"Company" or "We", as used in this policy, means: (i) if your are based in the US or North America, Clinch US Inc., and (ii) if you are based outside of the US or North America, Clinch Labs Ltd.
We recognize that privacy is important. This policy applies to all of the services, information, tools, features and functionality available on the Services offered by the Company or its subsidiaries or affiliated companies and covers how Information that the Company collects and receives, including in respect of any use of the Services, is treated. If you have any questions about this policy, please feel free to contact us at: firstname.lastname@example.org
1. Information We Collect and How We Use It. In order to provide and improve our Services, we may collect the following types of Information:
1.1. User Information. When you use our Services, we may automatically receive and record information from your device and browser, including information and statistics about your online status, your IP address, any type of device advertising ID (like IDFA/ADID), cookie information, browser ID, device ID, your regional and language settings, the physical location of your device (if you have permitted your location-aware device to transmit location data) – location data is used in real-time but not stored, network status (WiFi/ cellular carrier), and software and hardware attributes. We may use your location (city) (if you have permitted your location-aware device to transmit location data) to learn how to adjust and personalize your use of the Services. Our systems may automatically record and store technical information regarding the method and nature of your use of the Services, including without limitation which pages of the Services our visitors view and impressions. An IP address is a numeric code that identifies your device on a network, or in this case, the Internet. Your IP address is also used to gather broad demographic information. The Company uses all of the Information that we collect/use to understand the usage trends and preferences of our users. In EU countries, Clinch does not collect or store any user related data including IP, location, user agent, or any data that is considered PII or can be of aid to generate PII. In Addition, in EU countries, Clinch does not place cookies on the user browser.
1.2. Third Parties. Clinch may collect/use Information about you from third parties, such as social media platforms and online publishers. We sometimes supplement the Information that you provide with Information that is received from third parties.
1.3. Advertising. We may use your Information for providing targeted ads/interest based ads, cross-app advertising and ad delivery and reporting.
If you are a Clinch Solution user, please scroll down to Section 14 below entitled "Clinch Solution Users/Corporate Clients" for additional types of Information and its use.
2. Cookies. In order to collect/use the data described herein we may use temporary cookies that remain on your cookies file on your browser for a limited period of time. We may also use persistent cookies that remain on your cookies file on your browser until the cookies are removed via your browser's settings, in order to manage and maintain the Services and record your use of the Services and content you may have gained access to. Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to and stored on your computer. Cookies do not damage your computer. Most browsers may allow you to block cookies but you may not be able to use some features on the Services if you block them. You may set most browsers to notify you if you receive a cookie (this enables you to decide if you want to accept it or not). As noted in Section 1, in EU countries Clinch does not assign and/or place cookies on the user’s browser, nor uses any other method to track and/or identify the users or any user-related data.
We may also use web beacons via the Services to collect/use Information. Web beacons or "gifs", are electronic images that may be used in our Services. We use Web beacons to deliver cookies and to count visits. We also use third party (including Facebook, see their Data Policy), technologies, such as cookies and web beacons and various third party providers to process and analyze your Information and provide targeted ads/interest based ads, including without limitation tracking your use of the Services and elsewhere on the internet. Our systems use cross-device linking technologies in order to provide targeted ads/interest based ads to the same user across different devices, applications and sites.
3. Links. Links to third party services/sites (including advertisers) and applications may be provided by the Company as a convenience to our users. The Company is not responsible for the privacy practices or the content of other sites and applications and you visit them at your own risk. This privacy statement applies solely to Information collected/used by us.
4. Children. The Services are not intended or designed to attract children under the age of 13. The Company will not knowingly contact or engage with children under the age of 13 without said parental consent and do not intentionally gather, collect/use or share Information from children under the age of 13. If you have reason to believe that a child has provided us with their Information, please contact us at the address given above and we will endeavor to delete that Information from our databases.
5. Information Sharing. Except for de-identified and aggregate information, which we control, we are merely the processors of your Information on behalf of advertisement brokers, publishers and advertisers who serve the advertisements with which you interacted on the Services (e.g. by personalizing creative based on Information). They collect/use and process your Information . We require them to do so in accordance with applicable law, but we do not control their actions and therefore you are advised to review their privacy policies. As part of providing the Services, our affiliates, agents representatives and third party providers may have access to your Information . The Company may also share Information in the following circumstances: (a) as required for the provision, maintenance and improvement of the Services; (b) when permitted by you; (c) if we become involved in a reorganization, merger, consolidation, acquisition, or any form of sale of some or all of our assets; (d) to satisfy applicable law or prevention of fraud or harm or to enforce applicable agreements and/or their terms, including investigation of potential violations thereof; and/or (e) for processing the Information on our behalf. We require that our affiliates or other trusted businesses or persons processing the Information on our behalf agree to process such Information based on our instructions and in compliance with this policy and any other appropriate confidentiality and security measures.
6. Information Security and Retention. We follow generally accepted industry standards to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of Information. We keep your Information only for as long as reasonably necessary to fulfill a legitimate business need or to comply with any applicable legal or ethical reporting or document retention requirements. We retain advertising-related user Information, as mentioned in Section 1.2.1 above, for up to sixty (60) days from the last time we encountered a user. Cookies set via the Services expire within thirteen (13) months.
7. Data Integrity, Accessing and Updating Information. The Company processes Information only for the purposes for which it was collected/used and in accordance with this policy or any applicable service agreements. We review our data collection/usage, storage and processing practices to ensure that we only collect/use, store and process the Information needed to provide or improve our Services. We take reasonable steps to ensure that the Information we process is accurate, complete, and current, but we depend on our users to update or correct their Information whenever necessary. Nothing in this policy is interpreted as an obligation to store Information, and we may, at our own discretion, delete or avoid from recording and storing any and all information.
Upon receipt of your written request and enough information to permit us to identify your Information , we will disclose to you the Information we hold about you. Upon your request, we will also correct, amend or delete any Information that is inaccurate. We do not charge for complying with a correction request, however, for all other requests, we may charge a small fee to cover its costs. Requests to delete Information are subject to any applicable legal and ethical reporting or document retention obligations imposed on the Company. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical, or for which access is not otherwise required.
8. Enforcement. The Company regularly reviews its compliance with this policy. Please feel free to direct any questions or concerns regarding this policy or our treatment of Information by contacting us as provided above. When we receive formal written complaints it is the Company's policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of Information that cannot be resolved between the Company and an individual.
10. Consent To Processing. All users fully understand and unambiguously consent to this policy and to the collection and processing of Information (including abroad). The server on which the Services are hosted and/or are processed may be outside the country from which you access the Services and may be outside your country of residence. Some of the uses and disclosures mentioned in this policy may involve the transfer of your Information to various countries around the world that may have different levels of privacy protection than your country. By submitting your Information through the Services, you consent, acknowledge, and agree that we may collect, use, transfer, and disclose your Information as described in this policy. If you do not consent to the terms of this policy, please do not use the Services.
11. Questions. If you have any questions about this policy or concerns about the way we process your Information , please contact us at email@example.com. If you wish to delete all Information regarding your use of the Services, please contact us at: firstname.lastname@example.org.
12. Your California Privacy Rights and Do Not Track Notices. California Civil Code Section 1798.83 permits customers of Company who are California residents to request certain information regarding its disclosure of Information to third parties for their direct marketing purposes. To make such a request, please contact us at email@example.com. Please note that we are only required to respond to one request per customer each year. You are also advised that Company does not respond to “Do Not Track” signals.
13.1. Clinch Opt-Out Mechanism. If you prefer not to receive interest-based advertising, you can opt-out here. If you do opt-out, Clinch will set a cookie on your browser that tells Clinch not to tailor ads to your interests. Opting-out does not mean you will not be served advertisements by Clinch, but the advertisements we serve will be less relevant to your interests (although they are optimized based on statistics). Please note that the opt-out cookie only applies to the computer and browser where it is set.
13.2. Mobile Opt-Out. You may also limit ad tracking in mobile app environments on your device. For the most effective and up-to-date methods for doing so, you may consult https://www.networkadvertising.org/mobile-choice
13.3. NAI Membership. Additionally, Clinch is a member of the Network Advertising Initiative ("NAI") and adheres with the NAI Code of Conduct. You may visit http://optout.networkadvertising.org/#!/ to find out more about the NAI’s Self-Regulatory Program and to opt-out of Clinch and other NAI member company advertising programs.
14. Clinch Solution Users/Corporate Clients. If you are a Clinch Solution User/Corporate Client we may collect additional types of Information and use it as set forth below:
14.1.1. Information You Provide. We may collect/use the following Information for registration purposes and for provision of the Services: name, email address, job title and phone number.
14.1.2. User Communications. When you send communications to the Company, we may retain those communications in order to process your inquiries, respond to your requests and improve our Services. We may send you messages and other communications regarding news and updates in respect of the Services. We may also send you newsletters and promotional communications, you may opt-out of this service at any time by submitting a request at the following link: firstname.lastname@example.org.
14.1.3. Aggregate and Analytical Data. In an ongoing effort to better understand and serve the customers of the Services, Clinch may compile and analyze aggregated data generated from the Services in order to improve and personalize the Services including for the benefit of the Clinch Solution users. We may share this aggregate data with our affiliates, agents and business partners. This aggregate information does not identify you or any other individual personally. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
Last Date Updated: March 12, 2018.