Privacy Policy
Effective date: December 29, 2023
Last updated: June 24, 2024
Note this (english) version is a translation of the original (danish) version. In the event of discrepancy or inconsistency between the two aforementioned versions or any legal disputes, the original (danish) version shall prevail.
1. Purpose:
This Privacy Policy (hereinafter “Privacy Policy”) is an integral part of Cliarly ApS, CVR 44537249 (hereinafter “Cliarly”) Terms and Conditions and concerns the processing of personal data. The Privacy Policy describes how Cliarly collects, processes, discloses and protects any information that directly or indirectly can be used to identify a natural person, but not information that is anonymized or aggregated in such a way that it cannot (even with the help of other information) identify a specific natural person (hereinafter “Personal Data”). Unless otherwise stated, definitions used in the Privacy Policy have the same meaning as in the Terms and Conditions.
2. Application:
Consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy is a prerequisite for accessing Cliarly or using Cliarly’s services. When you create a profile through Cliarly and approve the Terms and Conditions (hereinafter “the User”), the User accepts to share some of his/her Personal Data with Cliarly and thereby approves that the information is transferred and stored on servers in the EU/EEA.
3. Data Controller:
Cliarly is responsible (hereinafter “Data Controller”) for the processing of Personal Data that takes place via Cliarly.com (hereinafter “the Website”) and within the framework of the services provided in the Terms and Conditions, including the Chrome extension. Cliarly is also responsible for ensuring that the processing of Personal Data is carried out in accordance with the principles laid down in the Privacy Policy.
4. Processing of Personal Data:
Cliarly processes both Personal Data that the User himself/herself provides to Cliarly, as well as Personal Data that Cliarly automatically collects about the User.
First and foremost, Cliarly collects and stores the Personal Data that the User provides in connection with both registration and use of the Website and related services, including services that may be made available through the use of Cliarly. Included, but not limited to, are the following Personal Data:
- Information provided to Cliarly when registering as a User on the Website, consisting of first and last name, email address and in some cases telephone number,
- Information on whether the User has made payment for Cliarly, or
- Information that Cliarly otherwise requests in connection with the fact that there is doubt about whether the Terms and Conditions are being complied with.
Thereafter, Cliarly automatically collects Personal Data when the User uses the Website or other services provided by Cliarly, clicks on links in newsletters from Cliarly or on the Website that are sent from the User’s computer or any other device used to make use of Cliarly. The information can only be attributed to the specific User if it is the case of a User in accordance with this Privacy Policy, such as a natural person who is registered on the Website. The information consists of information about connection, statistics on page views, URL and how much the User has used Cliarly. Thus, Cliarly records how much the User has used the Website and other services offered by Cliarly, but not what the User has read, written or dictated. Cliarly uses GA4, why reference is made to Google’s privacy policy, which can be read here: Google’s privacy policy.
5. Use of Personal Data:
Cliarly processes the User’s Personal Data with the purpose of giving the User access to Cliarly, including the Website and other services, handling daily business needs, monitoring and analysis, and being able to provide customer service and give you the opportunity to receive relevant information from Cliarly about marketing and new services. The legal basis for Cliarly’s processing of Personal Data is Cliarly’s legitimate interest and to make it possible for Cliarly to fulfill the agreement that the Terms and Conditions constitute between Cliarly and the User. By accepting Cliarly’s Terms and Conditions, and thereby the Privacy Policy, the User consents to Cliarly processing the User’s Personal Data for the following purposes:
- Access to the Website and Cliarly’s other services,
- Send information about news, updates and services that Cliarly offers from time to time,
- Administer, maintain, develop and ensure the Website and related services’ technical functionality in order to be able to offer the User a secure and efficient experience of the Website and related services,
- Monitor that the Website and related services are not used in violation of the Terms and Conditions and protect Cliarly’s or others’ rights in accordance with the Terms and Conditions, for example, but not limited to, preventing, detecting, investigating or preventing security incidents, potentially prohibited matters or other illegal activities,
- Use cookies or other tracking technology to be able to offer the services and/or work with other third parties, such as Youtube for streaming videos on the Website,
- Conduct statistics, perform market and customer analysis and perform general business and method development, including user feedback,
- Enable financing or transfer of all or part of Cliarly or its business, or
- Carry out checks in relation to the EU’s sanctions lists, the UN’s sanctions lists and PEP lists etc. as well as fulfill other obligations that follow from laws, regulations or internal rules in general.
6. Termination of Processing of Personal Data:
If the User does not wish to receive marketing or relevant information from Cliarly, the User can contact Cliarly at info@cliarly.com and object to the processing. If the User revokes his/her consent to the handling of Personal Data for the purposes specified in the Privacy Policy, this may result in Cliarly not being able to give the User access to the Website, other services offered by Cliarly or customer service offered by Cliarly in accordance with this Privacy Policy and the Terms and Conditions.
7. Disclosure of Personal Data:
Cliarly does not disclose, transfer or sell the User’s Personal Data to third parties, other than what is stated in the Privacy Policy, without the User’s express consent.
Cliarly discloses the User’s Personal Data to fulfill legal obligations and maintain adopted policies, and is only disclosed in accordance with applicable laws and regulations. To fulfill its obligations under the Terms and Conditions and the purposes described above, Cliarly may have to share your Personal Data with:
- Any future group companies to Cliarly with a view to delivering the same content and the same services, to detect and prevent violations of Cliarly’s policies, provide guidance on group companies’ products, websites, tools or services and in accordance with applicable law.
- Subcontractors used by Cliarly to run the business, including, but not limited to, IT suppliers and suppliers of cloud services.
- Supervisory authorities, the police, other authorities or appropriate third parties in connection with answering questions and investigating potential criminal acts or other activities that may result in liability for Cliarly or the User. To the extent permitted by applicable law, Cliarly will disclose information that is relevant and necessary for any investigation, such as name or email address.
- Information about Users to another company if Cliarly is to be sold to or merged with such a company. If the User’s Personal Data is to be used or disclosed for purposes other than those stated in the Privacy Policy, Cliarly will inform the User of this.
8. Cookies:
When the User visits or otherwise uses the Website and other services offered by Cliarly, Cliarly or its suppliers may use cookies, web beacons and similar technology to store information in order to create a faster and more secure experience for the User. For more information on which cookies Cliarly uses, as well as the User’s choices in relation to tracking technologies etc., see Cliarly’s Cookie Policy.
9. Access, review and change:
The User’s password is the key to the User’s account and should consist of unique numbers, letters and symbols. The User must not reveal his/her password to any outside party. The User is responsible for all activity via his/her account and must immediately change his/her password or inform Cliarly if the User’s password has fallen into the wrong hands, or the User has reasonable suspicion of this.
The User can review and change certain Personal Data in the account settings on the Website and must promptly update, or alternatively notify Cliarly’s customer service, that the User’s Personal Data must be changed or is incorrect. Cliarly will then fulfill the rights you have under the law, in relation to the possibility of requesting correction or deletion of your Personal Data.
10. Security:
Cliarly stores and processes the User’s Personal Data on servers in the EU/EEA. Cliarly uses physical, technical and organizational security measures that are appropriate in relation to the amount and sensitivity of the Personal Data processed, both to prevent unauthorized processing, including, but not limited to unauthorized access, appropriation and use of, or loss, deletion or other damage to the User’s Personal Data. Examples of security measures used by Cliarly are encryption and anonymization of data, as well as requirements for identification to access Personal Data.
11. Termination and Storage:
At the User’s request, Cliarly may close the User’s account and, as soon as possible, delete the User’s Personal Data. Deletion of Personal Data takes place in accordance with applicable law. Cliarly also reserves the right to close the User’s account, to the extent that it is used in violation of Cliarly’s Terms and Conditions. Personal Data that can be attributed to a closed account will typically be deleted or anonymized after the account has been closed. Cliarly may, however, need to retain Personal Data that can be attributed to closed or inactive accounts in the following cases:
- Cliarly has a legitimate business interest that is not prohibited by law, such as for use in bookkeeping, including investigation or correction thereof, etc.,
- To handle disputes and/or to ensure that Cliarly’s Terms and Conditions are complied with,
- If Cliarly is required by law to store the Personal Data, or
- To be able to take other measures that are permitted by law. Regardless of circumstances, the User’s Personal Data will be handled securely and only as long as necessary to fulfill the purposes described in the Privacy Policy.
12. Rights:
As a User, you have several rights, including:
The right of access
Users are entitled at any time to request Cliarly for information about, among other things, what information we have registered about the User, what purpose the registration serves, which categories of Personal Data and recipients of information, if any, as well as information about where the information comes from. The User has the right to obtain a copy of the Personal Data that Cliarly processes about the User. If the User wishes a copy of his/her Personal Data, the User must send a written request to info@cliarly.com. The User may be asked to document that the User is the person the User claims to be.
The right to rectification
The User has the right to have incorrect Personal Data about himself/herself rectified by Cliarly. If the User becomes aware that there are errors in the information that Cliarly has registered about the User, the User is encouraged to make a written request to Cliarly so that the information can be corrected. Information that Cliarly has collected in connection with the User’s registration on the Website, the User has the opportunity to correct himself/herself via log-in to his/her user profile on the Website.
The right to erasure
In certain cases, the User has the right to have all or some of his/her Personal Data deleted by Cliarly, for example, if the User revokes his/her consent and Cliarly has no other legal basis for continuing the processing. To the extent that continued processing of the User’s information is necessary, for example, for Cliarly to comply with its legal obligations or to establish, assert or defend legal claims, Cliarly is not obliged to delete your personal data.
The right to restrict processing to storage
In certain cases, the User has the right to have the processing of his/her personal data restricted to storage only, for example, if the User believes that the information that Cliarly processes about the User is not correct.
The right to data portability
In certain cases, the User has the right to have Personal Data that the User himself/herself has given Cliarly, delivered in a structured, commonly used and machine-readable format and has the right to transfer this information to another data controller.
The right to object
The User has the right at any time to object to Cliarly’s processing of his/her Personal Data for direct marketing purposes, including the profiling that is carried out to be able to target Cliarly’s direct marketing. The User also has the right at any time, for reasons relating to the User’s personal situation, to object to the processing of his/her Personal Data that Cliarly carries out on the basis of Cliarly’s legitimate interests.
The right to withdraw consent
The User has the right at any time to withdraw his/her consent that the User has given Cliarly for a given processing of Personal Data. If the User wishes to withdraw his/her consent, the User is requested to contact Cliarly at info@cliarly.com and inform thereof.
13. Contact Information:
For questions about the Privacy Policy, please direct questions to Cliarly at: Email: info@cliarly.com
14. Effective Date:
The Privacy Policy is effective from and including the above publication date.
15. Amendments:
The Privacy Policy is updated regularly and published on the website. Users will receive notification by email of major changes to the Privacy Policy.
16. Other Security:
Security is of paramount importance to both Cliarly and the User thereof. All text (hereinafter “Information”) processed through the use of Cliarly, including processed on the Website as well as other services offered by Cliarly, is considered confidential. Thus, no one other than the User himself/herself has access to this Information, why the Information can of course not be shared with others than the User himself/herself chooses to share the Information with. This Privacy Policy is by its nature limited to addressing matters such as confidentiality, and reference is made to the Terms and Conditions for, for example, general information on the security and confidentiality of the Information that the User processes through Cliarly.