This Privacy Policy (“Policy”) describes how Clairvoyant Networks, Inc. d/b/a Theora Care (“Clairvoyant”, “Theora Care”, the “Company”, “we”, “our”, or “us”) collects, uses, discloses, stores, and otherwise processes your Personal Data in connection with our Website, marketing activities, business interactions, and other circumstances in which we process Personal Data for our own purposes, including certain interactions with the Theora Care platform (the “Platform”) and related services (collectively, the “Services”).

This Policy applies to Personal Data that we collect and process on our own behalf, including Personal Data collected through our Website, marketing activities, and direct interactions with Users. This Policy does not apply to Personal Data contained in Customer Data that we process solely on behalf of our Customers in connection with the Services; such processing is governed by the applicable agreement with the Customer and applicable law.

By accessing or using the Services, you acknowledge that you have read and understood this Policy.

 

Personal Data Consent; Withdrawal

We process Personal Data as described in this Policy and in accordance with applicable law. Where applicable law requires your consent to a particular processing activity, we will obtain such consent as required. Where processing is based on your consent, you may withdraw that consent by contacting us using the information provided below, subject to applicable legal or contractual limitations.

 

Definitions

In this policy:

“Customer(s)” means the individual or entity that enters into an agreement with Theora Care for the Services.

“Customer Data” means information, content, records, files, or other materials that a Customer or its Users submit, transmit, upload, import, or otherwise make available through the Services, or that are collected or generated through a Customer’s or its Users’ use of the Services on behalf of the Customer. For purposes of this Policy, Customer Data does not include Personal Data that Theora Care processes for its own purposes and that is otherwise covered by this Policy.

“Personal Data” means information that identifies, relates to, describes, or can reasonably be linked to a particular individual, and includes information referred to as “personal information,” “personal data,” or similar terms under applicable data privacy laws. For purposes of this Policy, Personal Data does not include Customer Data that Theora Care processes through the Services solely on behalf of a Customer.

“User” or “you” means an individual who interacts with the Services, including an authorized user of a Customer account or a visitor to our Website. A Website visitor is a User even if the visitor is not a Customer or authorized user of the Platform. Personal Data that we collect from a User through our Website, marketing activities, or other interactions in which we process such information for our own purposes is covered by this Policy and is not treated as Customer Data solely because the individual is also associated with a Customer.

 

What Kind of Personal Data Is Collected?

• Personal Data you provide to us. This may include your name, address, email address, telephone number, account information, payment-related information, and other information you voluntarily provide when you interact with our Website, request a demo, communicate with us, or otherwise interact with us.
• Personal Data collected automatically. When you interact with our Website or other portions of the Services covered by this Policy, we may automatically collect information such as:
• browsing and navigation activity;
• search queries and interactions with Website content;
• IP address;
• browser type and operating system;
• device identifiers and device information;
• referring URLs; and
• dates, times, and information regarding your interactions with our Website.

Personal Data contained in Customer Data that we process solely on behalf of a Customer is outside the scope of this Policy.

How Do We Collect Your Personal Data?

We may collect Personal Data covered by this Policy:

1. Directly from you — when you complete a form, request a demo, communicate with us, subscribe to marketing communications, contact support, create or administer an account where we process such information for our own purposes, or otherwise interact with us.
2. Automatically — through cookies, analytics technologies, and similar technologies when you interact with our Website or other portions of the Services covered by this Policy.
3. From third parties — where permitted by applicable law, including service providers, business partners, referral sources, and publicly available sources.

Information We Collect Through Automatic Data Collection Technologies 

The technologies we use for this automatic data collection may include:

• Web Beacons. Pages of our website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related website statistics.
• Analytics Tools. We use analytics tools provided by our Analytic Partners, including Google Analytics, to help us understand website traffic, usage patterns, referral sources, and interactions with our Services. We use Google Analytics only on public marketing websites.

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. We and our Analytic Partners may use cookies, pixels, tags, software development kits, local storage, and similar technologies to automatically collect information about your interactions with our Services. These technologies may collect information such as your IP address, device identifiers, browser type, operating system, referring URLs, pages viewed, links clicked, time spent on pages, and other information about how you access and use the Services. We use these technologies to operate the Services, understand visitor activity, measure performance, improve user experience, and analyze the effectiveness of our marketing efforts. We respect “Do Not Track” signals where required by law. Most web browsers automatically accept cookies. You can modify your browser settings to decline cookies, delete existing cookies, or be notified when a cookie is set. If you disable cookies, some Services may not function properly.

How Is Collected Personal Data Used?

• User Experience: The collected Personal Data is used to improve the user experience for people like you who interact with the Services. The Personal Data is used internally to study and analyze how the site is used so that it’s overall design and functionality may be tested and the user experience improved.
• Security and Legal: Collected Personal Data may be used (i) to enforce the Terms of Service; (ii) to investigate potential violations of our terms and policies; (iii) to detect, prevent, or otherwise address fraud, security or technical issues; (iv) to protect against harm to the rights, property or safety of our users or the public as required or permitted by law.

How Do We Protect Your Personal Data?

• We maintain administrative, technical, and physical safeguards designed to protect Personal Data against unauthorized access, disclosure, alteration, and destruction, including encryption of data in transit and at rest, access controls, and monitoring.
• No system is completely secure, however, and we cannot guarantee the security of information transmitted to or from the Services. 
• You are responsible for maintaining the confidentiality of your account credentials

 

Do we share your Personal Data With Others?

We may disclose Personal Data covered by this Policy:

• with your consent or at your direction;
• to service providers that perform services on our behalf, such as hosting, analytics, communications, marketing, payment processing, customer support, security, and other business operations;
• to professional advisers, including legal, accounting, insurance, and similar advisers;
• where reasonably necessary to comply with applicable law, legal process, or governmental requests;
• to investigate or prevent fraud, security incidents, technical issues, or violations of our terms or policies;
• to protect the rights, property, or safety of Theora Care, our Users, or others; or
• in connection with an actual or proposed merger, acquisition, financing, reorganization, sale of assets, or other business transaction.

We do not sell your Personal Data.

Data Retention

We retain Personal Data only as long as necessary to provide the Services, comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Active account data: retained for the duration of the account relationship.
• Marketing contact data: retained until you unsubscribe or request deletion.
• Server logs and security telemetry: retained for ninety (90) days.

When Personal Data is no longer needed, we delete or de-identify it using industry-standard methods within a commercially reasonable period, subject to this Policy, and subject to applicable legal, regulatory, contractual, and operational requirements.

 

Contact Us; How to Request Deletion of Your Personal Data

You may request deletion of your account and the personal data associated with it at any time by contacting us at [email protected]. Please include the email address (or phone number) associated with your account so we can locate and verify the request.

From the moment we receive your request until deletion is complete, your Personal data continues to be protected by this Policy and is not used for any purpose other than completing the deletion and meeting our legal obligations.

We may retain limited Personal Data as required by law, regulation, or our legitimate business needs (such as fraud prevention, tax records, or pending legal matters), provided that retained Personal Data continues to be protected by this Policy

We will respond as soon as reasonably practicable and within the timeframes required by applicable law.

Your Rights and Choices

Depending on your jurisdiction, you may have rights regarding your Personal Data, including:

1. The right to access the Personal Data we hold about you.
2. The right to correct inaccurate or incomplete information.
3. The right to request deletion of your Personal Data (see Contact Us, above).
4. The right to receive your Personal Data in a portable format and transmit it to another controller.
5. The right to opt out of marketing communications.
6. The right to withdraw consent where processing is based on consent.
7. The right to object to processing in certain circumstances.
8. The right not to receive discriminatory treatment for exercising these rights.

To exercise these rights, submit a verifiable request to [email protected] providing: (a) information sufficient to identify you; (b) reasonable proof of your identity; and (c) a description of the right or information your request relates to. We will respond as soon as reasonably practicable and within the timeframes required by applicable law.

You may also at any time:

• Update or modify your account information by logging in and visiting your account settings.
• Opt-out of marketing communications (see Contact Us, above)
• Manage cookies through your browser settings (see Information We Collect Automatically, above).

Use of the Services by Minors

Our Website and marketing activities are not directed to children under the age of 18, and we do not knowingly collect Personal Data covered by this Policy directly from children under 18 for our own purposes.

The Services may, however, be used by or on behalf of minors where authorized by the applicable Customer, parent, guardian, or other authorized representative, as applicable. Personal Data relating to minors that is contained in Customer Data and processed by Theora Care on behalf of a Customer through the Services is outside the scope of this Policy and is governed by the applicable Customer agreement and applicable law.

Changes to This Policy

We reserve the right to update this Policy from time to time, as may be reasonably necessary. The “Last Updated” date at the top of this Policy reflects the date of the most recent revision.

 

California Privacy Rights

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. To make such a request, please contact [email protected]

 

Other State/Jurisdiction Privacy Rights

Depending on where you live and subject to applicable law, you may have certain rights regarding your Personal Data. These rights may include the right to:

1. confirm whether we process your Personal Data and access such Personal Data;
2. correct inaccuracies in your Personal Data;
3. request deletion of your Personal Data;
4. obtain a copy of your Personal Data in a portable and readily usable format;
5. opt out of the processing of your Personal Data for purposes such as targeted advertising, the sale of Personal Data, or certain profiling in furtherance of decisions that produce legal or similarly significant effects (note that Theora Care does not sell your Personal Data);
6. limit or opt out of certain uses or disclosures of sensitive Personal Data, where applicable; and
7. appeal our decision if we deny your privacy rights request.

These rights may apply to residents of states/jurisdictions with consumer privacy laws, including but not limited to, as applicable, residents of Canada, Mexico, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia.

Last Updated: August 20, 2026

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