What Information Do We Collect From You?
We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services. The information we gather enables us to personalize, improve, understand and continue to operate the Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your Personal Data. Below explains in greater detail the types of information that we collect from our users.
Information You Provide to Us
If you create an Account, you will provide information that could be Personal Data, such as your email address and a password. You may also choose to provide additional Personal Data, including your contact name, information about yourself, basic demographic information including age and gender identity, a description of your channel, and links to your website or social media profiles.
Additionally, if you register for or access the Services using a Third Party Service (such as your social media account login credentials), we may receive Personal Data that you have made available to share through such Third Party Service, which may include, without limitation, your user ID, email, name, and image. You acknowledge that this information may be personal to you, and by creating an Account and providing Personal Data to us, you allow others, including us, to identify you and therefore may not be anonymous. We may use your contact information to send you information about our Services.
Information From Others
Information Collected Automatically
We automatically receive and record information from your web browser or device when you interact with the Services, including your IP address, device ID and cookie information. This information is used for fighting spam/malware and also to facilitate collection of data concerning your interaction with the Services (e.g., what links you have clicked on). Your IP address may be used to send you geographically-targeted advertisements. Generally, the Services automatically collect usage information, such as the number and frequency of visitors to the Site and the Services. We may use this data in aggregate form, for example, as a statistical measure or in other anonymous forms, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.
Information Collected Using Cookies
Information Related to Advertising and the Use of Web Beacons
We collect statistical information about how both unregistered and registered users, collectively, use the Services (“Aggregate Information”). Some of this information is derived from Personal Data. This statistical information is not Personal Data and cannot be tied back to you, your Account, or your web browser.
Personal Data of Children
As noted in the Terms of Service, we do not knowingly collect or solicit Personal Data from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us Personal Data, please contact us at firstname.lastname@example.org.
How, and With Whom, Is My Information Shared?
The Services are designed to help you share information with others. As a result, some of the information generated through the Services is shared publicly or with Third Party Services. Below further describes the ways in which we may share your information.
Public Information About You and Your Activity on the Services
User profile and channel information that you choose to provide, including your username, contact name, images you upload, information about yourself, a description of your channel, and links to your website or social media profiles, may be displayed to other users to facilitate user interaction within the Services. We will not directly reveal user email addresses to other users.
Please remember that if you choose to provide Personal Data using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.
Information Shared Through Third Party Services
Information Shared In Connection with Related Services
We also share Aggregate Information with our partners, service providers and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use our Services and their services or websites, which facilitates improving both their services and how our Services interface with them. In addition, these third parties may share with us non-private, aggregated or otherwise non Personal Information about you that they have independently developed or acquired.
Information Shared with Our Agents
We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share Personal Data with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use Personal Data or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Data with our Agents.
Information Disclosed Pursuant to a Change in Control or Sale
In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy.
Information Disclosed for Our Protection and the Protection of Others
Information We Share With Your Consent
Except as set forth herein, you will be notified when your Personal Data may be shared with third parties, and will be able to prevent the sharing of this information.
What Choices Do I Have Regarding My Information?
Access and Control Your Personal Data
Opt-Out of Targeted Advertising
We want you to know that by opting-out of targeted advertising does not mean that you will no longer receive advertising, but just that the advertising that you do receive will not be customized to you and may feel less relevant to you.
Delete Your Account
Should you ever decide to delete your Account, you may do so by emailing email@example.com. Please note that we will need to verify that you have the authority to delete the Account. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and may remain accessible to the public.
How Long Do We Retain Your Personal Data?
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
Is the Information About Me Secure?
Your Account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Data by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account.
We seek to protect Account information to ensure that it is kept private; however, we cannot guarantee the security of any Account information. We store all of our information, including your IP address information, using industry-standard techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Data or otherwise. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
What If I Have Questions or Concerns?
If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to firstname.lastname@example.org. We will make every effort to resolve your concerns.
Effective Date: July 10, 2018
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
If you have any questions about this section or whether any of the following applies to you, please contact us at email@example.com.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below. The legal bases depend on the Services you use and how you use them.
Examples of these legitimate interests include:
Personal Data of Children: We do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at firstname.lastname@example.org.
What Rights Do You Have Regarding Your Personal Data? You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email email@example.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
Transfers of Personal Data: The Services are hosted and operated in the United States (“U.S.”) through CLILK and our service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to CLILK in the U.S. and will be hosted on U.S. servers, and you authorize us to transfer, store and process your information to and in the U.S., and possibly other countries. CLILK is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
CLILK complies with the EU.-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Data transferred from the EU to the U.S. CLILK has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU. The Privacy Shield Principles require that we remain potentially liable if any third party processing Personal Data on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). To learn more about the Privacy Shield Program, please visit www.privacyshield.gov.
In compliance with Privacy Shield Principles, CLILK commits to resolve complaints about our collection or use of Personal Data. Please contact us at firstname.lastname@example.org with any questions or concerns relating to Privacy Shield policy. CLILK has further committed to refer any unresolved Privacy Shield complaints through International Centre for Dispute Resolution – American Arbitration Association (ICDR-AAA), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, you can visit http://go.adr.org/privacyshield.html for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means.
What If You Have Questions Regarding Your Personal Data? If you have any questions about this section or our data practices generally, please contact us using the following information:
Name: CLILK, Inc.
Email address for contact: email@example.com
Designated representative and contact information:
Mob.: +7 (499) 029 46 49 E-mail: firstname.lastname@example.org
Effective Date: October 02, 2018