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Clippd Limited and its affiliates (“Clippd”, “we,” “our,” and/or “us”) are committed to protecting the privacy of individuals on the websites https://clippd.io and https://clippd.com (the “Website”) and the products and services that link to this privacy policy (collectively, the “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share Personal Information from users of our Services (“Users”, “you”) or their devices.

I. Information We Collect

We collect a variety of Personal Information from or about you or your devices from various sources, as described below. In this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual.

If you do not provide your Personal Information when requested, you may not be able to use our Services if that Personal Information is necessary to provide our Services or if we are legally required to collect it.

A. Information You Provide to Us

Registration and Profile Information.

If you register for our Services or otherwise provide us with Personal Information through the forms included in our Services, we may receive your first and last name, phone number, address, and email address. If you participate in surveys or promotions, we ask you for your name, email address, and other information.

Payment Information.

When you add a payment method to your account or make a purchase, a third-party service provider that handles payments for us will receive your financial information.

Communications.

If you contact us directly, we may receive additional Personal Information about you. For example, when you contact us or get support through the Website, we may receive your first and last name, email address, phone number, company name, the contents of a message that you may send to us, and other information you choose to provide. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.

Careers.

If you decide to apply for a job with us, you may submit your contact information and your resume through our online form. We will collect the Personal Information you choose to provide us as part of your job application, such as your contact information, current employment information, and other information you choose to submit with your application and on your resume.

B. Information We Collect When You Use Our Services

Device Information.

We receive information about the device and software you use to access our Services, including internet protocol (“IP”) address, web browser type, operating system version, and unique device identifiers.

Usage Information.

To help us understand how you use our Services and to help us improve them, when you use our Services, we automatically receive information about your interactions with our Services, like log files, performance logs, diagnostic reports, the pages or other content you view, the searches you conduct, pages you request, the websites you visited before using our Services, and the dates, times, and durations of your visits.

Location Information.

When you use our Services, we infer the general physical location of your device and the geographic regions our Users come from. For example, your IP address may indicate your general geographic region.

Information from Cookies and Similar Technologies.

We and our third-party partners may collect Personal Information using Cookies. Cookies are small files of letters and numbers that we store on your browser or the hard drive of your computer. They contain information that is transferred to your computer’s hard drive. We use cookies, beacons, invisible tags, and similar technologies (collectively “Cookies”) to collect information about your browsing activities and to distinguish you from other Users of our Services.

C. Information We Receive from Third Parties

Third-Party Services.

You may also post photos, comments, or reviews on our pages available through third-party platforms, including Facebook, Instagram, LinkedIn, or Twitter. If you do so, we and other users on those third-party platforms may be able to view the Personal Information you make available through these third-party platforms.

Partners.

We may receive additional Personal Information about you from third parties such as data or marketing partners and combine it with other Personal Information we have about you.

II. How We Use the Information We Collect

We use the Personal Information we collect for the purposes described below. If you are located in the European Economic Area, we only process your Personal Information when we have a valid “legal basis” to do so.

Communicating with you. We may use your email address or other Personal Information we collect on the Services as necessary to contact you for administrative purposes such as to provide services and information that you request, respond to comments and questions, and otherwise provide customer support.
Providing the Services and personalizing your experience. We may use your Personal Information to provide and maintain the Services, including to enable you to connect to our website and to facilitate transactions and payments. When doing so, we may use your Personal Information to personalize your experience on our Services such as by providing tailored content and recommendations.
Understanding usage and improving the Services. We use the Personal Information that we collect through our Services to analyze trends and statistics, and to improve and enhance our Services.
Surveys. From time to time, we may ask you to participate in surveys we conduct which are in our legitimate interest because they help us understand our userbase and improve the Service. If you participate, we process your registration information and any other information collected through the survey questions.
Marketing. We may use your email address and other Personal Information to send marketing communications related to our Services. Generally, you have the ability to opt-out of receiving any promotional communications as described below under Your Rights and Choices. Where required under applicable law, we will only send you promotional emails with your opt-in consent.
Advertising. We may use your usage information and other Personal Information to develop and provide you with promotional and advertising materials that may be relevant, valuable or otherwise of interest to you.
Legal obligation and Compliance. We use Personal Information to find and prevent fraud, respond to trust and safety issues that may arise, and for compliance purposes, including enforcing our legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
De-identifying the data for further use: We de-identify and aggregate information collected through our Services and use it for our business purposes in an anonymized manner.
Other Purposes. For other purposes for which we provide specific notice at the time the information is collected. For any of these purposes, we may rely on the following legal basis:
- You have consented to the use of your Personal Information, for example to send you marketing communications or to process Sensitive Information.
- We need to use your Personal Information to provide you with the Services, for example to give you access to the Services, or to respond to your inquiries.
- We need to use your Personal Information to comply with a legal obligation, for example to comply with a court order.
- We or a third party have a legitimate interest in using your Personal Information. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

III. How We Share the Information We Collect

We may disclose Personal Information we collect from or about you as described below or otherwise disclosed to you at the time of collection.

Partners and Affiliates.

We may share any Personal Information we receive with our partners, subsidiaries, and affiliates for any of the purposes described in this Privacy Policy.

Vendors and Service Providers.

We may share any Personal Information we receive with contractors, vendors, service providers, and other third parties retained in connection with the provision of our Services.

Analytics Partners.

We use analytics services such as Google Analytics and Mixpanel to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to google.com/policies/privacy/partners/ and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at tools.google.com/dlpage/gaoptout.

Advertising Partners.

We work with third-party advertising partners to show you ads that we think may interest you. These advertising partners may set and access their own cookies, pixel tags and similar technologies on our Services and they may otherwise collect or have access to information about you which they may collect over time and across different online services. Some of our advertising partners are members of the Network Advertising Initiative (optout.networkadvertising.org) or Digital Advertising Alliance (optout.aboutads.info). If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies.

Social Networks and Other Online Services.

Our Services allows you to, upon your direction, share information with social networking services, such as Twitter, Facebook and Instagram. You understand and agree that the use of your information by any social networking websites will be governed by the privacy policies of these third-party platforms and your settings on that platform. We encourage you to review their privacy policies. **As Required by Law and Similar Disclosures.** We may access, preserve, and disclose Personal Information about you if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. **Merger, Sale, or Other Asset Transfers.** We may disclose and transfer your Personal Information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our business or assets. **Consent.** We may also disclose Personal Information from or about you or your devices with your permission.

IV. Your Rights and Choices

Access to Personal Information.

Depending on your location and subject to applicable law, you may have the right to request details of Personal Information that we hold about you. A small administrative fee may be payable for the provision of Personal Information if your request is clearly unfounded, repetitive, or excessive. If you would like a copy of the Personal Information which we hold about you or believe that any Personal Information we hold on you is inaccurate, out of date, incomplete, irrelevant, or misleading, please email us at legalsupport@clippd.com. **Marketing Communications.** If you provide Clippd with your email address, you may be contacted by us for marketing purposes. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us. **How to block Cookies.** You can block Cookies by setting your internet browser to block some or all the Cookies. However, if you use your browser settings to block all Cookies (including essential Cookies) you may not be able to access all or parts of our Services. You can withdraw your consent at any time by deleting placed cookies and disabling Cookies in your browser, or as explained below. You can change your browser settings to block or notify you when you receive a Cookie, delete Cookies or browse our Website using your browser’s anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of Cookies or similar technologies which store information on your device, you should change your browser settings accordingly. You should understand that some features of our Website may not function properly if you do not accept Cookies or these technologies. Where required by applicable law, you will be asked to consent to certain Cookies and similar technologies before we use or install them on your computer or other device. **Your European Privacy Rights.** If you are located in the European Economic Area (‘EEA’) or in the (‘UK’), you have the additional rights described below.

You may request access to and receive information about the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
You may withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

You may exercise these rights by contacting us using the contact details at the end of this policy. Before meeting your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

V. Third Parties Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any Personal Information you disclose to these third parties. We are not responsible for the privacy practices or the content of such sites. If you have any questions about how these other sites use your Personal Information, you should contact them directly. We encourage you to read their privacy policies before providing any Personal Information to them.

VI. Retention

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the statute of limitations. If you wish to cancel your account or request that we no longer use your information to provide you the Services contact us at support@clippd.com.

VII. Information Security

We make reasonable efforts to protect your Personal Information by using technical and organizational safeguards designed to improve the security of the Personal Information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your Personal Information. If you have any questions about the security of your personal information, you can contact us at legalsupport@clippd.com.

VIII. Children’s Privacy

We do not knowingly collect, maintain, or use Personal Information from children under 16 years of age, and no part of our Services are directed to children. If you learn that a child has provided us with Personal Information in violation of this Privacy Policy, then you may alert us at legalsupport@clippd.com.

IX. International Visitors & Data Transfers

Our Services are hosted in the EEA. If you choose to use our Services from other regions of the world, then please note that you are transferring your Personal Information outside of those regions to the EEA for storage and processing. If you are located in the EEA, we will comply with applicable EEA data protection law when transferring your Personal Information outside of the EEA. We may transfer your Personal Information to countries which have been found to provide adequate protection by the EU Commission, use contractual protections for the transfer of Personal Information, transfer to recipients who have adopted Binding Corporate Rules, or rely on an appropriate legal derogation. For more information about how we transfer outside of the EEA and the UK, or to obtain a copy of the contractual safeguards we use for such transfers, you may contact us using the contact details given below.

X. Changes to This Privacy Policy

This Privacy Policy may be revised from time to time. We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective as of the last updated date. If we materially change the ways in which we use or share Personal Information previously collected from you through our Services, we will attempt to notify you of the changes through our Services, by email, or other means. ### XI. Contact Information Unless otherwise indicated in this Privacy Policy, Clippd Limited is the entity responsible for the processing of Personal Information described in this Privacy Policy. If you want to update your Personal Information or if you have any questions, comments, or concerns about our processing activities, please email us at support@clippd.com or write to us at: Clippd Limited
11 Bear Street
London
WC2H 7AS

II. How We Use the Information We Collect

Communicating with you. We may use your email address or other Personal Information we collect on the Services as necessary to contact you for administrative purposes such as to provide services and information that you request, respond to comments and questions, and otherwise provide customer support.

Providing the Services and personalizing your experience. We may use your Personal Information to provide and maintain the Services, including to enable you to connect to our website and to facilitate transactions and payments. When doing so, we may use your Personal Information to personalize your experience on our Services such as by providing tailored content and recommendations.

Understanding usage and improving the Services. We use the Personal Information that we collect through our Services to analyze trends and statistics, and to improve and enhance our Services.

Surveys. From time to time, we may ask you to participate in surveys we conduct which are in our legitimate interest because they help us understand our userbase and improve the Service. If you participate, we process your registration information and any other information collected through the survey questions.

Marketing. We may use your email address and other Personal Information to send marketing communications related to our Services. Generally, you have the ability to opt-out of receiving any promotional communications as described below under Your Rights and Choices. Where required under applicable law, we will only send you promotional emails with your opt-in consent.

Advertising. We may use your usage information and other Personal Information to develop and provide you with promotional and advertising materials that may be relevant, valuable or otherwise of interest to you.

Legal obligation and Compliance. We use Personal Information to find and prevent fraud, respond to trust and safety issues that may arise, and for compliance purposes, including enforcing our legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

De-identifying the data for further use: We de-identify and aggregate information collected through our Services and use it for our business purposes in an anonymized manner.

Other Purposes. For other purposes for which we provide specific notice at the time the information is collected. For any of these purposes, we may rely on the following legal basis:

You have consented to the use of your Personal Information, for example to send you marketing communications or to process Sensitive Information.
We need to use your Personal Information to provide you with the Services, for example to give you access to the Services, or to respond to your inquiries.
We need to use your Personal Information to comply with a legal obligation, for example to comply with a court order.
We or a third party have a legitimate interest in using your Personal Information. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

IV. Your Rights and Choices

Access to Personal Information.

You may request access to and receive information about the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

You may withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.