Privacy Policy

 

 

Last updated February 1, 2022

 

Introduction

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EcoBuds, Inc., d/b/a CLEANTheory Inc., including its wholly-owned affiliates, (“CLEANTheory”, "us," "we," or "our,") is committed to protecting the privacy of your information. This Privacy Policy (“Policy”) governs CLEANTheory’s use of personally identifiable information, also "personal data," about users of our products, services and/or third-party Partner services that are available for purchase and use through our sales teams, Partner ventures, accessible by download or authentication through our or Partner websites (our "Services"), and also users of our website http://www.cleantheory.net as well as the other websites that CLEANTheory may operate and that link to this Policy (collectively referred to as “Site(s)”). It also describes the choices available to you regarding our use of your personally identifiable information and how you can access and update this information.

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CLEANTheory does not participate in the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks and as such only conduct business within the United States and Canada (the “Territory”).  All other visitors from outside the Territory are kindly asked to terminate the use of the CLEANTheory website.

 

Privacy Policy Updates

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Due to the Internet’s rapidly evolving nature, CLEANTheory may need to update this Privacy Policy from time to time. If so, CLEANTheory will post our updated Privacy Policy within our Site located at http://www.cleantheory.net and post notice of the change so it is visible when users log on for the first time after the change is posted so that you are always aware of what personally identifiable information we may collect and how we may use this information. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page. CLEANTheory encourages you to review this Privacy Policy regularly for any changes. Your continued use of this Site and/or continued provision of personally identifiable information to us will be subject to the terms of the then-current Privacy Policy.

 

Data Integrity, Protection and Purpose Limitation

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CLEANTheory is a provider of compliance and assurance-related services primarily serving indoor agriculture, including floriculture and horticulture, as well as cultivators, processors, and manufacturers in the legal hemp and cannabis industry. CLEANTheory may also provide services to select non-agriculture clients.  CLEANTheory's platform performs disease mitigation and odor reduction services, includes environmental sensor products and offers support and professional consulting services all of which may require the collection of commercially identifiable information (hereafter "Commerical Data").  Such information may be gathered upon the initial engagement of CLEANTheory by its customers or on an ongoing and regular basis in accordance with the terms of the applicable agreement and services provided by and between CLEANTheory and its customer.

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CLEANTheory will maintain appropriate administrative, physical, and technical safeguards for the protection of the security, confidentiality, and integrity of Customer Data, as described herein and/or within an executed Subscription Services Agreement. Those safeguards will include, but will not be limited to, measures designed to prevent unauthorized access to or disclosure of Customer Data (other than by Customer or Users).  All Commercial Data or Personal Data collected by CLEANTheory or its Affiliates or Partners shall be stored in a commercially reasonable manner, such as through Amazon Web Services or an equivalent technology provider.  Upon request by Customer made within 30 days, or as otherwise stated within an executed Subscription Services Agreement between the Parties, after the effective date of termination of said agreement, CLEANTheory will make Customer Data available to Customer for export or download as provided in the Documentation and based on the then-current data collection policies, as shall be in commercial use at the sole discretion of CLEANTheory.  After such a 30-day period, CLEANTheory will have no obligation to maintain or provide any Customer Data, and as provided in the Documentation will thereafter delete or destroy all copies of Customer Data in its systems or otherwise in its possession or control, unless legally prohibited.

 

Information Collection and Use

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You can generally visit our Site without revealing any personally identifiable information about yourself. However, in certain sections of this Site, we may invite you to participate in surveys, questionnaires, or contests, contact us with questions or comments or request information, participate in chat or message boards, or complete a profile or registration form. Furthermore, we may require you to complete a registration form to access certain restricted areas of the Site, use certain services, and receive custom information. Due to the nature of some of these activities, we may collect personally identifiable information such as your name, e-mail address, address, phone number, password, screen name, credit card information, and other contact information that you voluntarily transmit with your online and in-person communications to us and personally identifiable information that you elect to include in your chart and message board postings.

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If you use a forum on this Site, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums. We receive permission to post testimonials that include personally identifiable information prior to posting.

 

Orders

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If you purchase a product or service from us, we request certain personally identifiable information from you on our order form. You must provide contact information (such as name, email, and shipping address) and financial information (such as credit card number, expiration date).

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We use this information for billing purposes and to fill your orders. If we have trouble processing an order, we will use this information to contact you.

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In addition, we may collect information about the performance, security, software configuration, and availability of customer networks or websites in an automated fashion as part of the CLEANTheory subscription services.

We use your personally identifiable information to register you to use our services or download or access software or other content, contact you to deliver certain goods, services, or information that you have requested, provide you with notices regarding goods or services you have purchased, provide you with notices regarding goods or services that you may want to purchase in the future, verify your authority to enter our Site and improve the content and general administration of the Site and our services.

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Certain services provided by CLEANTheory’s Partners may connect to your network or other technology infrastructure, and these modules may report to us, and we may collect, your IP address, operating system type, and version, web server type and version, PHP version, database type, and version, version of the services, information regarding the availability of your network or website (e.g. if your network is live or down), user statistics such as the number of nodes, number of users, number of sensors, number of messages (for sensors), geographic location, etc. The foregoing information will be linked to your personally identifiable information and user accounts and we may use the foregoing information to better provide technical support to you and our customers and to improve our services.

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If you choose to contact us by e-mail, we will not disclose your contact information contained in the e-mail, but we may use your contact information to send you a response to your message. Notwithstanding the foregoing, we may disclose to CLEANTheory Partners the content and/or subject matter of your message, therefore, you should not send us any ideas, suggestions, or content that you consider proprietary or confidential other than such information necessary for CLEANTheory to provide you with the Services. All e-mail content (except your contact information) will be treated on a non-proprietary and non-confidential basis and may be used by us for any purpose.

 

Communications from the Site & Special Offers and Updates

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We will occasionally send you information on products, services, special deals, promotions, etc. at our discretion. Out of respect for your privacy, we present the option not to receive these types of communications. Please see “Choice and Opt-out.”

 

Newsletters

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If you wish to subscribe to our newsletter(s), if offered, we will use your name and email address to send the newsletter to you. Out of respect for your privacy, we provide you with a way to unsubscribe. Please see the “Choice and Opt-out” section.

 

Service-related Announcements

 

We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if we detect a sensor reading out of acceptable limits or our service is temporarily suspended for maintenance, we might send you an email or text notification.

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Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account or ask us, in writing as instructed below, to remove you from our database.

 

Customer Service

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Based on the personally identifiable information you provide us, we will send you a welcoming email to verify your subscription status. We will also communicate with you in response to your inquiries, to provide the services you request, and manage your account. We will communicate with you by email or telephone, in accordance with your wishes.

 

Choice/Opt-out

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We provide you the opportunity to ‘opt-out’ of having your personally identifiable information used for certain purposes when we ask for this information.

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To request updates or changes to your information or your preferences regarding receiving future promotional messages from us, you may contact our Privacy Officer using the information in the Contact Us section of this Privacy Policy or follow the opt-out instructions that are contained at the bottom of the email communication you received.

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You will be notified prior to when your personally identifiable information is collected by any third party that is not our agent/service provider, so you can make an informed choice as to whether or not to share your information with that party.

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Please note that if you opt-out of receiving our promotional or marketing emails, you may still receive certain service-related communications from us, such as administrative and services announcements and messages about your account. Occasionally these materials are sent from a different email domain: info@CLEANTheory.net. 

 

Children's Privacy

 

CLEANTheory recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. This Site is not intended for children or adults under the age of 21. CLEANTheory does not target its services or this Site to children or adults under 21. CLEANTheory does not knowingly collect personally identifiable information from children or adults under the age of 21.

 

Cookies and GIFs

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We use small text files called cookies to improve the overall Site experience. A cookie is a piece of data stored on the user’s hard drive containing information about the user. Cookies generally do not permit us to personally identify you (except as provided below). We may also use clear GIFs (a.k.a. “Web beacons”) in HTML-based emails sent to our users to track which emails are opened by recipients.

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Additionally, when using the Site, we and any of our third-party service providers may use cookies and other tracking mechanisms to track your user activity on the Site and identify the organization or entity from which you are using the Site. If you register with the Site, we, and our third-party service providers, will be able to associate all of your user activity with your personally identifiable registration information. We will use such user activity information to improve the Site, provide context for our sales and support staff when interacting with you and customers, initiate automated email marketing campaigns triggered by your activity on the Site, and for other internal business analysis.

 

Aggregate Information

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The Site may track information that will be maintained, used, and disclosed in aggregate form only and which will not contain your personally identifiable information, for example, without limitation, the total number of visitors to our Site, the number of visitors to each page of our Site, browser type, External Web Sites (defined below) linked to and IP addresses. We may analyze this data for trends and statistics in the aggregate, and we may use such aggregate information to administer the Site, track users’ movement, and gather broad demographic information for aggregate use.

 

Disclosure

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We will not sell your personally identifiable information to any company or organization, except we may transfer your personally identifiable information to a successor entity upon a merger, consolidation, or other corporate reorganization in which CLEANTheory participates or to a purchaser or acquirer of all or substantially all of CLEANTheory’s assets to which this Site relates. We may provide your personally identifiable information and the data generated by cookies and the aggregate information to a parent, subsidiary, Partner, or affiliate entity within CLEANTheory’s corporate family, partner entities that are not within CLEANTheory’s corporate family, and vendors and service agencies that we may engage to assist us in providing our services to you. For example, we may provide your personally identifiable information to a credit card processing company to process your payment. Such third-party service providers may be obligated to protect your personally identifiable information consistent with the terms of this Privacy Policy and not for their promotional purposes and/or required to enter into written confidentiality and data processing agreements including the commitment to be compliant with the Standard Contractual Clauses issued by the European Commission. We will also disclose your personally identifiable information (a) if we are required to do so by law, regulation, or other government authority or otherwise in cooperation with an ongoing investigation of governmental authority, (b) to enforce the CLEANTheory Terms of Use Agreement or to protect our rights or (c) to protect the safety of users of our Site and our services.

 

The Site may provide links to other Web sites or resources over which CLEANTheory does not have control (“External Web Sites”). Such links do not constitute an endorsement by CLEANTheory of those External Web Sites. You acknowledge that CLEANTheory is providing these links to you only as a convenience, and further agree that CLEANTheory is not responsible for the content of such External Web Sites. Your use of External Web Sites is subject to the terms of use and privacy policies located on the linked External Web Sites.

 

Security

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We employ procedural and technological measures that are reasonably designed to help protect your personally identifiable information including sensitive data from loss, unauthorized access, disclosure, alteration, or destruction. CLEANTheory may use encryption, a secure socket layer, firewall, password protection, and other physical security measures to help prevent unauthorized access to your personally identifiable information including sensitive data. CLEANTheory may also place internal restrictions on who in the company may access data to help prevent unauthorized access to your personally identifiable information. These precautions take into account the risks involved in the processing, the nature of personally identifiable information, and best practices in the industry for security and data protection.

 

Accountability for Onward Transfer

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CLEANTheory is accountable for personally identifiable information that we receive and subsequently transfer to third parties. If third parties that process personally identifiable information on our behalf do so in a manner that does not comply with the CLEANTheory’s Privacy Policy, we are accountable, unless we prove that we are not responsible for the event giving rise to the damage.

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Contact information and Customer personally identifiable information are accessible only by those CLEANTheory employees and consultants who have a reasonable need to access such information in order for us to fulfill contractual, legal, and professional obligations. All of our employees and consultants have entered into confidentiality agreements, and/or have been subjected to thorough criminal background checks requiring that they maintain the confidentiality of Customer personally identifiable information.

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CLEANTheory will only disclose personally identifiable information to third-party agents that have given us contractual assurances that they will provide at least the same level of privacy protection as is required by this Privacy Policy and the Principles and that they will process personally identifiable information for limited and specific purposes consistent with any consent provided by the individual. If CLEANTheory has knowledge that a third party to which it has disclosed personally identifiable information covered by this Privacy Policy is processing such personally identifiable information in a way that is contrary to this Privacy Policy, CLEANTheory will take reasonable steps to prevent or stop such processing. In such a case, the third party is liable for damages unless it is proven that CLEANTheory is responsible for the event giving rise to the violation.

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CLEANTheory may use from time to time a limited number of third-party service providers, contractors, and other businesses to assist us in providing our solutions to our customers or in meeting internal business operation needs. These third parties may access process or store personally identifiable information in the course of performing their duties to CLEANTheory. CLEANTheory maintains contracts with these providers restricting their access, use, and disclosure of personally identifiable information in compliance with our obligations under the Principles.

 

Updating and Deleting Personally Identifiable Information

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If you wish to review and/or update any of the foregoing information, you may request your account information and review and update your personally identifiable information at the e-mail, phone, or mailing address listed below.

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CLEANTheory will also delete the personally identifiable information that you have provided to us: (a) upon your request, or (b) upon the termination of your CLEANTheory account; provided, however, CLEANTheory will retain a copy in its files of all personally identifiable information, if required for legal reasons.

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If you wish to review, correct or request the deletion of any information you have provided to us, contact us:

By mail: 221 River St., 9th Fl, Hoboken NJ 07030 USA.

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By email: info@CLEANTheory.net

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We will respond to your request for access within 30 days.

 

Enforcement and Liability

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CLEANTheory is subject to the jurisdiction and enforcement and investigatory authority of the United States Federal Trade Commission.

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CLEANTheory also commits to periodically reviewing and verifying the accuracy of this Policy and remedying issues identified. All employees of CLEANTheory that have access to personally identifiable information covered by this Policy in the U.S. are responsible for conducting themselves in accordance with this Policy. Failure of a CLEANTheory employee to comply with this Policy may result in disciplinary action up to and including termination and/or criminal prosecution.

 

Dispute Resolution

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CLEANTheory assures compliance with this Privacy Policy by fully investigating and attempting to resolve any complaint or dispute regarding the use and disclosure of personally identifiable information in violation of this Privacy Policy.

 

Any questions or concerns regarding the use or disclosure of personally identifiable information should first be directed to the owner of the website in question (our customer); or if the question or concern is from our customer, then to CLEANTheory at the address given below.

 

Contact Us

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If you have any questions or complaints regarding this Privacy Policy please contact us by:

 

By mail: 221 River St,9th Fl, Hoboken NJ 07030 USA.

 

By email: info@CLEANTheory.net