CLOOSIV PRIVACY POLICY

 

 

Cloosiv (“we”, “us” or “Cloosiv”) respects your right to privacy. Your ability to make informed choices about the use of your information is important to us. This Privacy Policy explains our policy regarding the collection, use, disclosure and protection of Personal Information we receive when you register and use the Service (“the App”). If not otherwise defined in this Privacy Policy, capitalized terms have the meaning given to them in our Terms of Service, which you may read at http://cloosiv.com/terms (the “Terms”).

 

Information We Collect

 

To use the features in the App, you will be required to register a Cloosiv account. Accounts are registered by connecting with your Facebook account. Some of the information you provide to register a Cloosiv account is Personal Information; “Personal Information” means information that can be directly associated with a specific person. By registering for a Cloosiv account through Facebook Connect, we may receive Personal Information about you as provided by Facebook. The information we receive depends on your privacy settings and, if applicable, your friends’ privacy settings on Facebook.

 

Cloosiv may collect and store some or all the following information shared by Facebook:

 

  • Your first and last name;

  • Your profile picture or its URL;

  • Your user ID number (Facebook ID number), which may be linked to publicly-available information like your name and profile photo;

  • The user ID number and other public data about your friends;

  • The login e-mail address you provided to Facebook when you registered your account;

  • Your physical location and that of the devices you use to access our Services;

  • Your gender;

  • Your birthday and/or age range;

  • Information about your activities on or through Facebook;

  • Other publicly-available information on Facebook; and/or

  • Any other information that you or Facebook share with Cloosiv.

 

If you access our App with Facebook, we recommend that you also read Facebook’s Terms and Policies (https://www.facebook.com/policies) and Facebook’s Privacy Policy (http://www.facebook.com/privacy/explanation), in order to understand what information we receive.

 

In addition, when you use the App, certain information may be automatically gathered about your mobile device, browser, operating system, location, IP address or tablet.

 

We also collect Personal Information when you contact us for any reason. It is your voluntary decision whether to provide us with any of the above referenced Personal Information, but if you refuse to provide such information your use of the Services may be limited.

 

How We Protect Information

 

We make efforts to follow generally accepted industry standards to protect Personal Information, both during transmission and once we receive it. However, you must realize that no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

 

In addition to staying up to date with security best practices, on a three-month cycle Cloosiv will complete a formal end-to-end review of our security parameters and standards, to ensure that your data infrastructure is safe and compliant. 

 

We will delete any Personal Information provided to and stored by us upon the user processing the deletion of their registered account, accessible within the App settings. While Personal Information will be deleted upon the user’s completion of this action, the user’s transaction history and demographic profile (e.g., gender, age) remains. We cannot restore Personal Information that we have deleted.

 

In the event of a data breach, Cloosiv will (a) immediately contact all users to notify them of the breach; (b) stop the breach; (c) review breach details; (d) communicate detailed findings of the review to all users; and (e) proceed with legal action on behalf of all users.

 

How We Use Information

 

Except as specifically set forth in these Terms, we will not share your Personal Information with third parties without your explicit permission, except when required by law, regulation, subpoena or court order, to protect our rights or to cooperate with an investigation by a law enforcement body.

 

We may use Personal Information internally – for example, to help diagnose problems with our servers, or to customize Cloosiv and personalize its content for you. We may deliver targeted marketing, service updates, and promotional offers.

 

We will use the information you provide in order to provide our service.

 

We may share your Personal Information with:

 

• third-party vendors or service providers (e.g, Businesses that accept Cloosiv, Facebook), including purchase history and demographic information. We require third party vendors and service providers to follow practices that protect your privacy rights on a level at least as restrictive as the practices described in this Privacy Policy.

• payment processors that enable the transfer of your payment submitted through the App to the Business with which you are conducting a transaction (e.g. Stripe, Inc, “Stripe”). Such payment processors may provide your Personal Information to credit card companies to enable billing. Additionally, such payment processors may provide the last four digits of your method of payment to the Business or third-party vendor to allow transaction identification. Such payment processors may also use your Personal Information for internal purposes; it is recommended that you review Stripe’s Privacy Policy to understand their standard use of your Personal Information (www.stripe.com/privacy). Please note that we do not control the privacy practices of these third-party vendors or service providers. If you wish to no longer allow that third-party to use your information, please contact that third-party directly.

• referring websites; if you were referred to the Services from a web site (for example, through a link), we may share some information about you with that referring website. We encourage you to review the privacy policies of any website that referred you here. Additionally, when you link to one of our partners from our Services or post to social media from our Services, we provide that partner with a unique identifier so they know that you were referred from our Services. This unique identifier will not contain any of your Personal Information.

 

We may share anonymized information (not personally identifiable information) about your demographics and your purchase history with Businesses. Such information will not be linked to your Personal Information and will only be used for purposes of tracking transactions and data collection.

 

By analyzing all information we receive, including all information concerning users, we may compile statistical information across a variety of users (“Statistical Information”). Statistical Information helps us understand trends and user needs so that new products and services can be considered, and so existing products and services can be tailored to user desires. Statistical Information does not indicate individuals’ identities, and we will not link Statistical Information to any Personal Information. We may share Statistical Information with businesses, without restriction, on commercial terms that we can determine in our sole discretion.

 

Sharing and Feedback

 

While we take great care to keep your use of the Services confidential and secure, when you share your purchases with others or provide feedback regarding your purchases and shopping habits, including by means of Facebook, Google+, Twitter or other social media sites, or by posting merchandise links to a forum, any information disclosed that way may be automatically made public, and such information will not be considered Personal Information by us.

 

Cookies

 

A cookie is a small piece of text that is sent to a visitor's browser. The browser provides this piece of text to the device of the originating visitor when this visitor returns. We use cookies to help personalize your Cloosiv experience and to recognize you as a valid user, so you will not need to log in each time you use the Services. A “persistent” cookie may be used to help save your settings and customizations. Most web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. Also, you are free to delete any existing cookies at any time. Please note that some features of the Services may not function properly when cookies are disabled or removed.

 

Online Links to Other Sites

 

We may provide links to other websites of third parties that provide useful information and/or services relevant to the App. Any Personal Information you provide on the linked pages is provided directly to this third-party and is subject to the provider’s privacy policy. We advise you check these privacy policies. We do not have access to the information collected by those third-party web sites or by our partners. Except as described in this Privacy Policy, we are not responsible for the content or privacy practices of third-party web sites to which we or our partners link.

 

Use of Cloosiv by Children

 

By registering an account with Cloosiv, you represent that you are at least 18 years of age or older, or that you have the permission of a legal guardian (e.g., a parent) to use the Products and the Services.

 

We do not knowingly collect personally identifiable information from children under the age of 18. In the event that you become aware that somebody under the age of 18 has enrolled without parental permission, please inform us immediately at security@cloosiv.com.

 

Correcting or Updating your Information. 

 

We allow you to view the information you provided during registration and to alter some data, inaccuracies or errors. If you seek to correct account registration information received through Facebook, you must logout of the App, correct the information on your Facebook profile, and login in to the App. If you seek to correct account registration information received through State-Issued ID scanning, you can do so by navigating to your user settings within the App and by scanning a new State-Issued ID. Please note that only one State-Issued ID can be accepted per account at any given time. Additionally, only one State-Issued ID can be assigned to a Cloosiv account at any given time; attempts to duplicate identification will be considered fraudulent and will be reported immediately.

 

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, you can do so by navigating to your user settings within the App.  We will retain transaction history and demographic information, and may use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

Communications 

 

We may send you e-mail or other messages about us or our products and services. By accepting the Terms of Service for the App (including the terms of this Privacy Policy which are incorporated therein) or using the App, you affirmatively consent to receive such commercial messages. As a registered member, you can remove your Personal Information from our mailing list and stop receiving future communication from us by following the unsubscribe link located at the bottom of any communication or by emailing us at support@cloosiv.com. Please note that we reserve the right to send you receipts for your purchases, service-related communications, including service announcements and administrative messages, relating either to your account or to your transactions on this site, without offering you the opportunity to opt out of receiving them unless you cancel your account.

 

Other Uses or Transfer of Your Information

 

We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior or digital content of any user suspected to have engaged in illegal or infringing behavior. We may use subcontractors that are located in countries other than your own, and send them information we receive. All our subcontractors will be subject to non-disclosure and non-use obligations. Nevertheless, some countries may have levels of protection of personal and other information which are not as high as in your country of residence or business. We may transfer our databases containing your Personal Information if we sell our business or part of it. 

 

Changes

 

We may update this Privacy Policy from time to time - we encourage you to review it periodically.

 

Comments and Questions

 

If you have any comments or questions about our privacy policy, please contact us at support@cloosiv.com

 

Last updated: September 2017