Privacy Policy

CLEAR Blockchain Technologies Privacy Policy

Last updated: August 14, 2018

Our Commitment to You
Clear Blockchain Technology Pte Ltd (“Clear”, “we” or “us”) are dedicated to providing users with the highest level of transparency and control over the use of their data. In order for us to provide you with our services we are required to collect and process certain personal information about you and your activity.

By entrusting us with your information, we would like to assure you of our commitment to keep such information private. We have taken measurable steps to protect the confidentiality, security and integrity of this Information. We encourage you to review the following information carefully. In this policy you can read about:

Contents
Grounds for data collection 1
How do we receive data about you? 1
What type of data we collect? 2
Tracking Technologies 2
How do we use the data we collect? 3
With whom do we share your Personal Data? 4
Transfer of data outside the EEA 5
How we protect your information 5
Retention 5
EU User Rights 5
How to contact us? 6
Our Policy toward Children 6
Updates to this Policy 6

Grounds for data collection
Processing of your “Personal Data” (meaning any information which may potentially allow your identification with reasonable means) is necessary for the performance of our contractual obligations towards you and providing you with our services on this website (the “Services”), to protect our legitimate interests and for compliance with legal and regulatory obligations to which we are subject.
When you use our Services, you consent to the collection, storage, use, disclosure and other uses of your Personal Data as described in this Privacy Policy.

How do we receive data about you?
We receive your Personal Data from various sources:
1. When you communicate with us – For example when you send us an email (or respond to our emails), or when you call us (or respond to our calls), we collect the Personal data you provided us with.
2. Technical data – When operating our Services, we use various technological tracking tools to collect information regarding your use of the Services in order to provide them and improve your experience. Along with our partners, we may use tracking technologies such as cookies, JavaScript, beacons and Local Storage, which are used to store content information and preferences. You can learn more about the tracking tools by reading the Tracking Technologies section below.
3. Third party data – We may receive your data from third party providers who help us with the provision and maintenance of our Services, such as business partners enrolled to our Services, traffic analytics vendors, fraud prevention agencies and others.

What type of data we collect?

Personal Data

In the course of using the Service, we may ask you to provide us with certain Personal Data to provide and improve the Service, to contact or identify you, to enable you to access certain parts of the Service, and as otherwise indicated in this Policy. We collect the following Personal Data about you:

• Contact information – when you contact us with regard to our Services, we will collect your name, your email address.
• When using our Services – our webserver will collect your IP-address, unique device identifiers and other technical data, as described below.

Non-Personal Data

We also collect data about the use of our Service and the characteristics and activities of users, in order to operate it and improve it. We may collect the following non-Personal Data:

• Technical information – this may include data such as your device type, device model, screen resolution, device language preferences, the browser you are using and its display settings, your operating system, session start/stop time, time zone, network connection type (e.g., Wi-Fi, cellular), installed apps, cookie information and your general location (city, country).
• Information from third parties – We may collect pseudonymous identifiers that some analytics and advertising partners choose to share with us. This information is used to enhance data points about a particular unique browser or device.
If we combine Personal Data with non-Personal Data, the combined data will be treated as Personal Data. Further Personal Data will only be stored and processed if you voluntarily provide it to us, e.g. through a contact form.

Tracking Technologies
When you visit or access our Services we use (and authorize 3rd parties to use) web beacons, pixels, cookies, and other tracking technologies. Those allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our Services, improve our Service’s performance, perform analytics and customize your experience. In addition, we may merge information we have with information collected through these tracking technologies with information we may obtain from other sources and, as a result, such information may become Personal Data.

We also use a tool called “Google Analytics” to collect information about your use of the Services. Google Analytics collects information such as how often Users access the Services, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Services. Google Analytics collects the IP address assigned to you on the date you visit, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to our Services is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

What are cookies?
Cookies are small text files (composed only of letters and numbers) that a web server places on your computer or mobile device when you visit a webpage. When used, the cookie can help make our Services more user-friendly, for example by remembering your language preferences and settings. You can find more information about cookies at www.allaboutcookies.org.

Cookies are widely used in order to make websites work in an efficient way. Cookies remember your preferences, and make the interaction between you and the Service smoother and more efficient.
How to manage your cookie settings

There are various ways in which you can manage and control your cookie settings. Please remember that, by deleting or blocking cookies, some of the features of the Services may not work properly or as effectively.

● Turning off cookies via your web browser
Most web browsers will provide you with some general information about cookies, enable you to see what cookies are stored on your device, allow you to delete them all or on an individual basis, and enable you to block or allow cookies for all websites or individually selected websites. You can also normally turn off third party cookies separately. Please note that the settings offered by a browser or device often only apply to that particular browser or device.

● Information about cookies is usually found in the “Help” section of the web browser. Below are some links to some commonly used web browsers:
o Google Chrome
o Internet Explorer
o Mozilla Firefox
o Safari (Desktop)
o Safari (Mobile)
o Android Browser
o Opera
o Opera Mobile

For other browsers, please consult the documentation that your browser manufacturer provides.
● Turning off third party cookies

You can turn off certain third party targeting/advertising cookies by visiting the following link: Network Advertising Initiative.
● Other helpful resources

To learn more about advertisers’ use of cookies the following links may be helpful:
o European Interactive Digital Advertising Alliance (EU)
o Internet Advertising Bureau (US)
o Internet Advertising Bureau (EU)

How do we use the data we collect?
• Provision of service – for the provision and improvement of our Services, including for support and to respond to your queries.
• Service announcements – we will use your Personal Data to communicate with you and to keep you informed of our latest updates to our Services and offer you service offers.
• Marketing and advertising purposes – by subscribing to our newsletter you will receive tips and announcements straight to your email account. We may also use your Personal Data in the following ways: we may send you promotional material concerning our Services, or our partners’ services, which we believe might interest you; we may also display certain adverts on our Services, which we believe will be relevant for you.

We make our best efforts to make sure you see only relevant ads and receive relevant communications from us, including but not limited to, by building an automated profile based on your Personal Data. You may however choose not to receive our promotional or marketing emails (all or any part thereof) by clicking on the “unsubscribe” link in the emails that you receive from us. Please note that even if you unsubscribe from our newsletter, we may continue to send you service-related updates and notifications, or reply to your queries and feedback you provide us. You may also object to the use of your Personal Data for advertising purposes by disabling your cookies, as described in the above Tracking technologies section.

o Opt-out of receiving marketing materials – If you do not want us to use or share your Personal Data for marketing purposes, you may opt-out in accordance with this “Opt-out” section. Please note that even if you opt-out, we may still use and share your Personal Data with third parties for non-marketing purposes (for example to fulfill your requests, communicate with you and respond to your inquiries, etc.). In such cases, the companies with whom we share your Personal Data are authorized to use your Personal Data only as necessary to provide these non-marketing services.

• Analytics, surveys and research – from time to time, we may conduct surveys or test features, and analyze the data we have to develop, evaluate and improve these features, all in order to improve our Services and think of new and exciting features for our users.
• Protecting our interests – we may use your Personal Data when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our services and protect the rights and property of Clear Labs, its users and/or partners.
• Enforcing of policies – we may use your Personal Data in order to enforce our policies, including but limited to our Terms of Service.
• Compliance with legal and regulatory requirements – we may use your Personal Data to investigate violations, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.

With whom do we share your Personal Data?
• Internal concerned parties – we share your information with companies in our group, as well as our employees, in order to provide you with our services.
• Business partners – we share your information with business partners, such as businesses who help us provide our Services, such as storage and analytics providers. These third parties may have access to your Personal Data so that they may perform these tasks on our behalf, but they are obligated to comply with this Privacy Policy and may not use your Personal Data for any other purpose.
• Compliance with laws and law enforcement entities – we cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
• Merger and acquisitions – we may share your data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Privacy Policy.

Transfer of data outside the EEA
Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

How we protect your information
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. Your data is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees or partners on a “need to know” basis, in order to enable the carrying out of the agreement between us.

While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the service, and you do so at your own risk.

Retention
We will retain your Personal Data for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, trading information, account opening documents, communications and anything else as required by applicable laws and regulations.

EU User Rights
You may request to:
a. Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
b. Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
c. Request rectification of your Personal Data that is in our control.
d. Request erasure of your Personal Data.
e.nObject to the processing of Personal Data by us.
f. Request to restrict processing of your Personal Data by us.
g. Lodge a complaint with a supervisory authority.

However, please note that these rights pertain to EU residents only, are not absolute, and may be subject to our own legitimate interests and regulatory requirements. Users outside the EU are welcome to contact us for any questions or requests at the details below.

How to contact us?
If you wish to exercise any of the aforementioned rights, or receive more information, please contact us using the details provided below:

Clear Blockchain Technology Pte Ltd.
Email: roni@clearx.io
6 BATTERY ROAD #10-01
SINGAPORE (049909)

Our Policy toward Children
We understand the importance of protecting children’s privacy, especially in an online environment. The Services are not designed for or directed at children under the age of 16 years old (“Minors”). We do not knowingly collect Personal Data from Minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Data, he or she should contact us using the details provided above.

Updates to this Policy
This Privacy Policy is subject to changes from time to time, in our sole discretion. The most current version will always be posted on our Services (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Privacy Policy.