Our commitment to you
Cleverly Limited and its affiliated companies (hereafter “Cleverly”, “us” or “we“) are dedicated to providing users with the highest level of transparency and control over the use of their information. In order for us to provide you with our services we are required to collect and process certain information about you, your equipment and your activity as is facilitated by the Cleverly system.
By entrusting us with your information, we would like to assure you of our commitment to keeping such information private. To this end, we have taken measurable steps to protect the confidentiality, security and integrity of this Information.
The basis for data collection
You are not legally required to provide us with your “Personal Data” (meaning any information which may potentially allow your identification with reasonable means) or “Business Data” (such as the amount that you pay in conducting such activities as are facilitated by the Cleverly system), but without it we might not be able to provide you with the full range of, or the best experience while using our website and App (hereinafter the “Website”, “App” and “Services” accordingly).
Processing of Personal Data is necessary for the performance of our contractual obligations towards you, for provision and operation of our Services, to protect our legitimate interests and for compliance with legal and regulatory obligations to which we are subject.
Our legal basis for collecting and using your Personal Data and Business Data will depend on the particular purpose for which your data is being processed, however, we generally use the following:
1. Performance of a contract: We will use this basis for processing necessary to make the Services, including support services, available to you, and to send you service communications.
2. Consent: In limited cases (where you choose to sign up to receive direct marketing emails, and where you accept cookies on our website) we will process your Personal Data based on your consent. You can withdraw your consent at any time by contacting us using the details provided below.
3. As part of our Services: We are required to collect data as part of our providing you with contextual information related to how you and others are undertaking activities on the system, and in the interests of saving you time and resources in the execution of such activities. These data will never be identifiable to any particular party and used solely on an aggregated and anonymous basis.
4. Legitimate interests: We will process your Personal Data based on our legitimate interests in maintaining and improving our Services, such as for the purpose of understanding how our Services are used and improving them, our customer service and support operations, and protecting and securing our users, ourselves and our Services.
5. Compliance with a legal obligation – In limited cases we may process your Personal Data where we need to do so to comply with a legal obligation e.g. which is set out in an applicable law, or if we receive an order from a court or regulatory body.
What type of data we collect?
In the course of using the Service, we may ask you to provide us with certain Personal Data to provide and improve the Service, to contact or identify you, to enable you to access certain parts of the Website, and as otherwise indicated in this Policy. We collect the following Personal Data about you:
- Registration information: your name, your mailing address, your email address, your home and work telephone number, information about your company and your position, and similar contact details.
- Information received from you: you may choose to provide us Personal Data voluntarily, such as when you contact us (via a contact form on our Services, e-mail or any other channel, including any support services), or when you provide us with your e-mail address when you sign-up to receive our newsletter or other communications.
- When using our Website: our server will collect your IP address, and information about your general location (such as city and country).
- Information from third parties: this includes information we receive from our business partners, and may include Personal Data such as your contact details (name, phone, email) as well as details pertaining to your company, your job description, etc
We also collect data about the use of our Service and the characteristics and activities of users, in order to operate it and improve it. We may collect the following non-Personal Data:
If we combine Personal Data with non-Personal Data, the combined data will be treated as Personal Data. Further Personal Data will only be stored and processed if you voluntarily provide it to us, e.g. through a contact form.
When you visit or access our Services we use (and authorize third parties to use) pixels, cookies, events and other technologies. Those allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our Services, improve our Services’ performance, perform analytics and customize your experience.
We and our advertising partners also use Tracking Technologies to collect certain data about you in order to improve our advertising practices and make ads and related marketing content we deliver more effective, relevant and enjoyable, including by deploying retargeting and ad measurement and attribution systems. Such data is pseudonymized and only includes advertising identifiers (Advertising IDs), IP addresses, and other interest-based information collected through ours or our partners’ services.
How do we use the data we collect?
- Provision of service: for the provision and improvement of our Services, including for support and to respond to your queries.
- Service announcements: we will use your Personal Data to communicate with you and to keep you informed of the latest updates to our Services and offer you service offers.
- Marketing purposes: we may use your Personal Data (such as your email address or phone number). For example, by subscribing to our newsletter you will receive tips and announcements straight to your email account. We may also send you promotional material concerning our services or our partners’ services (which we believe may interest you), including but not limited to, by building an automated profile based on your Personal Data, for marketing purposes.
- Opt-out of receiving marketing materials: You may choose not to receive our promotional or marketing emails (all or any part thereof) by clicking on the “unsubscribe” link in the emails that you receive from us.
Please note that even if you unsubscribe from our promotional or marketing emails, we may continue to send you service-related updates and notifications, or reply to your queries and feedback you provide us.
Please note that even if you opt-out, we may still use and share your Personal Data with third parties for non-marketing purposes (for example to provide our Services, fulfill your requests, communicate with you and respond to your inquiries, etc.). In such cases, the companies with whom we share your Personal Data are authorized to use your Personal Data only as necessary to provide these non-marketing services.
- Analytics, surveys and research: from time to time, we may conduct surveys or test features, and analyze the data we have to develop, evaluate and improve these features, all in order to improve our Service and think of new features for our users.
- Protecting our interests: we may use your data when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our services and protect the rights and property of Cleverly, its users and/or partners.
- Enforcing of policies: we may use your data in order to enforce our policies, including but not limited to our client agreement.
- Compliance with legal and regulatory requirements: we may use your data to investigate violations, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.
With whom do we share your data?
- Internal concerned parties: we may share your information with companies in our group, as well as our employees, in order to provide you with our services.
- Compliance with laws and law enforcement entities: we cooperate with government and regulatory officials and private parties to enforce and comply with the law. We will disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
Transfer of data outside the EEA (for EU data subjects)
Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.
How we protect your information
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your data. Your data is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees or partners on a “need to know” basis, in order to enable the carrying out of the agreement between us and the provision of our services.
While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the service, and you do so at your own risk.
We will retain your data for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, trading information, account opening documents, communications and anything else as required by applicable laws and regulations.
European Union Usersdescs:
If you reside in the EU, you may request to:
- Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
- Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
- Request rectification of your Personal Data that is in our control.
- Request erasure of your Personal Data.
- Object to the processing of Personal Data by us.
- Request to restrict processing of your Personal Data by us.