Privacy Policy

Effective Date: 14th December 2022

 

1. INTRODUCTION TO POLICY

Please, read this Privacy Policy (this “ Policy”) carefully as it contains information about how we process your data when you use the Clueo mobile application and associated website (the “ Clueo App”). This Policy carefully describes how we (Clueo) collects, use, disclose, transfer, store, retain, and secure your data, as well as the rights and choices you have as provided by the General Data Protection Regulation 2016/679 (“ GDPR”), Lei Geral de Protecao de Dados (“ LGPD”), California Consumer Privacy Act (“ CCPA”), and other applicable privacy laws. 

Your consent to our privacy practices is given when you sign up and click the “I agree” or “I accept” box or link. You are required also to review our Terms and Conditions, which governs how you use the Clueo App.


2. YOUR DATA CONTROLLER

As required under the GDPR, LGPD, and similar privacy laws, the Clueo App is provided to you by Neurondigital, located at 8, Maranatha, Triq Tal-Fieres, Kirkop, KKp 1502, Malta (trading as “ Clueo”). We determine all processing activities (including the collection, retention, disclosure, security, or storage) in relation to your data. If you have any questions regarding your data and how we process it, please reach out to us via our email address at info@clueo.app.


3. WHAT PERSONAL DATA Clueo COLLECTS

Personal data is any data that is able to identify you. This may include your name, email address, picture, device IP address, browser type and other identifiers, income, transactions, etc. We may collect personal data about you in the following ways when you use the Clueo App:

  • Personal data that you provide to us: We may collect the personal data you provide to us when you use the Clueo App. This personal data may be provided to us by you when you (i) register an account on the Clueo App; (ii) fill out your profile information; (iii) contact us to make a complaint, ask questions, inquiries, or leave feedback; (iv) submit your payment method information to pay for premium features; (v) create an account or sign up to use the Clueo App via any of the social media plugins (Apple and Facebook plugins); or (vi) submit your email address to receive our newsletters. You are under no obligation to provide us with the above data; however, we will not be able to provide you with certain features without this data.
  • The data we collect automatically: Clueo and third-party service providers, including our analytics partners, collect certain data from you automatically using cookies, pixels, and third-party tools. When you access the Clueo App, we collect data about (i) how you use the Clueo App, including the part of the Clueo App you are on, your duration of use, the features you click, your search terms, how many users are online and how they came to the Clueo App; and (iii) performance, diagnostics, and crashes.

The third-party tools we use in collecting the data above may include Google Analytics 4 (Analytics, Performance, and Crashlytics), Google Analytics, Sentry.io, and Google Play Services. Google Analytics is a third-party tool from Google Inc. that helps us gather some of the automatically collected data discussed under this paragraph. You can opt-out of Google Analytics from tracking and gathering certain data about. You can download the Google Analytics opt-out add-on to do so.

  • Social media integration: Clueo provides an account registration or login feature where you may be able to sign up or log in to your Clueo account via the Facebook or Apple plugins (“ Plugins”) available on the Clueo App. If you opt-in to use any Plugin to sign up or log in to your account, you are authorizing us to obtain certain personal data available on the Plugin account. For example, depending on the privacy settings you have on Facebook, we may obtain your name, picture, email address, etc., when you use the Facebook Plugin to sign up or log in to the Clueo App. The data we obtain from any Plugin you use is automatically shared by the Plugin service.
    You have the right to terminate your Plugin account from the Clueo App at any time or update your preference or permissions via your Plugin service account.

4. HOW Clueo USES THE DATA COLLECTED

Depending on the personal data collected, and depending on the method of collection, we may use your data for the following:

  • To generally provide you with a user account, identify you from other users, and provide our services to you;
  • To contact you regarding any notice (such as updates to this Policy or our services) we wish to communicate to you, including when you subscribe to our newsletters;
  • To respond to your inquiries, complaints, questions, queries, and concerns;
  • To troubleshoot or diagnose problems and crashes so as to provide fixes and upgrades and improve your user experience;
  • To gather anonymous analytics about how users use the Clueo App and identify where to improve;
  • To identify your preferences in order to retarget ads to you on other websites and/or apps;
  • To process your payments for our premium features;
  • To comply with our legal obligations and protect our rights and other third parties; and
  • To enforce our Terms and Conditions.

5. LEGAL BASES

We rely on the following legal bases when we process your data:

  • Consent: We will process personal data about you when you consent. For example, where you willingly subscribe to our newsletter or where you tick the “ I accept” or “ I agree” box wherever we make it available. Where you give us consent, you can easily withdraw such consent at any time. For example, you can unsubscribe from our newsletter by following the instructions for unsubscribing in any email newsletter sent to you by Clueo or via your account profile area.
  • Contract: Much of the reasons for processing your data are based on fulfilling our contractual obligations with you. For example, we request your payment method data to process your payment and deliver the services advertised.
  • Legitimate interest: We process certain data, such as usage and statistic data, to satisfy our legitimate interest, including troubleshoot problems and provide improvement to the Clueo App, and developing new features based on the statistical data we have gathered.

6. OUR DATA RETENTION PERIOD

Unless you request that we delete your user account or certain data, we will retain your data in our database for as long as you hold an active Clueo account. Notwithstanding, we will retain certain data, such as details of transactions, for more than 5 years to comply with our legal obligations.


7. WHO HAS ACCESS TO YOUR DATA?

Clueo does not share personal data about you with third parties for their marketing purposes. However, we may share anonymous or hashed data with third parties to help us market our services. We may share personal data for the purposes disclosed to you when you provide us such data. Likewise, we may share personal data in the following ways:

  • Other users: When you engage in a savings goal with one or more other users of the Clueo App, we may share your profile data with such users. The personal data you have on your profile, including your name and picture, will be visible to such users.
  • Service Providers: We may share personal data about you with service providers, such as our payment processor(s), email sender, data storage company, content delivery partner, app distributor(s), support provider, and other third parties who perform specific tasks for us. For example, we may share your payment method data with our payment processor to help us process your payments for our in-app premium services.
  • Advertising partners and agencies: We may share anonymous data about you, which we collected through third-party tools, and share them with ad agencies and partners in order to market our services and the Clueo App on other websites and apps. The data shared with ad agencies or partners are anonymous data based on user preferences and interests.
  • Clueo Group: People working within Clueo, including our employees, agents, and owners, may have access to personal data if necessary.
  • Business Transfer: Clueo may engage in any business transfer activity and share personal data about you, including without limitation, during a merger, sale of assets, acquisition, or consolidation, as well as during bankruptcy.
  • Law Enforcement: We may be asked by law enforcement or public offices to disclose personal data, including in response to a court order, subpoena, and other legal summonses. We may share personal data in response to claims relating to fraud or other illegal activities. We may also share personal data if sharing it will prevent or protect our properties or rights.
  • Your request: In the event that you exercise your right of data portability (see your data rights), we will have no option but to transfer your data as requested by you.

8. OUR DATA PROTECTION PRACTICES

Clueo values your privacy; we maintain adequate and sophisticated data protection practices when it comes to securing your data from unauthorized access or use.

All the data you transmit via the Clueo App is encrypted using a secure HTTPS connection. For example, we encrypt sensitive data, such as your savings goal and transaction name, in our database. In addition, we encourage all users to use passwords that are secure as much as possible. We also employ a Pin Lock feature on the Clueo App.

In addition to the technical safeguards employed above, we do not share personal data unless as described under this Policy. We do not share data with employees (or people within the company) unless it’s on a need-to-know basis.

However, users are aware that no method of transmitting data over the internet is 100% secure. Due to this, we cannot guarantee users that their data is 100% secure from unauthorized access or use. Clueo performs its data protection obligations accordingly; however, we cannot guarantee the security of your data or guarantee that data on our service will not be accessed, used, or altered by unauthorized persons. Likewise, Clueo will not be responsible for the security of data we disclosed to third parties in the course of the Services.

Users are also advised to maintain confidentiality when it comes to their login data and who has access. Users are also encouraged to immediately notify Clueo if they notice any unauthorized access to their account.


9. INTERNATIONAL TRANSFER OF DATA

Clueo runs the Clueo App from the European Union (“ EU”) where we process your data from. If you use the Clueo App from outside of the EU, be aware that we transfer and process your data in the EU. Likewise, we may work with service providers from outside of the EU and countries different from your location. We may transfer personal data about you to such third parties to perform certain services for us in their respective locations. However, we will only transfer personal data to such third parties with adequate safeguards.

For users within the EU and countries with laws similar to the GDPR (including Brazil), we are required to transfer personal data from the EU to countries outside the EU using the approved mechanisms. We will only transfer personal data to third parties outside of the EU on the basis of the approved transfer mechanisms by the European Commission, including using standard contractual clauses where the country does not have adequate data protection laws.


10. MANAGING YOUR DATA

Generally, all users have the right to access the data they have provided with us and correct them when the need arises. Likewise, users can request the deletion of certain personal data and/or close their account at any time.

To access, edit, or delete personal data about you or your account, please use the profile section of your Clueo App user account. For some reason, we may not be able to delete certain data if it goes against any applicable law (for example, where we are required to keep certain records for up to 5 years) or our legitimate interest.


11. RIGHTS UNDER THE GDPR AND LGPD

If you are using the Clueo App from within the EU, Brazil, and countries with similar laws, you have the following rights in addition to section 10 above.

  • The right to restrict processing: You may request that we restrict certain data about you, including (i) if you think we used it unlawfully but you do not want us to delete it (ii) if it is inaccurate, and (iii) if it is no more relevant, but you want Clueo to keep it for use in legal claims.
  • The right to data portability: You have the right to request the transfer of your data from our services to another service, app, or website without disrupting the usefulness of your data.
  • The right to object to direct marketing: You have the right to object to direct marketing from Clueo. Where you have subscribed to receive our newsletters, you can unsubscribe at any time by following the instructions for unsubscribing in every email newsletter sent to you by Clueo or via your user account profile.
  • The right related to automated decision making: Where we process your data with a machine rather than a human, and it affects your interest, you can request that we make such a decision using a human.
  • The right to withdraw your consent: Where we process your data based on consent, you may withdraw your consent at any time without issues.

To exercise the above rights, including if you believe we are unlawfully processing your data, you may contact us via our email address at info@clueo.app. You may also report us to any data authority applicable to your jurisdiction if we fail to comply.


12. CALIFORNIA USERS’ RIGHTS

In addition to the rights in section 10 above, California consumers (users) under the CCPA have the following rights:

  • The right to know about the categories of data we have shared with third parties in the past 12 months.
  • The right to opt-out of the sale of personal data: Fortunately, Clueo does not sell, buy, rent, or share personal data about users to third parties for their direct marketing or profit.
  • The right to exercise any rights under this Policy without Clueo discriminating against you based on your status, color, race, ethnicity, age, or religion.
  • The right to report us to any privacy authority in California if you believe we are unlawfully processing your data.

To learn more about the CCPA and how to exercise the above rights, please reach out to us via our email address at info@clueo.app.


13. CHILDREN POLICY

The Clueo App is targeted at individuals who are at least 18 years of age. You may not use the Clueo App or submit personal data to us if you are under 18 years of age. You may only use the Clueo App if you are under 18 years of age at the supervision of a parent(s) or legal guardian.


14. THIRD PARTY ADVERTS

The Clueo App may contain links and adverts from third-party websites or apps due to our use of Google’s AdMob. These adverts, if available on the Clueo App, are there for reference purposes based on your interest. Clueo is not affiliated with any of the companies behind these adverts, and we do not have any control over their content and privacy practices. If you access any advert and/or share personal data with such companies, you do so at your own free will, and you release Clueo from any loss of data when you submit personal data to such companies. We advise that you review their privacy practices before submitting personal data to such companies. 


15. AD RETARGETING

We may engage in ad retargeting. We may hire the services of ad agencies and marketing partners to help us display adverts about our products and services (the Clueo App) on their websites and apps. We may share the data we gather from third-party tools described above with these third parties in order to display ads to you on other platforms.

You may opt-out of ad retargeting by using the opt-out option on the channel used to display the ads to you. Also, some of our ad agencies and partners may be members of the Network Advertising Initiate (“ NAA”) and Digital Advertising Alliance (“ DAA”). Please, visit NAA and DAA to learn more about them and how to opt-out. 


16. CHANGES TO THIS POLICY

We may update and change parts of this Policy for certain reasons, including due to changes to applicable law or certain features of the Clueo App. Changes to this Policy will be posted on this page with the Effective Date changed to reflect such changes. We may also notify you of any changes to this Policy via your account associated email address. Your continued use of the Clueo App after any changes to this Policy constitutes your acceptance of such changes.


17. CONTACT US

You may contact us at info@clueo.app if you have any questions, inquiries, complaints, or issues with this Policy.

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