Privacy Policy

ClearDoc, Inc. D/B/A OpenReel

Last Updated Date: November 28th, 2022

This Privacy Policy describes how ClearDoc, Inc. d/b/a OpenReel (“OpenReel,” “OR,” “we,” “us,” or “our”) collects, uses, and discloses information collected through websites and mobile applications owned and operated by us that link to this Privacy Policy, such as www.OpenReel.com, OpenReel’s software-as-a-service platform, OpenReel’s mobile application(s), and other direct interactions (e.g., customer service and other communications) that you may have with OpenReel (collectively, the “Services”).  For purposes of this Privacy Policy, a “Customer” means a user who forms a contract with us to use the Services, who as part of their use of the Services may invite other users and permitted third parties (including recorded subjects) to participate in a project.

This Privacy Policy should be read together with, and is incorporated into, the OpenReel Terms of Service (“Terms of Service”). If you are a Customer using the Services to access our solutions or products pursuant to an agreement between you and OpenReel (such as a master services agreement), then your use of the Services may also be governed by the applicable agreement(s) entered into between the Customer and OpenReel, which may include applicable privacy-related provisions.

The Customer controls its projects within the Services and this Privacy Policy does not apply to information that we handle solely in our capacity as a service provider on behalf of a Customer (“Customer Data”). Customer Data may be subject to the privacy policies of the Customer, and you should read those policies carefully. We are not responsible for the privacy practices of our Customers. If you have any questions about a Customer’s privacy practices, please contact the applicable Customer. For more information about who is the controller of data and under what circumstances, refer to the “Your Choices and Rights” section below.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

This Privacy Policy includes the following sections:

1. Information We Collect

2. How We Use Your Information

3. Legal Bases for Use of Your Information

4. Cookies and Similar Technologies

5. Online Advertising and Advertising

6. How We Share Your Information

7. How We Protect Your Information

8. Retention of Information

9. Third Party Links and Features

10. Your Choices and Rights

11. Children’s Privacy

12. Notice to California Residents

13. Notice to Nevada Residents

14. International Users

15. Changes to Our Privacy Policy

16. How To Contact Us

1. INFORMATION WE COLLECT

Information you provide to us. We collect information you choose to share with us, including information you enter through the Services.  For example, when you:

• Create an account to use the Services, we may collect contact and registration information, such as your name, physical address, e-mail address, telephone numbers, and business information. If you are making any payments to us in connection with your use of the Services, we may also collect payment information, including your payment card number and associated billing information, and any other profile information you upload to your account.
• Interact with the Services, we may collect the content that you upload, including videos, audio, files, comments and other text, as well as other information you enter through the Services.
• Contact us with questions or for customer service, we may collect contact information, such as your name, email address, and phone number, as well as any information you provide in connection with your outreach.
• Participate in promotions, events, surveys, and sweepstakes, we may collect basic contact information and any other information you provide in connection with these activities.

Information we collect about our Customers’ users and subjects. We collect information from our Customers about their users, as well as the subjects or other third parties involved in their projects or to whom the Services are made available on behalf of our Customers.  For example, a customer may provide us with users’ contact information, such as their name, e-mail address, telephone number, and business information. Additionally, we may collect any information provided by a user or subject during video recordings, including corresponding audio and text, as well as the device and usage information of users (as discussed in more detail in the “Information we collect through automated means” section below).

Information we collect through automated means. We may automatically receive and store certain information about the computer or device you use to access the Services.  As discussed further below, we and our service providers, may use a variety of technologies, including cookies, to assist in this information.

• Device Information. We collect technical information associated with the device(s) you use to access our Services, including information related to your browser and operating system, IP address (the Internet address of your computer), unique device identifiers, device type, model, camera details, operating system and other information in accordance with your device settings and permissions, such as battery percentage, internet connection speed, and amount of storage available.
• Usage Information. We also collect information to better understand your use of our Services. This may include the webpage that you were visiting before accessing our Services, the webpages or features of our Services you use, how much time you spend there, date, time and use, how you engage with videos, and information about your usage preferences.

When you share content created through our Services, we also may collect device and usage information about how your recipient interacts with the content, including the recipient’s IP address and browser or operating system, as well as the number of times the recipient accesses your content and otherwise engages with your content.

Location information. When you use our Services, we may collect general geolocation information (such as your city/state inferred from your IP address).  This information may be used to deliver tailored content through Services.

Information we receive from third party applications. We may receive information about you from third parties if you choose to integrate any third party application with the Services. This information could include, but is not limited to, an access token necessary to access that service and any information that you have permitted the third party to share with us. If you choose to sign-up and/or authenticate using a third-party account, you authorize us to obtain account information from the third-party platform. You may also unlink your third party account from the Services by adjusting your settings on the third party service. If you unlink your third party account, we will no longer receive information collected about you in connection with that service. Please remember that third parties’ use of your information will be governed by their own privacy policies and terms of service.

2. HOW WE USE YOUR INFORMATION

We use your information to provide, support, personalize, and develop our Services.  In particular, we may use your information to:

• provide the information and Services you request;
• provide you with effective customer service;
• engage in transactions with you, including contacting you about your account, billing you or your organization for the Services, and processing payments;
• contact you with operational information and notices related to your use of the Services;
• contact you with special offers and other promotional content we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
• invite you to participate in promotions, sweepstakes, surveys and provide feedback to us;
• analyze use of the Services and improve the content, functionality and usability of the Services;
• secure the Services and investigate and help prevent fraud, security issues, and abuse;
• understand and resolve app crashes and other issues being reported;
• comply with any procedures, laws, and regulations where necessary for our legitimate interests or legitimate interests of others;
• establish, exercise, or defend our legal rights where necessary for our legitimate interests or the legitimate interests of others, including the enforcement of our Terms of Service, other usage policies, and other legal terms or controls, or to engage in other legal matters; and
• for any other purpose with your consent.

Combined information. For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.

Aggregate/de-identified information.  We may aggregate and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”).  We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties in our discretion.

3. LEGAL BASES FOR USE OF YOUR INFORMATION

If you are an individual from the European Economic Area (“EEA”), the UK, or Switzerland, our legal bases under the General Data Protection Regulation (“GDPR”) for using your personal information are as follows:

• Where we have your consent to do so;
• Where use of your information is necessary to perform our obligations under a contract with you (e.g., to comply with the Terms of Service and deliver the Services);
• Where use of your information is necessary for our legitimate interests or the legitimate interest of others (e.g., to operate our Services; provide security for our Services; prevent fraud; analyze use of and improve our Services; and for similar purposes); and
• Where use of your information is necessary to comply with applicable legal obligations.

4. COOKIES AND SIMILAR TECHNOLOGIES

To collect the information in the “Information We Collect Through Automated Means” section above, we and our service providers use web server logs, cookies, tags, SDKs, tracking pixels, and similar tracking technologies. We use these technologies in order to offer you a more tailored experience in the future.

• A web server log is a file where website activity is stored.
• An SDK is a set of tools and/or code that we embed in our applications and software to allow third parties to collect information about how users interact with the Services.
• A cookie is a small text file that is placed on your computer or mobile device when you use the Services, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv), enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files.
• Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email that are designed to: (1) collect usage information like ad impressions or clicks and email open rates; (2) measure popularity of the Services and associated advertising; and (3) access user cookie

As we adopt additional technologies, we may also gather information through other methods.

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies, including flash cookies and local storage objects with the Flash management tools available at Adobe’s website.  Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.

Except for strictly necessary cookies, all cookies used on our site will expire after a maximum of 1 year and thirty days.  Below is additional information about the cookies we use and the purposes for which we use them:

Please note that the above list of third party partners that place cookies on our Services is subject to change and thus this list may not include all such providers at any given time. If you have any questions about our use of cookies and similar technologies or if you would like to withdraw or adjust your consent to our use of the above cookies, please contact us at  privacy@openreel.com.

5. ONLINE ANALYTICS AND ADVERTISING

Analytics. We may use third-party analytics services (such as those of Google Analytics and HubSpot) on our Services to collect and analyze usage information through cookies and similar technologies; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you.   For more information regarding your options to control analytics cookies and tracking technologies, please review the “Analytics” section of the above chart.

Advertising. When you use the Services, we may display advertising to you about our products, services, and related features that we think may be of interest to you.

We work with a number of companies that assist in marketing our services to you on third party websites. These companies may collect information about online activities conducted on a particular computer, browser or device over time and across third-party websites or online services for the purpose of delivering advertising that is likely to be of greater interest to you, including about our Services, on sites and apps of third parties. These companies may use cookies and other similar technologies, often in conjunction with unique (anonymous) cookie identifiers, to collect data about your activities and interests, including the technologies described above. Some of these partners may use mobile device identifiers, such as Apple IDFAs and Google/Android Advertising IDs. Doing this allows the ad companies to recognize your computer or device each time they send you an online or mobile advertisement. In this way, the ad companies may compile information about where you, or others who are using your computer or device, saw their advertisements and measure your interaction with each ad. This information allows ad companies to deliver targeted advertisements that may be of increased interest to you. We, or our advertising partners, may use these technologies and data points (e.g., mobile identifiers, cookie identifiers, location-based data), through other services, to target advertising on other sites or mobile apps. Sometimes, these identifiers may be derived from a hashed or encrypted version of personal information such as your email address. We may use this information to measure the performance of our advertising as well, for instance, to evaluate which ads or content our users prefer, or which are most effective. In addition, sometimes we or an advertising partner may tailor advertising to you across different devices.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device by non-affiliated, third-party providers.  As described below, these providers may offer you a way to opt-out of the collection of information that is used for our interest-based advertising to you. We cannot guarantee that these instructions will not change, or that they will continue to be available; they are controlled by each third-party service provider, not us. For more information regarding your options to control cookies and tracking technologies, please review the “Targeting and advertising” section of the above chart.

Notice Concerning Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide our users with a “Forget this Device” option in our Apps, as well as the variety of opt-out mechanisms listed above.  Because of the changing state of technology and indecision within the industry regarding the meaning of DNT signals, we currently do not make any guarantee that we will honor DNT signals. Learn more about Do Not Track.

6. HOW WE SHARE YOUR INFORMATION

We will share your information collected from and about you in the following ways:

At Your or Your Organization’s Direction. We may share information with third parties when you or your organization directs us to do so, such as when you use the Services to capture content or share content created via the Services, or access events hosted or led by our customers or other users.

Service Providers. We may share information collected with select third parties who use the information to provide services on our behalf, such as Services operation, surveys, web hosting, marketing and sales, billing and payments processing, analytics and online advertising, security, fraud prevention, and legal services.

Other Users of the Services and Individuals Involved in a Project. To the extent that you choose to make certain of your content or information available to other users or individuals involved in your projects, such information and content can be read, collected, and used by others with permission to view it. Each Customer determines which authorized users have access to the Customer’s account and Customer Data. Additionally, certain device and usage information (as detailed in the “Information we collect through automated means” section above) is available to other users or individuals involved in your projects.

Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies.  In such transactions (including in contemplation of such transactions), information may be among the transferred assets.  If a portion or all of our assets are sold or transferred to a third party, user information would likely be one of the transferred assets.  If such transfer is subject to notifications or restrictions under applicable laws, we will comply with such requirements.

Comply with Laws and Protect Our Rights and the Rights of Others. We may disclose your information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena.  We may also disclose your information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of the Services; to enforce or apply our online Terms of Service or other agreements; or to protect our own rights or property or the rights, property, or safety of our users or others.

7. HOW WE PROTECT YOUR INFORMATION

We implement a variety of security safeguards designed to protect your information.  However, no method or transmission over the internet or electronic system is completely secure, so there is no guarantee that such data may not be accessed, disclosed, altered, or destroyed in connection with a breach of our physical, technical, organizational, or managerial safeguards.

When you create an account, you may be prompted to create a username and password.  If you create an account with us, you are responsible for maintaining the confidentiality of your account password and for any activity that occurs under your account.  We are not responsible for any loss or damage arising from your failure to maintain the confidentiality of your password. We urge you to change your passwords often, use a combination of letters and numbers, and make sure you are using a secure browser.  If you have reason to believe that your interaction with us is no longer secure or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in the “Contact Information” section below.

8. RETENTION OF INFORMATION

We will retain your information for as long as your account is active or as needed to comply with applicable legal obligations.  We will also retain and use your information as necessary to resolve disputes, protect OpenReel and our users, and enforce our agreements.

9. THIRD PARTY LINKS AND FEATURES

The Services may contain links, banners, or widgets to third-party sites, apps, services, and plug-ins.  We may also incorporate third-party software (including open source software) in the Services.  For example, when you record a video using the Services, you may have the option to incorporate stock content provided by a third-party stock content site. These links and features are provided for your reference and convenience only and do not imply any endorsement of information provided through these third-party links and features, nor any association with their operators.

OpenReel is not responsible for the practices of such third parties.  Any information you provide to third parties on their websites or services is covered under their privacy and data collection collections, and is not covered by this Privacy Policy. We urge you to read the privacy and security policies of these third parties.

10. YOUR CHOICES AND RIGHTS

You have certain rights with respect to your information as further described in this section, in addition to any rights discussed elsewhere in this Privacy Policy. Please note your rights and choices vary depending upon your location.

Marketing Communications. You may instruct us not to use your information to contact you by email, postal mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information below.  In commercial email messages, you can opt out by following the instructions located at the bottom of such emails.  Removing your name from the email list may take a reasonable amount of time.  Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law.  For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.

Account Information. You may have rights to review, change, or remove personal information that you have provided in connection with the Services.  If you want to exercise such an applicable right or if you wish to delete your account with us, please email us at privacy@openreel.com.

Additional Choices. You can also make certain choices by using the options described in the “Cookies and Similar Technologies” section above.   If you no longer wish to provide us information through the Apps, you may also uninstall the Apps from your device.

Identifying the Data Controller and Processor. Data protection laws in certain jurisdictions differentiate between the “controller” and “processor” of information. In general, Customer is the controller of Customer Data, and OpenReel is the processor of Customer Data and the controller of account information, usage information (including, internet or other network or device activity, Services metadata, log data, location information), cookie information, and other information provided to OpenReel (collectively, “Other Information”).

International. When OpenReel acts as a controller, individuals in the EEA, the UK, Switzerland, and some other jurisdictions (such as Canada and Australia) have certain additional legal rights to do the following with personal information we handle:

• obtain confirmation of whether we hold personal information about them, and receive information about how it is used and disclosed;
• obtain a copy of the personal information, and in some cases, receive it in a structured, commonly used and machine-readable format, or have it be transmitted to a third party in such form;
• update, correct or delete the information;
• object to the use or disclosure of the information;
• withdraw consent previously provided for the handling of the information (without affecting the lawfulness of prior use and disclosure of the information); and
• obtain a restriction on the use of the information.

Individuals whose personal information is subject to the GDPR also have a right to opt out of our handling of their personal information for direct marketing purposes.

Additionally, individuals whose personal information is subject to the Brazilian General Data Protection Law (LGPD) have the following rights:

• confirmation of whether your data is being processed;
• access to your data;
• correction of incomplete, inaccurate, or outdated data;
• anonymization, blocking, or erasure of data;
• portability of personal data to a third party;
• object to the processing of personal data;
• information of public and private entities with which we shared data;
• information about the possibility to refuse providing personal data and the respective consequences, when applicable; and
• withdrawal of your consent.

Many of the rights described above are subject to limitations or exceptions under applicable law.

If you wish to exercise any of these rights, or raise a complaint on how we have handled your personal information, please contact us at privacy@openreel.com.

If you are seeking to exercise applicable rights with respect to information that we handle solely on behalf of a Customer, you should direct requests to that Customer directly.

Individuals also have a right to file a complaint with the relevant supervisory authority, but we invite you to kindly first give us an opportunity to address your concern.

11. CHILDREN’S PRIVACY

The Services are intended for general audiences and not for children. We do not knowingly collect, maintain, or use personal information (as defined by the United States Children’s Online Privacy Protection Act) from children in the United States under the age of 13 or a European Union resident under the age of 16 without legally-valid parental consent. If you believe that we might have any such information from a child, please contact us as described at the end of this Privacy Policy. If we discover that personally identifiable information of a child has been submitted without legally-valid parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.

12. NOTICE TO CALIFORNIA RESIDENTS

California’s “Shine the Light” law gives California residents the right under certain circumstances to request information from us regarding the manner in which we share certain categories of “personal information” (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your “personal information” with third parties for their own direct marketing purposes.

13. NOTICE TO NEVADA RESIDENTS

Certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons.  We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting us using the methods outlined in the “Contact Information” section.  Please note we will take reasonable steps to verify your identity and the authenticity of the request.  Once verified, we will maintain your request in the event our practices change.

14. INTERNATIONAL USERS

Your personal information collected through the Services may be stored and processed in the United States and in any other country in which OpenReel or its service providers maintain facilities.

If you are located in the EEA or other regions with laws governing data collection and use that may differ from U.S. law, please note that we will transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which OpenReel or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

As required by applicable law, we will provide an adequate level of protection for your personal data using various means, including, where appropriate:

• relying on a formal decision by the European Commission that a certain country ensures an adequate level of protection for personal data (a full list of such decisions may be accessed online here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm);
• entering into appropriate data transfer agreements based on language approved by the European Commission, such as the Standard Contractual Clauses (2010/87/EC and/or 2004/915/EC), which are available upon request at privacy@openreel.com
• implementing appropriate physical, technical and organizational security measures to protect personal information against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing; and
• taking other measures to provide an adequate level of data protection in accordance with applicable law.

Any onward transfer is subject to appropriate onward transfer requirements as required by applicable law.

By choosing to use our Services, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the State of New York, and the adjudication of any disputes arising in connection with OpenReel or its Services will be in accordance with this Privacy Policy and OpenReel’s Terms of Service.

15. CHANGES TO THIS PRIVACY POLICY

We reserve the right to update or modify this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology.  We will make the revised Privacy Policy accessible through use of the Services, so you should review the Privacy Policy periodically. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Effective Date” included at the beginning of the document.  If we make a material change to the Policy, we will provide you with notice in accordance with legal requirements.  Your use of the Services following any such change constitutes your agreement that all information collected from or about you after the revised Privacy Policy is posted will be subject to the terms of the revised Privacy Policy.

16. CONTACT INFORMATION

If you have any questions about this Privacy Policy or your dealings with OpenReel, please feel free to contact us at:

ClearDoc, Inc. dba OpenReel

9450 SW Gemini Dr

PMB 66174

Beaverton, Oregon 97008-7105

Email: privacy@openreel.com

Attn: Privacy Department