WizRocket Inc. (a Delaware corporation) and its affiliates doing business as CleverTap (“CleverTap,” “we,” “us,” or “our”). CleverTap provides customers (“Customers”) with an online cloud-hosted solution providing them with the ability to analyze how their end users (“Customer End Users”) interact with Customers’ websites or mobile applications and contact Customer End Users via CleverTap’s platform (the “Service”)
CleverTap is committed to respecting your privacy and protecting your personal data. This privacy notice will inform you about CleverTap’s roles in managing personal data, the categories of personal data it collects, their sources, the purposes for using personal data, its practices in disclosing personal data, and how it secures personal data. This notice also tells you about your privacy rights and how to exercise them.
This privacy notice governs, among other things, CleverTap’s privacy practices regarding the clevertap.com website (the “Site”), its relationship with representatives of its business and organizational customers, representatives of other businesses, and candidates for jobs at CleverTap.
Please direct all privacy questions, comments, complaints, or requests to exercise privacy rights to CleverTap’s Data Protection Officer by using the following contact information: Postal mail or courier: WizRocket Inc., Attention: Angel Indzhov, 607 W Dana St. Suite A Mountain View, CA 94041 Email: email@example.com Web: https://clevertap.com/contact-us/
Types of Personal Data Received by CleverTap. CleverTap receives four categories of personal data via its Site, its marketing and business practices:
Personal data collected via CleverTap’s site from site visitors
Personal data collected from representatives of CleverTap’s Customers
Personal data collected from representatives of our vendors, business partners, and other businesses or organizations with which CleverTap has a relationship
Personal data collected from job candidates
Personal data of Customer End Users processed by CleverTap in connection with its operation of the CleverTap Service
CleverTap’s Role as Controller and Processor. Data protection legislation such as the European Union’s General Data Protection Regulation defines two types of businesses that manage personal data. Data “controllers” determine the purposes and means of processing personal data. Controllers have direct contact with the individuals whose personal data is collected and used. By contrast, data “processors” process personal data on behalf of a controller as a service provider to the controller. Processors do not have direct contact with the individuals whose personal data is collected and used. CleverTap acts as both a data controller and a data processor. However, this privacy notice focuses only CleverTap’s activities as a controller.
CleverTap’s Role as Controller. When CleverTap manages personal data collected from its site; representatives of its Customers; representatives of vendors, business partners, and other businesses or organizations; and job candidates, CleverTap acts as a controller. As mentioned above, this privacy notice focuses only CleverTap’s role as controller.
CleverTap’s Role as Processor. When CleverTap processes personal data of Customer End Users via the Service, CleverTap is acting as a processor. As a processor, CleverTap provides its Customers with an online cloud-hosted solution allowing them to analyze how Customer End Users inter act with their websites or mobile applications. CleverTap’s function is limited to providing and managing the Service and the control on the usage, transmission of personal data, is always in accordance with the discretion of a Customer and how a Customer interacts and uses the Service and the agreement between CleverTap and the Customer. However, it is each Customer that has the direct relationship with its Customer End Users. Our Customers would handle all privacy questions, comments, complaints, or requests to exercise privacy rights from Customer End Users under their own privacy policies. If you are an end user of a website or mobile application of one of our Customers, and wish to discuss any privacy matters, please contact the operator of the website or mobile application, not CleverTap.
Customers should be prepared to handle requests for individual rights from Customer End Users regarding personal data about their use of Customers’ websites or mobile applications.
If CleverTap receives a request for individual rights from a Customer End User, CleverTap will use reasonable efforts to identify the applicable Customer and direct the request to that Customer.
Personal Data We Collect, Sources of Personal Data, and Purposes of Use.
Personal Data Collected from Site Visitors
CleverTap collects several types of information from and about users of our site, including information by which you may be personally identified, such as name, company name, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“identifiers”). We may also collect from job candidates, in the nature of professional or employment-related information, including education, employment, and employment history.Also, if you use a web form on the Site to communicate with us, we will collect your name, work email, Company name, country, and whatever personal data you include in your message to us. The You are the source of this data. The legal basis for processing this personal data is your consent.
Finally, CleverTap may obtain analytics data in aggregate form or that does not relate or identify an individual. This is not personal data. CleverTap reserves the right to use and disclose this non-personal data without restriction.
Personal Data Collected from CleverTap’s Customers.
Personal Data collected from Representatives of CleverTap’s Customers. CleverTap collects Personal Data from Customer Representatives relating to Customer accounts and management of them. For instance, when Customer Representatives engage in certain activities via the CleverTap Service, including but not limited to creating an account, sending feedback, or otherwise using or participating in the CleverTap Service (collectively, “Identification Activities”), we may ask Customer Representatives to provide certain information. If they elect to engage in an Identification Activity, however, we may ask them to provide us with certain Personal Data, such as name, address (including zip code), email address and/or telephone number. Depending on the Identification Activity, some of the information we ask Customer Representatives to provide may be identified as mandatory and some identified as voluntary. If Customer Representatives do not provide mandatory information for a particular Identification Activity, they will not be permitted to engage in that Identification Activity with the CleverTap Service.
As Customer Representatives navigate the CleverTap Service, we may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from Customers Representative’s Web browsers (such as browser type and browser language), their Internet Protocol (“IP”) address, and the actions they take on the CleverTap Service (such as the Web pages viewed and the links clicked).Through our “import Customer End Users” feature option, a Customer Representative may also provide us with Personal Data about other Customer Representatives such as the name, company name, address, phone number, email address, and/or IP address of the Customer Representatives that you choose to share with us. When you provide us with Personal Data about Customer Representatives that have not provided Personal Data to us, we will only use this information for the specific reason for which it is provided, such as to add new records to your CleverTap account, or as agreed in the applicable agreement with Customer.
CleverTap’s Customers may electronically submit Customer End User Data to the CleverTap Service. CleverTap will not review, share, distribute, or reference any such Customer End User Data except as provided in CleverTap’s applicable agreement with Customer, or as may be required by applicable law. CleverTap acknowledges that Customer End Users have the right to access their Personal Data. If Personal Data pertaining to a Customer End User has been submitted to us by a Customer, and a Customer End User wishes to exercise any rights it may have to access, correct, amend, or delete such Personal Data, the Customer End User should inquire with the Customer directly. Because CleverTap personnel have limited ability to access data our Customers submit to the CleverTap Service, if a Customer End User wishes to make a request directly to CleverTap, please provide the name of the Customer who submitted your data to the CleverTap Service. We will refer your request to such Customer and will support them as needed in responding to your request within one month; provided that (i) such period may be extended by up to 2 additional months when necessary, taking into account the complexity and number of the requests and (ii) CleverTap shall inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.
Personal Data Collected from Representatives of Vendors, Business Partners, and Other Businesses. We collect Business Card Data from representatives of CleverTap’s vendors, business partners, and other businesses and organizations with which CleverTap has a relationship. We use this personal data to communicate with these businesses and organizations and in order to initiate, maintain, and terminate our relationship with them. Representatives of these businesses and organizations are the source of this information and the legal basis for processing this personal data is the performance of a contract with the applicable business or organization or the legitimate interests of CleverTap or the business or organization.
Personal Data Collected from Job Candidates.
Job candidates can view open positions at CleverTap on the Site and apply for these positions. The portion of the Site for job candidates is managed by Lever, an Employ Inc. brand, acting as a service provider to CleverTap. Candidates submit personal data to CleverTap using this portion of the Site, and candidates are the sources of this personal data.
CleverTap collects full name, email address, phone number, resume/CV, LinkedIn profile, expected salary information, notice period, and the candidate’s current location from every job candidate. Optionally, job candidates may submit the name of their current employers, Twitter URL, Github or portfolio URL, other websites, and any other personal data that the candidate provides using the Lever web form, such as a cover letter.
We use personal data collected from job candidates to review, consider, and process their job applications. The legal basis for processing this personal data is the consent of job candidates. If a job candidate withholds or withdraws such consent, we will not be able to consider the job candidate for a CleverTap position.
California resident job candidates: CleverTap has a separate notice of privacy practices covering job candidates who are California residents. California residents should consult the CleverTap Notice of Workplace Privacy Practices for California Candidates and Workers to understand CleverTap’s California privacy practices and their privacy rights.
Sharing or Disclosing Personal Data. CleverTap does not sell the personal data described in this notice in the ordinary course of its business. CleverTap may disclose or share personal data under the circumstances described below.
Authorized Service Providers. CleverTap provides the Service with the assistance of third parties. These “Service Providers” perform functions on our or your behalf. You or we may share personal data with such Service Providers to fulfill orders, analyze collected personal data, operate the Service, collect payment for the Service, troubleshoot, and provide customer service. We may also share your information with Service Providers to accomplish our administrative tasks. We require our Service Providers to maintain data protection policies and procedures at least as protective of personal data as the practices described in this privacy notice.
Corporate Transactions. We may share or transfer personal data about you in connection with a merger, acquisition, reorganization, or sale of assets of our business, in the event of bankruptcy, or during the negotiations leading to such an event. We will seek assurances from any buyer that your personal data will be used, shared, maintained, and disclosed consistent with the terms of this privacy notice.
Cross-Border Transfers of Personal Data.
Exports of Personal Data. CleverTap may process your personal data in and transfer it to a country other than where you are located. The privacy laws in these other countries may be different from your country of residence and may not offer the level of protection in your own country. We may maintain your personal data in any country in which we have an office or facility or in countries where our Service Providers are located. We will only process personal data and allow Service providers to process personal data in jurisdictions with an adequate level of protection for personal data or use another lawful transfer mechanism to provide an adequate level of protection when exporting personal data covered by this notice.
Privacy Shield Compliance. CleverTap has certified to the U.S. Department of State that it adheres to the Privacy Shield Principles intended as a transfer mechanism to provide an adequate level of protection when exporting personal data to the United States. See CleverTap’s Privacy Shield Policy for details. However, a European Court of Justice decision called Schrems II invalidated the Privacy Shield program. Accordingly, CleverTap is not relying on the Privacy Shield program as a transfer mechanism to protect cross-border transfers of personal data at this time. However, CleverTap is maintaining its Privacy Shield certification in anticipation of a revised Privacy Shield Framework and to demonstrate its continued commitment to protecting personal data imported into the United States.
Securing Your Personal Data. We are committed to ensuring that your personal data is secure. In order to prevent unauthorized access or disclosure, we have put in place industry-standard administrative, physical, and technical safeguards to secure the personal information we collect.
Customer representatives using the Service use authentication credentials or mechanisms to limit access to the Service. We require Customer representatives to protect these credentials or mechanisms by agreement.
Customer End User Data resides on a secure server that only selected personnel and contractors have access to. We encrypt certain sensitive information using session encryption initiated by Secure Socket
However, no data transmission can be guaranteed to be 100% secure. As a result, while we employ industry standard security measures to protect personal data being transmitted and seek to partner with companies that do the same, we cannot guarantee the security of any information transmitted over the Internet, and we are not responsible for the actions of any third parties involved in the transmission of personal data.
Links to Other Websites. Our Site may contain links to other websites of interest. However, once you have used these links to leave our Site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide while visiting such websites and these websites are not governed by this policy. You should exercise caution and look at the privacy statement applicable to the website in question.
Your Rights Regarding Personal Data. We provide the following rights under this privacy notice, which mirror your rights under the EU’s General Data Protection Regulation. Your rights described in this section may be limited by applicable law and there may be circumstances under applicable in which CleverTap must or is permitted to limit or deny your request.
Right of Access. You have a right to disclosure of the categories of personal data collected by CleverTap, the purposes of processing it, the categories of recipients of your personal data, and (where we obtained personal data by your consent or by automated means) copies of electronic information for data portability purposes.
Right to Rectification. You have the right to update or correct personal data about you in our records. Please be aware that applicable law may require or permit CleverTap to preserve some of your personal information as it is presently stored in our systems. Also, Customer representatives may change any of their applicable personal data by logging into their account and accessing the relevant section of the CleverTap Service. We encourage Customer representatives to promptly update their personal data to facilitate continuity of service.
Right of Erasure of Personal Data. If you wish for CleverTap to delete your personal data, please contact us. Please be aware that applicable law may permit or require CleverTap to retain some of your personal data.
Right to Restrict or Suspend Processing of Personal Data. If you contest the accuracy of personal data in our records, you believe our processing of personal data is unlawful (but you don’t wish for us to delete it), you have asked us to preserve personal data for legal reasons even though CleverTap no longer needs it, or you otherwise object to our processing it, please contact us.
Right to Withdraw Consent. If we have relied on your consent to process personal data, you may withdraw your consent at any time by contacting us. For instance, CleverTap offers the option to opt out of routine marketing communications from us. Note that even if you opt out of receiving communications from us, we reserve the right to continue communicating with you regarding announcements, administrative messages, and messages regarding account administration relating to the Service that are necessary to our relationship with you and performance of our contract with the applicable Customer.
Exercising Your Rights. To exercise any of the rights listed in Section 12, please contact us using the contact information.
We may need additional information to act on your request to exercise your rights. For instance, we may ask for information to confirm your identity as a security measure to prevent unauthorized access to your personal data.
We will respond to your request within the time limits provided under applicable law. If we deny your request, we will provide the reasons for the denial and the contact information of a CleverTap representative as a point of contact for following up.
We may deny your request if your request is manifestly unfounded or excessive (for instance because you make repetitive requests).
Right to Complain. You have the right to make a complaint at any time to the Republic of Bulgaria’s Commission for Personal Data Protection, the Bulgarian supervisory authority for data protection issues (https://www.cpdp.bg/en/). We would, however, appreciate the chance to address your concerns before you approach the Bulgarian supervisory authority. So please contact us first before lodging a complaint. You may also have the right to submit a complaint to a supervisory authority or regulator in your local jurisdiction.
Notice to California Residents. If you are a resident of the state of California, USA, California law may provide you with additional rights regarding our use of your personal data (which California law calls “personal information”). To learn more about your California privacy rights, visit https://clevertap.com/ccpa/.
Children. Anyone CleverTap deals with as a potential or current representative or a Customer or other business or organization must be at least 18 years if age. If a business or organization becomes aware that a child has provided us with personal data purporting to be a representative, please contact using the contact information in Section 1 so that we can delete it.
Amendments to this Notice. CleverTap may change this privacy notice from time to time by posting a revised copy of the notice on the Site. Any amended notice will be effective as of the date at the top of the notice.