Last updated: January 1st 2020
We adopted this policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this policy.
1. Information we collect
This policy relates to the collection of information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device (“personal information”).
The table below indicates the categories of personal information about consumers that we have collected within the last twelve (12) months. Note that the examples given below do not represent a comprehensive list. Note also that not all categories and examples shown below may apply to you.
|Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers.|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||A name, signature, address, telephone number, education, employment. Some personal information included in this category may overlap with other categories.|
|Commercial information||Records of services purchased or obtained from us, or considered, or other purchasing or consuming histories or tendencies relating to our services.|
|Internet or other similar network activity||Browsing history, search history, information on a consumer’s interaction with our services and advertisements.|
|Geolocation data||A device’s physical location – to the extent that an IP address may provide information regarding the location of a device you use to access our services.|
|Professional or employment-related information||Current or past job history.|
2. Where we collect information from
- Directly from you when you use our services or interact with us or indirectly through cookies and similar technologies included in our services (please click here for our cookies policy).
- From the organization(s) to which you belong or person(s) who have arranged your access to our services, e.g. your employer or the institution you are affiliated with may provide us with contact information so that we can set up your login.
- Our partners and service providers, e.g. technology providers in connection with your use of our services.
- Public or paid-for sources, e.g. we may acquire marketing lists from third parties to identify prospects for our services
3. Using your personal information
We may use or disclose your personal information for one or more of the business purposes listed below or to carry out other reasonable business purposes consistent with this list:
- Customer and product administration: to provide you with our services and information that you requested or that you access through our services, create product accounts, provide user and technical support, enforce our terms of business, report product usage information to our customers and business partners, report to our content and technology providers, contact you about renewal of your subscriptions, and other related administrative tasks.
- Legal rights: to exercise our rights and to the extent reasonably required, to assist third parties (such as your employee or our business partners) in exercising their rights, and to defend ourselves from claims and to comply with laws and regulations that apply to our group or third parties with whom we work.
- Product personalization: to deliver personalized functionality in our services, for instance we may retain your browsing and usage information to make your searches within our services more relevant. We also analyze product usage information to understand which content and tools are most useful for you and to allow us to deliver and suggest tailored content, features and other Clarivate services that we believe may interest you.
- Product analysis and development: we may use information collected on our services, usually in aggregated form, to analyze the functionalities we offer and to improve the design and content of our services (including sharing your personal data across our group which allows us to make all our services more user-friendly). We may also provide information about your use of the services to a third party who has made the services available to you (for instance, your employer) or to a business partner whose content or technology you accessed through the services.
- Marketing: to send you marketing messages for Clarivate services that may interest you. You can opt out from marketing messages at any time either by clicking the unsubscribe link on the message or emailing us at firstname.lastname@example.org. We do not disclose your contact information to third parties for their marketing purposes.
- Security: to protect the security of our IT systems, architecture and networks as well as to prevent misuses of our services.
- Legal obligation: to carry out our contractual obligations to you or to comply with legal or regulatory obligations such as to respond to a court order or a regulator.
- Business restructuring or similar transactions: to participate in, or be the subject of, any sale, merger, acquisition, restructure, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock.
We may also use your personal information as described to you in a notice when collecting your information.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
4. Sharing your personal information
In the preceding twelve (12) months, we have not sold any personal information as covered by this policy.
To make our services work as intended, we may need to share your personal information with other third parties and service providers.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
- California Customer Records personal information categories
- Commercial information
- Internet or other similar network activity
- Geolocation data
- Professional or employment-related information.
We may disclose your personal information for a business purpose to the following categories of third parties:
- Service providers such as cloud computing providers and web analytics services like Google Analytics and credit card payment processors.
- Business partners with whom we deliver co-branded services or host events; or whose content or technology we make available through our services.
- Professional advisors such as legal counsel and information security professionals where reasonably required to protect our rights, users, systems and our services.
- Prospective and actual buyers, sellers, advisers or partners in relation to any sale merger, acquisition, or similar corporate event involving Clarivate.
5. Your rights and choices about your personal information
The CCPA provides consumers with specific rights regarding their personal information. This section describes these rights and explains how to exercise them.
Right to know
You have the right to know what personal information we have collected about you over the past 12 months. You can request that we disclose certain information to you about our collection, use, disclosure and sale of your personal information. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- If we collected personal information about you and the categories of personal information collected;
- The categories of sources where we collected personal information about you;
- Our business or commercial purpose for collecting, sharing, disclosing that personal information;
- The categories of third parties with whom we share or disclosed that personal information;
- The specific pieces of personal information we collected about you (also called a data portability request);
- If we disclosed personal information about you for a business or commercial purpose and the categories of your personal information disclosed;
- The categories of personal information about you disclosed to third parties and the categories of third parties that received your personal information
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.
There are a number of exceptions that may apply. For example, we may deny your deletion request (in whole or in part) if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise their right to free speech, ensure the right of you or another consumer to exercise free speech rights, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Comply with a legal obligation; and
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Your CCPA Rights
To exercise your CCPA rights (the access, data portability, and deletion rights described above), please submit a verifiable consumer request to us by contacting email@example.com. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
You will need to provide certain personal information so that we can properly verify your consumer request. We will only use the personal information provided in a verifiable consumer request to confirm the requestor’s identity or their authority to make the request.
If we cannot verify the requestor’s identity or their authority to make the request or if we cannot confirm that the personal information provided relates to the consumer which is the subject of the request, we may deny the request.
The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative (e.g. full name and account details and information regarding the services that you use or have access to); and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Depending on the nature of your request, we may require additional information and we will advise you of this at the time.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer 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.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
6. Changes to Our Privacy Notice
7. How to Contact Us
If you have any questions or comments about this policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under the CCPA, please do not hesitate to contact us at firstname.lastname@example.org or write to us at:
FAO: Head of Privacy
160 Blackfriars Road
London SE1 8EZ