Privacy Policy

Effective Date: September 2020

At Clevyr, we are committed to protecting your information. Please read this Privacy Policy ("the Policy") carefully as it sets out important information relating to how we handle your personal information.

1. Introduction.

This Policy sets out how we collect and use personal information, and your choices and rights regarding our use of your personal information. This Policy describes our practices when using your information when you:

express an interest in or have signed up for our products including newsletters, apps, extensions, webinars, and e-books; or
activate a Clevyr user account and/or license;
attend a Clevyr event or conference; or
visit our websites (including our public and/or member-based websites) or social media pages.

This Policy will apply whether you have provided the information directly to us or we have obtained it from a different source, such as a third party. This Policy also applies to information we collect from you via surveys as outlined in more detail below. You may be shown an additional confidentiality notice before participating in a survey. Please note that in cases where the terms of any such survey-specific confidentiality notice conflict with any terms in this Policy, the terms of that notice will take precedence over the terms in this Policy. We will not use information we collect via our survey tools to contact you for marketing purposes.

By creating a user account; or by using our products and services; or by participating in our social media pages, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. “Processing,” means using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining, and disclosing information, all of which activities will take place in the United States. If you reside outside the United States your information will be transferred, processed and stored there under United States privacy standards.

Accordingly, when you use any of our products or services, you should check the date of this Policy (which appears at the top of this document) and review any changes since the last version. The most current version of the Policy will be available at all times here.

2. Information We Collect About You.

2.1. Data collection and use

Information we collect from visitors to our public websites and social media pages:
Categories of information we collect about you include:	Personal information such as your name and title, contact details, and company name; Communications with you; Information you provide when posting content on our social media pages.
We use this information for certain activities, including:	Facilitating the business through communication with corporate clients and other business contacts, for example, to communicate about vendor briefings or details of events or webinars; For internal analysis and research to help us improve our services; Administering our website, investigating any complaints, and providing customer service; Providing end-user support and To send marketing to business contacts regarding our services and products which may be of interest and to promote our business and brand; Monitoring social media content to manage relations with our clients and promote our business and brand.
We use this information because:	It is necessary to perform our obligations or exercise our contractual rights; It is necessary to comply with applicable laws or regulations; We have a legitimate business interest to: Manage and promote our business and brand; Provide and improve our services; Operate our business; and We have your consent (where required under applicable law) to use your information for marketing. Where we rely on your consent, you have the right to withdraw consent by contacting us.

Information we collect from users of: Our public and member-based websites and licensed services; Our apps; and Clevyr social media pages on sites such as LinkedIn, Facebook, or Twitter.
Categories of information we collect about you include:	Personal Information you provide when registering for a user account in our products and services or subscribing to our email newsletters, including name, business or personal email address, job title, organization, organization’s physical address, direct telephone number, photograph, and age; Where you have a registered user account for our products or services, log-in credentials and information about your use of and preferences for these services; Information you provide when you voluntarily enter information such as when you complete feedback forms; Posts, messages, document uploads, or other actions or interactions you create or provide while using our products or services; Transaction-related information, such as when you make purchases, respond to any offers, download or use our products or services; Billing and payment information such as payment card or other information you provide when making payments to us.
We use this information for certain activities, including:	Enabling you to access your user accounts across devices; Personalizing your experience of our products and services; Administering our products and services; Providing more customized client service; Investigating complaints; Monitoring social media content to manage relations with our clients and promote our business and brand.
We use this information because:	It is necessary to perform our obligations or exercise our contractual rights; It is necessary to comply with applicable laws or regulations; We have a legitimate business interest to: Promote our brand and business through our website and through social media tools; Monitor, investigate and report any attempts to breach the security of our website; Provide and improve our products and services including The Loop, our websites, and our apps; Operate our business; We have your consent (where required under applicable law) to use your information for marketing. Where we rely on your consent, you have the right to withdraw consent by contacting us.

Information we collect from users of:

Our public and member-based websites and licensed services;
Our apps; and
Clevyr social media pages on sites such as LinkedIn, Facebook, or Twitter.

Categories of information we collect about you include:

Personal Information you provide when registering for a user account in our products and services or subscribing to our email newsletters, including name, business or personal email address, job title, organization, organization’s physical address, direct telephone number, photograph, and age;
Where you have a registered user account for our products or services, log-in credentials and information about your use of and preferences for these services;
Information you provide when you voluntarily enter information such as when you complete feedback forms;
Posts, messages, document uploads, or other actions or interactions you create or provide while using our products or services;
Transaction-related information, such as when you make purchases, respond to any offers, download or use our products or services;
Billing and payment information such as payment card or other information you provide when making payments to us.

We use this information for certain activities, including:

Enabling you to access your user accounts across devices;
Personalizing your experience of our products and services;
Administering our products and services;
Providing more customized client service;
Investigating complaints;
Monitoring social media content to manage relations with our clients and promote our business and brand.

We use this information because:

It is necessary to perform our obligations or exercise our contractual rights;
It is necessary to comply with applicable laws or regulations;
We have a legitimate business interest to:
- Promote our brand and business through our website and through social media tools;
- Monitor, investigate and report any attempts to breach the security of our website;
- Provide and improve our products and services including The Loop, our websites, and our apps;
- Operate our business;
We have your consent (where required under applicable law) to use your information for marketing. Where we rely on your consent, you have the right to withdraw consent by contacting us.

Information about the use of our website and apps we collect automatically:
Categories of information we collect about you include:	Device information such as device brand and model, screen dimensions, and unique identifiers (e.g. IP address and device ID); Browser information (e.g URL, browser type, pages visited, dates and times of access); Location information collected from GPS (or other similar technology); Internet connection information; Behavioral information (such as information on the behavior or presumed interests of individuals which are linked to those individuals and may be used to create a user profile); and Information captured by our cookies.
We use this information for certain activities, including:	Personalizing user experience in our products and services; Administering our products and investigating any complaints; Performing statistical and trend analysis to improve the performance and user experience of our products and services; Providing better, more customized client service.
We use this information because:	It is necessary to comply with applicable laws or regulations; We have a legitimate business interest to: Monitor, investigate, and report any attempts to breach the security of our products and services; Improve the performance of our products and services; Improve and customize the user experience.

Information we collect from survey respondents:
Categories of information we collect about you include:	Personal information such as name and title, contact details, and company name; Demographic information provided by your employer; and Responses to survey or diagnostic questions.
We use this information for certain activities, including:	Validating and analyzing survey and diagnostics; Conducting general research, including creating or updating aggregate benchmark data sets and reports; Providing our services; and Developing new products and services.
We use this information because:	We have a legitimate business interest to: Provide and update benchmark data and analysis; and Validate and update our products and services.

2.2 Special categories of information

Certain types of personal information are more sensitive than others. This includes information about health, disability, race, ethnicity, criminal offences (or alleged offences), political opinions, biometric information or religion. It is voluntary for you to disclose this information, but where we collect and receive these types of information about you, we have identified the type of special information, how we will use it and why we will use it.

Information we may collect when you attend one of our events:
Categories of information we may collect about you include:	Any accommodations you request from us in order to participate fully in a conference, meeting, or event which may imply specific medical conditions. Any dietary restrictions or requirements you communicate to us that may imply specific religious beliefs or medical conditions. Any medical condition, physical or mental disability, or other impairment you may choose to voluntarily disclose to us.
We use this information for certain activities, including:	Providing hospitality that is suitable for attendees of our events.
We use this information because:	You have consented by providing us with the information. Where we rely on your consent, you have the right to withdraw your consent by contacting us.

2.3. Further information.

Where we collect and use information for our legitimate interests as mentioned above, a legitimate interest will only apply when we consider that your interests or rights requiring protection of your personal information do not override our legitimate interests. For more information regarding our legitimate interests as applied to your personal information, please contact us.

In certain circumstances, if you do not provide personal information which is required (for example, in relation to activating a product license), we will not be able to perform our contractual obligations or provide you with products and services. When this is the case, we will make it clear.

2.4. Children.

Our websites and online services are for individuals who are at least 18 years old. Our online services are not designed to be used by individuals under the age of 18.

We do not use our websites or online services to knowingly solicit data from or market to children under the age of 13.

If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at https://clevyr.com/contact. We will delete such information from our files within a reasonable time.

2.5. Recorded Communications with Clevyr.

We may record audio or video calls and meetings for training, quality assurance, and research purposes. All recordings will be treated as confidential. If you do not want us to record your call, you will be given a chance to opt out. If your call is already in progress, you may ask us to turn off the recording at the start of the call.

2.6. Sharing Information Outside our Sites and Apps via Email.

You may use sharing functionality on some of our sites or apps to send information from Clevyr to another party via email. In order to fulfil this request, we will ask you for your intended recipients' names and email addresses. We do not retain this data after the email is sent. Please be aware that your name and email address may be included in the communication sent to your intended recipient.

2.7. Payment Card Information.

Where you choose to pay for any Clevyr products or services using a payment card, we will collect your personal data connected to your payment card. We use this personal data in order to process your payment and to prevent fraudulent transactions. We do this on the basis of your consent to process this information.

2.8. User Created Content.

Some of our sites and applications allow users to create, upload, and save content; add labels, tags, and notes to existing content; and share content and notes with and receive content and notes from other users. We may review information about your use of these features, including the content and folders you create, any tags, labels, or notes you add to your saved content or folders, and any content that you share, and use such information to recommend content, tools, or other Clevyr products or services we think may be of interest to you. Information about your use of these features will only be accessible to Clevyr and will not be visible to or otherwise shared with other Clevyr clients unless you choose to share it.

2.9. Restricted Areas.

If you access the Restricted Areas of any of our sites (via browser or an app), we may collect information about your access to and use of administrative tools, research materials, and other online and offline resources we offer.

2.10. General Benchmarking and Research Purposes.

Clevyr may use information disclosed through surveys or otherwise provided to or generated by Clevyr or our users (collectively “Research Data”) for validation, research, and benchmarking purposes and product development. Unless otherwise specified prior to collection, Research Data will be disclosed in the aggregate and presented in anonymous form and will not include (directly or by inference) any information identifying participating organizations or any identifiable individual as the source of such data. Access to Research Data will be restricted to those individuals who need such access to develop, improve, or deliver Clevyr products and/or services.

3. When We Disclose Your Personal Information.

3.1. Permitted Disclosures to Third Parties.

We may disclose your personal information to third parties as follows:

When we have your consent to do so;
To third parties who work on our behalf to service or maintain business contact databases and other IT systems, e.g., suppliers of the IT systems which we use to process personal information, or who provide other technical services, such as printing;
To third parties providing services to us or on our behalf who have a need to access your information, e.g., our professional advisors (e.g. auditors and lawyers) or event venues;
To comply with applicable laws, protect rights, safety and property, and respond to lawful requests from public authorities (e.g., disclosing data in appropriate situations for national security or law enforcement purposes);
Subject to applicable law, in the event that Clevyr is merged, sold, or in the event of a transfer of some or all of our assets (including in bankruptcy), or in the event of another corporate change, in connection with such a transaction, or for pre-transaction review in relation to such transactions.

Your personal information may be shared if we anonymize and/or aggregate it, as in these circumstances the information will cease to be personal information.

3.2. Utilization Information.

We may share information with our organizational clients about how their employees use the products, services, and resources available to them through the products and services, such as how employees used certain features and integrations, utilization trends, which features were most popular with the client’s employees).

4. Your Rights in Regards to Your Data.

In certain circumstances, you have certain rights regarding your personal information. A summary of each right and how you can exercise it is set out below. To exercise any of these rights, please contact us at https://clevyr.com/contact.

Such requests should include information to allow us to verify your identity(e.g., your name, address, email address or other information reasonably required). If you are a California resident, please refer to Section 11 below for more detailed information on your rights under California law.

When we receive your request to exercise one of these rights, we will respond without undue delay and within the time required by applicable law. This may be extended in certain circumstances, e.g., where requests are complex or numerous.

We will provide the information free of charge, except where requests are manifestly unfounded or excessive, e.g. because of their repetitive character. In such circumstances we may charge a reasonable fee or may refuse to act on the request. We will advise you of any fees prior to proceeding with a request. We may ask for additional information to verify your identity before carrying out a request.

Right	How you can exercise the right
Right to access and/or correct your personal information	You have the right to access personal information we hold about you and to be provided with a copy of the information (in most circumstances). You also have the right to correct any information we may hold about you that is inaccurate.
Right to restrict use of your personal information	You have the right to ask us to restrict processing of your personal information where any of the following applies: The processing is unlawful but you want us to restrict use of the data instead of deleting it; Where you contest the accuracy of your personal information, the restriction will apply until we have verified the accuracy or corrected your personal information; We no longer require the personal information for the purposes of processing, but are required to keep it in connection with a legal claim; You have exercised your right to object to the processing. The restriction will apply until we have taken steps to verify whether we have compelling legitimate grounds to continue processing.
Right to request deletion of your personal information	You have the right to ask us to delete your personal information in certain circumstances. If you want to opt-out from receiving marketing communications, the best way to do so is to allow us to retain your information with a “do not contact” tag so we know not to contact you in the future. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal information is required to comply with a legal obligation or for the establishment, exercise or defense of legal claims.
Right to object to processing of your personal information	You may object to our use of your personal information for marketing purposes. You may also object to processing of your personal information in cases where we have used legitimate interests as the basis for processing. In such cases, we will stop processing your personal information until we verify that we have compelling legitimate grounds for processing that outweigh your interests, rights, and freedoms in asking us to stop processing the data, or in limited cases where we need to continue processing the data for the establishment, exercise, or defense of legal claims.
Right to data portability	In most cases, you have the right to receive all personal information you have provided to us in a structured, commonly used, and machine-readable format and to transmit this data to another data controller, where technically feasible.
Right to lodge a complaint with a supervisory authority	If you object to our processing of your personal information, you have the right to complain to the data protection authority (“DPA”) in the country where you reside, where you work, or where the alleged infringement of data protection laws has taken place.

5. Retention Periods.

We will retain your personal information for as long as required to perform the purposes for which the data was collected, depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations require us to retain it.

In general terms, this will mean that your personal information will be kept for the duration of our relationship with you and:

the period required by tax and company laws and regulations; and
as long as it is necessary for you to be able to bring a claim against us and for us to be able to defend ourselves against any legal claims. This will generally be the length of the relationship plus the length of any applicable statutory limitation period under local laws.

If you’d like us to delete user provided data that you have provided via our products or services, please contact us at https://clevyr.com/contact, and we will respond in a reasonable time. Please note that some or all of the user provided data may be required in order for our products or services to function properly.

6. Choices About Your Information.

6.1. Consent for Other Uses.

We believe it is important to give you choices about the use of your information. We will use your information as described in this Policy (or any other event- or service-specific Privacy Policy). If we want to use your information for a purpose not described in this Policy, we will first get your consent to do so.

6.2. Marketing Communications.

We will respect your wishes not to receive marketing communications. You can change your marketing preferences by contacting us at https://clevyr.com/contact.

If you gave us your email address to receive marketing communications, you can opt out at any time by using the unsubscribe links or instructions included at the bottom of our emails. Please note that we will continue to send you service-related communications regardless of any opt-out request.

We will not sell or share your information or information with third parties for their own promotional or marketing purposes unless you give us consent to do so and where permitted by applicable law.

7. Security

We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop, or improve our products and services. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches, and we cannot guarantee or warrant the security of any information you transmit via our websites or apps.

Please note that you are responsible for maintaining the security of your credentials used to access any Clevyr service or account, and you must report suspected unauthorized activity to us.

8. Cookies and Similar Technologies.

A cookie is a small text file which includes a unique identifier that is sent by a web server to the browser on your computer, mobile phone, or any other internet enabled device when you visit an on-line site. Cookies and similar technologies are widely used to make websites work efficiently and to collect and store information about your online preferences. For simplicity, we refer to all these technologies as "cookies".

Some of our website pages may contain electronic images known as web beacons (also known as clear gifs, tags or pixels) that allow us to count users who have visited our pages. Web beacons collect only limited information, e.g. a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. These beacons do not carry any information that could directly identify you. We may also include web beacons in email messages or newsletters to track whether you open the messages. We use this information to customize our services and measure the overall effectiveness of our online content, advertising campaigns, and products and services we offer.

9. Miscellaneous.

9.1. Links.

We provide links to other websites or resources that are not part of the products, programs, or services run by Clevyr. We do not control these websites or their privacy practices, and any information you provide to these sites is subject to the Privacy Policies of those sites and not this Policy.

9.2. Third-Party Integrations.

In certain of our products and services, we provide integrations to other websites, products, or services that are not part of the products, programs, or services owned by Clevyr. We do not control these sites or services or their privacy practices, and any information you provide to these integrated websites, products, or services is subject to the Privacy Policies of those sites and not this Policy.

9.3. Changes to this Policy.

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy at https://theloop.ai/privacy-policy. You are advised to consult this Privacy Policy regularly for any changes, as continued use of the products and services is deemed approval of all changes.

10. California Privacy Rights & Notice of Collection.

California law requires us to provide California residents with additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

Categories of personal information we collect. In Section 1, above, and otherwise throughout this Policy, we discuss in detail the specific pieces of information we collect from and about users. Below are the categories of personal information we collect:

Identifiers (such as name and title, contact details, and company name);
Internet or other network or device activity (such as browsing history or app usage);
Inference data about you; and
Other information that identifies or can be reasonably associated with you.

Use of categories of personal information. We may disclose the categories of personal information identified above for our operational purposes where the use is reasonably necessary and proportionate to achieve the operational purpose for which it was collected or processed, or for another compatible operational purpose.

Sale of Personal Information. The CCPA sets forth certain obligations for businesses that “sell” personal information. Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe we engage in such activity and have not engaged in such activity in the past twelve months (including that we do not “sell” the personal information of minors under 16 years of age). We do share certain information as set forth in Sections 1 and 2 of this Policy, and allow third parties to collect certain information about your activity, for example through cookies, as explained in Section 8 of this Policy.

Individual Rights. California law may provide you with certain rights and permit you to request the following:

Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
Provide access to and/or a copy of certain information we hold about you.
Delete certain information we have about you.

You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you and for compliance with applicable law. If you ask us to delete certain information, you may no longer be able to access or use the Services.

If you would like to exercise any of these rights, please contact us at https://clevyr.com/contact. You will be required to verify your identity before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

Subject to certain limits under California Civil Code § 1798.83, California residents may request certain information regarding our disclosure of information to third parties for their direct marketing purposes. To make such a request, please contact us at https://clevyr.com/contact.

California Online Privacy Protection Act Notice Concerning Do Not Track Signals. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser-related DNT signals, as the industry is currently working toward a common approach to responding to DNT. To learn more about Do Not Track, please click here.

11. Nevada Privacy Rights.

Nevada law requires us to provide certain Nevada consumers the ability to opt out of the “sale” of “personally identifiable information” as such terms are defined under Nevada law. We do not engage in such activity; however, if you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by sending a request via https://clevyr.com/contact.

Once your identity and contact information have been verified, we will maintain your request in the event our practices change.

How to Contact Us

If you have any questions regarding privacy while using any of our products or services, or have questions about our practices, please contact us https://clevyr.com/contact.