Privacy Policy

Effective Date: November 25, 2025

Introduction

This Global Privacy Notice (“privacy notice”) applies to Clarity Compliance Consulting LLC (“Clarity Consulting”, “we”, or “us”). This notice provides transparency to individuals about the personal information we collect, how that information is used, and how Clarity Consulting complies with data protection laws such as the EU General Data Protection Regulation ("GDPR") and California Consumer Privacy Act of 2018 ("CCPA").

We are committed to safeguarding all personal information we receive and collect in the course of legitimate business. To the extent you provide us with personal information about others, including your clients, you are responsible for sharing this notice with them directly.

Scope of this Privacy Notice

This privacy notice applies to personal information Clarity Consulting receives, collects, and/or uses in its capacity as a Controller, as defined in the GDPR or other similar laws. For the purposes of this privacy notice, "Personal Information" means information that is related to an identified or identifiable individual or is reasonably able to be associated with, directly or indirectly, a particular individual.

While this privacy notices provides details about our global privacy standards and practices, in cases when conflict-of-law issues arise, local country/state laws will take precedence. We are committed to complying with local legal requirements in jurisdictions where we offer services.

We have other privacy policies that apply to Clarity Consulting’s treatment of sensitive commercial information shared with us in confidence.

What Personal Information we collect

Depending on your relationship with Clarity Consulting and where you are located, we collect and use different types of personal information in various ways, directly or indirectly, or from third-party sources, including:

Contact and event registration (e.g., you attend a webinar we sponsor or contact us with any other enquiry).
Business relationships (e.g., you engage with Clarity Consulting to enquire about or request its services).
Third-party sources (e.g., we acquire a company or assets of a company that has your information).
Sources of information may include:

You, in your interactions with us as described above.

Services providers, such as analytics providers, IT, and system administration services.
Third parties, such as lawyers, bankers, auditors, and insurers, who provide consultancy, banking, legal, insurance, and accounting services.
Publicly available sources and databases.
Marketing/advertising companies, for example, consumer research companies and analysts or marketing/advertising companies.
Government of administrative agencies, for example, law enforcement, public health officials, or corporate registries.

Use of Personal Information

How you interact with Clarity Consulting will determine how and why we use your personal information. For example, we may use your personal information in connection with:

managing and promoting our communications with you;
providing and documenting training or webinars;
managing our business relationship with you and receiving feedback on services and products;
inviting you to attend events, seminars, etc.;
preventing fraud or criminal activity and safeguarding our technology systems and data security;
complying with applicable legal or regulatory requirements;
dealing with requests and communications from competent authorities; and
investigating or preventing security incidents;

We do not sell or share your personal information.

Legal Basis for Processing Information

In the majority of circumstances, we rely on one or more of the following lawful grounds when we collect and use your Personal Information for the purposes outlined above (in "Information Use”).

the processing is necessary for the performance of a contract to which you are a party, or to take steps with your consent to enter into a contract;
the processing is necessary for compliance with relevant legal obligations;
the processing is necessary for the performance of a task carried out in the public interest (e.g., background checks for anti-money laundering and terrorist financing purposes); or
the processing is in our legitimate interests (and are not outweighed by your privacy interests).

Before collecting and/or processing your personal information, we will apply a lawful basis or rely on exemptions that allow us to use that information.

Data Retention

Clarity Consulting will retain your personal information for the longest of the following periods:

as long as necessary to fulfill the purpose for which the information was collected or to comply with legal obligations;
any retention period that is required by law;
the end of the period in which litigation or investigations may arise in respect of the services provided.

We will delete your personal information after the relevant retention period, unless you authorize us to keep it, or when it is necessary to enforce our agreements or resolve disputes.

Data Security

We are committed to ensuring your data is adequately protected. We take commercially reasonable measures to secure your information against unauthorized access and use and we review our security protocols periodically.

We have implemented appropriate technical and organizational measures and maintain technological, physical, and administrative security protocols to ensure your data is not compromised or accessed by unauthorized users. These measures include:

education and training to relevant staff so they are aware of our privacy obligations;
administrative and technical controls to restrict access on a ‘need to know’ basis;
technological security measures, including firewalls and multi-factor authentication.
a regularly reviewed incident response plan.

Although we endeavor to protect personal information, it’s possible unauthorized users may attempt to illegally obtain and access your information. In the case that any personal information Clarity Consulting maintains about you is compromised, you will be notified immediately.

Your Rights

Depending where you are located, you may have certain rights under your local laws in relation to the personal information we hold about you, as outlined below. You can exercise relevant rights by contacting us as described at the end of this policy. Further, we encourage you to notify us of any changes to the personal information Clarity Consulting may hold about you to ensure accuracy.

US Residents

Depending on the US state you reside in, you may be entitled to privacy rights regarding the collection, use, and/or retention of your personal information. This Global Privacy Notice is intended to satisfy notice requirements under all applicable laws.

Notice at Collection
- Clarity Consulting may be required to provide you with notice prior to or at the point of collection of your personal information and the purposes for which it is being collected and used.

Right of Deletion
- Unless required to be retained or exempt, you may have the right to request the deletion of your Personal Information.

Right to Correct
- You may have the right to request the correction of inaccurate information about you that Clarity Consulting holds.

Right to Know/Information
- You may have the right to request what personal information Clarity Consulting has collected about you, including:
  - categories of personal information collected about you
  - categories of sources of personal information
  - business and/or commercial purposes for collecting and selling personal information
  - categories of third parties with whom we disclosed particular personal information, and categories of personal information that each recipient received for business purposes.
- California residents also have the right to know (and access) specific pieces of information that have been collected about them in the past 12 months, and may send a request no more than twice in a 12-month period for this information.

Right to Appeal
- US residents in states including (but not limited to) Colorado, Connecticut, and Virginia have a right to appeal our denial of any request made in relation to their Personal Information.

Right to Opt Out of Targeted Advertising
- US residents in states including (but not limited to) California, Virginia, and Florida have the right to opt out of the processing of their Personal Information for the purposes of targeted advertising.

Right to Limit the Use of Sensitive Information
- US residents in states including (but not limited to) California, Texas, and Oregon can limit the use and disclosure of their sensitive information to what is necessary for us to provide a service.

Right to Opt Out of Sale or Sharing of Personal Information
- US residents in states including (but not limited to) California, Florida and Texas may opt out of the sale and sharing of their Personal Information.

Right to Non-Discrimination, and Incentives
- US residents in states including (but not limited to) California, Florida and Texas may opt out of the sale and sharing of their Personal Information.

In addition, under applicable local law you may have the legal right to lodge a complaint with the relevant regulatory authority.

Your rights in Jurisdictions Covered by the GPDR and Similar Laws.

If you are located in the EEA/UK jurisdiction that has adopted the GDPR or similar rules, then, subject to certain exemptions, and dependent on how and why we use it, you have certain rights in relation to your Personal Information. The rights outlined below may vary depending on the specific local laws that apply to you.

You can exercise your rights by contacting us as described in the final section of this policy. Clarity Consulting may ask for additional information to confirm your identity before disclosing personal information to you, as described in "Requests for Information" below.

Right to Transparency and Information
- You have the right to be fully aware of how we use your Personal Information in our day-to-day operations at the time of collection, or as soon as possible after such date.

Right to Access
- You have the right to access your Personal Information which Clarity Consulting maintains, together with certain information about how and why we processes this information. This right is subject to certain exemptions which will be considered on a case-by-case basis.

Right to Rectification
- You have the right to request the correction of inaccurate or out of date Personal Information.

Right to Erasure
- You have the right under certain circumstances to request the erasure of your Personal Information. Your information can only be erased if it is no longer necessary for the purpose for which it was collected, and Clarity Consulting has no other legal ground for processing the information.

Right to Restrict Processing
- If the following circumstances apply, you have the right to restrict the processing of your Personal Information:
  - its accuracy is contested, to allow us to verify its accuracy, or
  - the processing is unlawful, but you do not want it erased; or
  - it is no longer needed for the purpose for which it was collected, but we still need it to establish, exercise, or defend legal claims; or
  - you have exercised the right to object, and verification of overriding grounds is pending.

Right to Data Portability
- You have the right to data portability, meaning we are required to provide you or another third-party controller with your Personal Information in a commonly used, machine-readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party.

Right to Object Processing
- You have the right to object to the processing of your Personal Information when such processing is based on our legitimate interests. If you choose to object, Clarity Consulting has the right to demonstrate that we have compelling, overriding legitimate interests.
Right to Lodge a Complaint with your Supervisory Authority
- You have the right to initiate a complaint to your local data protection authority if you are not satisfied with our response or how we process your Personal Information.

Transfer of Personal Information

If you are located outside the United States and you interact with Clarity Consulting online or provide us with your Personal Information directly, then your information may be transferred to the United States. Clarity Consulting will take all appropriate steps to ensure that transfers of Personal Information comply with applicable data privacy laws and provide the same level of protection for your information.

Requests for Information

All requests for personal information retained by Clarity Consulting require prior identity verification. To do so, we may ask you to provide us with your full name, contact information, and relationship to us. Depending on the nature of your request, further information may be required. Once received, we will review the information provided and determine whether we are able to match it with information we maintain to verify your identity.

If you are a third-party submitting a Personal Information request on behalf of someone other than yourself, please contact us to provide necessary proof that you are authorized to make the request, such as a valid power of attorney.

Disclosures

In connection with one or more of the purposes outlined in the "How do we use your information" section above, we may disclose details about you to: third parties that provide services to us; as part of a corporate transaction; competent authorities, including courts or regulators; and other third parties that have a reasonable requirement for obtaining your personal information.

In all cases, we will ensure there are adequate safeguards in place to protect your Personal Information that comply with our legal obligation.

Third-party requests

If you are submitting a personal information request on behalf of someone other than yourself, please contact us to provide the necessary proof that you are authorized to make the request, such as a valid power of attorney.

Third-party disclosures

In connection with one or more of the purposes outlined in the above, Clarity Consulting may disclose details about you to: third parties that provide services to us; as part of a corporate transaction; competent authorities, including courts or regulators; and other third parties that have a reasonable requirement for obtaining your Personal Information.

In all cases, we will ensure there are adequate safeguards in place to protect your personal information that comply with our legal obligation.

Lastly, we may also share non-personal, anonymized, and aggregated information with third parties for various purposes, including research and promotional purposes.

Sending you marketing information

You have the right to opt-out of any promotional or marketing communications. Please contact us as described below.

Changes to this Privacy Notice

Clarity Consulting reserves the right to make changes to this Privacy Notice at any time. If we maintain or process your personal information, you will receive notice of any material changes.

For questions or concerns regarding your privacy or how we protect personal information, please contact us at com@clarity-consultancy.com or cmg@clarity-consultancy.com.