Last updated: 25 November 2021
Claroo Ltd. and its affiliates (collectively, “Claroo”, “we”, “our”, and “us”) have a commitment to safeguard the privacy of information entrusted to us and value the trust of our existing and prospective business relations. The privacy principles set forth are intended to tell you how we collect, retain, and use personal information about you in accordance with applicable law.
When we mention "Claroo", "we", "us" or "our" in these principles, we are referring to the relevant entity responsible for processing your data. Claroo is the data controller and responsible for deciding how we use and hold your personal information.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation ("UK GDPR"), the EU General Data Protection Regulation ("EU GDPR") in relation to the goods and/or services (as the case may be) we offer to customers.
You, our employees and any third parties can report any complaints or unethical behaviour in a confidential manner to email@example.com.
Collection and Use of Personal Information
We may process personal information that identifies you as an individual or that relates to an identifiable person (“Personal Information”) such as:
- • Personal Details and Contact Information: Name; address; e-mail; telephone and fax details, signature and electronic signatures
- • Professional Affiliations: Business name, title, and address;
- • Financial Information: Payment card number; bank account number and account details; tax returns; salary; assets and income; personal bankruptcy; credit history and credit score;
- • Operational Data: Transactions, sales, purchases, uses, supplier information, credentials to online services and platforms, and electronic content produced by data subjects using company systems, including online interactive and voice communications, such as blog, chat, webcam use and network sessions;
- • Any further information required for credit verification, compliance/ethics checks, or customer due diligence;
We may collect Personal Information in various ways, such as: when you interact with one of our websites; when you enter into a transaction or contractual arrangement with us; when you participate in our programs or activities; when you provide data at industry events and trade shows; when you visit our facilities or we visit you at your offices; when you contact our customers services; or in connection with your inquiries and communications with us.
Additionally, the website operator may automatically collect or process Personal Information (such as your Internet domain or IP address) as part of the operation of the services or during the course of your activities on or use of the websites.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
We and our service providers use Personal Information for legitimate business purposes including:
- • Providing the functionality of the services and fulfilling your requests.
- ⚬ To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, or when you request a quote for or other information about our services.
- ⚬ To conclude and execute agreements with customers, suppliers and business partners, including required screening activities (e.g. for access to our premises or systems, or credit verification, compliance/ethics checks or customer due diligence.
- ⚬ To complete your transactions and provide you with related customer service.
- ⚬ To send administrative information to you, such as changes to our terms, conditions and policies.
- ⚬ To allow you to send messages to another person if you choose to do so.
We will engage in these activities where we have a legitimate interest, to manage our contractual relationship with you, and/or to comply with a legal obligation.
- • Providing you with marketing materials.
- ⚬ To send you marketing related emails, with information about our services, new products and other news in relation to Claroo. We will only engage in this activity with your consent or where we have a legitimate interest.
- • Analysis of Personal Information for business reporting and providing personalized services.
- ⚬ To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our services.
- ⚬ To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
- ⚬ To better understand your preferences so that we can deliver content via our services that we believe will be relevant and interesting to you.
We will provide personalized services either with your consent or because we have a legitimate interest.
- • Accomplishing our business purposes.
- ⚬ For data analysis, for example, to improve the efficiency of our services;
- ⚬ For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
- ⚬ For fraud and security monitoring purposes, for example, to detect and prevent cyber attacks or attempts to commit identity theft;
- ⚬ For developing new products and services;
- ⚬ For enhancing, improving, or modifying our current products and services;
- ⚬ For identifying usage trends, for example, understanding which parts of our services are of most interest to users;
- ⚬ For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
- ⚬ For operating and expanding our business activities, for example, understanding which parts of our services are of most interest to our users so we can focus our energies on meeting our users’ interests.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
How Personal Information is shared with third parties
We may disclose Personal Information to third parties assisting us in carrying out a transaction or providing services for you (such as packaging, sending and delivering purchases and information to you, clearing credit card transactions, or performing statistical analyses of our services). We may also disclose your Personal Information to our third party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, HR services & payroll, and other services.
We will not sell, trade, or disclose your Personal Information to third parties that want to market products to you.
Other uses and disclosures
We may use or disclose Personal Information as we believe to be necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions or in response to activities that are unlawful or a violation of any relevant terms and conditions, or applicable rules, for use of the Website; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
In addition, we have a legitimate interest to use, disclose or transfer your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
Other information we may collect, including ‘cookies’
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
- • Browser and device information
- • App usage data
- • Information collected through cookies, pixel tags and other technologies
- • Demographic information and other information provided by you that does not reveal your specific identity,
- • Information that has been aggregated in a manner that it no longer reveals your specific identity
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
- • Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the services (such as the app) you are using. We use this information to ensure that the services function properly.
Claroo has implemented adequate technological and operational security processes to protect your personally identifiable information from loss, misuse, alteration, or unintentional destruction. While no security measure can guarantee against compromise, Claroo regularly reviews and updates its security measures in an effort to provide appropriate security for all information held by Claroo. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
Change of purpose
We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so and to the extent required by applicable law, seek your consent.
To the extent a specific element of our processing of your Personal Information relies upon your consent, you may withdraw your consent at any time with future effect. A withdrawal of your consent will not affect the lawfulness of the processing prior to the consent withdrawal.
Claroo wants to maintain only accurate information about users. You have the right to request that we rectify inaccurate Personal Information concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal information completed, including by means of providing a supplementary statement.
You have the right to obtain from us confirmation as to whether or not Personal Information concerning you is being processed, and, where that is the case, to request access to your Personal Information. This access information includes, among others, the purposes of the processing, the categories of Personal Information concerned, and the recipients or categories of recipient to whom the Personal Information has been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.
Under certain circumstances, you have the right to ask us to erase Personal Information concerning you and we may be obliged to erase such Personal Information. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
Under certain circumstances:
- a) you have the right to ask us to restrict the processing of your Personal Information. If so, the applicable Personal Information will be marked and may only be processed by us for certain purposes.
- b) you have the right to ask us to provide you with your Personal Information, in a structured, commonly used and machine-readable format and you have the right to transmit that data to another entity without hindrance from us.
- c) you can object on grounds of relating to your particular situation at any time to the processing of your Personal Information by us and require us to stop processing your Personal Information. The right to object may especially apply if we collect and process your Personal Information for profiling purposes in order to better understand your interests in our products and services or for direct marketing. If you have a right to object and you exercise this right, we will no longer process your Personal Information for those purposes. You may exercise this right by contacting us. The right to object may, in particular, not exist if the processing of your Personal Information is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
Claroo will not retain your Personal Information longer than is necessary and permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Jurisdiction and cross-border transfer
Your Personal Information may be collected or processed by, and transferred to, processing facilities in North America (including Canada), Europe, Southeast Asia, Latin America and the United Kingdom and in other countries and such region(s) thereof, as applicable, where Claroo does business. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the apps or our social media pages.
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
If you have a complaint about the way in which we process your Personal Information, please contact us as referenced above and we will endeavor to address your concerns. You can also contact the competent data protection supervisory authority, details of which we can provide upon request.