Privacy Policy

Privacy Policy of Clever & Dynamic Systems SRL

Clever Marketing is committed to protecting your personal data. This privacy policy (“Privacy Policy”) governs Clever Marketing’s use of data collected by us, including any and all personal data. Personal data is information that relates to you and may identify you as an individual. We use your personal data in line with all applicable laws. To ensure compliance and to align with Clever Marketing’s values around trust and transparency we have a team of privacy champions responsible for continuously implementing our global privacy program.

Much of this Privacy Policy is divided into sections based on the way you may interact with Clever Marketing. You are either a Site Visitor, a User and/or a Business Partner (as defined below). Please determine what user type you are. For each user type we’ve explained what information we collect and why, what cookies and other similar technologies we use, how we share such information and your rights.

Site Visitors:

 You are a Site Visitor when you visit and interact with our web sites, web pages, interactive features, blogs and their respective contents.

(a) What information we collect and why

We want to understand what services on Our Sites interest you and we want to remind you about the services we offer when you are not on Our Sites. In order to do this, we collect the following information from your device: (i) IP address; (ii) User Agent data: device type (e.g., iPhone), browser type (e.g., Chrome), operating system (e.g., iOS); (iii) the pages visited on Our Sites (e.g., the Clever Marketing “About” page); (iv) the time of visit (and corresponding time zone); and (v) referring URLs and other information normally transmitted in HTTP requests (e.g. information telling us how you arrived on Our Sites).

In addition, we may also collect your name and email address if you agree to send your details to us via Our Sites (e.g., by signing up to receive our newsletter).

(b) What cookies and other similar technologies we use

Please see this 

Cookie Table which is updated from time to time, under the section “Site Visitors” for a detailed list of first and third party cookies (and their corresponding retention periods) that may be used when you visit Our Sites.

(c) How we may share information

  • Sharing Information we learn about you on Our Sites

We do not sell and/or share personal data about you with third parties for third party marketing or advertising purposes. We may use various third parties (each listed on the

 

Cookie Table

To help us market or advertise to you. We require that these third parties and companies agree to comply with all applicable data protection laws, keep all information shared with them confidential and to use the information only to perform their obligations to us. We do this by entering into agreements with all third parties who process personal data. If you post on our blog, your comment and information will be publicly available. Please contact [email protected] to remove your comment.

  • Using Third Party Services on Our Sites

Our Sites contain links to other websites that we do not own or operate. We do not control, recommend or endorse the content, products, services, privacy policies or practices of these third party websites. For example, on Our Sites you will notice clickable icons which take you to the Clever Marketing Facebook page or the Clever Marketing LinkedIn page. If you choose to click on these links, you should know that these sites are not owned or operated by Clever Marketing and therefore these third party websites may send their own cookies to your device and they may independently collect personal data. It is therefore important that you get familiar with the privacy policies of these third party websites.

Also see the Sharing section of this Privacy Policy.

(d) Your rights

Our 

Terms of Use

 govern your use of Our Sites and apply to you when you interact with Our Sites. You can stop using Our Sites at any time. If you do, you may also want to remove any cookies that we have placed on any device used to access Our Sites, you can do this via your browser. If during your use of Our Sites you provided your email address, any email you receive from Clever Marketing includes an “unsubscribe” option. In addition, you may also opt-out of direct marketing by emailing [email protected].

.

For Site Visitors in the European Territory, Clever Marketing has implemented a consent management platform (powered by 

OneTrust

) on Our Sites that provides you with the opportunity to consent, or not consent, to cookies and similar tracking technologies. Upon accessing Our Sites, you will see a banner in the centre of the page with information about the cookies we use. You may click the banner to reject any cookies (for example, performance cookies or targeting cookies) that are not strictly necessary cookies (as defined in the Cookie Table). By pressing “I Accept” on the banner you are indicating your acceptance to cookies and similar tracking technologies. Clever Marketing lawful basis for processing personal data of European Territory Site Visitors on Our Sites is consent. You may withdraw your consent at any time by clicking this button:

 

Cookies Settings

 

In respect of all other Site Visitors not located in European Territories, we rely on our legitimate interest for processing any personal data however, this does not preclude non-European Territory Site Visitors from withdrawing consent at any time via our consent management platform.

Users:

 You are a User when you visit a page of a website or application of one of Clever Marketing partners where the Clever Marketing widget is installed or our recommendations are placed (“Partner Sites”). The Clever Marketing widget is implemented on those websites. You know you are engaging with an Clever Marketing widget when you see text referencing Clever Marketing (e.g., “Recommended by Security

Clever Marketing has a dedicated security team. We maintain tight controls over the personal data we collect, retaining it in firewalled and secured databases with strictly limited and controlled access rights, to ensure it is secure. Please see our 

security standards

 for more information.

Business Partners have access to certain password-protected features of the Amplify or Engage service. Business Partners are responsible for keeping this password confidential and for ensuring the same for their employees and/or their agents. Please remember that, unfortunately, the transmission of information via the internet is never completely secure. A common Internet scam is known as “spoofing” or “phishing.” This occurs when you receive an email from what appears to be a legitimate source requesting personal data from you. Please be aware that we will not send you any emails requesting you to verify credit card, bank information, or any other personal data. If you ever receive an email that appears to be from us requesting such information from you, do not respond to it, and do not click on any links appearing in the email. Instead, please forward the email to us at [email protected] as we will investigate instances of possible Internet fraud.

Data Transfers Outside the EU/EEA

When we transfer personal data from the European Economic Area (EEA) we will ensure such transfers are in compliance with relevant data protection laws, including, if applicable, EU Standard Contractual Clauses, or a European Commission positive adequacy decision under Article 25(6) of Directive 95/46/EC or Article 45 of the GDPR. In other words, your rights and protections remain with your data and we used approved contractual clauses and other measures designed to ensure that the recipients of your personal data protect it. Clever Marketing has in place the Standard Contractual Clauses between Clever Marketing entities to govern the transfer of data outside of the EEA.

Sharing

In addition to the description of how we may disclose your personal data for each user type, we may also disclose personal data as follows:

  • Within the family of companies controlled by Clever Marketing for internal reasons, primarily for business and operational purposes;

  • If we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, your personal data will likely be among the assets transferred;

  • When legally required to do so (e.g., to cooperate with law enforcement investigations or other legal proceedings); and/or

  • To respond to a genuine emergency.

In addition, we combine your personal data with those of other users in order to share trend information and aggregate user statistics with third parties, always in aggregated and anonymized form.

Data Retention

The retention period for each of the cookies Clever Marketing uses (whether our own or on our behalf by third parties) is stated in the 

Cookie Table

. More specifically, the Clever Marketing cookie (Obuid),which is used for tracking user actions such as clicks, expires three (3) months after a user visited a particular site within our network however, this cookie will reset if a user returns to the same site or different site within our network. In addition, we do not retain any individual data point on a User for more than 13 months. For example, if UUID 123 read an article on December 31, 2018, on February 1, 2019 that article will no longer be part of UUID 123’s profile. Clever Marketing also maintains a Data Retention Policy that details the retention period for personal data based on our analysis of how long the specific data is reasonably required for legal or business purposes. When we no longer need personal data, we securely delete or destroy it. Aggregated data, which cannot identify a device/browser (or individual) and is used for purposes of reporting and analysis, is maintained for as long as commercially necessary.”, “by Clever Marketing” near recommendations If you click on the hyperlinked reference to Clever Marketing you will see a 

detailed notice

 that enables you to navigate to 

Clever Marketing Interest Portal

 and this Privacy Policy where you can opt out of personalized recommendations. In some instances, a partner may have white-label Clever Marketing service for their own offering. In such an event, such partners must disclose their use of Clever Marketing in their privacy policies.

Security

Clever Marketing has a dedicated security team. We maintain tight controls over the personal data we collect, retaining it in firewalled and secured databases with strictly limited and controlled access rights, to ensure it is secure. Please see our 

security standards

 for more information.

Business Partners have access to certain password-protected features of the Amplify or Engage service. Business Partners are responsible for keeping this password confidential and for ensuring the same for their employees and/or their agents. Please remember that, unfortunately, the transmission of information via the internet is never completely secure. A common Internet scam is known as “spoofing” or “phishing.” This occurs when you receive an email from what appears to be a legitimate source requesting personal data from you. Please be aware that we will not send you any emails requesting you to verify credit card, bank information, or any other personal data. If you ever receive an email that appears to be from us requesting such information from you, do not respond to it, and do not click on any links appearing in the email. Instead, please forward the email to us at [email protected].

, as we will investigate instances of possible Internet fraud.

Data Transfers Outside the EU/EEA

When we transfer personal data from the European Economic Area (EEA) we will ensure such transfers are in compliance with relevant data protection laws, including, if applicable, EU Standard Contractual Clauses, or a European Commission positive adequacy decision under Article 25(6) of Directive 95/46/EC or Article 45 of the GDPR. In other words, your rights and protections remain with your data and we used approved contractual clauses and other measures designed to ensure that the recipients of your personal data protect it. Clever Marketing has in place the Standard Contractual Clauses between Clever Marketing entities to govern the transfer of data outside of the EEA.

Sharing

In addition to the description of how we may disclose your personal data for each user type, we may also disclose personal data as follows:

  • Within the family of companies controlled by Clever Marketing for internal reasons, primarily for business and operational purposes;

  • If we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, your personal data will likely be among the assets transferred;

  • When legally required to do so (e.g., to cooperate with law enforcement investigations or other legal proceedings); and/or

  • To respond to a genuine emergency.

In addition, we combine your personal data with those of other users in order to share trend information and aggregate user statistics with third parties, always in aggregated and anonymized form.

Data Retention

The retention period for each of the cookies Clever Marketing uses (whether our own or on our behalf by third parties) is stated in the 

Cookie Table

More specifically, the Clever Marketing cookie (Obuid),which is used for tracking user actions such as clicks, expires three (3) months after a user visited a particular site within our network however, this cookie will reset if a user returns to the same site or different site within our network. In addition, we do not retain any individual data point on a User for more than 13 months. For example, if UUID 123 read an article on December 31, 2018, on February 1, 2019 that article will no longer be part of UUID 123’s profile. Clever Marketing also maintains a Data Retention Policy that details the retention period for personal data based on our analysis of how long the specific data is reasonably required for legal or business purposes. When we no longer need personal data, we securely delete or destroy it. Aggregated data, which cannot identify a device/browser (or individual) and is used for purposes of reporting and analysis, is maintained for as long as commercially necessary.

Children

None of our services are intentionally directed at children under 16. We do not knowingly collect personal data from anyone under 16 years of age. If we determine upon collection that a Site Visitor, a User or a Business Partner is under 16, we will not use or maintain his/her personal data. If we become aware that we have unknowingly collected personal data from a child under the age of 16, we will make reasonable efforts to delete such information from our records. If you’re a kid, please go play in the yard, don’t use or interact with Clever Marketing!

Sensitive data

We do not collect or receive any sensitive categories of personal data.

In compliance with certain privacy laws, in particular the European General Data Protection Regulation (GDPR), Clever Marketing provides specific additional rights for individuals who interact with Clever Marketing such as the right to access, rectification, right to object, to complaint, erasure and blockage. More specifically and under certain circumstances:

  • the right to request information about whether and which personal data is processed by us, and the right to demand that personal data is rectified or amended.

  • the right to request that personal data should be deleted.

  • the right to demand that the processing of personal data should be restricted.

  • withdraw your consent to the processing and use of your data completely or partially at any time with future application.

  • have the right to obtain your personal data in a common, structured and mechanically readable format.

  • contact our data protection officer if there are any questions, comments, complaints or requests in connection with our statement on data protection and the processing of your personal data.

  • the right to complain to the responsible supervisory authority if believed that the processing of your personal data is in violation of the legislation.

In addition to the above, we reference certain rights for European Territory citizens throughout this Privacy Policy. Pursuant to the GDPR, citizens from “European Territories” mean the European Economic Area (EEA), the European Free Trade Area (EFTA) and Switzerland. For the purpose of this Privacy Policy, the term “European Territories” shall continue to include the United Kingdom, even after the United Kingdom leaves the European Economic Area following Brexit. If you are in the UK, or the European Economic Areas, the controller of your data is Clever Marketing.

Please email [email protected] with any questions about exercising any of the above rights.

Some browsers transmit Do Not Track (DNT) signals to websites. Because there is no common understanding of how to interpret the DNT signal, Clever Marketing does not currently alter, change, or respond to DNT requests or signals from these browsers. We will continue to monitor industry activity in this area and reassess our DNT practices as necessary. In the meantime, you can use the range of other tools we provide to control data collection and use, including the ability to opt out of receiving personalized recommendations in the Users section.

We may change this Privacy Policy from time to time. We will place a prominent notice that will be visible to you as a Site Visitor or Business Partner, but we do not have a means of advising Users of an update by way of notice. You should check back here periodically to see if the Privacy Policy has been updated as we will always show the date of the latest modification of the Privacy Policy at the top of the page so you can tell when it was last revised.

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