Effective January 12th, 2022
CLEAR TO GO! ™is an enterprise-based service platform comprised of web and mobile-based applications that interface with a CTG Client's enterprise solution engaged to manage the entry and safe usage of facilities. The CTG Platform allows a Client to present a series of questions deemed necessary to comply with federal, state, and local guidelines for the safer operation of the Client's facilities and workforce. The CTG Platform is not a stand-alone app or software program. Public users may not download the app or use it for their individual purposes. A user must be invited or authorized by a CTG Client before downloading any CTG application or using the CTG Platform.
CTG takes your privacy seriously. CTG will never sell the personal information or aggregated data that we collect from our users to third parties. We collect and process your information solely to perform the Services for which we have been engaged to perform by the Client.
Information about your use of the Services is collected as follows:
- Registration. In order to use the Services, you may be required to register or provide certain personal information such as your name, email address or perhaps some information regarding the purpose of your visit, any recent travel, and possible exposure to contagions or other pathogens. You may be required to update or supplement this information that you provided at registration when entering a Client's facility.
- Information from Client Sources. We may obtain additional information about you from the Client to provide the Services. For example, we may use data from the Client to verify and update your registration information necessary to validate that you have been authorized by the Client to enter the facility or to otherwise personalize the Services for your use.
- Non-registered Users. You must have been invited to use the CTG Platform to access these Services fully as intended. However, you may be able to access certain limited aspects of the Services on our website. The information we collect includes the referring website, if applicable, the type of browser you use, the material viewed and the time and date that you accessed the Services. We do not sell or transfer such data to any third party except to the Client for which the Services are performed.
- Data Collected Relating to Students, Schools, and School Districts. You may supply data or personal information because you are required to do so by your educational institution or employer. The institution or employer requires this data and merely engaged CTG to gather such on such an organization's behalf. Students using the Services are responsible for complying with the requirements and qualifications for entry or such institution's compliance requirements as determined by their specific educational institution, school district, or employer. You are responsible for ensuring the accuracy and completeness of such information supplied via the CTG Platform used by your educational institution for facility entry, personnel management, and safety protocols. Authorized persons at Client may access and view personally identifiable information. We may retain the data supplied by such authorized persons for as long as required by the applicable Client educational institution, or as otherwise required by applicable law.
How Your Information May be Used
Information about you may be used for the following purposes:
- Provision of the Services. We may use the information collected about you to provide and improve the Services.
- K-12 Students. CTG shall not make any individual data gathered from students using the Services publicly available. CTG will not use any behavioral information to provide targeted advertising to Student or any user. We will not collect, use, or share information for any purpose beyond the authorized educational or school purposes, or as authorized by the applicable educational institution. CTG, however, does not limit an educational institution's use of the data that it is authorized to access in connection with the engagement of Services on the CTG Platform. In the event of an acquisition by another entity or merger, CTG will not provide a student's personal information to a successor entity unless the entity expressly agrees to the "Student Privacy Pledge" as set forth by the Future of Privacy Forum and the Software and Information Industry Association.
- Verification Purposes. We may use your information in conjunction with information from third parties (generally the applicable Client) to recognize you as a registered user when you visit one of our Client's Facilities, and to verify your identity and/or any applicable license, professional credentials, or vaccine card for security and access purposes. We also may be required to provide the Client with proof of your identity in addition to the CTG Badge on your mobile device, and if you are unable to do so to our reasonable satisfaction, we reserve the right to deny you access to the Services. While we do take steps to verify that users identify as the applicable registered user, we can make no guarantee as to their actual identity, the validity of any professional credentials, or whether the licensure documentation is genuine.
- Account Management. We may use your information to administer your account, forward to the applicable Client to gain entry, respond to your inquiries, fulfill your requests, and send you administrative communications about the Services.
Sharing Your Information with Third Parties
CTG shall only use information gathered to perform the Services. Information about your use of the Services will only be shared as follows:
- Clients. We disclose information that you provide CTG to the specific Client that has engaged the CTG Platform to gather information for screening and tracking personnel, contractors, vendors, and guests of the Client so that they may manage facility occupancy, workforce safety, and compliance with federal, state, and local guidelines.
- Service Providers. We work with third-party service providers to help us deliver the Services and assist CTG in the operation of the CTG Platform, including in the areas of email management and deployment, storage of personal health information (PHI), analytics, and credential validation as requested by client, as well as data storage and security. We may provide these service providers with personal information about users of the Services, which is encrypted and stored on HIPAA compliant server, so that CTG can fulfill its responsibilities to our Clients. All service providers must agree to perform their obligations in accordance with these Privacy Policies.
- User Profiles. Subject to applicable law, CTG may provide user profile data to the Client in order to provide the Services. CTG will not use or transfer data for any other purpose.
- Aggregated Information. We may provide aggregated information about users of our Services to third parties as we deem appropriate only to carry out the intent and purpose of the Services on CTG Platform. For example, CTG may tell a Client what percentage of registered users of the CTG Platform have presented with specific information or status at a particular facility or location. This data is provided in a non-identifiable format.
- Legal Requirements. We may release personal information when we believe such release (i) is required to comply with valid legal requirements such as a law, regulation, search warrant, subpoena, or court order, and to meet national security or law enforcement requirements; or (ii) is reasonable in response to a physical threat to you or others, to protect the property or defend or assert legal rights of us or others.
Security of Information
We have implemented appropriate technical and organizational security measures to protect the personal information that we have under our control as a "processor" or as the "service provider" from unauthorized access, use, disclosure, and accidental loss. When you enter personal information, we encrypt the transmission of that information or use SSL connections (Secure Socket Layer) technology. You are solely responsible for maintaining the security and confidentiality of your account username and password. Unfortunately, no method of transmission over the internet or method of electronic storage is completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.
Choice and Control
- Account Information. You may update your account information at any time through the account management feature available on the CTG Platform. You may also contact Customer Support at firstname.lastname@example.org and request that your registration information be updated or deleted entirely.
- Cookies. Most browser software can be set to reject all cookies, including third-party cookies, however, if you choose to reject our cookies, your ability to access and use the Services may be limited. Refer to our Cookies Policy for additional information about opting out of cookies.
- Interest-Based Ads. CTG will not sell data or use the CTG Platform to advertise any third-party products or services to you.
- Email Communications. If you no longer wish to receive a particular type of email communication from us, you may unsubscribe by clicking the "unsubscribe" link located at the bottom of the email and following the instructions. Note that certain email communications that we send to Users are service-related and as long as you are a user of the CTG Platform, you may not unsubscribe from such emails.
- Push Notifications. We may send you push notifications from time-to-time to notify you of upcoming updates that we think may be relevant to you with respect to the Services. If you no longer wish to receive these types of notifications, you may turn them off at the device level.
- California Residents. If you are a California resident, California law may provide you with additional rights regarding our use of your personal information, including certain rights detailed in the California Consumer Privacy Act, Cal Civ Code 1798.100 et seq. ("CCPA"). For more information relevant to our users who are California residents, please contact CTG customer service at email@example.com and request a copy of our Privacy Pledge.
Note to Users Outside of the United States
The CTG Platform and the Services are designed and intended for use by users of all ages, some of which may be minors. Any usage by a minor may only be in connection with an approved Client, educational institution, or similar organization that has obtained all appropriate parental approvals or legal authority regarding the minors' use of the CTG Platform.