This Privacy Policy describes the types of information gathered by Clipio, (“Clipio”, “we” or “us”) in the process of providing our website (https://www.clipio.com) (the “Site”), and the data, products, services, information, tools, functionality, updates and similar materials (collectively, the “Service”), how we use it, with whom the information may be shared, what choices are available to you regarding collection, use and distribution of information and our efforts to protect the information you provide to us through the Service.

By using the Service, you hereby consent to allow us to process information in accordance with this Privacy Policy. Please also refer to our Terms of Service, available here https://www.clipio.com/terms, which are incorporated into this document as if repeated in full. Capitalized terms found here which are not defined in this Privacy Policy shall have the same definition as in the Terms of Service.

This policy is subject to change. If our information retention or usage practices change, we will let you know by posting the Privacy Policy changes on the Service and/or otherwise making you aware of the changes. Your continued use of the Service following our notice of changes to this Privacy Policy (or other method of legal acceptance) means you accept such changes. Please refer to the “Effective Date” above to see when this Policy was last updated.

Territoriality

Regardless of where our servers are located, your personal data may be processed by us in the United States, where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world. BY VISITING THE SITE AND USING THE SERVICE, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY INFORMATION COLLECTED OR OBTAINED BY US THROUGH VOLUNTARY SUBMISSIONS, AND, TO THE EXTENT POSSIBLE, THAT U.S. LAW GOVERNS ANY SUCH COLLECTION AND PROCESSING.

This Privacy Policy may be subject to the provisions of the EU General Data Protection Regulation ("EU GDPR"), the UK General Data Protection Regulation (“UK-GDPR”, and together with the EU GDPR, the “GDPR”), and other applicable privacy laws. Under the GDPR, Clipio is a data “Controller.” If you are an individual who resides in the United Kingdom, Northern Ireland, the European Economic Area, or Switzerland (collectively, and for the purposes of this Privacy Policy, the “EEA”), you are a “Data Subject” with certain protected privacy rights concerning your “Personal Data.”  We will take commercially reasonable steps to maintain compliance with GDPR. Your Personal Data may identify you as a person, and thus may be referred to in this Privacy Policy as Personally Identifiable Information ("PII").

1. Who Collects Your Information on Our Service?

Clipio does. We collect information from you on the Service, and we are responsible for the protection of your information.

2. What Information Do We Collect?

A. Personal Information. We collect certain personal information about you, which may be supplied when you sign-up for the Service, when you complete a survey, when you create or update your Account, when you use the Site, when you request services, when you link your account to the Service or your social media account(s) via our optional integration, from third parties, and when you otherwise submit information to us. The types of personal information we collect and save include:

• Contact and/or account information such as your name, email address, physical address, phone number, username, certain employment information, and information collected through the Service’s optional social media integration;

• Technical information collected in our logs. Such information may include standard web log entries that contain your IP address, unique device identifiers (UDIDs), first party cookies (both session and persistent), third party cookies, flash cookies, web beacons, page URL and timestamp.

You may also provide us information when you interact with us through email, online chat, messaging functions within the Service, or otherwise. We may retain such information in order to provide you with Services, and you agree that we may share this information as needed with other users in order to resolve any issues that may arise between you and another user of the Service.

The Service may be integrated with third party social media platforms, such as Facebook and Instagram (“Platforms”). If you choose to interact with the Platforms through the Service, the Platforms may make additional Personal Information about you available to us.

The Service may record photos, audio, and video if you permit such access in order to use certain features of the Service. The Service may also notify us when you have read an email that we sent to you, and request permission to access your photo gallery, camera roll, or other device storage areas holding your images, audio, and videos for you to upload and transmit them through the Service.

The Service may also access the internet or use your mobile data plan in order to use certain features of the Service and send you push notifications.  If you elect certain functionality, the Service may also add icons and/or shortcuts to your device and/or browser.

Although it may appear that we collect financial information, it is actually collected and processed through our third-party payment processor (“Payment Processor”). Our Payment Processor may collect information such as banking information or credit card number, name, CVV code or date of expiration, from you through use of the Service.  Clipio does not hold your financial information.

B. Non-personal Information. Non-personal information is anonymous or non-personally identifiable information about you, including but not limited to links and materials posted (including product reviews, images of you with the product, and feedback), information about your web browser, which goods are purchased and the timing of purchases, the pages accessed most frequently, how pages are used, search terms entered, and similar non-personal data.

Automatically tracking Internet Protocol (IP) addresses is one method of automatically collecting information about your activities online and information volunteered by you. An IP address is a number that is automatically assigned to your device whenever you surf the internet, and may make it possible to identify your approximate location. Further, the Service may utilize web beacons, pixel tags, cookies, embedded links, and other commonly used information-gathering tools. Through collecting your IP address, we may be able to approximate your geographic location, however, unless and until this is information is paired with your PII, it cannot be used to identify you.  If non-personal information is paired or linked to any of your PII, we will treat that non-personal information as if it was also PII.

C. Aggregate Information. We may also collect anonymous, non-identifying and aggregate information such as the type of browser you are using, location, device information, session information, page views, operating system, referring websites, and IP Address.

3. Why Is My Information Being Collected?

We accept and gather information in an effort to provide the Service and our products to you.  We need to collect your personal information to, among other things, respond to your requests for products and information, to add you to our email lists, to integrate with the Platforms at your option, and generally to allow the Service to operate and our products to be sold and shipped to you.  Our Payment Processor collects your payment information for sales of products. We also collect aggregate information to help us better design the Service and improve our products or product lines. We collect log information for monitoring purposes to help us to diagnose problems with our servers, administer the Service, calculate usage levels, and otherwise provide products and services to you.

4. How Do We Use the Information We Collect?

A. We use the personal information you provide for the purposes for which you have submitted it including:

• Internal Uses. We may use your PII to respond to your inquiries, to fulfill your requests for information, track usage trends, conduct experiments, fraud prevention, develop and improve the Service and other offerings, and perform research and analytics.

• Creating and Maintaining Your Account. We use your PII to create and maintain an account for you to allow you to purchase and use the Service.

• Paying For Products. Our Payment Processor uses your PII to process your payment for products you order.

• Sending Orders and Information to you.  We use your PII to ship the products that you order, as well as other marketing materials, to you at the address provided.  This is usually done via a third-party carrier and/or the United States Postal Service, with whom we share your PII, which they use to coordinate and deliver these items to you.

• Sending Administrative, Marketing, and Promotional Emails. We may use your PII to send you emails to: (a) confirm your order and account information and your other PII; (b) process your transactions to purchase our products; (c) provide you with information regarding the Service or your orders; (d) inform you of changes to this Privacy Policy, our Terms of Service, or our other terms, conditions, or policies; or (e) provide you with information on our other services and products, or promotions related to the Service or our other services and products.

• Social Media Integration. We may use your PII to, at your request, integrate your social media accounts with the Service, and to provide to you the social media features of the Service.

• Serve You Targeted Advertisements. We may use your PII to serve you advertisements with the Service that are targeted to your interests.

B. We may use anonymous information that we collect to improve the design and content of our Service, and to enable us to personalize your internet experience. We also may use this information in the aggregate to analyze how our Site is used, as well as to offer you products or services

5. Do We Share Your Personal Information?

Clipio will not share your personal information except: (a) for the purposes for which you provided it; (b) with your consent; (c) as may be required by law or as we think necessary to protect our organization (including the defense of legal claims) or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or is about to cause, injury to or interference with the rights or property of another); or (d) with persons or organizations with whom we contract to carry out internal operations or business activities. With your knowledge and/or consent, we may share your personal information with our business partners, to provide similar products and services. We may also share aggregate information with others, including affiliated and non-affiliated organizations.

Finally, we may transfer or disclose your personal information to a third party, or our successor in interest, in connection with, and/or as the result of, an acquisition, sale, merger, reorganization, or bankruptcy involving our company.

6. Are There Other Ways My Personal Data Could Be Shared?

You may elect to share certain personal information with individuals or with the public via your use of the Site.  In this case, you will control such sharing via settings that we provide.  For example, the Site may make it possible for you to publicly share information via social media such as Facebook, Instagram, or Twitter.  Be aware that when you choose to share information with friends, public officials, or with the public at large, you may be disclosing sensitive information, or information from which sensitive information can be inferred.  Always use caution when sharing information through the Service. You understand and agree that we are not responsible for any consequences of your sharing of information through and beyond the Site.

7. How Can You Access and Control Your Information?

After becoming a user of the Service, you may revise or edit your information through your account (If applicable) or by sending an email to support@useclipio.com. For instructions on how you can further access your personal information that we have collected, or how to correct errors in such information, please send an e-mail to support@useclipio.com.  You may opt-out of third-party information sharing and/or receipt of promotional emails by emailing us at support@useclipio.com with “Opt-Out” in the subject line, and indicating that you wish to opt-out of one or both of the foregoing features.

8. How Do We Store and Protect Your Information?

A. After receiving your personal information, we will store it on our servers for future use. We have physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect. Unfortunately, no data transmission over the internet or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information, we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers' systems.

B. If you are visiting the Site from outside of the USA, you understand that your connection will be through and to servers located in the USA, and the information you provide will be securely stored in our servers and internal systems located within the US

C. We retain and store your personal information until you request us to remove it from our servers. We store our logs and other technical records indefinitely.

9. How Do We Use Cookies and Other Network Technologies?

A. To enhance your online experience with us, our web pages may presently or in the future use "cookies." Cookies are text files that our web server may place on your computer’s hard drive to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other PII unless you choose to provide this information to us. Once you choose to provide PII, however, this information may be linked to the data stored in the cookie. Although it may be possible to turn off the collection of cookies through your device or browser, certain features of the Services may not function properly without the aid of cookies.

B. Our Service uses Google Analytics, provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 (“Google”). Google Analytics uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may collect information regarding the use of other websites, apps and online resources.  For more information on how Google uses data when you use our Site or Service, please follow this link: https://policies.google.com/technologies/partner-sites.  You may be able to opt-out of some or all of Google Analytics features by downloading the Google Analytics opt-out browser add-on, available at, https://tools.google.com/dlpage/gaoptout.  For more information about interest-based ads, or to opt-out of having your web browsing information used for behavioral advertising purposes, please visit http://optout.aboutads.info.

C. We or our service providers may also use "pixel tags" "web beacons" "clear GIFs" or similar means (collectively, "Pixel Tags") in connection with some email messages for purposes of, among other things, compiling aggregate statistics about website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to website visitors and may be associated with cookies on visitors’ hard drives. Pixel Tags allow us and our service providers to count users who have visited certain pages of the Site, to deliver customized services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can inform the sender of the email whether and when the email has been opened.

D. Our Service also uses the “Custom Audience pixel” of Facebook, Inc., 1 Hacker way, Menlo Park, CA 94025 USA (“Facebook”) on our website. This allows user behavior to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, so we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Policy available at https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads. For more information about interest-based ads, or to opt-out of having your web browsing information used for behavioral advertising purposes, please visit http://optout.aboutads.info.

E. As you use the internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to “s "clickstream data”, can be collected and stored by a website's server. Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to the Site. We may use clickstream data as a form of non-personally identifiable information to determine how much time visitors spend on each page of our Site, how visitors navigate through the Site, and how we may tailor our web pages to better meet the needs of visitors. We will only use this information to improve our Site and Services.

F. Do Not Track. At present, the Site does not specifically respond to browser do-not-track signals.

10. Collection of Information by Others.

Our Terms of Service document may identify certain third-party websites to which we may provide links, and that you may click on our Site. Please check the privacy policies of these other websites to learn how they collect, use, store and share information that you may submit to them or that they collect.

11. 'EEA’ Privacy Rights.

If you currently reside in the EEA, the GDPR applies to your PII and you are a Data Subject.  The GDPR requires that we, as a Controller, have a legal basis to process your PII.  

A. We process your PII under one or more of the following legal bases: 

• Processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; 

• To perform the contract that we are about to enter with you (e.g., our Terms of Service); 

• To comply with a legal obligation; and/or

• If we have your consent to do so, such consent can be revoked at any time.

B. Under the GDPR, as a Data Subject you have certain rights. They are:

• The right to be informed. This is your right to be informed about what they are processing, why, and who else the data may be passed to.

• The right of access. This is your right to see what data about you is held by us.

• The right to rectification. This is the right to have your data corrected or amended if what is held is incorrect in some way.

• The right to be forgotten. This is the right to have your personal data to be deleted in the event that such data is no longer required for the purposes it was collected for, your consent for the processing of the data is withdrawn, or the data is being unlawfully processed.

• The right to restrict processing. This is the right to ask for a temporary halt to processing of your personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.

• The right to data portability. This is the right to ask for your personal data to be provided to you in a structured, commonly used, and machine-readable format.

• The right to object. This is the right to object to further processing your personal data if such processing is inconsistent with the primary purposes for which it was collected.

• Rights in relation to automated decision making and profiling. This is the right to not be subject to a decision based solely on automated processing. The Service does not engage in automated decision making and profiling. 

You can find instructions for enforcing some of these rights elsewhere in this Privacy Policy. Otherwise, if you wish to find out more about these rights, please contact us at support@useclipio.com.

11. Children and Young People’s Information.

We do not knowingly collect any information from any minors, and we comply with all applicable United States privacy laws including the GDPR, the USA’s Children's Online Privacy Protection Act (“COPPA”) and associated Federal Trade Commission (“FTC”) rules for collecting personal information from minors. Please see the FTC's website (www.ftc.gov) for more information. If you have concerns about our Site, wish to find out if your child has accessed our services, or wish to remove your child's personal information from our servers, please contact us at support@useclipio.com. Our Site will not knowingly accept personal information from anyone under 13 years old in violation of applicable laws, without consent of a parent or guardian. In the event that we discover that a child under the age of 13 has provided PII to us, we will make efforts to delete the child’s information in accordance with COPPA. If you believe that your child under 13 has gained access to our Site without your permission, please contact us at support@useclipio.com.

12. California Privacy Rights.

California law allows California residents to request information regarding our disclosures to third parties in the prior calendar year, if any, of their personally identifiable information. To make such a request, please contact us at support@useclipio.com with "Request for Privacy Information" in the subject line. Please include enough detail for us to locate your file; at a minimum, your name, email, and username, if any. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that this law does not cover all information sharing. Our disclosure only includes information covered by the law.

13. Our Contact Information.

If you have any questions or concerns about this Privacy Policy, you may e-mail us at support@useclipio.com.

Copyright © Clipio. All rights reserved. The Service is the property of Clipio, and is protected by national and international copyright, trademark, and other applicable laws. This includes the content, appearance, and design of the Service.  All service marks and trademarks used on the Site are owned by us or by our suppliers or other third parties.