Privacy Policy

Effective date: 09/07/2020

Hey!

This is the legal bit...

Below is our Privacy Policy. As a company, we’re 100% committed to safeguarding your information. We believe everyone has the right to digital security and protection. This means we take laws around data and privacy very seriously and make sure we fully comply with all of them.

You’ll also find our Terms and Conditions here too.

Please read it carefully to learn about your rights, the information we collect, how we use it and protect it.

Please reach out to us with any questions. We’re always super happy to hear from you and want to help you out wherever we can.

You can email hello@weareclario.com or feel free to write us a letter and send it to 7 Stratford Place, Marylebone, London, United Kingdom, W1C 1AY.

1. So, who are we?

We are Clario Tech Limited! We’re located at 7 Stratford Place, Marylebone, London, United Kingdom, W1C 1AY (hereinafter "Clario" or "Company"). Clario is a data controller and responsible for any personal data processed. We strictly follow all data protection procedures regarding the security of your personal data. You can read about how we collect and manage your information in this document, our Privacy Policy.

2. What does this Privacy Policy apply to?

This Privacy Policy applies to the Company’s products, services, and websites (jointly hereinafter the “Services”), namely:

  1. Product (Clario, Clario mobile application);
  2. Website: https://clario.co as well as any other linked pages and online services offered by the Company (hereinafter jointly known as the “Website”).

3. What kind of data do we process?

Well, this is the data we receive from you when you sign up to use our Services.

We collect certain categories of personal data as described below to provide you with our Services.

Third-party data.

Some of your personal data including your name, email address, the last four digits of the credit card number, the type of subscription you bought, the price, etc. may be processed and provided to us by third-party payment processors, such as FastSpring©, after the checkout stage. Please note we don't process information related to your credit card number or other payment data. Your credit card is passed directly to our payment processor and does not go through our servers.

Read the FastSpring® Privacy Policy to find out more about how they handle your data.

Account registration data.

You may access our Website without providing any of your data. However, to use the Product after the purchase you will be required to create a Clario account ("Account"), then install it. We will use your name and email address provided to us by FastSpring© to pre-populate our sign up form and allow you to create an Account and use Clario Services. You are free to edit the pre-populated email address at this stage.You will be asked just to enter a password to complete your Account creation.

To create the Account you’ll need to provide us with the following information:

  1. Name;
  2. Account login and password;
  3. Email address.

Data we automatically receive.

When you enter our Website, reply to our emails, or send us your inquiries, in addition to any data you provide us (such as basic contact details including name, telephone number, and email), we may automatically collect some information to optimize your experience when using our Website and improve the Product itself. This includes:

  1. Device information;
  2. User configuration information;
  3. Cookies information. Please read our Cookie Policy carefully for more details about the information we collect when you use our Website as well as how to manage cookies;
  4. Browser information.

Data collected via Product.

When you use our Product, we may collect different types of data. This includes:

  1. Name;
  2. Email;
  3. Telephone number;
  4. Information about your device (OS version, serial number, device name, model, MAC address, platform, overall system information);
  5. Device characteristics (type, CPU, RAM, VGA, memory, processor, etc.)
  6. The password to the system (in case of remote fixes);
  7. Information about your apps (e.g. versions, size, date of the last update, etc.), services, and software/hardware you use;
  8. IP address;
  9. Browser information (name; version);
  10. Network details;
  11. Wi-FI spots;
  12. Your Product activity information (including bugs, crashes, or system errors);
  13. Some non-personalized session and interaction data - application events (like first launch, log in, log out, and the like). We collect this data as it is crucial for us to ensure the proper functioning of our Product;
  14. Chat correspondence;
  15. Audio and/or video recording of a call/session;
  16. Static images of your screen, which may be captured during the remote session;
  17. Results of remote fixes;
  18. Results of data breaches, malware, and Disk scan.

To provide you with our Product or its specific features (also known as areas), the Company may use third-party software components. Some of these third-party materials may be subject to other terms and conditions. By accepting our Privacy Policy, you indicate your agreement to the terms and conditions of NordVPN’s Terms of Service and Privacy Policy, and BitDefender Privacy Policy and Terms of Services while activating and using VPN functionality and antivirus protection respectively.

Help from the experts.

Our experts may offer remote access services to assist in diagnosing and resolving security and privacy issues. In addition, experts will be able to help you fix technical issues and answer system questions related to your device. To perform a remote connection, experts must receive your prior explicit consent to do so. Explicit consent means an individual is clearly presented with an option to agree or disagree with the collection, use, or disclosure of personal data, then unambiguously signal his or her agreement.

Additionally, you can terminate the connection at any time. Experts will describe to you how to disconnect within the session.

The entire process allows the expert to access your device remotely to diagnose any conditions interfering with its security and privacy settings as well as technical performance. They can either repair it or provide advice on the available solutions to fix the issue. By taking advantage of this service, you are giving permission to the expert to log in to your device, which may contain your personal data, files, documents, etc.

We strongly recommend you secure your sensitive files before the expert remotely connects to your device. Please do not leave these files on your desktop. It is your responsibility to make your valuable information inaccessible to prevent any type of data loss or corruption. You can use built-in encryption tools on your device to make your files inaccessible to others.

Here you can find step-by-step instructions on how to do so:

  1. Mac user - http://www.hongkiat.com/blog/encrypt-mac-folder/;
  2. Windows user - http://www.computerhope.com/issues/ch000705.htm;

In addition, even if you do not secure or encrypt your files and they are stored on your desktop, experts will only search your device to identify security and privacy issues hindering its performance. They will attempt to keep their interaction with your files to a minimum.

When you request help from our experts, they may access your device remotely via third-party software, such as LogMeIn® and TeamViewer. By accepting our Privacy Policy, you therefore accept the Terms & Conditions and Privacy Policy of LogMeIn® and Terms & Conditions and Privacy Policy of TeamViewer. Please read all Privacy Policies listed above to make sure you agree with all conditions; otherwise, do not purchase or use our service.

Children’s data.

We don’t process the personal data of anyone below the age of 16 without prior parental consent. If you are under 16 years of age, then please do not use or access our Services. We will delete the personal data of a child aged under 16 which is processed without parental consent. If you are a parent or guardian and discover your child is using our Services, then contact us at hello@weareclario.com and request to delete the child’s personal data.

4. Why do we process your data?

We use data for the fast and efficient rendering of services to our customers. Also, we use your data for other reasons such as safety and security, customer support, Company communications, compliance with legal obligations, and also for research and development.

Provide you with our Product.

We process data to provide you with a personalized experience and to maintain and improve our Product. This includes using the data to:

  1. Create and update your Account;
  2. Password recovery;
  3. Enable your access to Product features (areas);
  4. Provide you with expert assistance;
  5. Deliver or install some programs or assistance tools and software;
  6. Help resolve issues related to Clario Services;
  7. Answer your questions and inquiries;
  8. Monitor and improve our expert support;
  9. Perform necessary operations to provide you with a fully functioning Product, such as troubleshooting software bugs and operational problems, to make data analysis, testing, research and to monitor and analyze usage trends.

Safety and security.

We use data to help maintain the safety and integrity of our Services. This includes using data to:

  1. Prevent, detect and combat fraud;
  2. Enforce our Terms and Conditions.

Communications and marketing.

We use personal data to communicate with you, i.e., send you notifications (including any information about changes to this Policy), newsletters, alerts, personalized recommendations, tutorials, and other Product related materials.

Moreover, we use collected personal data to provide support and assistance to you, respond to any inquiries you make, and resolve disputes.

If we receive your prior opt-in consent, we may contact you via email to tell you about special offers, promotions, and update you on our products or services. You may opt out of future contact from us at any time by using the method provided in the email (such as clicking on an unsubscribe link), or contacting us via email hello@weareclario.com.

Feedback.

If you take part in a product preview or test, we expect you to provide feedback on product use and to share your valuable user experience with us as well as any suggestions on further product development. Thus, we may use your personal data in order to conduct interviews with you (including via emails or phone calls), send you satisfaction surveys, research, feedback reminders, and collect your feedback in order to understand your experience and improve our products.

Research and development.

We may use the data we collect for the purpose of testing, analysis, research, statistics and overall development of the product. This also allows us to enhance safety and security and to develop new features.

Also, we may share some of the collected data with third parties only for analysis and statistics to improve our Services.

For instance, we use a third-party analytical tool provided by AppsFlyer Inc. (100 1st Street, 25th floor San Francisco, California 94105, USA) for analytical purposes within the Clario mobile application (hereinafter the “App”).

We may collect and share with AppsFlyer some session and interaction data to research and analyze how you have found our App (for example, which advertiser delivered an ad that led you to our Product in App Store). Also, based on this data AppsFlyer helps us to understand how you use our app as well as improve user-friendliness of our app and to make it easier for you to use (for instance, by providing statistical patterns of our App use). The session and interaction data is collected and shared after being rendered anonymously, and is only evaluated in anonymised, summarised form and used for analytical and statistical purposes only.

In order to receive analytical services from AppsFlyer, we may share such data as:

  1. device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier;
  2. IDFA (Apple identifier for advertisers), Google Advertiser ID and other similar unique identifiers;
  3. information relating to your actions in the App (like clicks on the ads, ad impressions viewed, the URL from the referring website, downloads and installations of Applications), and other interactions, events, and actions (like registration, login, start trial, purchases made).

Please check the AppsFlyer Privacy Policy to get more information on how AppsFlyer processes your data.

We use Analytics for Firebase and Crashlytics - service from Google LLC. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) in order to derive App analytics, see how users interact with our App, as well as track and prevent any bug affecting our iOS and Android App.

Firebase services process personal data, but, in most cases, it is limited to so-called “instance IDs”, which are provided with a time stamp. These “Instance IDs” assigned by Firebase are unique and thus allow the linking of different events or processes. This data does not represent personally identifiable information. We process these aggregated data to analyze and optimize usage behavior.

Namely, while you are using our App, certain information may be sent to Google:

  1. device information (like name, type, OS version, and certain hardware information about your mobile device, settings, and language of the device);
  2. unique identifier of App installation;
  3. version and functionality of the App;
  4. time of the crash, the state of the application at the time of the crash, and stack traces.

Data transmitted to Crashlytics neither stored or transferred to other services or resources, nor associated with other data available to Google.

For Analytics for Firebase, Google uses not only the “Instance ID” described above, but also the advertising ID of the end device. You can restrict the use of the advertising ID in the device settings of your mobile device:

  1. For Android: Settings > Google > Ads > Reset Ad ID
  2. For iOS: Settings > Privacy > Advertising > No ad tracking

Please see more information on Firebase and Crashlytics privacy settings here:

  1. https://docs.fabric.io/apple/fabric/data-privacy.html;
  2. https://firebase.google.com/products/analytics;

Google privacy policy is available at:

  1. https://policies.google.com/privacy.

Both AppsFlyer and Google are certified under the Privacy Shield and thus guarantee compliance with European privacy laws.

If you do not wish to be tracked by AppsFlyer or transfer information to the Google in the future, you can opt out at any time via:

  1. App settings;
  2. Email to hello@weareclario.com.

Also, you may opt out of future transmission of data from your device to AppsFlyer's servers by using the Opt-Out Button.

We may anonymize your personal data when you stop using our Services. Anonymous data does not relate to a particular person, so we are unable to re-identify you. However, anonymous data does allow us to improve our Services.

Specific features.

We may use your data to provide you with specific features (areas) of our Product. For instance:

  1. “Identity”
  2. “Browsing”
  3. “Device”
  4. “Money”
  5. “Network”
  6. “Data”

Compliance with legal obligations.

We collect your data to comply with our legal obligations. Also, we may use the data we collect to investigate or address claims or disputes in relation to the usage of the Services or as otherwise allowed by applicable law, or as requested by regulators or government entities.

5. What are the grounds for data processing?

Before proceeding to the processing of your personal data (as described in section 4) we evaluate the data we collect, then we determine the legal basis of processing. We use the following basis to collect and process your data: performance of a contract, compliance with legal obligations, our legitimate interest, and your consent.

Description of why Company
processes your personal data
(“processing purpose”)

To provide you with the Product

Safety and security

Communications and marketing

Compliance with legal obligations

Research and development

Specific features

Legal basis for the processing
purpose

Performance of a Contract

Legitimate interest

Performance of a Contract
Consent
Legitimate interest

Compliance with legal obligations

Legitimate interest

Consent

Categories of personal data used by
the Company for the processing
purpose

  1. Account registration data
  2. Data that we receive
    automatically
  3. Data collected via Product
  1. Account registration data
  1. Account registration data
  2. Data collected via Product
  1. Account registration data
  2. Data that we receive
    automatically
  3. Data collected via Product
  1. Account registration data
  2. Data that we receive
    automatically
  3. Data collected via Product
  1. Account registration data
  2. Data we receive
    automatically
  3. Data collected via
    Product

Your Consent.

Sometimes we may need to process your personal data for purposes not listed in this Policy. In such cases, we’ll ask for your prior consent before proceeding in order to process your personal data. You may withdraw your consent at any time by emailing us at hello@weareclario.com.

6. Do we share or disclose your data?

We may share your data with some companies, consultants and contractors we hire to provide limited services on our behalf. These organisations or bodies value data privacy as much as we do. We will only provide those companies with personal data they need to deliver the Service. Also, we may disclose your data if we receive a governmental request and when it is required by applicable law. Or we may share data with your consent.

We do not sell, rent, or trade your personal data to anyone.

We will not sell your personal data to any company or organization, but we may transfer your personal data to a successor entity upon a merger, consolidation or other corporate reorganization in which we may participate or to a purchaser or acquirer of all or a substantial part of Company’s assets to which this application relates. In such an event, we will notify you before your personal data is transferred and becomes subject to a different Privacy Policy.

7. Do we transfer your data?

We may need to process your data outside of your country of residence. We apply measures to protect our data transfers and use all appropriate safeguards such as standard contractual clauses adopted by the European Commission.

8. How do we handle your data?

The security of your personal data is very important to us, and we do our best to keep it secure.

Data security.

We protect your data by using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Please be aware we are not responsible for the privacy policies of other websites and services linked to from our Website.

Data storage.

We will retain your personal data for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

9. How can you manage your data?

If you would like to access, review, update, rectify, and delete any personal data we hold about you, simply send your request directly to dpo@weareclario.com. Please use the email address used for the Account creation, address your inquiry to an expert via chat, or call 1 (800) 9908699 (US/CA), 8000698411 (UK), 1 (800) 823948 (AU).

We will process your request immediately upon receipt. However, please note it may take up to thirty (30) days from receipt for your request to be implemented. Once your request is implemented, we will notify you by follow-up email accordingly.

Also, you can exercise a right to object or restrict processing and data portability. Please, address inquiries for the execution of these rights to dpo@weareclario.com. In case you are unhappy with how we handle your data, you have a right to lodge a complaint with a supervisory authority.

Access.

You can request an explanation of the personal data we process about you. Also, you can request a copy of your personal data undergoing processing.

Rectification.

You can correct any inaccurate data about you, or you can update your personal data.

Data portability.

You have a right to receive the personal data concerning you, which you provided to us. You can make a request to transmit this data directly to another data controller in a structured, commonly used and machine-readable format. We will transmit your data directly to another controller in cases where it is technically feasible.

Erasure.

You have the right to delete all personal data you have provided to us. We may retain certain information as required by law and for legitimate business purposes permitted by law.

Restrict processing.

You can request us to temporarily or permanently stop processing all or some of your personal data.

Object processing.

You can, at any time, object to the processing of your personal data on grounds relating to your particular situation. For example, you have a right to object to your personal data being processed for direct marketing purposes.

Lodge complaints.

You have a right to file a complaint with a supervisory authority in relation to the Company’s usage of your personal data.

10. California privacy rights

We make these disclosures to California residents visiting our website which supersede and replace any conflicting disclosures found elsewhere on our website as well as reflecting privacy rights granted by the California Consumer Privacy Act (CCPA) with effect from January 1, 2020.

Opt-out of disclosure for direct marketing purposes.

California Civil Code Section 1798.83 permits California residents to learn the identities of entities sent their personal data for marketing purposes and the categories of information disclosed. You may request such information by emailing hello@weareclario.com. Please reference California Privacy Rights in your subject line. You may also write to us at 7 Stratford Place, Marylebone, London, United Kingdom, W1C 1AY.

Please be aware this opt-out does not prohibit our disclosure of personal data for any purpose other than direct marketing. The data we process and share may include your name, address, email address, and telephone number.

Automatic gathering of information.

We collect data you provide to us online, and through websites of unaffiliated third parties.

Automatic gathering of information by third parties.

When you visit our website, third parties can collect personal data about your online activities over time and across different websites pertaining to your visit to or use of our and other websites.

Do-not-track requests.

California residents visiting our website may request we do not automatically gather and track information pertaining to their online browsing movements across the Internet. Such requests are typically made through web browser settings controlling signals or other mechanisms providing consumers with the ability to exercise choice regarding the collection of personal data about online activities, third-party websites or online services. We currently do not have the ability to honor these requests. We may modify this Policy as our abilities change.

The CCPA rights.

The CCPA has extended California residents' data protection rights. However, we have already guaranteed all these rights and described them precisely in this Policy as well as a means of rights exercising. Please refer below to find out more.

Right to be informed.

Please find a list of personal data we collect about you and your activity, sources and business purposes of personal data collection, and third parties we may share your personal data with in Sections 3 - 7 of this Policy.

Your Right of access, Data portability, and Right to delete are outlined in Section 9 of this Policy.

You can exercise these rights any time by contacting us via:

  1. email dpo@weareclario.com;
  2. Contact us form.
  3. product chat by addressing your inquiry to an expert;
  4. call to 1 (800) 990-8699.

Non-discrimitation right.

We will not discriminate (including by denying products or services, charging different prices for products or services, providing different quality of products and services) against you for exercising any of your CCPA data protection rights.

Note, the CCPA envisages some specific requirements related to the exercising of these data protection rights. Considering them we may:

  1. respond to your request within 45 (forty five) days of receiving the request;
  2. provide you with personal data we collected about you no more than twice in a 12-month period (categories and specific pieces of collected personal data, business purpose and sources of collection, categories of third parties personal data is shared with);
  3. NOT provide you with personal data if we cannot verify your identity. You shall provide us with sufficient information to verify you as the person about whom we collected personal data to gain access. However, we do consider requests made through your Account sufficiently verified;
  4. NOT transmit your personal data to another entity.

Also, please be aware we are allowed to maintain personal data after a deletion request is received as permitted by the CCPA (for instance, for the purposes of detection of security incidents, repair errors, compliance with legal obligations, transaction completion).

We want to highlight how the Company does not sell, rent, or trade your personal data to anyone.

11. Changes to this Policy

From time to time, we may amend this Policy in response to changing legal, technical or business developments and we recommend reviewing it to stay up to date. When we update our Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make (via email or by displaying the information within our product or on the website). Find out when this Policy was last updated by checking the “updated” date displayed at the top of this document.

12. Contact Us

If you have any questions or suggestions concerning our Privacy Policy, don’t hesitate to contact us at hello@weareclario.com.