- Types and Uses of Collected Information. CleverTap collects both Personal Data and Non-Personal Data:
- 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 Customer Representatives and Personal Data from Customer End Users.
- Personal Data of Customer Representatives
- Non-Personal Data. “Non-Personal Data” is information that does not identify a specific person.
- Non-Personal Data from Customer Representatives
- Non-Personal Data from Customer End Users
CleverTap’s Customers may electronically submit Non-Personal Data from Customer End Users to the CleverTap Service. CleverTap will not review, share, distribute, or reference any such Non-Personal Data except as provided in CleverTap’s applicable agreement with Customer, or as may be required by applicable law. CleverTap uses such Non-Personal Data for the purpose of enhancing or providing the CleverTap Service.
- Data Tracking.
- 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.
- Sharing of Personal Data. We will not sell or share Personal Data with other parties except as provided below:
- Extraordinary Circumstances. Other extraordinary circumstances not listed here may require disclosure: 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.
- Data Controller and Data Processor; Data Protection Officer. We process Personal Data both as a Processor and as a Controller, each as defined in the General Data Protection Regulation (“GDPR”):
(a) The Customer which Customer End Users provided Personal Data to, with the assistance of the CleverTap Service, will be the Controller for Customer End User Data. We will be the Processor. (b) For Personal Data in Customer Data received directly from Customer Representatives, we will be the Controller. For Customer Representative Personal Data received from another Customer Representative, we are a Processor processing such Personal Data in accordance with the Customer’s instructions.
- Data Protection Officer.
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:
Attn: Francis PereiraC/o. WizRocket Technologies Pvt Ltd.
19th Floor, DLH Park, SV Road, Goregaon West, Mumbai 400062
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.
- Security. 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 to or from or via the CleverTap Service, and we are not responsible for the actions of any third parties that may receive any such information.
- Sharing of Non-Personal Data. 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.
- Your California Privacy Rights. If you are a California resident, 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.
- Updating Information. Customer Representatives may change any of their applicable Personal Data by logging into their account and accessing the “My Profile” 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.
- Choices on Collection/Use of Information. Customer Representatives can always choose not to provide certain information, although a certain level of information may be required to engage and participate in the CleverTap Service. Customer Representatives, however, cannot opt-out of Administrative Emails. “Administrative Emails” relate to Customer’s activity on the CleverTap Service, and include but are not limited to emails regarding a Customer’s account, requests or inquiries. If a Customer Representative does not want to receive promotional emails from us, such Customer may elect to opt-out of receiving promotional emails at any time after registering by e-mailing us at firstname.lastname@example.org or by hitting the “unsubscribe” button at the bottom of any of our e-mails.
- Email Choice/Opt-out. 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.
- Privacy Settings. 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.
- Public Areas. Customer Representatives also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties, such as comments on blogs (collectively, “User Contributions”). Although they may set certain privacy settings for such information by logging into their account profiles, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom Customer Representatives may choose to share their User Contributions. Therefore, we cannot and do not guarantee that User Contributions will not be viewed by unauthorized persons.
- Children. 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 us at the above website. Our 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.