Privacy Policy

Effective as of: 15.07.2023.

Your privacy is extremely important to us. As such, we aim to inform you about our online information practices and give you options regarding the way your information is collected and used. This Privacy Policy relates to the information collected by Cliper (referred to in this Privacy Policy as "Cliper" "we" or "us" or "our") through your use of our website and our platform, as well as Services, features, and information available on our website (which are collectively referred to in this Privacy Policy as the "Cliper Service").

Scope of this Privacy Policy

Please be aware that this Privacy Policy does not govern all the information Cliper may process. Our commitment to customers and service providers is governed by a separate Data Protection Addendum.

This Privacy Policy is also incorporated into and governed by our Terms of Use.

Our commitments to employees are governed by our internal employment policies.

We are committed to transparency with our customers, employees, and to protecting your data privacy in all instances.

What Information do we Collect?

You will be required to establish an account in order to take advantage of certain features of the Cliper Service. If you wish to establish an account you will be required to provide us with information (including personally identifiable information and non-personally identifiable information). In addition, we may obtain your personally identifiable information from you if you identify yourself to us by sending us an e-mail with questions or comments.

Depending on your use of the Cliper Service, we collect two types of information: personally identifiable information and non-personally identifiable information.

Personally Identifiable Information

Personally identifiable information identifies you or can be used to identify or contact you (for example: your name, IP address, company name, job title, address, e-mail address, telephone number, and billing and credit card information).

Non-Personally Identifiable Information

Non-personally identifiable information is information, any single item of which, by itself cannot be used to identify or contact you (for example: demographic information - age, profession, company industry, gender, current location, or zip code - IP addresses, browser types, domain names, and statistical data) involving the use of the Cliper Service. Certain non-personally identifiable information may be considered a part of your personally identifiable information if it were combined with other identifiers (for example: combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered non-personally identifiable information when they are taken alone or combined only with other non-personally identifiable information (for example: your account preferences).

Why do we Need your Personal Data

We do not sell any data, including your personal data. We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to Cliper. If you registered with us, you will have been asked to check a tick box indicating your agreement to provide this data to access our services. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this policy, please do not use our platform.

Information we collect automatically when you use the Services:

We collect information about you when you use our Services, including browsing our websites and apps and taking certain actions within the Services.

Your use of the Services: We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use; frequently used search terms; channels that you follow; as well as number of video notifications received and opened, generally and per channel.

Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services.

Cookies and Other Tracking Technologies: Cliper and our third-party partners, such as our advertising and analytics partners, use cookies and other tracking technologies (web beacons, device identifiers and pixels) to provide functionality and to recognize you across different Services and devices. For more information, please see our Cookies and Tracking policy, which includes information on how to control or opt out of these cookies and tracking technologies.

Log files: We collect non-personally identifiable information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Cliper Service. This information may be used to analyze trends, to administer the Cliper, to monitor the use of the Cliper Service, and to gather general demographic information. We may link this information to personally identifiable information for these and other purposes, such as personalizing your experience on the Cliper Service, and evaluating the Cliper Service in general.

Information we receive from other sources

We receive information about you from other Service users, from third party services, and from our business and channel partners.

Other services you link to your account: We receive information about you when you enable third-party apps or integrate or link a third-party service with our Services. The information we receive when you link your account with a third-party service depends on the settings, permissions and privacy policy controlled by that third-party service. You should always check the privacy settings and notices in these third-party services to understand what data may be disclosed to us or shared with our Services.

Other partners: We receive information about you and your activities on and off the Services from third-party partners, such as advertising and market research partners who provide us with information about your interest in, and engagement with, our Services and online advertisements.

Cliper's use of information received, and Cliper's transfer of information to any other app, will adhere to Google's API Services User Data Policy, including the Limited Use Requirements.

Your Rights

Where and when is information collected? You may contact us anytime to opt-out of:

1. Direct marketing communications;

2. Automated decision-making and/or profiling;

3. Our collection of sensitive personal data; or

4. Any new processing of your personal data that we may carry out beyond the original purpose. Please note that your use of some of the platform may be ineffective upon opt-out.

Access: You may access the data we hold about you at any time by contacting us directly.

Amend: You can contact us to update or correct any inaccuracies in your personal data.

Erase and Forget: In certain situations, for example when the data we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

You may contact us at contact@cliper.co anytime for any questions you may have about your personal data and our use of such personal data.

Where will Data be Transferred to?

Your data, including personal data that we collect from you, may be transferred to, stored at and processed by us and other third parties outside the country in which you reside, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our platform, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy. Your team's project and task data will never be transferred to third parties. The only data we share with third parties is for analytics, error tracking, and marketing.

How Long will Data be Stored?

We will only retain your personal data as long as reasonably required for you to use the Site/Application(s) and/or to provide you with the Services unless a longer retention period is required or permitted by law (for example, for regulatory purposes).

Do we Collect Information from Children under 16 years of age?

We are committed to protecting the privacy of children. The Cliper Service is not designed for or directed to children under the age of 16. We do not collect personally identifiable information from any person we know is under the age of 16.

What do we do with the information we Collect?

We use the information collected to provide you with a great overall experience using the Cliper Service, to help us understand who uses the Cliper Service, for internal operations such as operating and improving the Cliper Service, to contact you for customer service and billing purposes, and to facilitate the delivery of our advertising.

We use your information to send you a welcome e-mail after you create an account, when you are invited to Cliper, or when you sign up for a demo, webinar or to receive our newsletter. We also use your information to send other e-mail communication related to the Cliper website and apps. We always give you the option to unsubscribe in any email we send you.

We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Cliper Service. We may link some of this information to personally identifiable information for internal purposes or to improve your experience with the Cliper Service.

When do we Disclose Information to Third Parties?

Except as set forth in this Privacy Policy, the Cookie Policy, or the Cliper Data Protection Addendum or as specifically authorized by you, we will not disclose any information to third parties outside of Cliper.

Laws and Legal Rights

We may disclose your information (including personally identifiable information) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, or other valid legal process. We may disclose personally identifiable information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be violating our Terms of Service, to detect fraud, or to protect the safety and/or security of our users, the Cliper Service or the general public. We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Outside Contractors

We may employ independent contractors, vendors and suppliers (collectively, "Outside Contractors") to provide specific services and products related to the Cliper Service, such as hosting, credit card processing and fraud screening, and mailing list hosting for the Cliper Service. In the course of providing products or services to us, these Outside Contractors may have access to information collected through the Cliper Service, including your personally identifiable information. We require that these contractors agree to:

1. Protect the privacy of your personally identifiable information consistent with this Privacy Policy or the Data Protection Addendum, and

2. Not use or disclose your personally identifiable information for any purpose other than providing us with the products or services for which we contracted or as required by law. Please see our Data Protection Addendum for more information about sub-processors.

Sale of Business

We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of Cliper or any of its Corporate Affiliates (as defined herein), or that portion of Cliper or any of its Corporate Affiliates to which the Service relates, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding, provided that the third party agrees to adhere to the terms of this Privacy Policy.

Affiliates

We may disclose information (including personally identifiable information) about you to our Corporate Affiliates. For purposes of this Privacy Policy, "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under common control with Cliper, whether by ownership or otherwise. Any information relating to you that we provide to our Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.

Does this Privacy Policy apply when I link to other websites and apps or services?

The Cliper Service may provide you with access to other websites and apps and services. Please be aware that we are not responsible for the privacy practices of any websites and apps or services other than the Cliper Service. We encourage you to read the privacy policies or statements of each and every such website and service. This Privacy Policy applies solely to information collected by us through the Cliper Service.

Is the information collected through the Cliper Service secure?

We take precautions to protect the security of your information. We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your information. However, neither people nor security systems are foolproof, including encryption systems. In addition, people can commit intentional crimes, make mistakes or fail to follow policies. If applicable law imposes any non-disclaimable duty to protect your personally identifiable information, you agree that intentional misconduct will be the standards used to measure our compliance with that duty.

Could my Information be Transferred to other Countries?

Personally identifiable information collected on the Cliper Service may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and the Cliper Service may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such data. To the fullest extent allowed by applicable law, by using the Cliper Service and submitting such information on it, you voluntarily consent to the trans-border transfer and hosting of such information. To the fullest extent allowed by applicable law, if you are a User accessing the Cliper Service from a jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from those of Croatia, please be advised that all aspects of the Cliper Service are governed by the internal laws of Republic of Croatia, regardless of your location.

EU-U.S. Privacy Shield Framework

Cliper complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. We have certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Program, and to view our certification page, please visit https://www.privacyshield.gov/.

In compliance with the EU-US Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Cliper at contact@cliper.co.

We have further committed to cooperate with EU Data Protection Authorities (DPAs) with regard to unresolved Privacy Shield complaints. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.

As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints that are not resolved by other means set forth above.

In cases of onward transfer to third parties of Personal Data received pursuant to the EU-US Privacy Shield, Cliper is potentially liable. Please see our DPA (Data Protection Authorities) for more details.

What Choices do I have regarding the Collection, Disclosure and Distribution of Personally Identifiable Information?

Except as otherwise described in this Privacy Policy or in the Data Protection Addendum, we will only use personally identifiable information for the purposes described above, or as otherwise disclosed at the time we request such information from you. You must "opt in" and give us permission to use your personally identifiable information for any other purpose. You may also change your preference and "opt out" of receiving certain marketing communications from us by clicking the unsubscribe link included at the bottom of all such communications, or by contacting us via email.

Do Not Track

The term "Do Not Track" refers to a HTTP header offered by certain web browsers to request that websites and apps refrain from tracking the user. We take no action in response to Do Not Track requests.

Can I update or correct my personally identifiable information?

You can contact us in order to:

1. Update or correct your personally identifiable information,

2. Change your preferences with respect to communications and other information you receive from us, or

3. Delete the personally identifiable information maintained about you in our systems (subject to the following paragraph), by deleting your account. Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. Promptly after receiving your request, all personal information stored in databases we actively use, and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as and to the extent reasonably and technically practicable.

How will I know if there are any changes to this Privacy Policy?

We may revise this Privacy Policy from time to time. We will not make changes that result in significant additional uses or disclosures of your personally identifiable information without notifying you of such changes via email. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your personally identifiable information, for which an email is not required. We encourage you to check this page periodically for any changes. If any non-significant changes to this Privacy Policy are unacceptable to you, you must immediately contact us and, stop using the Cliper Service until the issue is resolved. Your continued use of the Cliper Service following the posting of non-significant changes to this Privacy Policy constitutes your acceptance of those changes.

Whom do I Contact if I have any Privacy Questions?

If you have any questions or comments about this Privacy Policy or feel that we are not abiding by the terms of this Privacy Policy, please contact our Privacy Agent via email at contact@cliper.co.

Subject to the next paragraph, we ask that you not send or disclose to us any sensitive personal data (for example: social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics, or genetic characteristics, criminal background or trade union membership) on or through [the Site/Applications(s)/Services] or otherwise.

If you send or disclose any sensitive personal data to us when you submit user-generated content to [our Site/Application(s)/Services], you consent to our processing and use of such sensitive personal data in accordance with this policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user generated content to our platform.

By using the Cliper Service, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not use the Cliper Service. Continued use of the Cliper Service following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your personally identifiable information will mean that you accept those changes.