TransparentC Privacy Policy

Last modified/Effective Date: January 7, 2019


TransparentC, Inc. (“we,” “us,” “our” or the “Company”) respects the privacy of our Users (“Users,” “You,” or “Your”), and, as the provider of (“Site”) is committed to protecting it through our compliance with this Privacy Policy (as it may be amended from time to time, the “Privacy Policy”). This Privacy Policy discloses the privacy practices for this Site. Please carefully read the information below to learn about Your use of this Site. You acknowledge that this Privacy Policy is part of our Terms of Use, available at (as it may be amended from time to time, the “Terms of Use”), and by accessing or using our Site, You agree to be bound by all its terms and conditions. If You do not agree to these terms, please do not access or use this Site. Capitalized terms used herein and not otherwise defined shall have the meaning ascribed to them in the Terms of Use.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the Site, and our practices for collecting, using, maintaining, protecting and disclosing that information. This Privacy Policy applies to information we collect on or through the Site, any other website, mobile site, mobile applications or services operated or offered by the Company or from e-mail, text and other electronic messages between you and the Company or the Site.

This Privacy Policy also applies to information collected by the Company through any offline services. This Privacy Policy does not apply to any information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from the Site, and you should familiarize yourself with all such third party privacy policies prior to using the Site.

We reserve the right to change this Privacy Policy at any time. Such changes, modifications, additions, or deletions shall be effective immediately upon notice thereof, which may be given by means including but not limited to sending an e-mail to the e-mail address provided to us by Users and posting the revised Policy on this page, with the Effective Date representing the most recent date of revisions. Your continued use of the Site after such modifications will constitute Your acknowledgment of the revised Policy and agreement to abide and be bound by the modified Policy.

Children under the Age of 13

The Site is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Site. We do not knowingly collect personal information from children under age 13. If you are under age 13, do not use or provide any information on to the Site, or on or through any of its features, register on the Site, make any User Account through the Site, complete any purchases through the Site, use any of the interactive or public comment features of the Site or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under age 13 without verification of parental consent, we will delete that information.

If you believe we might have any information from or about a child under 13 years of age, please contact us at

Types of Information We Collect from You

Our primary goal in collecting information from You is to provide an efficient and customized experience while using our Site. To better provide You with our services, we collect two types of information about about our Users: Personally Identifiable Information and Non-Personally Identifiable Information.

  • Personally Identifiable Information: This refers to information that, either alone or in combination with other identifiers, lets us know specifics about you or who You are and may also be called personal data in this Policy. When You engage in certain activities on this Site, such as sending us a message, we may ask You to provide certain information about Yourself. It is completely optional for You to engage in these activities. But, if You elect to do so, we may ask that You provide us personal information, such as Your first and last name, e-mail address, employer, and telephone number, and other Personally Identifiable Information. Personally Identifiable Information also includes online identifiers, including Your Internet Protocol (“IP”) address. An IP address is an identifier for a computer or other electronic device (“Device”) on a Transmission Control Protocol/Internet Protocol (“TCP/IP”) network, such as the World Wide Web. Networks like the Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to Your Device whenever You are surfing the Web, allowing web servers to locate and identify Your Device. Devices require IP addresses for users to browse the Internet.
  • Non-Personally Identifiable Information: This refers to information that does not identify a specific individual. This may include information that is about you but individually does not identify you, such as job title, salary, work experience and/or college education. We gather certain information about You based upon where You visit on our Site. This information is compiled and analyzed on an aggregated and anonymized basis. This information may include the Web Site’s Uniform Resource Locator (“URL”) that You just came from, which URL You next go to, and what browser You are using. A URL is the global address of documents and other resources on the World Wide Web.; and/or

Collection and Use of Information

Except as otherwise described in this Policy, we do not collect any Personally Identifiable Information about You unless You voluntarily provide it to us, including when You send messages, submit forms or transmit other information by telephone or letter or submit other information when visiting the Site. We may also collect information from You at other points on our Site that state that such information is being collected. We use Your IP address to diagnose problems with our servers or software, to administer our Site, and to gather demographic information. In the event of third-party advertising on our Site, the third party’s servers will also provide us with a summary, but not individual reports, that will tell us how many ads were presented and clicked upon at our Site.

In addition, we may also collect, or our server may collect, certain Non-Personally Identifiable Information.

The provision of Personally Identifiable Information as described in this Policy is partly a requirement to provide You with our services, including use of this Site and the performance of any contract with You. If You fail to provide certain information when requested, we may not be able to provide our services to You.

We rely on the following legal grounds for the collection, processing, and use of Personally Identifiable Information where applicable under relevant data protection laws:

  • Consent, as permitted by applicable law;
  • Compliance with legal obligations;
  • Performance of a contract with You;
  • To the extent that laws of the European Union apply, our legitimate interest, where the legitimate interest may be:
    • customer relationship management and other forms of marketing;
    • physical security, IT and network security;
    • prevention of fraud, misuse of company IT systems, or money laundering; and
    • intended mergers and acquisitions.

We will primarily use Your Personally Identifiable Information to provide our services or products to You. We also use Personally Identifiable Information collected through our Site:

  • for security, credit monitoring or fraud prevention purposes;
  • to improve the content, functionality and usability of our Site;
  • to improve our marketing and promotional efforts;
  • to contact You with special offers and other information we believe will be of interest to You (in accordance with any privacy preferences You have expressed to us);
  • to invite You to participate in surveys and provide feedback to us (in accordance with any privacy preferences You have expressed to us);
  • to statistically analyze site use;
  • to improve our product and service offerings;
  • to customize our Site’s content, layout, and services;
  • to deliver information or otherwise respond to You;
  • to contact You regarding administrative notices;
  • to resolve disputes, troubleshoot problems, and enforce our agreements with You, including our Site Terms of Use and this Privacy Policy; and
  • for any other purpose identified in an applicable privacy notice, click-through agreement or other agreement between You and us.

Sharing of Information

We do not sell, trade, or rent Your Personally Identifiable Information to others.

We do provide some of our services through contractual arrangements with affiliates, service providers, partners and other third parties. We and our service partners use Your Personally Identifiable Information to operate our Site and to deliver their services.

In relation to an ongoing or proposed business transaction (such as transferring the ownership and operation of the Company or a potential bankruptcy), we may transfer Your information to a successor or potential successor organization. If such a transfer occurs, the successor organization’s use of Your information that was collected through this Site will remain subject to this Policy and the privacy preferences You have expressed to us.

Occasionally we may be required by law enforcement or judicial authorities to provide Personally Identifiable Information to the appropriate governmental or regulatory authorities. We may disclose Personally Identifiable Information upon receipt of a court order or subpoena, to cooperate with a law enforcement investigation, or as may otherwise be required by applicable law. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

We may also provide Non-Personally Identifiable Information about our customers and related Site information to third-party advertisers, but these statistics are provided on an aggregate basis and do not include any Personally Identifiable Information. We may use the Personally Identifiable Information we have collected from You to help us assist our advertisers by displaying their advertisement to the target audience.

User Choices on Collection and Use of Information

We may, from time to time, send You e-mail regarding our products and services. If You indicated to us that You are interested in receiving offers or information from us and our partners, we may occasionally send You direct mail about products and services that we believe may be of interest to You. Only we (or those working on our behalf) will send You these direct mailings. We may provide You with an “opt in” or “opt-out” mechanism depending on where You are located when we collect Your Personally Identifiable Information. An “opt-in” mechanism will provide You the opportunity to positively indicate that You would like or do not object to our sending You such further communications, and we will not send You any further communications unless You have “opted-in.” An “opt-out” mechanism will provide You the opportunity to indicate that You do not want us to send You such further communications, and if You “opt-out” we will not send You any. Either way, opting-in or opting-out will be up to You. In addition, if You do not want us to use Your Personally Identifiable Information for a particular purpose or disclose it to a third party, You may “opt out” at any time by contacting us as provided below. You also have choices with respect to cookies, as described below. By modifying Your browser preferences, You have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If You choose to reject all cookies some parts of our Site may not work properly for You.

Do Not Track Mechanisms.

Your browser may deliver a “Do-Not-Track (‘DNT’) signal,” or similar mechanism for exercising choices about the collection of information about Your online activities. Because of the changing state of technology, we do not guarantee that we will honor DNT signals or similar mechanisms at this time.

Retention of Information

We retain information collected through our Site for as long as the information is necessary for the purposes for which it was collected, or as otherwise permitted by applicable law. For example, we may retain information (including Personally Identifiable Information) if such retention is reasonably necessary to prevent fraud and abuse, to comply with any legal obligations or satisfy any regulatory requirements, to resolve any disputes or litigation, or as otherwise needed to enforce this Privacy Policy.

To determine the appropriate retention period for the information we collect from You, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we process the data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Security of Information

We rely on current industry standards to secure Your Personally Identifiable Information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be completely secure. As a result, while we strive to protect Your Personally Identifiable Information, You acknowledge that: (a) we cannot control security and privacy on the Internet; (b) the security, integrity, and privacy of information or data exchanged between You and us through this Site cannot be guaranteed; and (c) any such information and data may be viewed or compromised when in transit by a third party.


When You use our Site we may store cookies on Your Device in order to facilitate and customize Your use of our Site, as well as to provide us with information about Your visit to our Site. A cookie is a small data text file which a Web site stores on Your Device that can later be retrieved for various purposes as detailed below. Web browsers typically allow some control of most cookies through browser settings. You are always free to decline our cookies if Your browser permits this. Declining cookies may prevent You from taking full advantage of our Site.

Cookies are divided into four primary categories: (1) Strictly Necessary Cookies (such as those used for password-protected log-in areas, online calculators or language selection); (2) Performance Cookies (such as Web traffic monitoring services like Google Analytics); (3) Functionality Cookies (such as use of contact forms, viewing embedded YouTube videos, or using social media features included on our Sites); and (4) Targeting Cookies (typically placed by third parties for advertising purposes).

Category 1 cookies enable services You have specifically asked for. Category 2 cookies collect aggregated, and therefore anonymous, information about how visitors use a web site—for example, which pages visitors go to most often. Category 3 cookies remember choices You make on our Site and permit us to provide services You have asked for to improve Your experience on this Site. Category 4 cookies are used to deliver advertising that is relevant to You and Your interests, to limit the number of times You see a particular ad and to help measure advertising effectiveness, in the event that we engage in third-party advertising on this Site.

Other third parties may deliver cookies to Your Device in order to track Your online behaviors over time and across nonaffiliated websites or to deliver targeted advertisements either on this Site or on other websites. You have choices about the information third parties may collect about You through this Site. For example, if You do not want Your information sent to a third party, You may download an Opt-out Browser Add-on by clicking here.

By using our Web Site, You agree that we can place these types of cookies on Your device, unless You limit them using Your browser settings.

For Users in the European Economic Area

References to ‘personal data’ mean any information relating to an identified or identifiable individual.

Under European Union data protection laws, You have the rights to:

  • withdraw Your consent to the processing of Your personal data (this will not affect our right to process Your personal data up until such time as You provide us with notice that You no longer consent);
  • access to Your personal data;
  • receive or ask that we provide You with (or transfer to a third party) Your personal data in a structured, commonly used and machine readable form;
  • request us not to process Your personal data for marketing purposes (including profiling to the extent that it is related to our marketing activities). We will provide You with appropriate choices to opt-in or opt-out as set out above. You can also exercise the right at any time by contacting us at;
  • request us to rectify any inaccurate personal data that we may hold;
  • request us to erase personal data where: (a) it is no longer necessary for us to hold such personal data; (b) You no longer consent to the processing of Your personal data; (c) Your personal data has been unlawfully processed; or (d) we are otherwise required by law to erase Your personal data;
  • be informed of any automated decision making processes using Your personal data, including the logic involved in such processes;
  • make a complaint with the national data protection authority in the country where You are based.

You may contact us at any time at the address and/or email address noted above to exercise any of these rights.

The data that we collect from You will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It will also be processed by personnel operating outside the EEA who work for us. Where we transfer personal data to a destination outside the EEA, we do so subject to appropriate safeguards.

Privacy Policies of Third-Party Sites

Except as otherwise provided in this Privacy Policy, this Policy only addresses the use and disclosure of information we collect from You. Other sites accessible through our Site have their own privacy policies and data collection, use, and disclosure practices. Please consult each site’s privacy policy as we are not responsible for the policies or practices of those sites or any third parties. If we allow other companies to place advertising on our Site, those companies may collect information about You when You view or click on their advertising through the use of cookies. We cannot and do not control this collection of information. You should contact these advertisers directly if You have any questions about their use of the information that they collect.

Miscellaneous Privacy Issues

This Site is not intended for or directed at children under the age of 18 and You must be at least 18 years old to have our permission to use this Site. Our policy is that we do not knowingly collect, use, or disclose Personally Identifiable Information about visitors that are under 18 years of age. If You are a parent or guardian of a minor under the age of 18 and believe that we have collected, used, or disclosed such information, please contact us using the contact information below.

Your California Privacy Rights

California residents who have an established business relationship with us may request and obtain information, free of charge and on an annual basis, about personal information that we shared with other businesses for their own direct marketing use within the prior calendar year (as provided in California’s “Shine the Light Law”). If applicable, this information would include a list of the categories of personal information shared with third parties and the names and addresses of all third parties with whom we shared this information in the immediately preceding calendar year. To obtain this information, please write to us using the contact information below, with “California Shine the Light Privacy Request” in the subject line as well as in the body of Your message. We will then respond to Your mailing address with the requested information.

If You are a California resident and under the age of 18, You may request that we remove content or information that You have posted to our website by contacting us below. Please be aware that such removal does not ensure complete or comprehensive removal of the content or information posted on this Site.

International Data Transfers

Information that we collect from You may be stored and processed in and transferred between any of the countries in which we operate. For European and Asian customers and users, Your Personally Identifiable Information may be transferred outside the European Union and Asian countries for us to provide the services and information You request from us. Wherever we transfer, process, or store Your Personally Identifiable Information, we will take reasonable steps to protect it. We will use the information we collect from You in accordance with this Policy and any relevant rules and international standards. By using this Site, You agree to the transfers of Your Personally Identifiable Information described within this section.

Information We Collect about You from Third Parties

The Site may contain content or applications, including advertisements, which are served by third parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies to collect information about you when you use the Site. The information these third parties collect may be associated with your personal information. These third parties may also collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies, privacy policies or how your personal or non-personal information may be used by such third parties. If you have any questions about an advertisement or other targeted content, you should contact the responsible third party directly.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Site and visiting your User Account or profile page. You may also send us an e-mail at to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your User Account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you delete your User Contributions from the Site, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Site users. Proper access and use of information provided on the Site, including User Contributions, is governed by our terms of use.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to a User Account or any other parts of the Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is never completely secure. Although we do our best to protect your personal information, we cannot and do not guarantee the security of your personal information transmitted to the Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

We Store Information in the United States

Information we maintain will be stored within the United States. If you live outside of the United States, you understand and agree that we may transfer your Information to the United States.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, or to exercise any of Your rights under this Privacy Policy, contact us at: