Revised as of March 16th, 2023
By accessing this Site or using the Services you acknowledge that you have read and understood this Policy and accepted the rules and conditions provided herein.
We reserve the right to make changes to this Policy at any time and for any reason. We will alert you about any changes by updating the “Revised” date of this Policy. Any changes or modifications will be effective immediately upon posting the updated Policy on the Site, and you waive the right to receive specific notice of each such change or modification.
You are encouraged to periodically review this Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Policy by your continued use of the Site after the date such revised Policy is posted.
1. INFORMATION COLLECTED
We may collect information about you in a variety of ways. The information we may collect on the Site includes:
Information we collect directly from you. We collect information directly from you when you provide it to us when You use Our Services, create an account on Our Site, or contact Us through email, telephone number or any other way.
The personal information provided by You may include the following:
Please note that we do not collect any sensitive information like racial or ethnic origin, political opinions, religious or philosophical beliefs, physical or mental health information. etc.
Information collected through automatic data collection technologies. We collect information through automatic data collection technologies like cookies and web beacons additionally to any information provided by You whenever you interact with Our Site and/or use Our Services.
Information or data obtained by us with the use of automatic data collection technologies may include:
Information collected from other sources. If you choose to register your account on Our Site with a third-party service (e.g. Google, Facebook), we may receive certain information about you from your social media provider such as your profile information. Any personal information that we collect from your social media account depends on your social media account’s privacy settings.
Payment Information. We use third-party payment providers that process your payment information in accordance with their privacy policies.
We do not store your payment information on our servers.
We may also use your payment card transaction data as shared by third-party service providers to confirm a specific transaction occurred, for example, the date and amount of your purchase and the last 4 digits of your card number so that we can verify your purchase with our records.
2. LAWFUL BASES FOR PROCESSING
We process your personal information only when we have lawful bases under applicable law.
If you are located in the EU, UK, other countries of the European Economic Area (“EEA”) or Switzerland, processing will be justified on the basis that:
If you are located in California, please see section 13 below.
If you are located in Canada, please see section 14 below.
3. PURPOSES FOR PROCESSING YOUR PERSONAL INFORMATION
We may process the personal data you provided us voluntarily for the purposes defined below:
4. PERSONAL DATA CONTROLLER
CLARKETIC OÜ legal entity incorporated under the laws of the Republic of Estonia (Registration number: 16320965) Registered address: Tornimäe tn 7-26, Kesklinna linnaosa, Tallinn, Harju maakond, Estonia, 10145 will be the controller of your personal data.
5. DATA SHARING
Third-party service providers. In order to provide Services and operate the Site We may share your data with third-party service providers, contractors, who perform services for Us such as hosting services, billing and payment processors, web analytics and performance tools services. Consistent with applicable legal requirements, we take appropriate technical and organizational measures to require third parties to adequately safeguard your personal information and only process it in accordance with our instructions.
Compliance with laws and law enforcement entities. We share personal information with law enforcement agencies, public authorities or other parties in order to respond to a subpoena or court order, judicial process or to regulatory authorities, if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes;
6. COOKIES AND OTHER TRACKING TECHNOLOGIES
Types of cookies that We use:
Essential cookies. Some cookies are essential for our service to function and cannot be switched off in our systems. They are used to enable core functionality, such as authentication, security, connection stability, etc. You can always set your browser to block or alert you about these cookies, but this may affect the Site functions.
Analytics Cookies. Analytics cookies help us know which pages are popular and how visitors move around the site. We use them to count visits, check traffic sources, and measure and improve the Site’s performance.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the sites you visit.
7. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
Your personal information will be stored no longer than is necessary for the purposes for which the personal information is processed unless a longer retention period is required or permitted by law. Generally, We retain your personal information as long as your account is active.
In case your account expires or you decide to delete your account We retain your personal data no longer than necessary to fulfill our legal obligations.
Personal Information collected when you opted in receiving marketing letters will be stored as long as you are interested in receiving our marketing emails and newsletters. We consider that you’re interested in this until you unsubscribe from the mailing list or the newsletter by clicking the respective link contained in each of our emails.
8. LINKS THIRD-PARTY SITES
9. SECURITY OF YOUR PERSONAL INFORMATION
We take technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information. We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of your personal user data and other information transmitted to us. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
10. COLLECTING PERSONAL INFORMATION FROM MINORS
Our Site and Services are not intended for use by children under the age of 18 years. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn we have collected or received personal information from a child under 18, we will delete that personal information. If you believe we might have any information from or about a child under 18, please contact us at firstname.lastname@example.org.
11. YOUR PRIVACY RIGHTS
Under applicable EU regulation, you have the following rights in respect of your personal information:
In addition to the above, you have the right to lodge a complaint with a supervisory authority for data protection.
You can make a request by contacting us by using the contact details provided in the section 15 below.
We will consider and act upon any request in accordance with applicable data protection laws. We will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested to you. We reserve the right to charge a fee where permitted by law. We will decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause Us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, We will retain where necessary certain personal information for a limited period of time for record-keeping, accounting and fraud prevention purposes.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 15 below.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided in the section 15 below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account Information. If you would at any time like to review or change the information in your account or terminate your account, you can: Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
12. CONTROLS FOR DO-NOT-TRACK FEATURES
13. CALIFORNIA RESIDENTS’ PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice. The California Code of Regulations defines a “resident” as: (1) every individual who is in the State of California for other than a temporary or transitory purpose and (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
Your Rights under the CCPA. The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:
We may deny Your deletion request if retaining the information is necessary for Us to:
Exercising Your CCPA Data Protection Rights. In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us by using the contact details provided in the section 15 below. If you are an authorized agent submitting a rights request on behalf of a California consumer you need to provide a copy of the written authorization signed by the consumer.
Verification process. Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate. We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
14. CANADA RESIDENTS’ PRIVACY RIGHTS
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
15. CONTACT US
You may contact us with any questions, clarification requests and discussion on Services provided and these Terms:
Tornimäe tn 7-26, Kesklinna linnaosa, Tallinn, Harju maakond, Estonia, 10145