within 45 days of receipt. If we require additional time, we will inform you of the reason and the extension period in writing.
11.7 Exceptions
We may deny your deletion request if retaining the Personal Information is necessary for us to:
• Complete the transaction for which we collected the Personal Information;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Identify and/or repair errors that impair the functionality of our services;
• Make other lawful uses of the Personal Information that are compatible with the context in which you provided it; and
• Comply with a legal obligation.
• Other exceptions as allowed by consent, contract, relevant laws, rules or regulations.
11.8 Content of Responses to Requests for PII Maintained by Clarus Direct
Any Personal Information we provide you with will only cover the 12-month period preceding our receipt of your request. Once we receive your request, validate your identity (and unless one of the exceptions above apply) we will disclose to you:
• The categories of Personal Information we collected about you;
• The categories of sources for the Personal Information we collected about you;
• Our business purpose for collecting that Personal Information and whether it was sold;
• The categories of third parties with whom we shared the Personal Information;
• If we sold or disclosed your Personal Information for a business purpose, we will provide you with information about those sales and disclosures along with the Personal Information categories that were provided and each recipients category.
• The specific pieces of Personal Information we collected about you (also called a data portability request, as detailed below).
11.9 Data Portability
For data portability requests, we will select a data format that is readily useable and should allow you to transfer the Personal Information to another entity without difficulty.
11.10 No Charge for Consumer Rights Requests
We do not charge a fee to process or respond to your Personal Information request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
11.11 No Discrimination in Processing Consumer Rights Requests
Clarus Direct will not discriminate against any consumer for exercising their rights under any applicable law or regulation.