Last updated: April 22, 2019

Introduction

Cloverly, Inc. ("Cloverly" or "we") operates the www.cloverly.com website (the "Website"). In addition, we also operate the Cloverly application program interface (the "Software") which you may encounter on the websites of our business-to-business customers (our "B2B Customers"). This Privacy Policy describes the types of information we may collect about you or that you or our B2B Customers may provide to us when you visit the Website or use the Software. It also describes our practices for collecting, using, protecting and disclosing that information.

This Privacy Policy applies to information we collect on the Website or through the Software, including information about you that is provided to us by our B2B Customers when you use the Software on such customers' websites. It does not apply to information collected by us offline or through any other means, including information collected on any other website operated by Cloverly, its affiliates or any third party. It also does not apply to any other information collected by a third party (including our affiliates) through any means, including information collected through any application or content (other than the Software) that may link to or be accessible from or on the Website.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using the Website or the Software, you agree to our collection, use, protection and disclosure of your information in accordance with this Privacy Policy. If you do not agree with our policies and practices, do not use the Website or the Software. This Privacy Policy may change from time to time, and your continued use of the Website or the Software after we make changes to this Privacy Policy is deemed to be an acceptance of those changes. Please check this Privacy Policy periodically for updates.

Information Collection - Information Provided by You

While using the Website, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Information"). Such Personal Information may include, but is not limited to, your email address and the username and password created if you register on the Website.. We collect such information directly from you when you provide it to us. This includes information that you provide by filling out forms on the Website, such as information provided at the time of registering on the Website or requesting further services or information from us. This also includes records and copies of your correspondence if you contact us. We may also ask you for information when you report a problem with the Website.

If you use the Software, we may collect Personal Information about you, such as your mailing address, or information that is about you but does not individually identify you, such as your zip code. We collect such information directly from you when you provide it to us or from our B2B Customers when you provide such information to them. This includes information that you provide by filling out forms when using the Software, such as information provided to request services from us or from our B2B customers.

Information Collection - Information Collected Automatically

As you navigate through and interact with the Website, we may use automatic data collection technologies to collect certain information about your equipment and browsing actions and patterns. This may include information that your browser sends whenever you visit the Website ("Log Data"), such as your computer's Internet Protocol ("IP") address, browser type, browser version, location data, the pages of the Website that you visit, the time and date of your visit, the time spent on those pages and other usage statistics.

The technology we use for this automatic data collection on the Website may include cookies. Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and placed on the hard drive of your computer. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The help feature on most browsers provides information on how to accept cookies, how to disable cookies or how to receive notifications when receiving a new cookie. Please note, however, that if you do not accept cookies, you may not be able to use some features of the Website.

We may also use automatic data collection technology to collect information about your online activities over time and across third-party websites or other online services (also known as behavioral tracking). Currently, the automatic data collection technology used on the Website does not respond to "Do Not Track" settings and similar mechanisms.

In addition, we may use third-party services, such as Google Analytics, that collect, monitor and analyze usage data on the Website. We may also use remarketing services (or behavioral advertising services) to advertise Cloverly's services to you on third-party websites after you have visited the Website. As discussed further below, these third-party service providers have their own privacy policies addressing how they use such information.

We do not automatically collect any information about you when you interact with the Software on a website operated by one of our B2B Customers.  

Use of Your Information

We use information that we collect about you or that you or our B2B Customers provide to us, including any Personal Information, for the following:

Disclosure of Your Information

We may disclose Personal Information that we collect or that you or our B2B Customers provide to us as follows:

Notwithstanding any other provisions of this Privacy Policy, we also reserve the right to access, preserve and disclose any information, including Personal Information, as we believe is necessary, in our sole and absolute discretion, for the following:

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

Accessing and Correcting Your Information

If you have registered and created a user account on the Website, you can review and change your Personal Information by logging into your account.

Security

The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store in order to protect it from unauthorized access, destruction, use, modification or disclosure.

However, please be aware that no method of transmission over the internet, or method of electronic storage, is 100% secure, and third parties may unlawfully intercept or access transmissions or private communications. We are unable to guarantee the absolute security of your information or that your information or private communications will always remain private. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of information at any time. Any transmission of information is at your own risk, and we are not responsible for the circumvention of any security measures implemented on the Website or within the Software.

The safety and security of your information also depends on you. Information provided through your creation and use of an account (if any) is protected by a password for your privacy and security, and you are responsible for keeping this password confidential. It is important that you prevent unauthorized access to your account and information by using a unique, secure and protected password and limiting access to your password.

Third Parties

Some applications or tracking technology on the Website are served by third parties, which may use cookies or other tracking technologies to collect information about you when you use the Website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based, or behavioral, advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used.

This Privacy Policy addresses only our collection, use, protection and disclosure of information collected by us on or through the Website or the Software and that you or our B2B Customers provide to us on or through the Website or the Software. It does not apply to the practices of third parties that we do not own, control, employ or manage, including any third-party websites, applications, services or businesses (including the practices of our B2B Customers). If you disclose your information to others, different rules may apply to their use or disclosure of the information you disclose to them. For example, the Website may contain links to other sites that are not operated by us, and if you click on such third-party links, you will be directed to that third party's site.

You acknowledge that if you provide information to third parties, that information will be subject to the privacy policies of those third parties, which may differ from this Privacy Policy. We have no control over and are not responsible for the content, privacy policies, or practices of third parties, and we encourage you to ask questions before disclosing your information to others. We strongly advise you to review the privacy policy of every site you visit.

Behavioral Advertising

As stated above, we may also use third-party remarketing services to advertise Cloverly's services to you on third-party websites after you have visited the Website. We and our third-party vendors may use cookies or other tracking technologies to optimize and serve advertisements to you on third-party websites based on your past visits to the Website. The third-party vendors which we may use include Google Inc. and Facebook Inc. For more information on the privacy practices of Google and Facebook (including how to opt out from tracking technology and interest-based advertising), please visit the Google and Facebook data or privacy webpages.  

Children's Privacy

Only persons age 18 or older have permission to access the Website or utilize the Software. In particular, neither the Website nor the Software is intended for children under 13 years of age. We do not knowingly collect Personal Information from children under 13. If you are under 13 years of age, do not provide any information on the Website or via the Software or otherwise provide any information about yourself to us, including your name, address, telephone number or email address. If we learn that we have collected or received Personal Information from a child under age 13 without verification of parental consent, we will take steps to delete that information.

Changes to This Privacy Policy

The date this Privacy Policy was last revised is identified at the top of this page. We reserve the right to update or change our Privacy Policy at any time by posting the updated or new Privacy Policy on this page. If we make any material changes to this Privacy Policy, we will also notify you by email to the email address you have provided to us (if any) or by placing a prominent notice on the Website. All amended terms automatically take effect after they are initially posted on this page, unless a change in any applicable law requires immediate amendment.

Use of information we collect or that you or our B2B Customers provide to us is subject to the Privacy Policy in effect at the time such information is collected or provided. You are responsible for ensuring that we have an up-to-date active and deliverable email address for you and for periodically visiting the Website and this Privacy Policy to check for any changes. Your continued use of the Website or the Software after we post any modifications to the Privacy Policy on this page will constitute your acknowledgement of the modifications and your consent to abide and be bound by the modified Privacy Policy.

Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at: [email protected].