Jenks Enterprises LLC dba Clearly Communicate ("Clearly Communicate," "Company," "we," "our," or "us") respects your privacy and is committed to protecting the personal information you provide through https://clearlycommunicate.com (the "Site") and our related products and services, including coaching, consulting, training, workshops, webinars, retreats, speaking engagements, digital products, memberships, and online courses (collectively, the "Services").
This Privacy Policy describes how we collect, use, disclose, store, and protect your personal information, and explains the privacy rights available to you, including rights under California law.
By using the Site or Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use the Site or Services.
Information We Collect
Information You Provide to Us
We may collect the following information when you provide it to us directly:
- Name, email address, phone number, and mailing address
- Company name and job title
- Billing information (processed by our third-party payment processors)
- Communication preferences
- Information submitted through forms, surveys, or registrations
- Coaching intake information
- Business and employment-related information voluntarily provided during consulting or coaching engagements
Information Collected Automatically
When you visit the Site, we and our service providers may automatically collect:
- IP address and approximate (city-level) location inferred from it
- Browser type and device information
- Website activity, pages viewed, and time spent on pages
- Referral URLs and session data
- Cookie identifiers and similar online identifiers
Categories of Personal Information (California)
For purposes of the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA"), the categories of personal information we have collected in the preceding 12 months are:
| Category (per CCPA) | Examples We May Collect | Collected? |
|---|---|---|
| Identifiers | Name, email address, phone number, mailing address, IP address, cookie identifiers | Yes |
| Customer records (Cal. Civ. Code § 1798.80(e)) | Name, contact information, billing information | Yes |
| Commercial information | Services or products purchased or considered; program enrollment history | Yes |
| Internet or network activity | Browsing activity on our website, pages viewed, referral URLs, session data, interactions with our ads and emails | Yes |
| Geolocation data | Approximate (city-level) location inferred from IP address | Yes |
| Professional or employment-related information | Company name, job title, role, business and employment information voluntarily provided during coaching or consulting engagements | Yes |
| Inferences | Preferences and interests inferred from your use of our website and services (e.g., for marketing) | Yes |
| Sensitive personal information | We do not seek to collect sensitive personal information. Payment card details are collected directly by our payment processors. Health-related information voluntarily shared in coaching is addressed in our Consumer Health Data Privacy Policy. | Limited |
| Biometric, audio/visual, education records | Recordings of webinars or sessions you attend may capture your voice or image, where notice is provided | Limited |
Sources of Personal Information
We collect personal information from the following sources:
- Directly from you, when you fill out forms, register for programs, purchase Services, communicate with us, or participate in coaching or consulting engagements
- Automatically, through cookies, pixels, and similar technologies when you use the Site
- From our service providers, such as payment processors, scheduling tools, and email platforms
- From advertising and analytics partners, such as Google, Meta, and LinkedIn, regarding your interactions with our content on their platforms
How We Use Your Information
We use personal information for the following business and commercial purposes:
- To provide coaching, consulting, training, workshops, webinars, retreats, and educational services
- To process payments and fulfill purchases
- To deliver digital products, memberships, and online courses
- To schedule appointments and manage engagements
- To respond to inquiries and provide customer support
- To send newsletters and marketing communications (with your consent where required, and always with the ability to opt out)
- To analyze and improve the Site, Services, and marketing performance
- To advertise our Services, including through interest-based advertising on third-party platforms
- To maintain client records and business operations
- To detect, prevent, and address fraud, security incidents, and technical issues
- To comply with legal obligations and enforce our agreements
- To protect our rights, property, and safety, and the rights, property, and safety of others
We do not use or disclose personal information for purposes materially different from those described in this Privacy Policy without providing you notice and, where required by law, obtaining your consent. We do not knowingly use personal information in a manner that requires us to provide a notice of financial incentive under California law, and we do not currently offer financial incentives in exchange for personal information.
Cookies, Analytics, and Online Tracking
We and our partners use cookies, pixels, tags, and similar technologies on the Site, including:
- Google Analytics — to understand how visitors use the Site. Learn more or opt out at tools.google.com/dlpage/gaoptout.
- Meta Pixel — to measure and improve our advertising on Meta platforms (Facebook and Instagram) and to deliver interest-based ads. You can manage your Meta ad preferences in your Facebook settings.
- LinkedIn Insight Tag — to measure and improve our advertising on LinkedIn and to deliver interest-based ads. You can manage your LinkedIn ad preferences in your LinkedIn settings.
- Essential cookies — necessary for the Site to function (e.g., shopping cart, security).
You can control cookies through your browser settings, including by blocking or deleting cookies, though some Site features may not function properly without them. You may also opt out of interest-based advertising generally through the Digital Advertising Alliance and the Network Advertising Initiative.
Opt-Out Preference Signals (Global Privacy Control) and Do Not Track
If your browser or browser extension transmits an opt-out preference signal, such as Global Privacy Control (GPC), we will treat it as a valid request to opt out of the sale or sharing of personal information for that browser, as required by California law. Other than GPC, the Site does not currently respond to "Do Not Track" browser signals, for which no industry standard has been adopted.
How We Disclose Personal Information
We may disclose each of the categories of personal information identified in Section 1 to the following categories of recipients, for the business purposes described in Section 3:
- Service providers — companies that assist our business operations, such as website hosting, email delivery, scheduling, customer relationship management, learning management platforms, and IT support, under contracts that restrict their use of your information
- Payment processors — including PayPal and QuickBooks Online (Intuit), which process payments on our behalf; we do not store complete payment card numbers on our servers
- Advertising and analytics partners — including Google, Meta, and LinkedIn, as described in Section 4
- Professional advisors — legal, accounting, and other professional advisors
- Legal and safety recipients — government authorities, courts, or other parties when required by law, subpoena, or court order, or when we believe disclosure is necessary to protect rights, safety, or property
- Business transfer recipients — in connection with a merger, acquisition, financing, reorganization, or sale of all or part of our business, your information may be transferred as a business asset, subject to this Privacy Policy
"Sale" and "Sharing" of Personal Information Under California Law
We do not sell personal information in exchange for money. However, California law defines "sale" and "sharing" broadly. Our use of third-party advertising cookies and pixels (such as the Meta Pixel and LinkedIn Insight Tag) may be considered "sharing" of personal information for cross-context behavioral advertising, or a "sale," under the CCPA. The categories involved are identifiers, internet or network activity information, and commercial information, disclosed to advertising networks and analytics providers.
You have the right to opt out of this sale/sharing at any time. See "Your Privacy Choices" in Section 6 and "Your California Privacy Rights" in Section 13. We do not knowingly sell or share the personal information of consumers under 16 years of age.
Your Privacy Choices
- Opt out of sale/sharing: Adjust your cookie preferences, enable Global Privacy Control in your browser, or email us at [email protected] with the subject line "Do Not Sell or Share."
- Marketing emails: Unsubscribe at any time using the link included in every marketing email, or by contacting us. We will continue to send transactional messages related to your purchases and engagements.
- Cookies: Manage cookies through your browser settings and the opt-out tools described in Section 4.
- Access, correction, and deletion: Submit requests as described in Sections 13 to 15.
Email and Marketing Communications
If you submit your information to us, you may receive communications regarding our services, events, educational content, promotions, and company updates. Consistent with the federal CAN-SPAM Act, our marketing emails identify us as the sender, include our valid physical postal address, and include a clear unsubscribe mechanism. We will honor opt-out requests promptly, and in any event within 10 business days. You may unsubscribe at any time using the link included in our emails or by contacting us at [email protected].
Payment Processing
Payments may be processed through third-party providers, including PayPal and QuickBooks Online (Intuit). When you make a payment, your payment card information is collected and processed directly by these providers, subject to their privacy policies and security standards. We do not store complete payment card information on our servers.
Data Security
We maintain commercially reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, and destruction. However, no website, internet transmission, or electronic storage system can be guaranteed to be 100% secure, and we cannot guarantee the absolute security of information submitted to us electronically.
Data Breach Notification
In the event of a security breach affecting personal information, we will notify affected individuals and regulators as required by applicable law, including the Washington data breach notification law (RCW 19.255), which generally requires notice to affected Washington residents within 30 days of discovery, and the California breach notification law (Cal. Civ. Code §§ 1798.29, 1798.82), as well as the laws of other applicable states.
Data Retention
We retain personal information for as long as reasonably necessary to provide the Services, meet legal, tax, and accounting obligations, resolve disputes, and enforce our agreements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process it and whether those purposes can be achieved through other means; and applicable legal requirements.
As a general matter:
- Client and engagement records are retained for the duration of the engagement plus up to 7 years for legal and tax purposes
- Marketing contact information is retained until you unsubscribe or it becomes inactive
- Website analytics data is retained according to the settings of our analytics providers, generally no longer than 26 months
When personal information is no longer needed, we delete, anonymize, or securely destroy it.
Children's Privacy
The Site and Services are intended for adults and are not directed to children. We do not knowingly collect personal information from children under 13 years of age, consistent with the federal Children's Online Privacy Protection Act (COPPA), and we do not knowingly sell or share the personal information of consumers under 16 years of age. If you believe a child has provided us with personal information, please contact us at [email protected] and we will delete it.
Third-Party Websites
The Site may contain links to third-party websites and services. We are not responsible for the privacy practices or content of those third parties, and this Privacy Policy does not apply to them. We encourage you to review the privacy policies of any third-party sites you visit.
Your California Privacy Rights
This section applies to California residents and supplements the rest of this Privacy Policy. Subject to applicable law, if you are a California resident, you have the following rights with respect to your personal information:
- Right to Know/Access: Request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purposes for collecting, selling, or sharing it, and the categories of third parties to whom we disclose it.
- Right to Delete: Request that we delete personal information we have collected from you, subject to certain exceptions.
- Right to Correct: Request that we correct inaccurate personal information.
- Right to Opt Out of Sale/Sharing: Direct us not to sell or share your personal information, including sharing for cross-context behavioral advertising. See Section 6 for how to exercise this right, including via Global Privacy Control.
- Right to Limit Use of Sensitive Personal Information: We do not use or disclose sensitive personal information for purposes that would trigger the right to limit under the CCPA; if that changes, we will update this Policy and provide the required "Limit the Use of My Sensitive Personal Information" link.
- Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.
- Right to Data Portability: Request a copy of your personal information in a portable and readily usable format.
How to Submit a Request
You may submit a request by emailing [email protected] with the subject line "Privacy Rights Request." We will confirm receipt of your request within 10 business days and respond within 45 calendar days, which may be extended once by an additional 45 days where reasonably necessary, in which case we will notify you of the extension.
Verification and Authorized Agents
To protect your information, we will take reasonable steps to verify your identity before fulfilling a request, which may include matching information you provide against information we maintain. You may designate an authorized agent to submit a request on your behalf; we may require proof of the agent's authority (such as a signed permission or power of attorney) and may still require you to verify your own identity.
California "Shine the Light"
California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.
Washington Residents and Consumer Health Data
Washington's My Health My Data Act (RCW 19.373) provides rights to consumers with respect to "consumer health data," which is defined broadly and may include health-related information voluntarily shared during coaching or consulting (for example, information about stress, burnout, or wellbeing). Our collection and handling of consumer health data, and the rights available to Washington consumers (including the rights to access, withdraw consent, and delete consumer health data, and to appeal our decisions), are described in our separate Consumer Health Data Privacy Policy, available by request at [email protected].
Other U.S. State Privacy Rights
Residents of other states with comprehensive privacy laws (such as Colorado, Connecticut, Virginia, Texas, and Oregon) may have similar rights to access, correct, delete, and opt out of certain processing of their personal information, including targeted advertising, where those laws apply. Although our business may fall below the applicability thresholds of some of these laws, you may submit a request as described in Section 13 and we will respond in accordance with applicable law.
If we decline to act on your request and your state's law provides an appeal right, you may appeal by replying to our decision, and we will respond to your appeal within the period required by your state's law.
International Users
The Site and Services are operated from the United States and are intended for users located in the United States. If you access the Site from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction.
Changes to This Privacy Policy
We may update this Privacy Policy periodically. The "Last Updated" date at the top indicates when this Policy was last revised. Changes become effective upon posting. If we make material changes, we will provide notice on the Site or by email (where we have your address) before the changes take effect.
Accessibility
If you have a disability and need to access this Privacy Policy in an alternative format, please contact us using the information below and we will provide it.
Contact Information
Jenks Enterprises LLC dba Clearly Communicate
510 Lakeway Drive, Bellingham WA 98225
Email: [email protected]
Website: https://clearlycommunicate.com