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Cleap Privacy Policy

Last Revised: December 6, 2019

 

Introduction

 

Clean Pay Ltd. ("us", "we" or "Company") respect the privacy of our users (each, "you" or "User") and are committed to protect the privacy of Users who access, engage, use, download, install or register to our mobile application(s) (the "Application"), or any other online services we provide (collectively: the "Services").

 

Please note that the terms "you" or "User" shall refer to customers and store owners, as applicable.

 

Our privacy policy ("Privacy Policy") will help you understand what types of information we collect through the Services, how the Company use it, and what choices you have. We encourage you to read this Privacy Policy carefully and use it to make informed decisions. By using our Services, you agree to the terms of this Privacy Policy and your continued use of the Services constitutes your ongoing agreement to the Privacy Policy.

 

In this Privacy Policy, you will read about, among other things:

 

  • What type of information we collect

  • How we use the information

  • With whom we share the information and for what purpose

  • International transfer

  • For how long we retain the information

  • Your privacy rights

  • How we protect your information

  • Minors

  • How to contact us

 

What type of information we collect

 

We may collect the following types of data and information from or about you:

 

Non-personal Information

The first type of information is un-identified and non-identifiable information pertaining to you, which may be made available or gathered via your use of the Services ("Non-personal Information"). We are not aware of the identity of the user from which the Non-personal Information is collected. Non-personal Information which is collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information about your device (e.g., the device you use, the type of browser and operating system your device uses, language preference, access time, the website's domain name from which you linked to the Services, etc.). We may use this information in order to administer the Services and analyze this information to improve and enhance the Services by expanding their features and functionality. Such information may also be used for troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services. We may also collect information about your activity on the Services (e.g., receipts for your purchases).

 

For the avoidance of doubt, if we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information as long as it remains combined.

 

Personal Information

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual ("Personal Information"). Such information may include:

  • Registration Information: When signing-up or registering to our Services, we may collect certain information that can be used to identify you. You may register to the Services directly through the Application or through your social network account.

 

  • Registering through the Application: When you register to the Services through the Application, we may collect from you the following information: phone number, as well as other relevant details that you agreed to share with us.

 

  • Registering through social network account: When you register or sign-in to the Services via your social network account (e.g., Facebook), we may have access to basic information from your social network account, such as your full name, home address, email address, birthdate, profile picture, friends list, personal description, as well as any other information you made publicly available on such account or agreed to share with us. At all times, we will abide by the terms, conditions and restrictions of the social network platform.

 

  • Voluntary Information: We may collect information that you provide us voluntarily. For instance, when you respond to communications from us, ask our support, communicate with us via email or share additional information about yourself through your use of the Services. We may also collect the feedback, suggestions, complaints and reports that you send to us.

 

  • Device Information: We may collect specific types of connection details and information with regard to your device, software or hardware that may identify you. Such information may include: geolocation data and device’s unique identifiers.

 

For the avoidance of doubt, please note that with respect to login information that is provided by the Users, the Company will act as a "data controller" and will handle such information in accordance with the provisions of this Privacy Policy.

 

If you have any reason to believe that our Services are misused, in any way, please do not hesitate to inform us at: info@cleapapp.com.

 

How we use the information

 

We use the information in the manners described in this Privacy Policy. In addition to the purposes listed herein, the information we collect, which may include your Personal Information, is used for the following purposes:

 

  • To set up Users' accounts;

  • To identify and authenticate Users' access to certain features of our Services;

  • To provide the Services to our Users;

  • To serve you personalized advertisements when you use the Services;

  • To support and troubleshoot our Services and to respond to your queries;

  • To communicate with you and to keep you informed of our latest updates;

  • To obtain Users’ feedback with regards to the Services;

  • To perform a research or to conduct analytics in order to improve and customize the Services to Users' needs and interests;

  • To investigate and resolve disputes in connection with your use of the Services;

  • To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and

  • To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

 

With whom we share the information and for what purpose

We do not rent or sell any Personal Information. We may share Personal Information with the following recipients: (i) our subsidiaries; (ii) affiliated companies; (iii) trusted subcontractors and third-party service providers (e.g., Microsoft Azure); (iv) auditors or advisers of our business processes; and (v) any potential purchasers or investors in the Company.

 

We may share Personal Information with our recipients for any of the following purposes: (i) storing or processing Personal Information on our behalf (e.g., cloud computing service providers); (ii) assisting us with our business operations; and (iii) performing research, technical diagnostics, personalization and analytics that will enable us to improve the Services.

 

We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our agreements), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our affiliates, our users, yourself or any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.

Third-party collection of information

 

Our Privacy Policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via the Services (e.g., by clicking on a link to any other website or location) or via other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them.

 

You acknowledge that we are not responsible for the products, services, or descriptions of products or services that you receive from third-party sites or to the content or privacy practices of those sites, and that this Privacy Policy does not apply to any such third-party products and services. You are knowingly and voluntarily assuming all risks of using third-party sites to purchase products and services. You agree that we shall have no liability whatsoever with respect to such third-party sites and your usage of them.

International transfer

Since we operate globally, it may be necessary to transfer data, including Personal Information, to countries outside the European Union. In these instances, we will transfer your data only to such countries as approved by the European Commission as providing an adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.

For how long we retain the information

 

We retain the information that we collect from Users for as long as needed to provide our Services and to comply with our legal obligations, resolve disputes and enforce our agreements (unless we are instructed otherwise). Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we may keep records containing Users Personal Information, account opening documents, communications and anything else as required by applicable laws and regulations.

 

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Your privacy rights

Certain jurisdictions provide Users with certain statutory rights to their Personal Information. Subject to exemptions provided by law, and with proper identification, you may have the right to certain actions to your Personal Information such as:

 

  • Right to verify your Personal Information (to access, delete, change or update any Personal Information relating to you. For example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted);

  • Right to see what Personal Information about you we have;

  • Right to request that we erase Personal Information about you (subject to any other legal obligation that may require us to keep that information);

  • Right to restrict us from processing Personal Information pertaining to you (for example, you may request that we will stop using or sharing your Personal Information with third-parties); and

  • Right to export Personal Information in a portable format.

If you wish to exercise any of these rights, contact us at: info@cleapapp.com. When handling your request, we will ask for additional information to confirm your identity (which may include Personal Information). However, please note that if you choose not to allow us to process your Personal Information, we may be prevented from providing our Services.

 

Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.

 

If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at: info@cleapapp.com.

 

If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can file a complaint to the applicable data protection authority.

How we protect your information

We take great care in implementing and maintaining the security of the Services and your information. We employ industry standard procedures and policies to ensure the confidentiality, integrity, and availability of your information, the safety of your Personal Information and prevent unauthorized use of any such information.

However, we cannot guarantee that hackers or unauthorized personnel will not gain access to information despite our efforts. You should note that by using our Services, your information would be transferred through third-party infrastructures that are not under our control. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security, and we make no warranty, express, implied or otherwise, that we will prevent unauthorized access to our Services.

 

If you believe that your privacy was not treated in accordance with our Privacy Policy, or if any person attempted to abuse our Services or acted in an inappropriate manner, it will be advisable to contact us directly at: info@cleapapp.com.

Corporate transaction

We may share information, including Personal Information, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale of an asset or transfer in the operation thereof) of the Company. In the event of the above, the acquiring company or transferee will assume the rights and obligations as described in this Privacy Policy.

 

Minors

The Services are not designated to individuals under the age of 16. If you are under 16 years old, you should not download the Application, use the Services, or provide any Personal Information to us.

 

We reserve the right to access and verify any Personal Information that is collected from you by us. In the event that we become aware that an individual under the age of 16 has shared any information, we will discard such information. If you have any reason to believe that a minor shared any information with us, it will be advisable to contact us at: info@cleapapp.com.

 

Updates or amendments to the Privacy Policy

We may revise this Privacy Policy from time to time, in our sole discretion, and the most current version will always be posted on our website or Application (as reflected in the "Last Revised" heading). In the event of a material change to the Privacy Policy, we will notify you through the Services or via email, or you may be notified within the Application. We encourage you to review this Privacy Policy regularly for any changes.

 

Your continued use of the Services, following the notification of such amendments, constitutes your acknowledgement and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

 

How to contact us

If you have any general questions regarding the Services or the information that we collect about you and how we use it, please contact us at: info@cleapapp.com.

 

Information about us

The details of the Company are as follows:

Clean Pay Ltd.

Tel Aviv, Israel, 6765315