Privacy Policy

Clearview Data Management by Hough & Associates
Last Updated: February 21, 2026

Clearview Data Management by Hough & Associates ("we," "us," or "our") is committed to protecting the privacy of our users and the data processed through our qualitative data analysis platform. This Privacy Policy explains how we collect, use, store, and protect your information.

1. Information We Collect

We collect the following categories of information:

Account Information: Username, email address, and encrypted password required for platform access.
Survey Responses: Open-ended and structured survey data uploaded by authorized users for qualitative analysis, including response text, timestamps, and associated metadata.
Participant Demographics: Demographic information associated with survey participants, such as job title, department, years of service, generation, quota quintile, and geographic region.
Qualitative Analysis Data: AI-generated themes, sentiment scores, code books, action plans, and other analytical outputs derived from survey data.
Usage Data: Session information, page visits, and interaction patterns collected through analytics tools.

2. Data Encryption and Security

We employ industry-standard security measures to protect your data:

Field-Level Encryption: Sensitive participant data, including names, email addresses, and other personally identifiable information (PII), is encrypted at the field level using Fernet symmetric encryption before storage in our database.
Transport Security: All data transmitted between your browser and our servers is encrypted using TLS/SSL protocols.
Session Security: User sessions are protected with HTTP-only, secure cookies with SameSite attributes and automatic expiration.
CSRF Protection: Cross-Site Request Forgery tokens are implemented on all forms to prevent unauthorized actions.
Password Security: User passwords are hashed using secure one-way hashing algorithms and are never stored in plaintext.

3. How We Use Your Information

We use the information we collect for the following purposes:

Providing and operating the qualitative data analysis platform.
Processing and analyzing survey data to generate themes, codes, sentiment analysis, and action plans.
Authenticating users and managing access controls.
Generating reports, whitepapers, and data exports.
Improving the platform through usage analytics.
Communicating with users about account and service matters.

4. Data Retention and Deletion

We retain your data for as long as your account is active or as needed to provide our services. You may request deletion of your data at any time by contacting us at the email address listed below.

Account Data: Retained for the duration of the account and deleted upon request or account termination.
Survey and Analysis Data: Retained per the terms of the service agreement with the data owner. Data can be archived or permanently deleted upon request.
Usage Logs: Retained for up to 12 months for operational and security purposes.

5. Lawful Basis for Processing

Under the GDPR and applicable data protection laws, we process personal data based on the following lawful bases:

Consent: Where you have given explicit consent for processing, such as accepting cookies or agreeing to receive communications. You may withdraw consent at any time by contacting us or adjusting your cookie preferences.
Contract Performance: Processing necessary to fulfill our contractual obligations, including providing Platform access, processing survey data, and generating analysis outputs.
Legitimate Interests: Processing necessary for our legitimate business interests, such as improving the Platform, ensuring security, and preventing fraud, provided these interests do not override your fundamental rights and freedoms.
Legal Obligations: Processing necessary to comply with applicable laws, regulations, or legal proceedings.

6. AI Data Processing

Our Platform uses artificial intelligence (AI) to process survey data. The following details apply to AI-powered data processing:

Purpose: AI is used for qualitative analysis including theme extraction, sentiment analysis, code book generation, and action plan creation.
Data Transmitted: Survey response text and associated metadata may be transmitted to our AI processing partner (OpenAI) via secure API connections. We do not transmit account credentials or passwords to third-party AI services.
Data Minimization: We send only the minimum data necessary for analysis. Personally identifiable information is stripped or anonymized before AI processing where technically feasible.
Automated Decision-Making: AI-generated outputs (themes, sentiment scores, action plans) are provided as analytical tools and do not constitute automated decisions with legal or similarly significant effects on individuals. Human review and oversight remain integral to the analysis process.
Opt-Out: Data owners may request that their survey data not be processed by AI services by contacting us at the email address below.

7. GDPR Compliance

For users in the European Economic Area (EEA), we comply with the General Data Protection Regulation (GDPR). Under the GDPR, you have the following rights:

Right to Access: You may request a copy of the personal data we hold about you.
Right to Rectification: You may request correction of inaccurate or incomplete personal data.
Right to Erasure ("Right to Be Forgotten"): You may request deletion of your personal data where there is no compelling reason for continued processing. Upon receiving a verified erasure request, we will delete your personal data from our systems within 30 days, unless retention is required by law.
Right to Restrict Processing: You may request restriction of processing of your personal data under certain circumstances.
Right to Data Portability: You may request a machine-readable copy of your personal data for transfer to another service. We provide data export functionality in CSV, Excel, and PDF formats.
Right to Object: You may object to the processing of your personal data where we rely on legitimate interests as the legal basis.
Right Regarding Automated Processing: You have the right not to be subject to decisions based solely on automated processing, including profiling, which produce legal or similarly significant effects.

To exercise any of these rights, please contact us at admin@houghandassociates.com. We will acknowledge your request within 72 hours and respond substantively within 30 days. If additional time is required due to the complexity of the request, we will notify you of the extension within the initial 30-day period.

8. CCPA Compliance

For California residents, we comply with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). Under these laws, you have the following rights:

Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you, the sources of that information, the business purposes for collecting it, and the categories of third parties with whom we share it.
Right to Delete: You may request deletion of your personal information, subject to certain exceptions required by law.
Right to Correct: You may request correction of inaccurate personal information that we maintain about you.
Right to Opt-Out of Sale: You may opt out of the sale of your personal information. We do not sell personal information and have not sold personal information in the preceding 12 months.
Right to Limit Use of Sensitive Personal Information: You may request that we limit our use of sensitive personal information to purposes necessary to provide our services.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights. You will not receive different pricing, quality of service, or access levels for exercising your privacy rights.

Categories of Personal Information Collected: Identifiers (name, email), professional information (job title, department), internet activity (usage data, session information), and inferences drawn from the above (AI-generated analysis).

To exercise any of these rights, please contact us at admin@houghandassociates.com. We will verify your identity before processing your request and respond within 45 days.

9. Cookies and Tracking

Our platform uses cookies and similar technologies for the following purposes:

Essential Cookies: Required for platform functionality, including session management, authentication, and CSRF protection.
Analytics Cookies: Used to understand how users interact with the platform, helping us improve the user experience.
Preference Cookies: Store user preferences such as theme selection (light/dark mode).

You may manage your cookie preferences through your browser settings. Disabling essential cookies may affect platform functionality.

10. Third-Party Services

We use the following third-party services in the operation of our platform:

OpenAI: We use OpenAI's API for AI-powered qualitative data analysis, including theme extraction, sentiment analysis, code generation, and action plan creation. Survey data may be transmitted to OpenAI for processing. OpenAI's data usage policies apply to data processed through their API.
Hotjar: We use Hotjar for analytics and user experience insights, including heatmaps and session recordings. Hotjar may collect anonymized usage data and interaction patterns. For more information, see Hotjar's Privacy Policy.
SendGrid: We use SendGrid for transactional email delivery, including account notifications and deployment status updates. Email addresses are shared with SendGrid for the purpose of email delivery.

11. Data Sharing

We do not sell your personal information. We may share data in the following limited circumstances:

With third-party service providers as described in Section 8, solely for the purposes of operating the platform.
When required by law, regulation, or legal process.
To protect the rights, safety, or property of our users, ourselves, or the public.

12. Multi-Tenant Data Isolation

Our platform operates on a multi-tenant architecture. Each tenant's data is logically isolated, ensuring that survey data, analysis results, and user information belonging to one organization cannot be accessed by another. Tenant-level access controls are enforced at both the application and database layers.

13. International Data Transfers

Our Platform infrastructure and third-party service providers may process data in locations outside your country of residence, including the United States. When personal data is transferred internationally, we ensure appropriate safeguards are in place:

Standard Contractual Clauses (SCCs): We use EU-approved Standard Contractual Clauses where required for transfers from the EEA to countries that have not received an adequacy decision from the European Commission.
Data Processing Agreements: We maintain Data Processing Agreements (DPAs) with all third-party sub-processors that handle personal data on our behalf, ensuring they provide adequate data protection safeguards.
Adequacy Decisions: Where possible, we transfer data to countries that have received adequacy decisions from the relevant data protection authorities.

Organizations requiring a Data Processing Agreement may request one by contacting us at admin@houghandassociates.com.

14. Data Subject Rights Requests

We provide multiple ways for you to exercise your data privacy rights:

Data Export: Authorized users can export their survey data, analysis results, and reports directly through the Platform's export functionality in CSV, Excel, and PDF formats.
Account Deletion: You may request complete deletion of your account and all associated data by contacting us. Upon verification of your identity, we will process the deletion within 30 days and provide written confirmation.
Data Access Request: You may request a comprehensive report of all personal data we hold about you by emailing admin@houghandassociates.com.
Data Correction: You may update your account information through your profile settings or by contacting us for corrections to other data.

All data subject requests will be verified for identity before processing. We do not charge a fee for processing reasonable requests. For manifestly unfounded or excessive requests, we may charge a reasonable administrative fee or refuse the request.

15. Children's Privacy

Our platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal data from a child, we will take steps to delete that information promptly.

16. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of individuals, we will:

Notify the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by the GDPR.
Notify affected individuals without undue delay if the breach is likely to result in a high risk to their rights and freedoms.
Document all breaches, including their effects and remedial actions taken.
Cooperate with regulatory authorities during any investigation.

17. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify users of significant changes by posting a notice on the platform or by email. Your continued use of the platform after changes are posted constitutes acceptance of the updated policy.

18. Contact Information

If you have questions, concerns, or requests related to this Privacy Policy or our data practices, please contact us at:

Clearview Data Management by Hough & Associates
Email: admin@houghandassociates.com