APPLICATION PRIVACY POLICY

Effective Date: 11/30/2021

Purpose

The purpose of this Application Privacy Policy (“Privacy Policy”) is to summarize the ways in which the owner of this application, Clear Link Technologies, LLC (“Clearlink”, “we”, “us”), collects, maintains, and uses information about you (“you”, “your”). This policy describes:

  • The types of information we collect when you use the Speed Test application (the “App”); and
  • Our practices for using, maintaining, protecting and disclosing that information.

This policy applies only to information we collect on the App. It does not apply to information that we may collect when you visit our websites, that we may collect offline, or that we may collect through any other sources. For information on our practices regarding the collection, use, disclosure and sale of personal information, please see our comprehensive privacy policy.

Use of Third Party Measurements

 The App operates by sending requests to Measurement Lab (also referred to as M-Lab), which is an open source project dedicated to, among other things, providing an open, verifiable measurement platform for global network performance. When you use the App to request a speed test, the App communicates your request, along with certain information such as your internet protocol (IP) address, to M-Lab. Accordingly, you understand that by requesting an internet speed test through the App, you are requesting that we provide your IP address and other information regarding your request to M-Lab. M-Labs’ privacy policy, which describes its use of the data it is provided in connection with internet speed tests, can be found here. If you do not want your IP information or other information regarding your request to be provided to M-Lab, you should not use the App.

Children Under the Age of 16

The App is not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at by submitting an email request to privacy@clearlink.com, by writing to Clear Link Technologies, LLC, Privacy Department, 5202 W. Douglas Corrigan Way, Salt Lake City, Utah 84116, or calling us at (877) 698-0218. We do not sell personal information of consumers we know are younger than 16 years old or that we are prohibited from selling under applicable law.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Contacting Us

Please feel free to contact Us by email at privacy@clearlink.com or by mail at Clear Link Technologies, LLC Privacy Department, 5202 W. Douglas Corrigan Way, Salt Lake City, Utah 84116 with any questions or concerns about this Privacy Notice or the information We gather about You.

Information we Collect and How we Collect It

When you use the App, we collect your IP address and other information regarding your device automatically as a necessary aspect of communication over a network (“User Information”). We do not collect your name, age, or any other information that is not necessary for operation of the App.

How We Use Information We Collect

We use the information we collect to operate the App, as well as to create and maintain a record of your use of the App. We use the information we collect to operate the App, as well as to analyze, and evaluate the App and to determine if we should develop and/or release additional applications.

How We Share Information We Collect

We may share the information we collect with third parties who provide services which are necessary to support the operation of the App. We may also disclose the information we collect to a buyer or other successor in the event of a merger, divestiture, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information we hold is among the assets transferred.

We may also share the information we collect in order to comply with any subpoena, court order, or legal process, including to respond to any lawful government or regulatory request.

Your California Privacy Rights

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Please note that we will not discriminate against you for exercising your rights under the CCPA. However, as noted below using the subheading “Right to Opt-Out” if you exercise your right to opt out, the App will not function for you, as the sharing of personal information is critical to the App’s operation.

To exercise your right to know, or your right to delete (described in more detail below), please submit a request by calling toll-free (877) 698-0218, emailing privacy@clearlink.com, or by writing to Clear Link Technologies, LLC, Privacy Department, 5202 W. Douglas Corrigan Way, Salt Lake City, Utah 84116.

If you submit a request to know or request to delete, we will take steps to verify that you are who you say you are, or that you have the authority act on behalf of someone else.  We perform this verification by comparing the information you submit with your request against our records to confirm that they are consistent.  If the information you provide with an initial request is not sufficient for us to verify your identity, we may request additional information, such as the last time you used the App before submitting your request.

If you wish, you may authorize an agent to submit a request on your behalf.  To designate an authorized agent, you must provide the authorized agent with signed permission to make the request on your behalf. If your authorized agent is a business entity, then the authorized agent must be registered with the California Secretary of State to conduct business in California. We may deny a request from an authorized agent if the agent cannot provide us with the signed permission from you demonstrating that the agent has been authorized by you to act on your behalf. Further, before responding to a request from an authorized agent, we will still require the authorized agent provide us with enough information so that we can verify your identity.

Right to Know

California residents have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your personal information (the “right to know”). Once we receive your request and verify your identity, 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.
  • The business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

You have a right to obtain a copy of the specific pieces of personal information we collected about you (also called a data portability request). Once we receive your request and verify your identity, we will provide you a copy of your personal information that is responsive to your request.

Right to Delete

California residents have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive your request and confirm your identity, we will review the request to see if an exception applies that allows us to retain some or all of your information. If an exception applies, we will provide you information about that exception.

We will delete or deidentify personal information not subject to one of the exceptions from our records and will direct our service providers to take similar action.

Right to Opt-Out

California residents have the right to opt out of the sale of their personal information. However, please know that we do not sell any personal information collected via the App.

Disclosure of Right to Opt Out Under Nevada Law

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to privacy@clearlink.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements (which require the exchange of covered information for monetary consideration).

Security Measures

We have implemented a variety of encryption and security technologies and procedures to protect information stored in our computer systems from unauthorized access.

Changes to This Privacy Policy

We will update this Privacy Policy from time to time to reflect changes in our business. If We change how we use personally identifiable information we collect, or the purposes or entities for and to which such information, we will include such updates within this Privacy Policy.

Correction of Information

If You believe that information we have collected about you is incomplete or inaccurate, please contact us at privacy@clearlink.com, or by writing to Clear Link Technologies, LLC, Privacy Department, 5202 W. Douglas Corrigan Way, Salt Lake City, Utah 84116, and we will correct the information upon verification of the omission or error and that the person requesting the change is the person about whom the Customer Information relates.

CCPA Notice to California Residents of Information We Collect, Use and Share

We collect information that identifies, relates to, describes, or is capable of being associated with, a particular individual (“CCPA personal information”). We have collected the following CCPA personal information using the App within the last 12 months:

Category of InformationCollected in the preceding 12 months?Example
A. Identifiers.YESIP Address
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).YESIP Address
C. Protected classification characteristics under California or federal law.NoN/A
D. Commercial information.YESHistory of using the App
E. Biometric information.NON/A
F. Internet or other similar network activity.YESHistory of using the App
G. Geolocation data.NON/A
H. Sensory data.NON/A
I. Professional or employment-related information.NON/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).NON/A
K. Inferences drawn from other personal information.NON/A

The above information is collected automatically when you use the App.

As noted above, we have not sold any CCPA personal information within the preceding 12 months. We disclose (and have disclosed within the previous 12 months) CCPA personal information for a business purpose to the categories of third parties indicated in the following table:

Category of InformationCategory of Recipient
A. Identifiers.Test provider (M-Lab)
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).Test provider (M-Lab)
C. Protected classification characteristics under California or federal law.Not shared
D. Commercial information.Not shared
E. Biometric information.Not shared
F. Internet or other similar network activity.Not shared
G. Geolocation data.Not shared
H. Sensory data.Not shared
I. Professional or employment-related information.Not shared
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Not shared
K. Inferences drawn from other personal information.Not shared

International Users

Residents of the EEA or Switzerland may be entitled to specific rights under Regulation (EU) 2016/679 of the European Parliament and of the Council of the European Union 27 April 2016 (the “General Data Protection Regulation” or “GDPR”). These rights include rights to:

  • Access your personal data as the term is defined by GDPR
  • Request deletion of your personal data
  • Request correction of your personal data
  • Restrict processing of your personal data
  • Object to processing of your personal data
  • Receive your data in a portable manner.

To exercise your rights, call Clearlink’s toll-free number, (877) 698-0218, email Us at privacy@clearlink.com, or write to Clear Link Technologies, LLC, Privacy Department, 5202 W. Douglas Corrigan Way, Salt Lake City, Utah 84116. Additionally, you may opt out of receiving further email communications from us regarding other offers and promotions by visiting the webpage http://clearlink.com/unsubscribe.

In each of the above-mentioned contact methods, to protect your and others’ privacy, we will request verification of your identity. If a third party makes a request on your behalf, we will ask them to provide proof of your permission for them to act in your stead. We may contact you further to request information that will enable us to fulfill your request. An overriding lawful basis for processing your personal data may exist, or certain exemptions may apply, in which case we may refuse your request. If we refuse your request, we will explain the reasons why.

Please be aware that the information we collect through our services may be transferred to and stored on servers in North America. By using the App, you acknowledge and consent to the transfer and processing of your personal information in the United States as described in this Privacy Policy. Please be aware that the data protection laws and regulations applicable to your personal information transferred to the United States may be different from the laws in your country of residence.