This privacy policy (“Privacy Policy”) governs how we, Twtrland, Ltd (“Klear” “we”, “our” or “us”) use, collect and store information pertaining to you (“User”, “you”) in the following use cases:(i) When you make use of our website www.klear.com (“Website”); (ii) When you sign up as an “influencer” in our Website; (iii) When you provide us with your Personal Data via/through any of the forms made available by us; and (iv) When you request a demo. We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data” means any information that can be used, alone or together with other data, to uniquely identify any living human being.
When You Visit our Websites - You are free to explore the Websites without providing any Personal Information about yourself. When you visit the Websites or register for the Subscription Service, we request that you provide Personal Information about yourself, and we collect Navigational Information.
"Personal Information" -
This refers to any information that you voluntarily submit to us (like when you request a demo or signup as an influencer) and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, social accounts, brand co-operations, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers. Personal Information also includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual. Navigational information refers to information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. We collect and process payment information from you when you subscribe to the Subscription Service, including credit cards numbers and billing information, using third party PCI-compliant service providers. Except for this, we do not collect Sensitive Information from you. We save this information unless you withrdraw consent. The legal basis is consent and we save the information until you withdraw consent.
Log Files - When you use our services our view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by Klear for the operation of the Subscription Service, to maintain quality of the Subscription Service, and to provide general statistics regarding use of the Klear Website. For these purposes, we do link this automatically-collected data to Personal Information such as name, email address, address, and phone number. The legal basis is legitimate interest and we save the information for 12 months.
Information we collect from third parties - From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and publicly available sources such as social media websites.
HOW WE PROTECT AND STORE YOUR INFORMATION
I. Security.
We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
II. Retention of your Personal Data.
In addition to the retention periods mentioned in Section 1 above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.
HOW WE SHARE YOUR PERSONAL INFORMATION
In addition to the recipients described in Section 1, we may share your information as follows:
o To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. Merger, Sale or Bankruptcy. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.
o Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
o Service Providers - We employ other companies and people to provide services to visitors to our Websites, our customers, and users of the Subscription Service and may need to share your information with them to provide information, products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data or performing statistcal analysis, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service or support. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.
o Klear Partners - In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information. We partner with trusted third parties to provide you with co-marketing content that we think may be relevant to you. When you engage with these co-marketing partners, we will tell you who we are sharing data with, and provide a link to the co-marketing partner’s privacy policy so you can learn more about how to opt-out of the partner’s communications. These co-marketing partners are required to adhere to our privacy and data protection policies. For more information on our co-marketing program, see this page.
o Corporate Events - If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Klear on the Websites and the Subscription Service. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
o Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION
Where we transfer your Personal Data outside of Klear, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data.
Some of these assurances are well recognized certification schemes like the EU - US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States; or
Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.
YOUR RIGHTS
The following rights (which may be subject to certain exemptions or derogations), shall apply to individuals who are protected by the GDPR:
You have a right to access information held about you. Your right of access is normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
You have the right to request that we amend any Personal Data we hold that it is inaccurate or misleading.
o You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;
o The right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
o The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
o You have the right to object to profiling;
o You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority
o The right to withdraw your consent. Please note that t there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.
o You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.
You can exercise your rights by contacting us at privacy@klear.com.
Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
USE BY CHILDREN
We do not offer our products or services for use by children. If you are under 18, you may not use the Website, or provide any information to the Website without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.
CONTACT US
If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@klear.com.
