Revised Febuary 19, 2021
CTG takes your privacy seriously and will never sell the personal or aggregated data that we collect from our users.
Information about your use of the Services is collected as follows:
- Registration. In order to use the Services, you may be required to register an account and provide certain personal information such as your name, email address, zip/postal code, profession, occupation, specialty and perhaps some information regarding your current activities and possible exposure to contagions or other pathogens. You may be required to update or supplement this personal information that you provided at registration at times through your account when requested by CTG customer service.
- Services Information. We automatically collect and store information about your use of the Services, such as your responses to questionnaires and particular content which may include personal health information. We also collect information about your device when you access the Services including IP address and browser information (including referring URL).
- Information from Third Party Sources. We may obtain additional information about you from third party sources to assist us in providing the Services. For example, we may use third party information to verify and update your registration information, for research purposes or to personalize the Services.
- Data Collected Relating to Students, Schools, and School Districts. You may supply data on the CTG Network because you are required to do so by your educational institution or employer. CTG does not require you to provide such data. Any student using the Services are responsible for complying with the requirements and qualifications as permitted user, as determined by their educational institution or school district. You are responsible for ensuring the accuracy and completeness of all information supplied to CTG for use by your educational institution. Authorized persons may access, view, and correct personally identifiable information through use of the Service at any time. We may retain the data supplied by such authorized persons for as long as required by the applicable educational institution and/or applicable law, or as otherwise authorized by you.
- Geofencing. Employers and organizations may enable geofencing of their physical locations. When using the Android or iOS app, and when background location is enabled, Clear To Go servers receive precise location data only when the device enters or leaves one of the geofenced locations. This information is used to understand when someone was present in the event of a health or security incident. It is not shared with any third party.
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, and to develop new or related Services.
- K-12 Students. CTG will 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, nor any user. We will not collect, use, or share behavioral information for any purpose beyond the authorized educational or school purposes, or as authorized by the applicable education institution. CTG, however, does not limit an educational institution's use of the data that it is authorized to access in connection with engagement of Services on the CTG Network. 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 to recognize you as a registered user when you visit one of our Client's Facilities or commercial properties, and to verify your identity and/or license or professional credentials for security and access purposes. We may require you to provide 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 and any Client facility. While we take steps to verify that our users identify as the registered users, we make no guarantee as to their identity, professional credentials, or licensure status.
- Account Management. We may use your information to administer your account, respond to your inquiries, fulfill your requests, and send you administrative communications about the Services.
Sharing Your Information with Third Parties
Information about your use of the Services may be shared as follows:
- Clients. We disclose information that you provide CTG to the Client that has engaged the CTG Network to gather information for screening and tracking personnel, contractors, vendors, and guests at Client facilities to best manage occupancy and compliance with federal, state, and local guidelines for safer operation of such facilities.
- Service Providers. We work with third party service providers to help us provide the Services and otherwise assist us in the operation of the CTG Network, including in the areas of email management and deployment, storage of personal health information (PHI), analytics, marketing, market research, identity, license, and professional credential validation, content distribution, customer service, payment fulfillment, event logistics, website maintenance and data storage and security. We may provide these service providers with personal information about users of our Services so that they can fulfill their responsibilities to us and our Clients; however, we do require that they agree to limit their use of this personal information to the fulfillment of these responsibilities.
- User Profiles. Subject to applicable law, CTG may provide user profiles, and portions thereof, (excluding contact information and information about your participation in specific named activities or visitation to facilities) only to those third parties necessary to provide the Services provided on the CTG Network..
- 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 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 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 registration information at any time through the Account Management feature available on each of our properties. You may also contact Customer Support at firstname.lastname@example.org and request that your registration information be updated or deleted. Note that if we delete your account, we may maintain certain de-identified information about you for internal business purposes including research, analytics and reporting.
- 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 will be limited. Refer to our Cookies Policy for additional information about opting out of cookies.
- 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. Also, you may manage your newsletter subscriptions within the newsletter subscriptions area within your account settings. Note that certain email communications that we send to Users are service-related and as long as you are a User of the CTG Network, you may not unsubscribe from such emails.
- Push Notifications. We may send you push notifications from time-to-time to notify you of upcoming events or updates that we think may be relevant to you. 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. For more information relevant to our users who are California residents, please contact CTG customer service at email@example.com.
Note to Users Outside of the United States
The CTG Network 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 must be in connection with an approved Client or educational institution or similar organization that has obtained all appropriate parental approvals regarding such minor's usage of the Services.
Please note that if you contact us to assist you, we may need to verify your identity before fulfilling your request.
Effective date : September 10, 2020