WizRocket Inc., a Delaware corporation doing business as CleverTap (“CleverTap”, “we,” “us,” or “our”) provides its customers (“Customers”) with the ability to analyze how their end users (“Customer End Users”) interact with Customer website(s) or mobile application(s) and the ability to contact Customer End Users via the CleverTap service platform (the “CleverTap Service”). Customers’ users of the Service and other representatives of our Customers (collectively, “Customer Representatives”) interact with CleverTap to establish, maintain, and manage their use of the CleverTap Service.
CleverTap collects both Personal Data and Non-Personal Data:
1.1 Personal Data.“Personal Data” is information relating to a specific identified or identifiable person. Generally, CleverTap collects two types of Personal Data, Personal Data from Website users, Customer Representatives and Personal Data from Customer End Users.
1.2 Non-Personal Data. “Non-Personal Data” is information that does not identify a specific person.
2.2 Other Tracking Devices. When you access the CleverTap Service, or open or click an email, pixel tags and web beacons generate a Non-Personally Identifiable notice of that action. Pixel tags allow us to measure and improve our understanding of visitor traffic and behavior on the CleverTap Service, as well as give us a way to measure our promotions and performance. We may also utilize pixel tags and web beacons provided by our marketing partners for the same purposes.
We do not sell Personal Data or Non-Personal Data related to our Customers or Customers End Users. We use all Personal Data and Non-Personal Data to strictly provide Services or Website and its content to you. We will not share Personal Data with other parties except as provided below:
3.4 Extraordinary Circumstances. We may also disclose information when we believe it’s necessary to prevent imminent and serious bodily harm to a person; to address fraud, security, or spam; or to protect our rights or property.
We process Personal Data both as a Processor and as a Controller, each as defined in the General Data Protection Regulation (“GDPR”):
CleverTap has a Data Protection Officer (as defined in the GDPR) who is responsible for matters relating to privacy and data protection. Our Data Protection Officer can be reached as follows:
For Customer Representatives and Customer End Users located in the European Data Region in the European Economic Area (EEA), all processing of Personal Data is performed in accordance with the GDPR.
All data collected by CleverTap through the CleverTap Service will be stored exclusively in secure hosting facilities provided by Amazon Web Services. CleverTap has a data processing agreement in place with its provider, ensuring compliance with the GDPR. All hosting is performed in accordance with the highest security regulations. All transfers of data out of the EEA is done in accordance with the applicable data processing agreement. If you are a Customer located in the EEA, we exclusively store and process Personal Data in the EEA. Customers have the ability to export Personal Data in a manner that transfers such Personal Data to a third country. We will perform such transfers in accordance with Customers’ instructions.
We have adopted reasonable physical, technical and organizational safeguards which substantially mirror the GDPR-required safeguards against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of Personal Data in our possession.
Customer Representatives can access the Personal Data that the Customer has provided via the CleverTap Service with a password and username. This password is encrypted. We advise against sharing passwords and usernames with anyone. If a Customer Representative’s account is accessed via a third-party site or service, there may be additional or different sign-in protections via that third-party site or service. Customer Representatives must prevent unauthorized access to their account and the Personal Data that they have provided, including without limitation any applicable Customer End User Data, by selecting and protecting their passwords and/or other sign-in mechanism appropriately and limiting access to their computers, browsers, or mobile devices by signing off after finishing accessing their accounts. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. In the event that we believe that the security of a Customer Representative’s login credentials may have been compromised, we may seek to notify the Customer of that development.
In addition, the Personal Data that a Customer has provided, including without limitation 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 Layer (SSL) or Transport Layer Security (TLS) technology to secure the transmission of Personal Data to us. However, no data transmission can be guaranteed to be 100% secure. As a result, while we employ appropriate and commercially reasonable security measures to protect data and seek to partner with companies that do the same, we cannot guarantee the security of any information transmitted over internet, and we are not responsible for the actions of any third parties that may receive any such information.
We may disclose or share Non-Personal Data without restriction. For example, we may share Non-Personal Data such as aggregated demographic information (which does not include any Personal Data) or use Third-Party Service Providers to track and analyze Non-Personal Data usage and volume statistical information from our Customers and Customer End Users to administer the CleverTap Service. In order to administer the CleverTap Service, we collect Customer End User Data and provide analyses of anonymized aggregate Customer End User Data to the applicable Customer and, if applicable, Third-Party Service Providers. We may also publish this aggregated information for promotional purposes. Notwithstanding the foregoing, Customer is the owner of its applicable Customer End User Data in the form of Non-Personal Data.
These companies may use Non-Personal Data about your visits and use of the CleverTap Service and/or the CleverTap Websites, and visits to other websites or locations in order to provide, through the use of network tags, advertisements about goods and services that may be of interest to you.
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 information. To learn more about your California privacy rights, visit https://www.clevertap.com/ccpa.
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 if it changes, as out-of-date Personal Data may negatively affect the quality of their CleverTap Service experience.
CleverTap offers the option to opt out of routine communications from us. Please contact customer support as described in Section 16 below to exercise this option. We will make commercially reasonable efforts to implement a Customer Representative’s email opt-out requests promptly, but he or she may still receive communications from us for up to ten (10) business days as we process the opt-out request. Note that even if a Customer Representative opts out of receiving communications from us, we reserve the right to continue communicating with the Customer Representative regarding service announcements, administrative messages, and messages regarding account administration relating to CleverTap that are necessary to our relationship with you.
As a user, Customer Representatives may have limited access to privacy settings. These settings help hide information they wish to share with other users and/or the public. It is up to them to select the appropriate privacy settings. Only administrative user Customer Representatives have full access to administrative systems to set privacy settings for a Customer. If you don’t agree with the available privacy settings, please stop using the CleverTap Service.
Customer Representatives must be at least 18 years if age. If a Customer becomes aware that a child has provided us with Personal Data purporting to be a Customer Representative, please contact us at https://clevertap.com/contact-us so that we can delete it.
If you have a complaint about our privacy practices, you may submit a complaint to our Data Protection Officer. Our Data Protection Officer and compliance team will evaluate your complaint and may request additional information. Providing sufficient information to understand the facts and circumstances of a complaint are important and necessary to resolve complaints.