Privacy Policy
This Privacy Policy outlines how Clued.ai collects, uses, and shares your information when you use our service. It also explains your privacy rights and how they are protected under Western Australian law.
We collect and use your personal data to provide and enhance our service. By using our service, you agree to our collection and use of your information as described in this policy.
For the purposes of this Privacy Policy, the following definitions apply:
- “Account” refers to the unique account created for you to access our service.
- “Company” (also referred to as “we”, “us”, or “our”) means Clued.ai, the legal entity providing the service.
- “Cookies” are small files placed on your device by our website to track your browsing history.
- “Device” means any electronic device, such as a computer, mobile phone, or digital tablet, that can access our service.
- “Personal Data” refers to any information that can be used to identify you, such as your name, location data, or online identifier.
- “Service” means the online and/or mobile services, website, and software provided by Clued.ai.
- “Usage Data” refers to data collected automatically, either generated by your use of the service or from the service infrastructure itself.
By using our service, you consent to the collection and use of your personal data in accordance with this Privacy Policy. We may also share your information with third-party service providers who assist us in providing the service.
Collection of personal information
You can access and use the Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features offered on the Services, you may be asked to provide certain Personal Information (for example, your name and e-mail address).
We receive and store any information you knowingly provide to us when you create an account, make a purchase, or fill any forms on the Services. When required, this information may include the following:
– Account details (such as user name, unique user ID, password, etc)
– Contact information (such as email address, phone number, etc)
– Basic personal information (such as name, country of residence, etc)
– Sensitive personal information (such as ethnicity, religious beliefs, mental health, etc)
– Biometric information (such as facial recognition, fingerprints, etc)
– Proof of identity (such as a photocopy of a government ID)
– Payment information (such as credit card details, bank details, etc)
– Geolocation data of your device (such as latitude and longitude)
– Certain features on the mobile device (such as contacts, calendar, gallery, etc)
– Information about other individuals (such as your family members, friends, etc)
– Any other materials you willingly submit to us (such as articles, images, feedback, etc)
Some of the information we collect is directly from you via the Services. However, we may also collect Personal Information about you from other sources such as social media platforms, public databases, third-party data providers, and our joint partners. Personal Information we collect from other sources may include demographic information, such as age and gender, device information, such as IP addresses, location, such as city and state, and online behavioural data, such as information about your use of social media websites, page view information and search results and links.
You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features on the Services. Users who are uncertain about what information is mandatory are welcome to contact us.
Privacy of children
We recognize the need to provide further privacy protections with respect to Personal Information we may collect from children under the age of 13 and take many special precautions to protect their privacy. We may require a child to disclose some Personal Information to use the Services. However, we do not require a child to disclose more information than is reasonably necessary to use the Services and Personal Information will not be used or disclosed for purposes other than those for which it was collected. All of the information created or submitted by a child is set to private by default, meaning only the User who submitted it may view it.
We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Services without their permission. We also ask that all parents and legal guardians overseeing the care of children take the necessary precautions to ensure that their children are instructed to never give out Personal Information when online without their permission. We believe parents and legal guardians should be involved in the online activities of their children and suggest that parents do their best to provide their children with a safe and friendly online environment.
Use and processing of collected information
We act as a data controller and a data processor in terms of the GDPR when handling Personal Information, unless we have entered into a data processing agreement with you in which case you would be the data controller and we would be the data processor.
Our role may also differ depending on the specific situation involving Personal Information. We act in the capacity of a data controller when we ask you to submit your Personal Information that is necessary to ensure your access and use of the Services. In such instances, we are a data controller because we determine the purposes and means of the processing of Personal Information and we comply with data controllers’ obligations set forth in the GDPR.
We act in the capacity of a data processor in situations when you submit Personal Information through the Services. We do not own, control, or make decisions about the submitted Personal Information, and such Personal Information is processed only in accordance with your instructions. In such instances, the User providing Personal Information acts as a data controller in terms of the GDPR.
In order to make the Services available to you, or to meet a legal obligation, we may need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used for the following purposes:
– Create and manage user accounts
– Fulfil and manage orders
– Deliver products or services
– Improve products and services
– Send administrative information
– Send marketing and promotional communications
– Send product and service updates
– Respond to inquiries and offer support
– Request user feedback
– Improve user experience
– Post customer testimonials
– Deliver targeted advertising
– Administer prize draws and competitions
– Enforce terms and conditions and policies
– Protect from abuse and malicious users
– Respond to legal requests and prevent harm
– Run and operate the Services
Processing your Personal Information depends on how you interact with the Services, where you are located in the world and if one of the following applies: (i) you have given your consent for one or more specific purposes; this, however, does not apply, whenever the processing of Personal Information is subject to California Consumer Privacy Act or European data protection law; (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which you are subject; (iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party. We may also combine or aggregate some of your Personal Information in order to better serve you and to improve and update our Services.
We rely on user’s consent and our own legitimate interests as legal bases as defined in the GDPR upon which we collect and process your Personal Information.
Note that under some legislations we may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other of the legal bases above. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Payment processing
In case of Services requiring payment, you may need to provide your credit card details or other payment account information, which will be used solely for processing payments. We use third-party payment processors (“Payment Processors”) to assist us in processing your payment information securely.
Payment Processors adhere to the latest security standards as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. Sensitive and private data exchange happens over a SSL secured communication channel and is encrypted and protected with digital signatures, and the Services are also in compliance with strict vulnerability standards in order to create as secure of an environment as possible for Users. We will share payment data with the Payment Processors only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries related to such payments and refunds.
Please note that the Payment Processors may collect some Personal Information from you, which allows them to process your payments (e.g., your email address, address, credit card details, and bank account number) and handle all the steps in the payment process through their systems, including data collection and data processing. Where necessary for processing future or recurring payments and subject to your prior consent, your financial information will be stored in encrypted form on secure servers of our Payment Processors. The Payment Processors’ use of your Personal Information is governed by their respective privacy policies which may or may not contain privacy protections as protective as this Policy. We suggest that you review their respective privacy policies.
Disclosure of information
Depending on the requested Services or as necessary to complete any transaction or provide any Service you have requested, we may share your information with our trusted subsidiaries and joint venture partners, affiliates, contracted companies, and service providers (collectively, “Service Providers”) we rely upon to assist in the operation of the Services available to you and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. We will not share any information with unaffiliated third parties.
Service Providers are not authorised to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Service Providers are given the information they need only in order to perform their designated functions, and we do not authorise them to use or disclose any of the provided information for their own marketing or other purposes. We will share and disclose your information only with the following categories of Service Providers:
– Advertising networks
– Affiliate programs
– Cloud computing services
– Communication and collaboration services
– Data analytics services
– Data storage services
– Financial services
– Government agencies
– Order fulfilment services
– Payment processors
– Performance monitoring services
– Product engineering and design services
– Sales and marketing services
– Social networks
– User authentication services
– Website hosting service providers
We may also disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and your Personal Information will likely be among the assets transferred.
If you have any questions or concerns about our use of your personal data, please contact us at Clued.group@gmail.com
This document was last updated on April 27, 2023
