Skip to content
English

Privacy Policy

 

LAST UPDATE: July 2025

Please read this Privacy Policy (hereinafter referred to as the “Policy”) carefully as it contains important information regarding how, when, and why Engage Technologies Group Inc collects, uses, and stores your personal data, with whom it may share it, as well as to inform you about your rights as a data subject and the measures taken to protect your personal data, in connection with Engage Technologies Group Inc’s processing over its website, platform, and services.

Accessing and/or using Engage Technologies Group Inc website, platform, and services by any person imposes the obligation to comply with the provisions set forth in the Terms and Conditions.

The website https://clarityperformance.com/ (hereinafter referred to as the “Website”) and the platform https://auth.engagetg.com/login (hereinafter referred to as the “Platform”) are owned and managed by Engage Technologies Group Inc, a company incorporated by United States laws, headquartered at 3540 E Longwing Lane, Suite 300, Meridian, Idaho, 83646, United States.

 

1.      APPLICABILITY

This Policy regarding the processing of personal data only applies to the processing activities performed by Engage Technologies Group Inc and shall be complemented with the Terms and Conditions and the Cookie Policy.

The Website may contain information about or links to other websites that are outside Engage Technologies Group Inc custody and/or control. Carefully read and review the privacy policies of each of those websites when you browse on them to get an understanding of how your personal data is being used and shared by those third-party websites.

 

2.      DEFINITIONS

The terms used within this Policy have the same meaning as those mentioned in Terms and Conditions, unless otherwise mentioned in this Policy.

  • “Clarity”, "we”, “us” or “our” means Engage Technologies Group Inc and any of its affiliates that are providing the Website, Platform, and services.

  • “Users” means any natural person or any customer’s employees, representatives, consultants, contractors, or agents who are using the Services for customer’s benefit.

  • “You” or “your” means current or potential customer of Clarity, as a User of the Website, Platform, and Services provided by Clarity.

  • “Services” means all of our web-based websites (including this website), applications, tools and platforms that you have subscribed to or that we otherwise make available to you, and are developed, operated, and maintained by us, accessible via the Website, the Platform or another designated URL, and any ancillary services, including any consulting services, that we provide to you either for a fee or free of charge; Services or other features made available by us to you on an unpaid trial or free basis are considered free Services.

  • “Personal data” means any information relating to an identified or identifiable natural person;

  • “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

  • “Processing activity(ies)” means one or more operations that relate to one of the different stages that the processing of personal data may involve.

  • “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. For the purposes of this Policy, Clarity acts as Controller.

  • “Data subject” means an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

  • “Consent” of the data subject means any freely given, specific, informed and unambiguous indication of the user's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

 

3.      Collecting PERSONAL DATA

In general, the personal data we process is collected directly from you, as a data subject. However, there may be situations where your personal data is collected indirectly from social media, from the website of the company you represent, from your employer as a contact person, from a third party who recommended you or from various public platforms (for example ad platforms).

When we, as the Controller, do not receive the personal data directly from you, we will inform you within the legal term about our processing of your personal data.

If you provide us with personal data belonging to other individuals (for example, colleagues), you have the responsibility to make sure you have obtained prior approval from those persons for sharing their data with us.

 

4.      CHILDREN AND SPECIAL DATA

Our Website and Services are not directed at children. We do not knowingly or intentionally collect personal data from children who have not reached the level of maturity in their country and who are not able to assume obligations in accordance with the applicable legislation.

If you are the holder of parental responsibility of a child who has not reached the level of maturity in the country of residence and you believe your child has provided us with personal data, please contact us to request the erasure of their personal data and we will act upon your request in accordance with the legal requirements.

 

5.      processed PERSONAL DATA, PURPOSES, LEGAL GROUNDS AND RETENTION PERIODS

Below you will find information about the purposes for which we process your personal data, the categories of personal data we collect for those purposes, the legal grounds on which we carry out the processing activities and the periods of time we store the personal data in relation to the purposes of the processing.

We will inform you and, where the lawful basis is your consent, we will ask for you freely-given consent if we intend to process your personal data for a new purpose that is materially different from that for which the personal data was initially collected.

Where the lawful basis for the processing is your consent, you may withdraw it at any time without constraint and without affecting the lawfulness of the processing prior to its withdrawal.

You may refuse to provide part or all of your personal data. Certain personal data are essential to fulfill the purposes below and your refusal to provide necessary information may result in our impossibility to deliver the Services requested.

Depending on the nature of our relationship or interaction, we will process your personal data for the following purposes:

 

5.1.      Purpose: Initiate or carry out the B2B contractual relationship with your employer or with the company that you represent.

Personal data categories: First name, last name, e-mail address, phone number, position/role, name of the company that you represent, signature (for the representatives), billing information, and billing address (when you are contracting as an individual).

Legal basis: Processing of your personal data is performed considering our legitimate interest to conclude the service contract with the company that you represent, or for the performance of a contract concluded with you when you are contracting as an individual, depending on the case.

Retention period: Personal data will be stored for as long as there is a contract in place with the company that you represent. At the end of the storage period, personal data will be deleted.

 

5.2.      Purpose: Provide you access to our Platform by creating an account

Personal data categories: E-mail address and/or phone number.

Legal ground: Processing of your personal data is performed considering our legitimate interest to conclude the contract and provide services to the company that you represent, or considering the performance of a contract concluded with you when you are purchasing the services as an individual, depending on the case.

Retention period: Personal data will be stored for the duration of the contract. At the end of the storage period, personal data will be deleted.

 

5.3.      Purpose: Answering requests and provide assistance and support related to accessing/using our services to ensure customer satisfaction

Personal data categories: First name, last name, e-mail, phone number, name of the company that you represent, role/position, state, postal code, industry type, and any other personal data that you choose to include in the subject and/or description of the request.

Legal ground: Processing of your personal data is necessary considering our legitimate interest to communicate with you and provide our support in solving your requests that arise from using/accessing our services, and to maintain and promote your satisfaction.

Retention period: Personal data will be stored for as long as we have an existing contractual relationship in place. Your data will be deleted within 6 (six) months if you choose to terminate the contractual relationship. If we don’t have a contractual relationship yet, but you choose to contact us, we will store your personal data for a period of 6 (six) months after which it will be deleted. 

Your enquiry may be stored and processed through a third-party Customer Relationship Management (CRM) software provider that ensures that we do not miss any messages from you and that we follow through on your enquiries until they are resolved.

 

5.4.      Purpose: Market prospecting, directly or through partners

Personal data categories: First name, last name, phone number, e-mail address, name of the company that you represent and company’s address, role, or any other public details.

Legal ground: Processing of your personal data is based on our business's legitimate interest to promote our services and extend our client portfolio.

Retention period: Personal data will be stored for up to 2 years after you have not received a communication from Engage, or have been unengaged from communications. If you opt-out or request erasure of your data, we will delete the data accordingly.

There may be situations when your personal data will be collected again after this period, when, for example, we find your public data again when we prospect the market or if you were referred by an individual. In this case, we will inform you again regarding the processing of your personal data.

 

5.5.      Purpose: Selecting and recruiting for filling vacant roles

Personal data categories: first name, last name, phone number, e-mail, education, professional experience, targeted role, profession or qualification, professional and social skills, address and any other relevant information provided by you, as a candidate.

Legal ground: Processing of your personal data is necessary in order to take steps at the request of the data subject prior to entering into a contract.

Retention period: Personal data will be stored for the duration of the recruitment and selection process and subsequently for a period of 6 months to handle possible complaints. At the end of the storage period, personal data will be deleted.

 

5.6.      Purpose: Contacting the candidate (i.e. you) in case of new opportunities and proposing job offers

Personal data categories: Name, phone number, e-mail, education, professional experience, targeted role, profession or qualification, professional and social skills and any other relevant information provided by you, as candidate

Legal ground: Processing of your personal data is based on your consent. You can withdraw your consent at any time, without affecting the legality of the processing based on consent before its withdrawal.

Retention period: Your personal data will be stored for up to 1 (one) year from the termination of the selection and recruitment process you have previously applied for, or from the date you have voluntary provided your CV to us, as long as we have your consent. At the end of the retention period, personal data will be deleted. If you decide to withdraw your consent, we will proceed to the deletion of your personal data.

 

5.7.      Purpose: Ensure functionality and security of our Website and Platform, perform checks and technical support to prevent and identify frauds, and improve our Website and Platform

Personal data categories: First name, last name, email address, IP address and log files.

When using the Website, we also collect and process data such as: browser details i.e. name and browser version, the name of the operating system version of the device on which the browser is installed, device identification, system language, your device’s network location data when you sign in (such as country and state), as well as the version of the Website you are using. Furthermore, when you login and/or register within the Platform, we store and process certain data in so-called log files. A log file provides information about the date and time the registration/authentication attempt was made, if it was successful, the e-mail address provided and the IP address. In addition, we collect and process data related to your interaction with the Website, such as the sections visited, time spent the number of clicks and scrolls. Your login details are encrypted, stored and used to log in and to avoid having to sign in again every time you open the Website until you sign out of your account.

Legal ground: Processing of your personal data is based on our legitimate interest to protect your personal data and to monitor and improve the information security of our services.

Retention period: your personal information will be stored for 2 years. At the end of the retention period, personal data will be deleted.

5.8.      Purpose: Carry out and enable your participation to the webinars you have booked

Personal data categories: First name, last name, e-mail, practice name, role in practice, industry type.

Legal ground: Processing of your personal data is necessary for the performance of the contract represented by the Terms & Conditions.

Retention period: Personal data will be stored for a period of 1 month from the date of the webinar.

 

5.9.      Purpose: To inform you electronically about promotions, offers, or similar promotional activities, and any other information related to the sale of and access to our Services that we think you may be interested in (e.g., industry information, new blog posts).

Personal data categories: Name, email address.

Legal basis: We rely on your freely expressed consent or our legitimate interest if the case, to send you direct marketing and information that we think you may be interested in.

Retention period: Personal data will be processed until you withdraw your consent or object to the processing, after which the data will be deleted where there is no other legal ground for the processing. You can withdraw your consent or object to the processing at any time, by clicking Unsubscribe/Opt-out at the bottom of any of our emails, without affecting the legality of the processing based on the consent or our legitimate interest before its withdrawal.

 

5.10.   Purpose: Collect your feedback through satisfaction surveys in order to help us improve our services and where the case post your review on the website

Personal data categories: First name, last name, image, company name, position/role within the company, and any other personal data provided by you and contained in the review message.

Legal basis: We rely on your freely expressed consent when you voluntary fill out our review form. You can withdraw your consent at any time, without affecting the legality of the processing based on consent before its withdrawal.

Retention period: Personal data will be stored for as long as we have your consent until withdrawal, in which case data will be deleted. However, we can proceed to the deletion of personal data when we decide that it is no longer relevant for achieving the purpose.

In addition to the purposes mentioned above, we may process your personal data for the purpose of fulfilling our legal obligations under the laws governing our activity, including those regarding equal opportunities and non-discrimination, ensuring physical and IT security and protecting whistleblowers in the public interest. In these situations, the categories of data processed and the data storage periods are determined according to the applicable legal provisions.

Your data may also be processed, based on the legitimate interest of the Controller, for the purpose of exercising or defending a right or legitimate interest in a judicial, administrative or similar procedure, in which the Controller is involved or to respond to requests from public authorities, courts and tribunals or criminal investigation and prosecution bodies, based on and within the legal obligations the Controller is subject to. The categories of data processed and the storage periods are determined on a case-by-case basis, depending on the applicable legal procedures and provisions.

At the end of the retention periods specified above, personal data will be deleted or anonymized, as applicable to the specific situation.

 

6.      tracking technologies

Our website uses cookies, plug-ins and other online identifiers (collectively referred to as “cookies”) in order to ensure functional browsing or to provide a better browsing experience, to perform statistical analysis regarding accessed information, or to provide you with custom content and advertising appropriate to your preferences and interests.

Detailed information regarding the cookies we use may be found in our Cookie Policy.

 

7.      AUTOMATED DECISION MAKING, INCLUDING PROFILING

We do not make decisions based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

 

8.      DISCLOSURE AND TRANSFER OF PERSONAL DATA

We may transfer your personal data, to the extent that this is necessary, to the following categories of recipients: companies from the same group, service partners, subcontractors, payment providers, courier service providers, archiving companies, IT service providers, software or hardware vendors, market research companies, marketing companies, public authorities, court or arbitral tribunals, as well as competent authorities to investigate criminal offenses.

Personal data may be disclosed or transferred to the categories of recipients mentioned above in order to provide our Services at the highest quality level, ensure the intervention of specialists by outsourcing parts of our business or to provide access to services and benefits according to our business partnerships, or to ensure compliance with the specific legal obligations to which we are subject according to the activity carried out.

In the event that personal data is transferred to third countries we will apply the technical and organizational measures required by law and we will inform you about the transfer in accordance with the legal requirements.

 

9.      SECURITY OF PERSONAL DATA

The security of your personal data is important to us. Therefore, we maintain a variety of appropriate technical and organizational measures to protect your personal data from loss, misuse, and unauthorized access or disclosure. We limit access to personal data to employees or contractors who we believe reasonably need to retrieve that information to provide our Services. Considering the current state of technology, we have implemented reasonable physical, technical and procedural safeguards designed to protect your personal data, such as limiting access, encrypting, anonymizing, or storing it on secure media.

It is very important that you, as a data subject, know the risks and take the measures to protect your personal data, for example by checking the sources of information, avoiding access to suspicious or unknown links, regularly changing passwords and using appropriate anti-virus and anti-malware solutions.

 

10.  YOUR RIGHTS AND HOW TO EXERCISE THEM

The law grants data subjects enforceable and effective rights concerning their personal data which can be exercised under particular conditions.

You have the following rights regarding your personal date:

  • Right to be informed: You have the right to be informed regarding the processing of your personal data, as we are doing through this Policy.

  • Right of access: You have the right to obtain confirmation whether or not we process your personal data, as well as information on the specifics of the processing activities, and get access to that personal data.

  • Right to rectification: You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

  • Right to erasure: You have the right to obtain from us without undue delay the erasure of your personal data, to the extent that the legal requirements are met. Personal data will be erased when the legal requirements are met.

  • Right to restriction of processing: If the applicable legal provisions are met, you have the right to obtain the restriction of processing of your personal data.

  • Right to data portability: If the applicable legal provisions are met, you have the right to receive your personal data which you have provided to us, in a structured, commonly used and machine-readable format, and the right to transmit those data to another Controller.

  • Right to object: In certain situations, such as when we process personal data based on legitimate interest, you have the right to object to the processing of your personal data. In the event of unjustified opposition, as Controller we are entitled to further process your personal data.

  • Right to object to commercial communication: You may also object to the processing of your personal data for the purpose of sending commercial messages.

  • Right not to be subject to decisions based solely on automated processing, including profiling: If the applicable legal provisions are met, you have the right not to be subject to a decision based solely on automatic processing, including profiling, which has legal effects on you or affects you similar to a significant extent.

  • Right to Opt-Out of Sale or Sharing of Personal Data: If we sell your personal data to third parties or share it with third parties for cross-context behavioral advertising, you have the right, at any time, to stop us from selling or sharing your personal data.

  • Right to address to the Supervisory Authority: You have the right to file a complaint with the competent Supervisory Authority on any violation of your rights regarding the processing of your personal data.

If you want to contact the Supervisory Authority from your place of residence in EU, you may find the contact details at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

  • Consent withdrawal: To the extent that we process your personal data based on your given consent, you can withdraw your consent at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.

  • Right to No Retaliation: If you choose to exercise any of these rights, we will not discriminate against you in any way. However, if you exercise certain rights, understand that you may be unable to use or access certain features of our websites or services, or we may be unable to execute the employment or collaboration agreement with you.

Except for the right to contact the Supervisory Authority, which you can exercise using the contact details indicated above, you can exercise your legal rights by contacting our Data Protection Officer by e-mail at dpo@clarityperformance.com.

We will respond to your requests without undue delay and in any case within one month of receiving the request. This period may be extended by two months where necessary, taking into account the complexity and number of requests. We will inform you of any such extension within one month of receiving your request, stating the reasons for the delay.

In the event that we do not take action on your request, we will inform you, without undue delay and no later than one month after the receipt of your request, of the reasons for not taking action. In such a case, you have the possibility to lodge a complaint with the competent Supervisory Authority or to take a legal action.

 

11.  EUROPEAN UNION REPRESENTATIVE

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons regarding the processing of personal data and on the free movement of such data (GDPR), our designated representative in the European Union is Mr. Alexandru Ganea. If you are based in the European Union, you may contact directly our representative by e-mail at eurep@engagetg.com.

 

12.  DATA PRIVACY FRAMEWORK

Engage Technologies Group Inc complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. Engage Technologies Group Inc has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this Policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Engage Technologies Group Inc commits to process only the types of personal data which are adequate and limited to what is necessary for the purposes for which the personal data are to be processed, as mentioned in Section 5 above, and to ensure the strict application of the DPF Principles to processing involving the respective types of personal data. Any disclosure, passing on or making available of personal data by Engage Technologies Group Inc is subject to the terms mentioned in Section 8 above. Engage Technologies Group Inc shall remain liable under the DPF Principles if its agent processes personal data in a manner inconsistent with the DPF Principles, unless Engage Technologies Group Inc proves that it is not responsible for the event giving rise to the damage. Engage Technologies Group Inc grants individuals the right to access their personal data by contacting Engage Technologies Group Inc at: dpo@clarityperformance.com.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Engage Technologies Group Inc commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF should first contact Engage Technologies Group Inc through the designated representative in the European Union, as mentioned in Section 11 above, at: eurep@engagetg.com. UK individuals with inquiries or complaints regarding our handling of personal data received in reliance on the UK Extension to the EU-U.S. DPF should first contact Engage Technologies Group Inc at: dpo@clarityperformance.com.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Engage Technologies Group Inc commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.

The Federal Trade Commission (FTC) has jurisdiction over Engage Technologies Group Inc’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF.

If you consider that your complaint was not resolved under the DPF mechanism, you may have the possibility, under certain conditions, to invoke binding arbitration through the Data Privacy Framework Panel. For additional information related to binding arbitration, please visit https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or Law Enforcement requirements.

 

13.  UPDATES

This Policy is subject to periodic reviews and updates to ensure that it always corresponds to reality, and it is in line with the applicable legal requirements. For this reason, please regularly consult this Policy to keep up to date with any changes. Any major changes to this Policy will be notified accordingly.

 

14.  CONTACT

If you have any questions or concerns regarding the processing of your personal data, this Policy or how it applies, or you wish to exercise any of your rights, you can contact our Data Protection Officer by e-mail at: dpo@clarityperformance.com.