Effective on 15 April 2020
CLEAR PURPOSE’s mission is to connect professionals (leaders, changemakers and entrepreneurs) to the CLEARING PURPOSE FRAMEWORK and to people, with the goal of developing their leadership with a clear purpose and in connection to people.
For us, it is highly important and fundamental to be transparent on the data we collect, how they are used and with whom we share them.
We are CLEARING PURPOSE FRAMEWORK, the business name of legal person JOANA BRANDI MAO TREINAMENTOS E ASSESSORIA, registered under CNPJ number 36.239.908/0001-08, who is responsible for all information and based in Brazil.
Our registered users (“Users”) share their professional identities and projects, interact with their networks, exchange knowledge and professional information, post and view content, while they actively learn through the CLEARING PURPOSE FRAMEWORK process how to develop skills through leadership projects with a clear purpose. They find opportunities to present and generate engagement on these projects by producing content derived from the CLEARING PURPOSE FRAMEWORK process directed to non-users (“Visitors”). Content and data may be visible to non-users (“Visitors) through the Visions channel.
2. DATA WE COLLECT
2.1. Data you provide to us
You provide your personal information in order to sign up for an account on CLEAR PURPOSE. It will be used so that you can enjoy the platform’s functionalities.
To create an account, you provide the following information: full name, email and a password of your choice, following the platform’s security criteria.
You select any additional information you will add to your profile, such as academic background, professional experience, skills, profile picture, job position, brief biography, industry, context or situation of interest, date of birth, city, country, your website and social media profiles (Facebook, Twitter, LinkedIn).
2.2. Information from third parties
Others may post or write about you.
Contents and posts
You and others may post content which include information about you (as part of articles, posts, comments and videos) on our Services. Unless you disable this option, we will collect public data about you, such as news and professional results (for example, the progress of the CLEARING PURPOSE FRAMEWORK process, your vision’s impact, contributions to and interactions with your network, etc.) and we will make them available as part of our Services (for example, as suggestions for your profile or notifications to others about mentions in the media).
Clients and partners may provide us with data.
We receive your personal information (picture, full name, job position, brief biography, industry, areas of experience and occupation, language, date of birth, city, country, your website and social media profiles on Facebook, Twitter and LinkedIn, your email and a password of your choice), as well as your availability to provide assistance on the platform when you act in our services facilitating the CLEARING PURPOSE FRAMEWORK to our clients.
2.3. Service use
We log your visits and the use of our Services, including apps for mobile devices.
We log usage data when you visit or otherwise use our Services, including the technology of websites, apps and platforms. That is, when you view or click on content (for example, learning videos) or advertisements (on or off our websites and apps), perform a search, install or update one of our mobile device apps or share articles. We use accesses, cookies, device data and IP addresses to identify you or log your use.
2.4. Cookies, beacons and similar technologies
We collect data via cookies, beacons and similar technologies.
The user will be able to navigate anonymously on the website in order not to be identified by cookies or beacons. In these cases, the user might be prevented from using some features and functions.
2.5. Third-party websites and services
We obtain data when you visit websites which contain our ads, cookies, or any of our plug-ins, or when you log in to other services using your account from our platform.
We receive information on your visits and interactions with services provided by others when you log in with your CLEAR PURPOSE account or when you visit other services which include some of our plug-ins, ads, cookies or similar technologies.
2.6. Payment Details
Some of our Services are paid.
Some of our experiences on CLEAR PURPOSE are paid, and such payments will be made through PayPal. Thus, sensitive bank account or credit card information will not be collected by us. Please, check PayPal’s Privacy Declaration in order to understand how they may collect, store, process, share and transfer your personal information when you use their services for payments on our platform.
We are improving our Services, which means we will receive new data and come up with new ways of using information.
3. HOW WE USE YOUR DATA
We use your data to provide, support, personalise and develop our Services.
Data from registered users will only be used for the platform’s internal operation. The way we use your data depends on the Services used, on the way they are used and on the settings defined. We use the data we have about you to provide and personalise our Services.
Our Services help you structure and implement leadership projects with a clear purpose, connect with people and receive support throughout your project’s development.
We use your data to verify your access to our Services and to meet your settings.
Our Services allow you to gain knowledge and receive facilitation on the CLEARING PURPOSE FRAMEWORK with trained and certified facilitators, and to post your project’s development on the Visions channel to non-users (“Visitors”) in order to get feedback in the form of interactions and comments.
We will use collected data (such as your profile, profiles your have visited or data provided through the upload of lists of addresses or integrations with partners) to help non-users (“Visitors”) find your profile, to suggest connections to you and to others (for example, Users who have contacts, projects or work experiences in common) and to allow you to invite others to connect with you.
Develop a leadership project with the CLEARING PURPOSE FRAMEWORK Our Services allow you to develop a leadership project through purpose clearing in four modular levels.
The 4 acquirable modules of the CLEARING PURPOSE FRAMEWORK with online facilitation, which configure the development stages of a leadership project within the platform, are:
- Purpose – with focus on elevation of context perception and appreciation, and contact with a clear purpose.
- Vision – with focus on reaching new ideas and possibilities of using resources and potentials towards a greater good.
- Meaning – with focus on testing and validating the vision’s value to people.
- Impact – with focus on evaluating results and designing a final vision for implementation.
Before deciding on acquiring the 4 levels, Users can have free access to the CLEARING PURPOSE FRAMEWORK trial version, in order to get to know the product.
Share the Development of Projects with a Clear Purpose
Our Services allow you to develop your leadership by sharing the progress of projects with a clear purpose on the Visions channel.
Our Services allow you to receive support and collaboration from our “Visitors” through interactions and comments.
Our Services allow Users to receive support and acceleration through optional investments we can make based on the performance of their leadership projects. These investments’ optionality follows criteria, including, but no limited to, the interaction and demonstration of trust by our “Visitors”, demonstrated through qualitative and quantitative analytics of their interactions with the User’s profile and posts.
Acceleration is a process of circular investment, i.e., an initial investment which is made under the agreement of it being returned in the same value (with monetary corrections) in the form of a new investment in another leadership project from CLEAR PURPOSE. When applicable, the contract of investment takes place only at “Level 4 – Impact”.
Generation of Impact
Data collected from cookies and beacons, as well as browsing data, may be commercialised for non-profit purposes only in order to support the platform’s circular economy proposal.
We contact you and enable communication between Users. We offer settings to control the types of messages received and the frequency in which you receive some of them.
We will contact you by email or notifications posted on our websites or apps and other means made available by our Services. We may send you messages about the availability of our Services, security, or other Service-related issues. We also send out a monthly newsletter to the email address informed upon signing up. You may change your communication preferences at any time. Know that you cannot disable receiving our service messages, including legal and security notifications.
We also allow communication between you and others through our Services, such as invites, comments, messages between users and between users and “Visitors”.
We advertise our Services to you and others.
Besides advertising our Services, we use Users’ data and content for invites and communication that promote membership and growth to the platform’s network, and engagement on our Services, by, for example, showing your connections that you have used a feature on our Services.
3.4. Service Development and Research
We use data, including public feedback, to conduct research and develop our Services in order to offer you and others a better, more intuitive and personalised experience, to foster growth and interaction in our Services and to help connect professionals to each other and to economic opportunities.
Our mission is to create impact generation opportunities out of leadership projects with professionals and to help them structure these projects with clear and successful purposes. We use available personal information in order to research social, economic and leadership performance trends, such as areas of interest and global social development trends and goals. In some cases, we work with reliable third parties to carry out this research, under controlled conditions developed to protect your privacy. We publish and allow other people to publish social economic insights, presented as aggregated data, not personal data.
We and others may carry out polls and surveys through our Services. It is not mandatory to answer to polls or surveys, and you may choose which information to provide. You can disable survey invites.
3.5. Customer support
We use data to help you and to solve problems.
We use data (which may include your messages) to investigate, respond to and solve complaints and problems, and also issues related to the Service (e.g. bugs).
3.6. Information which does not identify you
We use data to produce information which does not identify you.
We use your data to produce and share information which does not identify you. For example, we may use your data to generate analytics on our users, their professions or areas, to calculate impressions on ads shown or clicked on, or to publish demographic data of visitors of a Service or to create demographic statistics.
3.7. Security and Investigations
We use data for security, fraud prevention and investigation.
Moreover, we may disclose personal information about users to police, court and administration authorities by virtue of law or court decision which may oblige us to make such personal information available to authorities.
4. HOW WE SHARE INFORMATION
All information you include in your profile, any content you post, or any social actions (e.g. liking, following, commenting, sharing) you perform on our Services may be viewed by other people, according to your settings.
4.1. Our services
Your profile is completely visible to all Users and clients of our Services. According to your settings, it can also be shown to other users within or outside our Services.
Posting, liking, followers, comments and messages
Our Services allow viewing and sharing information, including when posting, following, liking and commenting.
- When you share a project in the form of a text, image, video or report (e.g., an update, article, album or graphic), they can be seen by all and shared again anywhere else. Users, Visitors and others can find and view content you share publicly, including your name (and your picture, if you have provided one).
- By following a person or organisation, you become visible to others and to the “page owner” as a follower.
- When you like, share or comment on someone else’s content (including ads), other people can view these “social actions” and associate them to you (your name, profile and profile picture, when provided).
4.2. Partners and suppliers
We can commercialise some of your data to support the platform’s circular economy proposal.
Partners and suppliers can receive your data collected from cookies and beacons, as well as browsing data, which are commercialised by us, non-profit, only and exclusively in order to guarantee support to the platform’s circular economy proposal.
Revenue and reinvestment results are published periodically on the Visions channel.
4.3. Service providers
We may hire third parties to help us in our Services.
We hire third parties to help us provide our Services (e.g., maintenance, analysis, auditing, payments, fraud detection, marketing and development). They will have access to necessary information in order to execute tasks on our behalf and are obliged not to disclose them or use them for other purposes.
4.4. Legal Disclosures
It might be necessary to share your data in case it is requested by law enforcement or in order to help protect your data, as well as ours and other people’s.
There is the possibility we might need to disclose your personal information if it is thus required by law, court intimation or another legal process, or if we believe in good faith that the disclosure is necessary in order to: (1) investigate, prevent, or take action against suspected or actual illegal activities or to cooperate with government agencies; (2) enforce our contracts; (3) investigate and defend ourselves against any third party claims or allegations; (4) protect our Services’ security or integrity or (5) exercise or protect the rights and safety of the platform, our Users, employees or others. Upon there being legal demands referring to any user’s personal information, we will notify the user of the situation, except in case of express legal or court prohibition to do so, or if the request takes place on an emergency basis. We will make our best efforts to analyse such requests from authorities, especially in order to put away those that might be excessive, vague or lack proper authority.
4.4. Change in control or Sale
Following such sale or transfer, users will be able to contact the entity to whom they will transfer their personal information with any questions regarding the processing of that information.
5. YOUR OPTIONS AND OBLIGATIONS
We will keep most of your personal data while your account is active.
5.1. Data retention
Usually, we store your personal data while you maintain an open account or as necessary in order to provide you with our Services. This includes data you or other people provide us and data generated or inferred from your usage of our Services. Even if you rarely use our Services, we will store your personal information and keep your profile active, unless you terminate your account. In some cases, we choose to store this data (e.g., data on Services use) in a depersonalised or aggregated manner.
5.2. Rights to access and control your personal data
You can access and delete your personal data. We offer you several options on how your data is collected, used and shared.
We offer you several options on how your data is collected, used and shared, from the removal or correction of information added to your profile, to the control of your posts’ visibility, and options to disable ads and control communications. We offer settings to control and manage the personal information we have about you, and you will be able to request us, at your discretion and at any time, the removal of your personal information collected through this website.
In regards to the personal information we have about you, the following actions are possible:
- Deleting information: you can request to delete or erase some of your personal information (e.g., when they are no longer necessary for us to provide you with Services).
- Changing or correcting information: you can edit some of your personal information on your account. You can also request updates, alterations or corrections of your information in certain cases, especially if they are incorrect.
- Objections, limits or restrictions, to data use: you can request us to stop using all or some of your personal information (e.g., when we no longer have the right to continue using them), or limit our use (e.g., when your personal information is incorrect or illegally stored).
- Right to access or copy your data: You can request a copy of your personal information and of information you have provided in a machine-readable format.
However, the platform will be able to store data relative to IP and to date and time of user access for periods of time determined according to local legislation, after which the user may also request definite removal of any IP records and date and time of access records.
You may contact us through the contact information below and we will consider your request according to applicable legislation.
5.3. Terminating an account
We will keep some of your personal information even after you terminate your account.
Should you opt to terminate your account, your personal information, as a rule, will no longer be visible to others on our services within 24 hours. Except in the situations described below, within 30 days of terminating the account, we remove, as a rule, all data from the terminated account.
Information you have shared with others will remain visible even after you terminate your account or remove information from your own profile or inbox. Besides, we do not control information other Users have copied from our Services. Groups content and ratings or review content posted by deleted accounts will be shown as having been created by an unknown user. Your profile might continue to be shown on other services (e.g., search engine results) until they refresh their cache.
6. OTHER IMPORTANT INFORMATION
We monitor and try to prevent security breaches. Use our Services’ security features.
The platform complies with the security settings and policies of our server symply.com, based in the European Union.
We have secure and appropriate technical and administrative methods, created to protect personal information provided by users against unauthorised or illegal destruction, loss, alteration, access, disclosure or use. We implement security safeguards developed do protect your data. We regularly monitor our systems in order to check for vulnerabilities and attacks. We cannot completely guarantee the safety of the information you send us. There is no guarantee that the information will not be accessed, disclosed, altered or destroyed in case of violation of any of our physical, technical or managerial safeguards.
Still, it is the user’s responsibility to keep the environment of their devices of access safe, by using their own available tools, such as antivirus and firewall software, among others, and by using updated and efficient software when accessing the website. Under no circumstances will we request personal information via email, especially information related to passwords. We do not take responsibility for any fraudulent electronic communication that might collect users’ personal data. (phishing).
Moreover, we are completely exempt from any accountability over third party actions, which might take place online or in face-to-face meetings that might arise from virtual contact made through our platform. We cannot take responsibility for actions that are external or alien to our platform, which do not follow common sense, morality or national legislation. Anomalous conducts must be reported not only on our platform but also to law enforcement authorities.
Still, as a security and precautionary measure, the platform recommends users not to provide personal information such as document numbers, names of relatives, professional data and information, addresses, etc. The platform does not take responsibility for the content of conversations kept through the app, and the user must be cautious with respect to data shared in that environment.
In that sense, the platform will not breach confidentiality, nor will it access users’ conversations, except in matters involving other users’ safety following reports and/or court order.
6.2. Cross-border data transfers
We store and use your data outside your country.
We process data inside and outside of Brazil, and rely on mechanisms to transfer data across borders. Countries where we process data may have legislation that is different from, and potentially less protective than, your own country’s.
6.3. Lawful bases for processing
We have lawful bases to collect, use and share data about you. You have options regarding how we use your information. You can withdraw the consent you have given whenever you wish, in Settings.
We only collect and process personal data about you in places where we have lawful bases to do so. Lawful bases include consent (whenever it has been given), contract (whenever there is a processing need to sign a contract with you), and “legitimate interests”.
Whenever we need your consent to process personal data, you have the right to withdraw or deny consent should you wish to, and whenever we count on legitimate interest, you have the right to refuse. Should you have any questions about the lawful bases for collecting and using your personal information, do no hesitate in contacting us.
6.4. Direct Marketing
Currently, we do not share personal data with others for direct marketing purposes without your permission.
6.5. Contact information
Should you have any questions or complaints regarding this Policy, contact us first of all at this email address: email@example.com.
Version 1 – effective: April 2020 or upon user acceptance.