Clear AmbitionSM Privacy Policy
Age Appropriate Access, Consent, and
Notice to Parents regarding
Children Under the Age of 13
The Clear Ambition program and Website (the
"Program") is designed for people of middle school age up through pre-retirement
age. The Program supports the Children’s Online Privacy Protection Act (“COPPA”)
which requires parental notice and consent when a website operator knowingly
desires to collect, use and disclose personal information from a child under the
age of 13.
Clear Ambition considers anyone under the age of 18 to be a minor,
and as such, requires written consent from a parent or legal guardian (“Parent”)
to participate in our Program. Such consent is obtained online prior to
information being stored as part of the sign up process for the Program. For
Parents of children under the age of 13, in addition to obtaining consent from
the Parent before the child can sign up to be a client, we provide the following
notice:
(1) The name and contact information for Clear Ambition is provided at the end of
this Privacy Policy. Clear Ambition will respond to all inquiries from Parents about
the Website’s Privacy Policy.
(2) We may collect non-personally
identifiable information and client information (as outlined below) from the
children of Parents either directly from the Parent or directly from the child,
after receiving the Parent’s consent, or via cookies.
(3) Clear Ambition uses
the information described in (2) above, for the purpose of providing the Program
to its clients, including those who are children, and to correspond with such
clients.
(4) Clear Ambition does not disclose the child’s information to third
parties beyond those involved in the operation and delivery of the Program. The
third parties who have access to Clear Ambition’s database include our offsite web
host server administrator and the provider of Clear Ambition’s online assessment and
planning tools. Additionally, our career consultants have access to the personal records of
only those clients to whom they are providing guidance. These third parties
and consultants have agreed to maintain the confidentiality and security of the
child’s information.
(5) The Parent has the option to agree to the
collection and use of the child’s information without consenting to the
disclosure of such information to such third parties described above.
(6)
Clear Ambition will not require a child to disclose more information than is
reasonably necessary to participate in any activity as a condition of
participation.
(7) A Parent can review the child’s information, ask to
have it deleted and refuse to allow any further collection or use of the child’s
information by contacting Clear Ambition as described at the end of this Privacy
Policy. Parent understands and agrees that such action may limit Clear Ambition’s
ability to provide the Program to the child and that Clear Ambition may provide a
refund as set forth in the
Terms and
Conditions of Use Agreement.
Information Collected
For each visitor to our Website, we may collect
non-personally identifiable information such as the IP address, browser type,
dial-up domain, computer operating system, and the pages viewed when visiting
the Website. This information is used to continually improve the content and
performance of our Program.
To enable us to provide the best service
possible to those who join our Program, we collect the following personal
information: a) name; b) home address; c) phone number; d) email address; e)
date of birth;
f) gender; g) ethnicity; h) educational background; i)
current educational/employment status; and j) credit card payment information.
If you are a minor (under the age of 18), consent is required from your Parent
to allow you to join our Program. In such cases, we also collect (a) name of
Parent; (b) home address of Parent; (c) email address of Parent; and (d) phone
number of Parent. In the course of the telephone guidance sessions, other
information may be collected from clients to help us guide them in their
decision making process about their career, education, and/or future life
direction.
The data we collect from clients is used to provide basic
background information for consulting sessions and to enable us to communicate
with our clients for purposes such as enrollment confirmation, notification
of important information, new services, and providing helpful advice through our monthly newsletter.
We occasionally conduct surveys and may contact clients to ask for their participation in a “blind” survey, meaning
one in which the data can only be viewed in its aggregate form and not at the
individual level. Clients may opt out of receiving communication from us at any
time by using the contact information at the bottom of this window.
Cookies
Clear Ambition utilizes “cookies” to enhance its clients' experience
on our Website. A cookie is a small file placed by our Website on the hard drive
of your computer to enable our Website to tailor and customize content for you.
Clients have the option to accept, reject or be notified when our Website sets a
cookie by configuring their Internet browser preferences.
Information Disclosure
We do not sell, rent, or trade the information
gathered from our Website users or Program clients.
From time to time,
we may monitor, to the extent allowable by law, the telephone guidance sessions for
the purposes of supervision, quality control, and continual improvement of the
services we provide.
Clear Ambition and its career consultants keep all consulting
records in strict confidence. However, in situations in which a career consultant
believes that a client represents a clear and imminent danger to themselves or
others, the consultant will take the steps necessary to protect the individual
and any others involved, and/or inform responsible authorities. By
accessing our Website, you acknowledge and agree that, to the extent permitted
under applicable law, Clear Ambition may comply with requests from law enforcement
agents or US government agencies if asked to disclose information required to
assist them in the investigation of illegal activity.
Access to Database
Access to Clear Ambition’s database is limited to Clear Ambition
personnel, our offsite web host server administrator, and the provider of
Clear Ambition’s online assessment and planning tools. Additionally, career consultants have
access to the personal records of only those clients to whom they are providing
guidance. You understand and agree that records from the guidance sessions
are stored electronically and/or in hard copy with your consultant as well as in
the administrative and central files at Clear Ambition. You agree that Clear Ambition
administrative personnel may access these records from time to time for the
purposes of supervision and quality control.
Information Retention
Clear Ambition will maintain all client records in its
physical possession (hard copy, electronic, and/or tape recordings) for a
minimum period of five (5) years following the last consultant/client contact.
Once the records related to the client’s guidance sessions in Clear Ambition’s
physical possession are destroyed, only the client’s personal portfolio records
(e.g., contact information, assessment results, favorite occupations, schools,
and Clear Ambition Plan) will be maintained. These portfolio records will be saved
securely for clients for their future reference in subsequent life stage
transitions and planning. All client data will be released to the client upon
written request.
Security
We take protecting the security of your information seriously. We use
128-bit Secure Socket Layer (SSL) encryption technology in combination with
offsite, secured servers to guard the privacy of your data in our database.
Despite
our best effort to protect your data, the security of information shared over
the Internet cannot be guaranteed. By accessing and using the Clear Ambition Website
(or any links within our Website) you acknowledge, accept, and agree that
Clear Ambition cannot guarantee the secure transmission of information sent via the
Internet and that third parties may unlawfully access such information.
Additionally, to protect your privacy, Clear Ambition career consultants always use
a landline telephone service to conduct guidance sessions with our clients. This prevents
third parties from intentionally, or unintentially, intercepting calls made from a cell phone.
You acknowledge, accept, and agree that Clear Ambition cannot guarantee the complete privacy of
any phone conversation held between you and a Clear Ambition career consultant if you choose to use
a cell phone on your end.
Links
You acknowledge and agree that Clear Ambition is not liable for the
content, security, or privacy practices of other websites linked to our Website.
We recommend that you review their individual privacy policies.
Policy Updates
We reserve the right to change our Privacy Policy from
time to time at our sole discretion. When changes are made, they will be posted
on our Website along with the date of the last changes made, so you may easily
remain informed of our continued commitment to protecting your data.
Contact Information/Questions
If you have questions about this Privacy
Policy, our practices, or the use of our Website, please email us at
customerservice@clearambition.com.
If you have questions or issues regarding our guidance program or career consultants, please email us at
guidance@clearambition.com.
You may also contact the National Board for Certified Counselors at
www.nbcc.org for more information
about the practice of distance guidance. If you wish to contact
us by phone, call us toll free at 1-800-988-7721.
If you prefer to write
to us, please direct your letter to:
Clear Ambition
185 Main Street,
Suite 401
New Britain, CT 06051
Policy Last Modified 9/30/08