,eniakcilC a/b/d .o.r.s sdA eguH
,185 23 912 :DI ynapmoC
,52/1322 oheksarH ta detaes
,4 eugarP 00 841
,cilbupeR hcezC eht
(“Clickaine” or “We”) respects your privacy and commits to protecting it through our compliance with the practices described in this policy.
This policy describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you visit our website or other digital properties, communications, or forms that link or refer to this policy (our “Website”).
This policy applies to the personal data collected through our Website, regardless of the country where you are located.
The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections might allow the third party to collect or share data about you. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.
For the purposes of this policy, “you” refers to any individual who interacts with our Website, including visitors who browse our Website without entering into an agreement with us, as well as individuals with whom we have entered into an agreement for the provision of services (“Services”), whether you are an Advertiser or Publisher, under our Terms of Service (“User”). We may also process personal data of Users’ employees, contractors and other persons, who use our Website and Clickaine Network on the User’s behalf. The legal basis and scope of data processing may differ accordingly, depending on whether you are a Website visitor or a User.
In the EEA area we always process your personal data in compliance with legal regulations. The main one is Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, "GDPR").
Please read this policy carefully to understand our policies and practices for processing and storing your personal data. By engaging with our Website as a Website visitor, you accept and consent to the practices described in this policy. As a User, you take into account this policy when entering into an agreement with us. We may change this policy on one or more occasions (see Changes to Our Privacy Policy). Your continued engagement with our Website or use of our Services after any such revisions indicates that you accept and consent to them, so please check the policy periodically for updates.
We are the controller of your personal data. Therefore, we are responsible for the processing of your Personal data as described in this privacy policy. If you have questions about your data or your rights, you may contact the data controller at privacy@clickaine.com.
We may collect various types of data from and about you:
If we combine or connect non-personal, demographic, or technical data with Personal data so that it directly or indirectly identifies an individual, we treat the combined information as Personal data.
We use different methods to collect data from and about you including through:
Our Website uses cookies (small files placed on your device) or other automatic data collection technologies to distinguish you from other Website users. This helps us deliver a better and more personalized service when you browse our Website.
Please note that we do not recognize or respond to any do not track signals (DNT). For more information about DNT, visit www.allaboutdnt.com.
In the EU, you have the right to choose whether to accept or reject non-essential cookies. When you first visit our Website, we will ask for your consent to use cookies that are not strictly necessary for the functioning of the Website (such as analytics or marketing cookies). You can manage your cookie preferences at any time through our cookie consent tool or in your browser settings.
In the US, you may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, certain parts of our Website may become inaccessible and certain features may not work correctly. Unless you adjust your browser settings to refuse cookies, our system will issue them. For detailed information on the cookies and other tracking technologies we use and the purposes for which we use them, see our Cookie Policy.
Our Website may also contain web beacons (small transparent embedded images or objects, also known as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or to compile other similar statistics including recording Website content popularity or verifying system and server integrity.
Some content or applications on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. They may associate the information collected with your personal data or they may collect information, including personal data, about your online activities over time and across different websites or other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control how these third-party tracking technologies operate or how they may use the collected data. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Your Personal Data Use Choices.
We use your Personal data to provide you with products, offer you services, communicate with you, deliver advertising and marketing, or conduct other business operations, including using data to improve and personalize your experiences. Examples of how we may use the Personal data we collect include to:
We may use non-personal data for any business purpose.
We may share your personal data with:
We may also disclose your personal data to third parties:
We may share non-personal data without restriction.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Our Website may, on one or more occasions, contain links to and from the websites of our partner networks, advertisers, and affiliates, or include plug-ins enabling third-party features. If you follow a link to any third-party website or engage a third-party plug-in, please note that these third parties have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these third parties.
US state consumer privacy laws may provide their residents with additional rights regarding our use of their Personal data.
California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:
The exact scope of these rights might vary by state. To exercise any of these rights please email privacy@clickaine.com. To appeal a decision regarding a consumer rights request please email privacy@clickaine.com.
Nevada provides its residents with a limited right to opt-out of certain Personal data sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: privacy@clickaine.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.
We try to respond to all legitimate requests within one month. Occasionally it might take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will let you know and keep you updated.
You will not have to pay a fee to access your Personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to honor your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal data (or to exercise any of your other rights). This is a security measure to ensure that Personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information regarding your request to speed up our response.
If you live in the European Economic Area (or the United Kingdom), the following terms apply to you:
We always need a lawful reason to process your Personal data. This means there has to be a legal basis for any processing of your data.
| What is the legal basis for the processing? | Why do we process your personal data? | How long? | What Personal data? |
|---|---|---|---|
|
CONSENT Article 6.1 a) GDPR or LEGITIMATE INTEREST Article 6.1 f) GDPR |
Provision of the basic functions of our Website, analytics, improvements of our services etc., with the help of cookies and beacons. Preferences can be set in the cookie bar. | The period of processing varies depending on the cookie type, see below the cookie table. | Information about the User’s visit of the Website may include IP address, the date and time of the visit, operating system, language settings, history of behavior on the Website, data concerning mobile phone etc. |
|
LEGITIMATE INTEREST Article 6.1 f) GDPR |
Defending against and tracing attacks by hackers, protecting our Website. | The IP addresses are stored for no more than 1 month. | To protect against attacks, we store the IP addresses of all users who access our Website. The logs created are only used to monitor security breaches and are only actively viewed and used when such an event takes place. |
|
TAKING STEPS PRIOR TO ENTERING INTO A CONTRACT Article 6.1 b) GDPR |
Processing of your data when you complete our contact form on the Website or give us information in relation to a possible entering into a contract together. | Closed inquiries are deleted regularly, but no later than 3 years from the date of the inquiry. |
Basic identification data (e.g., name, surname) Contact details (e.g., e-mail address, phone number) Information from our communications (other information included in the contact form or an e-mail message, or by other means of communication) |
|
LEGITIMATE INTEREST Article 6.1 f) GDPR |
Dealing with other inquiries or questions not directly related to entering a contract together. | Closed inquiries are deleted regularly, but no later than 3 years of the date of the inquiry. |
Basic identification data (e.g., name, surname) Contact details (e.g., e-mail address, phone number) Information from our communication (other information included in the contact form or an e-mail message, or by other means of communication) |
If you choose to enter into a contract with us and use our Services, we will process Personal data only to the extent necessary to provide the services in accordance with the Terms of Service.
| What is the legal basis for the processing? | Why? | How long? | What Personal data? |
|---|---|---|---|
|
CONSENT Article 6.1 a) GDPR or LEGITIMATE INTEREST Article 6.1 f) GDPR |
Provision of basic functions of our Website, analytics, improvements of our Services. The User can set preferences in the cookie bar. | The processing processes varies depending on the cookie type, see the cookie table in the Cookie Policy. | Information about the User’s visit of the Website may include IP address, the date and time of the access, operating system, language settings, history of behavior on the Website, data concerning mobile phone etc. |
|
THE PERFORMANCE OF THE CONTRACT Article 6.1 b) GDPR |
Conclusion and execution of the contract to fully start using the Services. Creation and maintenance of the User account in the extent necessary to provide all the features of the Service. Provision of any other agreed upon Services. Notification about changes to the Website and Services. |
For the term of the Agreement and potentially for up to 30 days afterwards, if we agree to let you export data from the User account. |
Basic identification data (e.g., name, surname) Contact details (e.g., e-mail address, phone number) Billing details and bank details Logging into the User account and actions taken with respect to the User account (e.g., the information filled in by the User in the User account, the time of signing up, the date of the last profile update) Information about our contract (e.g., how is the contract fulfilled by both parties, how was the remuneration calculated etc.) Cookies and IP address, activity data (including information about device, operating system and browser) Information from our communication |
|
LEGAL REQUIREMENTS Article 6.1 c) GDPR |
Sometimes we must process Personal data when the law requires us to do so. This concerns mainly accounting and tax regulations. | For the period required by the legislation (normally 10 years from the end of the financial year in which the tax/accounting event occurred) |
Basic identification data (e.g., name, surname) Contact details (e.g., e-mail address, phone number) Billing details and bank details |
|
LEGITIMATE INTEREST Article 6.1 f) GDPR |
Where we believe it is necessary to protect our legal rights, interests and the interests of others, we may use the Personal data in connection with legal claims, compliance, regulatory or audit functions. | For the period of up to 16 years, which corresponds to the longest statute of limitations period (15 years) and one extra year to deal with any potential disputes brought upon by you. |
Basic identification data (e.g., name, surname) Contact details (e.g., e-mail address) Information about our contract (e.g., how is the contract fulfilled by both parties, how was the remuneration calculated etc.). |
|
LEGITIMATE INTEREST Article 6.1 f) GDPR |
To monitor compliance with our Terms of Service, prevent fraudulent activities, and enhance network security. |
For up to 3 months. If an event happened (e.g. violation of Terms of Service, fraudulent activity, security breach), we may process your Personal data to protect our legitimate interest for up 16 years, as mentioned above. |
Logging into the User account and actions taken with respect to the User account (e.g., the information filled in by the User in the User account, the time of signing up, the date of the last profile update) Information about our contract (e.g., how is the contract fulfilled by both parties, how was the remuneration calculated etc.) Cookies and IP address, activity data (including information about device, operating system and browser) |
|
CONSENT Article 6.1 a) GDPR |
We process your Personal data based on your consent in cases where the processing cannot be justified under any of the above-mentioned legal grounds for data processing. We will retain your Personal data for as long as your consent is granted. You may withdraw your consent at any time, for example, via email. However, withdrawing your consent or its expiration does not necessarily mean that we must delete all the Personal data we have processed based on it. We may continue processing the Personal data where another legal basis allows us to do so. | The data processed under consent includes those specified in the consent form for personal data processing. | The Controller does not process any special categories of Personal data. |
We may share your Personal data with other entities to ensure our efficient operation. Our service providers become processors of Personal data but are only authorized to process your data to the extent we have agreed upon with them.
We may share your Personal data with:
We are ready to provide you with an up-to-date list of specific entities to which we transfer your personal data. Just send a request via email or contact us in any other way.
We may also provide your Personal data to third persons in the following cases:
Under certain circumstances, you have rights under data protection laws concerning your Personal data. Your rights may include the following:
If you believe that our data processing practices infringe on your rights under GDPR, you may lodge a complaint with a supervisory authority in the country where you live or work.
In addition, you have the right to object if we process your Personal data for the purposes of the legitimate interests and direct marketing purposes pursued by us. You can submit this objection by sending it to our contact address or email. We will evaluate it within one month of receiving it. To exercise any of these rights please email privacy@clickaine.com.
You will not have to pay a fee to access your Personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to honor your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal data (or to exercise any of your other rights). This is a security measure to ensure that Personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information regarding your request to speed up our response.
The security of your Personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your Personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure. We store all Personal data you provide to us behind firewalls on servers employing security protections. We encrypt any payment transactions using SSL technology.
The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal data, we cannot guarantee the security of your Personal data transmitted to our Website. Any transmission of Personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website.
Except as otherwise said in the policy, permitted or required by law or regulation, we will only retain your Personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Personal data processed under consent may be retained until consent is withdrawn. Under some circumstances, we may anonymize your Personal data so that it can no longer be associated with you. We may use that anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. Anonymized or aggregated data may be retained and used indefinitely.
Where you have provided your consent to the collection, use, and transfer of your Personal data, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at privacy@clickaine.com. Please note that if you withdraw your consent, we might not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
Our services on the Website are available only to individuals who are 18 years of age or older. If we learn we have mistakenly or unintentionally collected or received Personal data from a child without appropriate consent, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us at privacy@clickaine.com.
If you have created an account on our Website, you can access, review, and change your Personal data by logging into the Website and visiting your account profile page.
If you nave not created an account on our Website or you cannot access, review, or change your Personal data on your account profile page, you may send us an email at privacy@clickaine.com to request access to, correct, or delete any Personal data that you have provided to us. We cannot delete your Personal data except by also deleting your user account. We might not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or negatively impact the information’s accuracy.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal data that we hold about you or make your requested changes. Law might allow or require us to refuse to provide you with access to some or all the Personal data that we hold about you, or we might have destroyed, erased, or made your Personal data anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
If you are concerned about our response or would like to correct the information provided, you may contact us at privacy@clickaine.com.
We will post any changes we might make to our privacy policy on this page. If the changes materially alter how we use or treat your Personal data we will notify you by email to the primary email address specified in your account or through a notice on the Website home page. Please check back frequently to see any updates or changes to our privacy policy.
We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:
,.o.r.s sdA eguH
,52/1322 oheksarH
,00841 eugarP
,cilbupeR hcezC
privacy@clickaine.com
We have procedures in place to receive and respond to complaints or inquiries about our handling of Personal data, our compliance with this policy, and with privacy laws. To discuss our compliance with this policy, please contact our data privacy officer using the contact information listed above.