Effective Date: This Privacy Policy was last revised on March 23, 2023.
Introduction
This Privacy Policy explains how Clever Content LLC and its group companies (collectively "Clever Content", "we", "us", and "our") collect, use, share, and protect your personal data when you use our website https://www.womensandfashion.com and any other Clever Content websites, apps, and services that link to this Privacy Policy (collectively, the "Services"). We make available through these web sites and/or that post a link to this Privacy Policy (collectively, referred to herein as the “ Site”), regardless of how you access or use the Site, whether via personal computers, mobile devices or otherwise. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Service (unless otherwise stated below).
To the extent we provide you notice on our Site of different or additional privacy policies or practices ( e.g., at the point of our collection), those additional terms shall govern such data collection and use.
In addition, please review the Site's Terms and Conditions of Service which governs your use of the Site. By using our Site,you consent to our Privacy Policy and Terms and Conditions of Service and our collection, use and sharing of your information and data, and other activities, as described below.
Scope of Privacy Policy
This Privacy Policy explains how we collect, use, disclose and manage your personal information that you provide to us when using the Site or otherwise, as well as our privacy practices. This Privacy Policy applies, without limitation, to any individual or entity that (i) uses the Site, (ii) creates an Account (as defined in our Terms of Service), or (iii) otherwise provides any personal information to us.
WHEN YOU ACCESS OR USE THE SITE, OR OTHERWISE PROVIDE ANY INFORMATION TO US, YOU AGREE TO THIS PRIVACY POLICY, INCLUDING THE MANNER IN WHICH WE USE YOUR INFORMATION, WHETHER OR NOT YOU HAVE AN ACCOUNT WITH Clever Content LLC. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES WE SUBSEQUENTLY MAKE TO THIS PRIVACY POLICY, YOU MUST IMMEDIATELY STOP USING THE SITE OR OTHERWISE PROVIDING ANY INFORMATION TO US.
The Site contains links to other websites. This Privacy Policy does not apply to information collected on or through any such third party websites. We are not responsible for the privacy practices of such third parties or the content of their websites. Such third parties have their own privacy policies and you should review those privacy policies to determine their privacy practices.
Linkable Table of Contents
The Full Detailed Privacy Policy
1. Information We Collect
We collect the following information:
2. How We Collect Information
We may collect this information through various forms and in various places on the Site, including if you register for a newsletter, through “contact us” forms, or when you otherwise interact with the Site.
Ways that we collect information include but are not limited to the following:
3. Use of Tracking Technologies
We may use various developed methods and technologies to collect Usage Information (“ Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):
Cookies. A cookie is a data file placed on a Device when it is used to visit the Site. HTML5 cookies can be programmed through HTML5 local storage. HTML5 cookies do not require a plug-in. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to HTML5 cookies. Please be aware that if you disable or remove cookies or HTML5 cookies on your Device, some parts of our Site may not function properly, and that when you revisit our Site your ability to limit cookies is subject to your browser settings and limitations.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Site's pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP and/or HTML5 cookies.
We may use Tracking Technologies for a variety of purposes, including:
There may be other Tracking Technologies now and later devised and used by us in connection with the Site. Further, third parties may use Tracking Technologies in connection with our Site, which may include the collection of information about your online activities over time and across third-party web sites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third-party Tracking Technologies in connection with use of our Site and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties.
(f) California / Delaware Do Not Track Disclosures
Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer's online activities over time and across third-party web sites or online services ( e.g., browser do not track signals). We currently monitor or take action with respect to these signals or other mechanisms to the extent we are required to, in accordance with the CCPA.
4. How We Use the Information Collected
(a) Use of Information By Us
We may use your information for various purposes, including:
Where you have consented (or not opted out, as applicable), we may add your information to our databases to contact you through future emails, postal mailings and SMS text-messaging regarding site updates, upcoming events, and new products and services. When you sign up for an account with us, we will send you a welcome email. We will also communicate with you in response to your inquiries, to provide any services you request, to provide newsletters or other updates that you request and to manage your account. In addition, when you register an Account with us, you can consent to our contacting you by email and to receiving our email subscriptions, editorial emails and advertorial emails (see below) from us. If, at any time, you no longer want us to contact you by email and/or receive our email subscriptions, editorial emails and advertorial emails, you can opt out of these functions by changing the preferences in your Account. You can contact customer service by email, telephone or postal mail at the contact information listed below to assist you with any such changes to your Account. If you have an Account with us, then from time to time, and in addition to emails or email subscriptions sent by us, we will send you emails that contain advertising or other content sponsored by third party retailers or businesses (“advertorial emails”). These advertorial emails are clearly marked as such in the subject line and a note at the top of the article itself. The content is paid for by our sponsors and does not reflect the opinions of our editorial staff. If you prefer not to receive these emails, you can deactivate your Account or otherwise opt-out as provided in the “Opting Out” section of this Privacy Policy below. We send advertorial emails on behalf of the third party sponsors. We do not share your personally identifiable information with such sponsors, except as otherwise provided in this Privacy Policy, but we can sell or share aggregate, non-personal information with such sponsors for any legally permissible purpose.
(b) Use of Information for Recruitment Purposes
Where you have provided us with information as part of an online application for employment or internship, we may use that information in order to allow us to make an informed decision about whether to proceed with your application. We may, as part of this recruitment process, collect information about your education, employment history and similar matters. Where this information is considered to be sensitive, you expressly consent to our processing of this information for recruitment purposes by submitting it to us.
5. How and When We Disclose Information to Third Parties
We may share non-personal information, such as aggregated user statistics, with third parties. Further, we may share your Device Identifiers with third parties along with data related to you and your activities. We do not share your personal information that we have collected directly from you on our Site with third parties for those third parties' direct marketing purposes unless you have consented (either through an opt-in our opt-out opportunity) at the time you provide your personal information. In addition, we may share the information we have collected about you, including personal information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. Clever Content LLC may disclose your information as follows:
(a) When You Request Information From or Provide Information to Third Parties
You may be presented with an option on our Site to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our Site or link to them from our Site. This may include using third party tools such as Facebook, Twitter, Pinterest or other third party posting or content sharing tools. Your use of these features may result in the collection or sharing of information about you by these sites or applications, depending on the feature. It may also include ordering or purchasing products from third parties through us where we indicate that the third party rather than us is the seller. We have no control over and are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.
(b) Third Parties Providing Services on Our Behalf
We may use third-party vendors to perform certain services on behalf of us or the Site, such as: (a) to assist us in Site operations; (b) to manage a database of customer information; (c) hosting the Site; (d) designing and/or operating the Site's features; (e) tracking the Site's activities and analytics; (f) enabling us to send you special offers or perform other administrative services; and (g) other services designed to assist us in maximizing our business potential. We may provide vendors with access to your information to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own technologies on your Device and they may otherwise collect or have access to information about you. We are not responsible for those third party technologies or activities arising out of them. However, some third parties may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available in the chart at the end of this Privacy Policy. We are not responsible for the effectiveness of or compliance with any third parties' opt-out options.
(c) Administrative and Legal Reasons
We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information) to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Site's Terms and Conditions of Service or other policies applicable to the Site, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Site or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.
(d) Affiliates and Business Transfer
We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.
(e) Co-branded Areas
Certain areas of the Site may be provided to you in association with third parties (“ Co-Branded Areas”) such as our donation partners, and may require you to disclose Personal Information to them. Such Co-Branded Areas will identify the third party and indicate if they have a privacy policy that applies to their collection and use of you information. If you elect to register for products and/or services, communicate with such third parties or download their content or applications, at Co-Branded Areas, you may be providing your information to both us and the third party. Further, if you sign-in to a Co-Branded Area with a username and password obtained on the Site, your Personal Information may be disclosed to the identified third parties for that Co-Branded Area. We are not responsible for such third party's data collection or practices and you should look to such third party privacy policies for more information.
(f) Sweepstakes, Contests and Promotions
We may offer sweepstakes, contests, and other promotions (any, a “ Promotion”) through the Site that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners list.
6.Publicly Disclosed Information
(a) User-Generated Content and Public Information
The Site may permit you to submit ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content, including Personal Information (collectively, “ User Content”), such as on profiles, blogs and message boards. We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you. Others may have access to this User Content and may have the ability to share it with third parties. Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Please note that Clever Content LLC does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. Our promises under this Privacy Policy do not apply to any information that you disclose publicly, share with others or otherwise upload onto the publicly available positions of our Site. We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the Site.
(b) Name and Likeness
We may also publish your name, voice, likeness and other Personal Information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities. For full terms and conditions regarding User Content you submit to the Site, please review our Terms and Conditions of Service .
7. Ads and Information About You
We may use third parties such as network advertisers and ad exchanges to serve advertisements across the Internet and may use third party analytics service providers to evaluate and provide us and/or third parties with information about the use of these ads on third party sites and viewing of ads and of our content. Network advertisers are third parties that display advertisements, which may be based on your activities across the Internet and mobile media (“ Behavioral Ads”). Behavioral Ads enable us to target advertisements to you for products and services in which we believe you might be interested. If you object to receiving Behavioral Ads from us on third party sites, you can learn more about your ability to limit Behavioral Ads below. Our third party ad network and exchange providers, the advertisers and/or traffic measurement services may themselves set and access their own technologies on your Device and track certain behavioral Usage Information via a Device Identifier. These third party technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements; and (c) understand the usefulness of the advertisements that have been delivered to you. Note that any images (or any other parts of a web page) served by third parties in association with third party cookies can serve as web beacons, which enable third parties to carry out the previously described activities. Third party cookies, web beacons and other third party technologies are governed by each third party's specific privacy policy, not this one.
Statements regarding our practices do not apply to the methods for collecting information used by these third parties or the use of the information that such third parties collect. We do however work with third parties to make efforts to have you provided with information on their practices and any available opportunity to exercise choice. The relevant third party's terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third party advertisers or advertising networks or exchanges or related third parties.
We may also use third-party advertising companies to target Behavioral Ads to you on our Site, across the web, on your mobile device and on any of your other devices, based on the information we have collected from and about you, as well as information relating to your and other users' visits to this and other websites and online services. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags) or recognize an identifier associated with your mobile device. These companies may also use Tracking Technologies, along with personal information they or we collect on the different Devices you use, to recognize you across the Devices you use, such as a mobile Device and a laptop or other computer. Some third parties may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available in a chart at the end of this Privacy Policy.
8. Opt-Out of Third Party Tracking
You can opt out of the Ad Tech Network by clicking https://www.youronlinechoices.com/opt-out-interface.
If you would like to opt out of having interest-based information collected during your visits to our Website or other sites, both the National Advertising Initiative (the “NAI”) and the Digital Advertising Alliance (the “DAA”) offer opt out tools to assist you in managing your choices. Click https://www.networkadvertising.org/choices/ to visit the NAI opt out page and click https://www.aboutads.info/choices/ for the DAA opt out page.
Further, while sites use a variety of companies to serve advertisements, you may wish to visit https://www.networkadvertising.org/optout_nonppii.asp, which provides information regarding this practice by Network Advertising Initiative (“ NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members. Opting out of one or more NAI members only means that those NAI members no longer will be allowed under their own rules to deliver Behavioral Ads to you, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different Device or change web browsers, your NAI opt-out may not, or may no longer, be effective.
You may also opt-out from receiving Behavioral Ads on participating sites and services by visiting the Digital Advertising Alliance (“ DAA”) website at https://www.aboutads.info/choices/. You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps. Similar limitations may apply to the DAA opt-out.
When you use our website, we share information that we may collect from you, such as your email (in hashed form), IP address or information about your browser or operating system, with our partner/service provider, LiveRamp Inc and its group companies (‘LiveRamp'). LiveRamp may use our first party cookie on your browser to match your shared information to their marketing databases in order to provide back a pseudonymous privacy-centric identifier for our use in real time bidding in digital advertising. These third parties may in turn link further demographic or interest-based information to your browser. To opt out of this use, please click here (https://liveramp.com/opt_out/).
When you link out to products on certain affiliated retailer websites, we work with Rakuten Advertising in order to share your information with the retailer to complete your transaction, which is subject to such retailer's terms and conditions and privacy policy. You may opt-out/request Do Not Sell to Rakuten Advertising by linking to their web forms page: https://rakutenadvertising.com/legal-notices/subject-requests/.
We are not responsible for effectiveness of or compliance with any third parties' opt-out options or programs.
9. Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appearing on the Site
The Site may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Site are served to you. In addition, when you are on the Site you may be directed to other sites that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off the Site onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies.
Third-party applications may also be available via the Site. The owners of these applications (“Third-Party Owners”) may collect Personal Information and other data from you and may have their own policies and practices. We are not responsible for how Third-Party Owners or their applications collect or use your information and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. These Third-Party Owners may have their own terms of service, privacy policies or other policies and ask you to agree to the same. We are not responsible for these third-party privacy policies or the practices of Third-Party Owners. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications. We also encourage you to note when you leave our Site and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.
10. Changing Your Information and Communications Preferences
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided to us. You may provide updates and changes by contacting us using the form available here: https://www.womensandfashion.com/contact-us or updating your Account. You may also contact us at privacy@clever-content.com
To request that we not sell your data, please fill out the form located here:https://www.womensandfashion.com/do-not-sell
To request a copy of your information or that your data be deleted from the Site, please fill out the form located here: https://www.womensandfashion.com/manage-my-data
If you send us a request to make changes, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. Also, if you have made any public postings on the Site such as in forums or blogs, these communications cannot generally be removed. When you edit your Personal Information or change your preferences on the Site, information that you remove may persist internally for our administrative purposes. You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails or in some cases by logging into your Site account and changing your communication preferences. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Subsequent or different subscriptions will be unaffected. Please note that we reserve the right to send you certain communications relating to your account or use of our Site, such as administrative and Site announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications. If you have any questions about the Privacy Policy or practices described in it, you should contact us using the form available here: https://www.womensandfashion.com/contact-us or at privacy@clever-content.com
California Residents please see section [18] below for additional rights pertaining to the deletion of your information.
11. Opt Out
If you want to be removed from our marketing list and do not want us to send you email, postal mail or other messages about our products and services, you can opt out. To do so, please send an email to privacy@clever-content.com with the word “REMOVE” in the subject line.
California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of such residents' personal information to third parties for such third parties' direct marketing purposes. To make such a request, please email us at privacy@clever-content.com.
12. Transfer of Information to the United States
Our Site is operated in the United States and intended for users located in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.
13. EU and UK Users
If you are in the EU or UK, you have certain additional rights and protections under the law regarding the collection and processing of your personal data. We will comply with applicable data protection laws anytime that we transfer your personal information outside of the European Economic Area (EEA). Some of the ways we will do so are:
•Where the transfer of your personal data is to a country that has officially been deemed to provide an adequate level of protection for personal data by the European Commission.
•Using the EU Model Clauses, which are specific contracts approved by the European Commission giving personal data the same protection it has in Europe.
•Transferring data to US-based providers if they are part of the Privacy Shield, which requires similar protection to personal data shared between Europe and the US.
Legal Basis for Processing
If you are in the EU or UK, we will collect and process your personal data:
Recipients
We share your personal information with the following categories of third parties:
Your Rights and Choices Regarding the Use of Your Personal Information
We provide a number of choices about how you may control the use, collection and storage of your personal information, and want you to be aware of that you have all of the following rights regarding your personal information:
You have the ability to correct, update, modify or delete your personal information by updating your information on the Site. Please note that some information may remain in our records even after you request deletion of your information. Additionally, there may be limits to the amount of information we can practically provide. For example, we may limit an individual's access to personal information where the burden or expense of providing access would be disproportionate to the risks to the individual's privacy or where doing so would violate others' rights.
Please contact us at privacy@clever-content.com with any questions or requests in regards to any of the above or to make requests regarding your personal information.
Questions or Complaints
In the event that you have a concern about our collection and processing of your data, please contact us first at privacy@clever-content.com and we will do our best to fix it. You also have the right to lodge a complaint directly with your local supervisory authority.
14. Data Retention
After you have terminated your use of our services, we may store your information in an aggregated and anonymized format.
15. No Information Collected From Children
The content and services provided by us or our affiliates, sponsors and advertisers, including without limitation the Site, are not intended for anyone under the age of 18 and you should not access such content or services if you are under the age of 18. No information is knowingly collected or retained from children under the age of 13, nor is any such information knowingly used for any marketing or promotional purposes whatsoever, either inside or outside the Site. No part of the Site is designed to attract anyone under the age of 13. Children are not eligible to use any services provided by us and we ask that children under the age of 13 not submit any personal information to us or visit the Site. We will delete any personal information collected that we later determine to be from a user younger than the age of thirteen (13). If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed personal information to us, please contact us by using the Contact us using the form available here: https://www.womensandfashion.com/contact-us or by email at privacy@clever-content.com.
16. Security
We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, including Personal Information, and you use our Site and provide us with your information at your own risk.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personally identifiable information. Our security procedures mean that we will occasionally request proof of identity before we disclose personal information to you. You are responsible for protecting against unauthorized access to your password and to your computer/mobile device. We ask you not to share your password with anyone.
Our employees are trained and required to safeguard your information. Our internal controls limit access to personally identifiable information based on job functionality.
17. Changes to the Privacy Policy
We reserve the right to change this Privacy Policy at any time without notice to you. Any changes will be effective immediately upon the posting of the revised Privacy Policy. However, we will not use your Personal Information in a manner materially different than promised at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
18. California Residents
As of January 1, 2020, California residents are provided with specific rights regarding their personal information. This section describes further how we comply with the requirements of the California Consumer Privacy Act of 2018 (“CCPA”) and your rights under that law. Any capitalized terms used but not defined in this section shall have the meanings given to them in the CCPA. This section does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals (see Employee Handbook).
The table below explains the categories of information that we have collected in the past 12 months, the sources of that information, the purpose for that collection, use and sharing, and the categories of third parties with whom we share that information.
| Category | Categories of Sources: | Business or Commercial Purposes for Collection, Use or Sharing: | Disclosed for Business Purposes to Third Parties: | Sold to the Following Categories of Third Parties: |
| User provided information (e.g. identifiers, such as, first name and last name, email address, phone number) | All categories listed below | All purposes listed below | All categories listed below | All categories listed below |
| Location Information (geolocation information and commercial information) | All categories listed below | All purposes listed below | All categories listed below | All categories listed below |
| Site and Account usage information (e.g. browsing history, search history, interactions with a website, email, application or advertisement, pages viewed, and customer service inquiries) | All categories listed below | All purposes listed below | All categories listed below | All categories listed below |
| Device level information (e.g. internet and other network activity information, including ADIDs, cookies, IP address, and other device hardware and software information) | All categories listed below | All purposes listed below | All categories listed below | All categories listed below |
| Inferred Data (e.g. inferred user information, preferences or tastes) | All categories listed below | All purposes listed below | All categories listed below | All categories listed below |
| Other information about you that is linked to the personal information above | All categories listed below | All purposes listed below | All categories listed below | All categories listed below |
Categories of Sources: We collect this personal information from the following categories of sources:
Why We Use and Disclose California Information. We use and disclose the personal information we collect for our commercial and business purposes as further described in this Privacy Policy. These commercial and business purposes include, without limitation:
Recipients of California Personal Information.
The CCPA has defined a “sale” to include any transfer of personal information by us to another entity for anything of value. For these purposes, in the past 12 months, we have “sold” (for the purposes of the CCPA) the categories of personal information designated above to the third parties below for a business or commercial purpose:
We may disclose the categories of personal information designated above to the categories of third parties listed below for business purposes including but not limited to:
Your Rights and Choices
As applicable under the CCPA, from January 1, 2020, if you are a California resident, you may make requests to us as set out below. We will review all requests received and determine the extent to which and how to respond. We will not discriminate against any California resident who makes such requests.
Right to access/know
You may request from us a list of: (i) the categories and specific pieces of personal information we collect, use, disclose, and sell about you; (ii) the categories of sources from which we collected your personal information; (iii) our purposes for collecting or selling your personal information; (iv) the categories of your personal information that we have either sold or disclosed for a business purpose; and (v) the categories of third parties with which we have shared personal information. In addition, for certain categories of personal information, you have the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties.
Right to delete your personal information
You may request to delete your account and the personal information we have collected from you or maintain about you.
Right to opt-out from the sale of your personal information
You may request, at any time, to direct us to stop “selling” (for the purposes of the CCPA) your personal information. We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
Right to Non-Discrimination
You have the right to not receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA. We may offer you certain financial incentives permitted by applicable law as compensation for allowing us to collect, sell, or maintain your personal information.
Making Requests
To exercise rights described above, please submit a verifiable consumer request to us by either:
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
You may also submit such requests through an authorized agent. To designate an authorized agent, please send us a notarized power of attorney / notarized letter authorizing said agent. Requests from agents that do not submit such proof that they have been authorized by you to act on their behalf will be denied.
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@clever-content.com.
19.Contact Us
If you have any questions or suggestions regarding this Privacy Policy, please contact us using our contact details you can find in our Contact Page
Or by email:
privacy@clever-content.com
We maintain a list here of third parties that use a form of tracking technology to collect information about you when you visit our Site. They have given us notice that you may obtain information on their policies and practices, and in some instances opt-out.
PLEASE NOTE: We are not responsible for third-party policies or practices. We try to keep this information current. Please contact the applicable third parties regarding their privacy and data security policies and practices.