CloviFi App Privacy Policy

Clovitek, Inc.’s GDPR Compliance Statement

Introduction

The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.

The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardize data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.

Our Commitment

Clovitek, Inc. (‘we’ or ‘us’ or ‘our’) are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognize our obligations in updating and expanding this program to meet the demands of the GDPR and the United States of America.

Clovitek, Inc. is dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarized in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

How We Prepared for the GDPR

Clovitek, Inc. already has a consistent level of data protection and security across our organization, however it is our aim to be fully compliant with the GDPR by May 25th, 2018.

Our preparation includes: -

  • Information Audit - carrying out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
  • Policies & Proceduresrevising our data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: -
    • Data Protection – our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
    • Data Retention & Erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimization’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
    • Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
    • International Data Transfers & Third-Party Disclosures – where Clovitek, Inc. stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
    • Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
  • Legal Basis for Processing - we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
  • Privacy Notice/Policy – we have revised our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
  • Obtaining Consent - we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
  • Direct Marketing - we have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
  • Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
  • Processor Agreements – where we use any third-party to process personal information on our behalf (e. Payroll, Recruitment, Hosting etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organizational measures in place and compliance with the GDPR.
  • Special Categories Data - where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.

Data Subject Rights

In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via our website of an individual’s right to access any personal information that Clovitek, Inc. processes about them and to request information about: -

  • What personal data we hold about them
  • The purposes of the processing
  • The categories of personal data concerned
  • The recipients to whom the personal data has/will be disclosed
  • How long we intend to store your personal data for
  • If we did not collect the data directly from them, information about the source
  • The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
  • The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
  • The right to lodge a complaint or seek judicial remedy and who to contact in such instances

Information Security & Technical and Organizational Measures

Clovitek, Inc. takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorized access, alteration, disclosure or destruction and have several layers of security measures, including: -

  • SSL, 
  • access controls, 
  • password policy, 
  • encryptions, 
  • pseudonymization, 
  • IT authentication

GDPR Roles and Employees

Clovitek, Inc. has designated Vitaly Magidov Kirkpatrick as our Appointed Person and have appointed a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. The team are responsible for promoting awareness of the GDPR across the organization, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.

Clovitek, Inc. understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans. We have implemented an employee training program specific to the which will be provided to all employees prior to May 25th, 2018, and forms part of our induction and annual training program.

If you have any questions about our preparation for the GDPR, please contact Appointed Person.
 

CloviFi App Privacy Policy

Last updated May 30, 2018  

Thank you for choosing to be part of our community at CloviTek Inc (“company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at info@clovitek.com.

When you visit our mobile application, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Apps and our services.

This privacy policy applies to all information collected through our mobile application, ("Apps"), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Sites"). 

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.  

TABLE OF CONTENTS  

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE USE YOUR INFORMATION?
  3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?   
  4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  5. DO WE USE GOOGLE MAPS?  
  6. HOW DO WE HANDLE YOUR SOCIAL LOGINS? 
  7. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
  8. HOW LONG DO WE KEEP YOUR INFORMATION?
  9. HOW DO WE KEEP YOUR INFORMATION SAFE?
  10. DO WE COLLECT INFORMATION FROM MINORS?
  11. WHAT ARE YOUR PRIVACY RIGHTS?
  12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  13. DO WE MAKE UPDATES TO THIS POLICY?
  14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
  1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us 

In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, payment information, and social media login data.  

We collect personal information that you voluntarily provide to us when registering at the Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Apps (such as posting messages in our online forums or entering competitions, contests or giveaways) or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Apps, the choices you make and the products and features you use. The personal information we collect can include the following:

Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.

Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.

Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.  

Social Media Login Data. We provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS" below.  

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Additional information related to personal information is found in our Privacy Policy.

Information automatically collected 

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Apps.

We automatically collect certain information when you visit, use or navigate the Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Apps and other technical information. This information is primarily needed to maintain the security and operation of our Apps, and for our internal analytics and reporting purposes. 

Like many businesses, we also collect information through cookies and similar technologies.   

Information collected through our Apps 

In Short: We may collect information regarding your geo-location, mobile device, push notifications, when you use our apps.

If you use our Apps, we may also collect the following information:

  • Geo-Location Information.We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings. 
  • Mobile Device Access.We may request access or permission to certain features from your mobile device, including your mobile device’s Bluetooth, calendar, microphone, sensors, social media accounts, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings. 
  • Mobile Device Data.We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.   
  • Push Notifications.We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.   

Information collected from other sources 

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources. 

We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).  

  1. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.  

We use personal information collected via our Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes"), in order to enter into or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below.  

We use the information we collect or receive:  

  • To facilitate account creation and logon process with your Consent. If you choose to link your account with us to a third party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below headed "HOW DO WE HANDLE YOUR SOCIAL LOGINS" for further information.  
  • To send you marketing and promotional communications for Business Purposes and/or with your Consent. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS" below).  
  • To send administrative information to you for Business Purposes. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.  
  • Fulfill and manage your orders for Contractual reasons. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Apps. 
  • Deliver targeted advertising to you for our Business Purposes and/or with your Consent. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.   
  • Administer prize draws and competitions for our Business Purposes and/or with your Consent. We may use your information to administer prize draws and competitions when you elect to participate in competitions.
  • Request Feedback for our Business Purposes and/or with your Consent. We may use your information to request feedback and to contact you about your use of our Apps.  
  • To protect our Sites for Business Purposes. We may use your information as part of our efforts to keep our Apps safe and secure (for example, for fraud monitoring and prevention).  
  • To enable user-to-user communications with your Consent. We may use your information in order to enable user-to-user communications with each user's consent.   
  • To enforce our terms, conditions and policies for Business Purposes and/or for Legal Reasons.  
  • To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.  
  • For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Apps, products, services, marketing and your experience.  
  1. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.   

We only share and disclose your information in the following situations: 

  • Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). 
  • Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.  
  • Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Apps, which will enable them to collect data about how you interact with the Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. 
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.  
  • Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Apps. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.  
  • We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.  
  • With your Consent. We may disclose your personal information for any other purpose with your consent.  
  • Offer Wall. Our Apps may display a third-party hosted “offer wall.” Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for acceptance and completion of an advertisement offer. Such an offer wall may appear in our mobile application and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will leave our mobile application. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account.  
  1. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.  

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.   

  1. DO WE USE GOOGLE MAPS?

In Short: Yes, we use Google Maps for the purpose of providing better service.  

This website, mobile application, or Facebook application uses Google Maps APIs. You may find the Google Maps APIs Terms of Service here. To better understand Google’s Privacy Policy, please refer to this link.  

By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service. By using our implementation of the Google Maps APIs, you agree to allow us to gain access to information about you including personally identifiable information (such as usernames) and non-personally identifiable information (such as location). We will be collecting the following information:  

  • Geo location data 

For a full list of what we use information for, please see the previous section titled "HOW DO WE USE YOUR INFORMATION?" and “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” We use information about location in conjunction with data from other data providers.  

The Maps APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Union, please take a look at our EU User Consent Policy. 

  1. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our websites using a social media account, we may have access to certain information about you.  

Our Apps offer you the ability to register and login using your third party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public.  

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Apps. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.    

  1. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites.   

The Apps may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Apps. You should review the policies of such third parties and contact them directly to respond to your questions.  

  1. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.  

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us. 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. 

  1. HOW DO WE KEEP YOUR INFORMATION SAFE? 

In Short: We aim to protect your personal information through a system of organizational and technical security measures.  

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Apps is at your own risk. You should only access the services within a secure environment.  

  1. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.  

We do not knowingly solicit data from or market to children under 18 years of age. By using the Apps, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at support@clovitek.com.   

  1. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.  

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws. 

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.   

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.   

Account Information  

If you would at any time like to review or change the information in your account or terminate your account, you can:  

  • Log into your account settings and update your user account. 
  • Contact us using the contact information provided.  

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements. 

Cookies and similar technologies:  Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Apps. To opt-out of interest-based advertising by advertisers on our Apps visit  http://www.aboutads.info/choices/ .   

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:  

  • Note your preferences when you register an account with the site.  
  • Access your account settings and update preferences.  
  • Contact us using the contact information provided.   
  1. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.   

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. 

If you are under 18 years of age, reside in California, and have a registered account with the Apps, you have the right to request removal of unwanted data that you publicly post on the Apps. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Apps, but please be aware that the data may not be completely or comprehensively removed from our systems. 

  1. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.  

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information. 

  1. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email us at support@clovitek.com or by post to:

CloviTek Inc    

PO Box 65793   

Salt Lake City, UT 84165   

United States    

Phone: (844) 500-6854  

If you have any further questions or comments about us or our policies, email us at info@clovitek.com or by post to: 

CloviTek Inc  

PO Box 65793   

Salt Lake City, UT 84165   

United States   

Phone: (844) 500-6854  

  1. Notification of Breach of Personal Data.

In accordance with Art. 33 of GDPR, in the event of a personal data breach, Clovitek, Inc. shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority competent in accordance with Article 55, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. 2Where the notification to the supervisory authority is not made within 72 hours, it shall be accompanied by reasons for the delay.

  1. The processor shall notify Clovitek Inc. without undue delay after becoming aware of a personal data breach.
  2. The notification referred to in paragraph 1 shall at least:
    • describe the nature of the personal data breach including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;
    • communicate the name and contact details of the data protection officer or other contact point where more information can be obtained;
    • describe the likely consequences of the personal data breach;
    • describe the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.
  3. Where, and in so far as, it is not possible to provide the information at the same time, the information may be provided in phases without undue further delay.
  4. Clovitek Inc. shall document any personal data breaches, comprising the facts relating to the personal data breach, its effects and the remedial action taken. 2That documentation shall enable the supervisory authority to verify compliance with this Article.
  1. Subject Access Requests.

At any time a User may request access to the Data being held by Clovitek Inc. Within 30 days of such a request, Clovitek Inc. shall attempt to: 1) verify the User’s identity, 2) collect all of the Subject Access information together, 3) send to the User a detailed listing of all data collected on the User.

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here. We will respond to your request within 30 days.