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Data & Privacy Protection Policy

WHO WE ARE

The website www.clara.co is operated by Clara Technologies Limited (we, our, Clara or us) so that we may:

(1) help direct you to products and services which may be of interest to you; and

(2) contact you with information and offers, suggestions and recommendations of products and services which may be of interest to you from either Clara, its affiliates or its partners

Where we use our site in this Data & Privacy Protection Policy, we mean www.clara.co.

Company Name: Clara Technologies Limited
Registered Number: 000001598
Registered Office: 2406 ResCo-work02, 24th Floor, Al Sila Tower, Abu Dhabi Global Market Square, Al Maryah Island, Abu Dhabi, United Arab Emirates

DATA & PRIVACY

What we collect

At Clara, we gather information in a range of different ways:

Information automatically collected

Each time you visit our site, we may automatically collect information about you and the device you are using, including:

  • information about which pages you visit and which resources you use on our site
  • information about how you got to our site
  • your internet protocol address known as your IP address which is used to connect your device to the internet
  • information about your preferences and items you have bookmarked, liked or shared
  • your device’s operating system and platform
  • the type and version of the browser you are using
  • MAC addresses which are used as network addresses for Wi-Fi and Ethernet
  • traffic data, which is aggregated information about the number of visitors, sessions, users and page visits to our site
  • location data
  • time zone setting
  • weblogs
Information we get from others

We may get information about you from other third-party sources, such as your employer when they issue you options or shares, or from the Founders of a company that you invested in who use Clara. These other third-party sources will have their own applicable privacy notices, cookie notices and terms and conditions regarding the use of personal data and we do not accept any responsibility or liability for those notices, terms and conditions or the use of your personal data by those other third party sources.

Information you give us

If you sign up with us, we may also collect:

  • your name
  • your email address
  • your address
  • your social media account information
  • your telephone number
  • your gender
  • your date of birth
  • username
  • password
  • driver’s licence, passport number or national ID number

Please note that as a user of our website, you are responsible for keeping your login information including your password confidential. If you believe that your login information or password has been compromised or that someone else has accessed your account, please notify us immediately by contacting us at privacy@clara.co

Please see ‘Our use of cookies’ below for details of the cookies we use on our site.

Where do we get your information from?

We collect the information you provide to us directly or by filling in any of the forms on our website. We also collect information directly from your device. We use cookies to collect some of this information. Please see ‘Our use of cookies’ below for details of the information we collect through our site.

Why do we need your information?

We need the information we collect automatically about your visit to our site to:

  • administer our site
  • improve our site to ensure that content is presented in the most effective manner
  • allow you to participate in interactive features of our services when you choose to do so
  • analyze how visitors use our site (including behavior patterns and the tracking of visits across multiple devices)
  • improve your online experience

We need the information you provide directly to us or by filling in any of the forms on our site to:

  • direct you to products and/or services which may be of interest to you
  • contact you with information and offers, suggestions and recommendations of products and/or services which may be of interest to you
  • contact you about those products and/or services on our site in which you have expressed an interest
  • provide our services to you
  • comply with our regulatory or legislative requirements

You do not have to give us any information or confirm that the information we have obtained from other sources is correct.

Who do we share your information with?

We sometimes share some of your information with other organizations, including our affiliates and partners.

In some cases, we may choose to buy or sell business assets. In these types of transactions, user information is typically one of the transferred business assets. If we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your personal information as set out in this Privacy Policy.

We use Google Analytics to collect details of how you use our site, as well as anonymous data that you enter into our forms. We do this to help us analyze how visitors use our site (including behavior patterns and the tracking of visits across multiple devices). All the information that is collected is anonymous and is only used to improve how our site works. Please see ‘Our Use of cookies’ below for more details about Google Analytics.

We also use a number of carefully selected third parties to supply us or you with products and services. We will only share your information with our suppliers, affiliates and partners where it is necessary for them to provide us or you with the services that are needed.

Where is your information stored?

Your information is stored on servers and filing systems in the United States of America. Our servers are hosted on Google Cloud using Google Kubernetes Engine.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Where we use providers based in the United States of America, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the United States of America.

Our site may contain links to and from the websites of third parties (e.g. payment processing sites). If you follow a link to any of these websites, please note that these websites have their own terms and conditions, privacy notices and cookie notices and we do not accept any responsibility or liability for those notices or your use of those websites.

How do we protect your personal data?

Clara is concerned with keeping your personal data secure and protecting it from unauthorized disclosure. We implement a variety of security measures to ensure the security of your personal data on our systems, including extensive due diligence on our code and run periodically vulnerability tests to make sure our applications and your data is always safe and secure.

We use enhanced security on top of our Container-Optimized OS including locked-down firewalls, read-only file systems and limited user accounts with disabled root login. Any personal data collected by us is contained behind secured networks and is only accessible by a very limited number of employees who have special access rights to such systems and whom are subject to strict confidentiality obligations. Where personal data is collected by us it will be transmitted and protected via a secure protocol and encrypted in our databases to be accessed only as stated above.

If and when we use subcontractors to store your data, we enter into written agreements with them which comply with applicable data protection law to help ensure the security of your personal data is within best international standards. Unfortunately, no transmission of data over the internet is guaranteed to be completely secure. It may be possible for unauthorized third parties, to intercept or access transmissions or private communications unlawfully. While we strive to protect your personal data, we cannot ensure or warrant the security of any personal data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

How long do we keep your information for?

We only keep your information for as long as we need it.

If you have an online account with us or provide information directly to us by filling in the forms on our site or via social media, we will keep your information for no more than five years from the date you cease to have any active accounts with us. We keep your information for this long so that we can:

  • ensure we contact you with information on products, services, suggestions, offers and recommendations relevant and appropriate to you
  • deal with any issues or concerns that you may have about how we handled your account
  • bring or defend any legal claims
  • comply with regulatory audit requirements

Do we carry out profiling and automated decision making?

We use Google Analytics to collect details of how you use our site, as well as anonymous data that you enter into our forms. We do this to help us analyze how visitors use our site (including behavior patterns and the tracking of visits across multiple devices), administer our site and manage your account. Please see ‘Our Use of cookies’ below.

The profiling and automated decision-making we carry out in respect of the information we hold about you and your account is used to enable us to ensure relevant information, suggestions and recommendations for products are sent to you by us.

What rights do you have?

Under the data protection rules, you have a number of rights in respect of your information, which include the right to:

  • access your information
  • withdraw your consent to the processing of your information at any time
  • ask us to make changes to the information we hold about you to make sure that it is accurate and up to date
  • delete or erase your information (sometimes called the right to be forgotten)
  • stop or restrict our processing of your information
  • object to our processing your information
  • not be subject to automated decision-making
  • request the transfer of some of the information we hold about you (known as data portability)

If you would like to exercise any of your rights, please contact us at privacy@clara.co. Please note that an archive copy of any information provided to us may be retained by us for our records and for audit purposes.

You have the right to request a copy of the information we hold about you by sending your request in writing to us at privacy@clara.co.

You can unsubscribe from our emails at any time by clicking on “unsubscribe” at the bottom of the email.

You can typically remove and reject cookies from our website with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it may affect how our website works for you. Please see ‘Our Use of cookies’ below.

California Privacy Rights

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and third parties for marketing purposes and providing contact information for such affiliates and third parties. If you are a California resident and would like a copy of this notice, please submit a written request to privacy@clara.co.

Making a complaint

If you have any questions, concerns or complaints about the way we process your personal information, please contact privacy@clara.co.

If you are not happy with the way we have handled your complaint or are still concerned about our handling of your personal information, you can lodge a complaint with your local data protection supervisory authority or, where applicable, the US Department of Commerce and/or the Federal Trade Commission.

In the European Economic Area, the relevant supervisory authority is the one in the country or territory where:

  • you are resident;
  • you work; or
  • the alleged infringement took place.

A list of National Data Protection Authorities in the European Economic Area can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

OUR USE OF COOKIES

What are cookies?

Cookies are text files containing small amounts of information which are downloaded to your device when you visit our site. Our site recognizes those cookies on each subsequent visit, enabling our site to recognize you.

Unless you have adjusted your browser settings to refuse cookies (and details of how to do this are signposted at the end of this policy), our site will set cookies as soon as you visit our site.

How and why we use cookies

We use cookies on our site to:

  • recognize you whenever you visit our site
  • remember the notifications you’ve seen so that we don’t show them to you again
  • allow you to navigate between pages efficiently
  • measure how you use our site so it can be updated and improved to give you the best possible experience on our site

The information we obtain from our use of cookies will not usually contain information from which you can easily be identified, such as your name. However, we do collect some personal data relating to your computer or other electronic device, such as your IP address, your browser and other internet log information.

In most cases we will need your consent to use cookies on our site. The exception to this is where the cookie is essential for us to provide you with a service you have requested. 

When you open our site in your browser a cookie pop-up message will be displayed and this will ask you for your consent for non-essential cookies to be placed on your device. If you do not click to accept cookies but you continue to use our site without disabling cookies, we will consider this to mean that you accept our use of these non-essential cookies.

A record of your acceptance will be stored in a functional cookie for 30 days, after which the cookie will expire, and the cookie pop up message will be displayed again.

You may withdraw your consent or acceptance at any time by following the instructions for disabling cookies, signposted at the end of this policy.

We use the following cookies on our site:

Functional cookies

These non-essential cookies allow our site to remember choices you make. The information these cookies collect may be anonymized and they cannot track your browsing activity on other sites.

Cookie name

[token]

What is the purpose of this cookie

You will see a pop-up cookies message when you first visit our site. We’ll store a cookie so that your computer knows you’ve seen it and knows not to show it again. This expires after 30 days when you will see a pop-up cookie message again to remind you of this Data & Privacy Protection Policy and to ask you to consent again to our use of non-essential cookies.

How long this cookie lasts

Valid unless deleted

Third party performance cookies

These non-essential cookies collect information about how visitors use our site, for example which pages visitors go to most often and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and is therefore anonymous. It is only used to improve how a website works.

Cookie name

[_ga]

What is the purpose of this cookie

We use Google Analytics to collect information about how you use our site.

YWe use the information to compile reports and to help us improve our site. The cookies collect information in an anonymous form, including the number of visitors to our site, where visitors have come to our site from and the pages they visited.

We don’t allow Google to use or share our analytics data.

Google Analytics stores information about:

  • the pages you visit on our site
  • the actions you perform on our site
  • how long you spend on each page
  • how you got to our site
  • what you click on while you’re visiting our site
  • information about the browser and device you use to navigate our site, (including an anonymized IP address)

We don’t collect or store any personal information (for example your name or address) that can be used to identify who you are.

More details about how Google Analytics collects and processes data are available at www.google.com/policies/privacy/partners.

You can opt out of being tracked by Google Analytics cookies across all websites http://tools.google.com/dlpage/gaoptout.

Valid unless deleted

Where to find more information

You can adjust the settings in your web browser to determine whether (all) sites can set cookies on your computer. More information about cookies and how to manage them, specific to your browser, can be found at https://ico.org.uk/for-the-public/online/cookies/.

If you have any further questions, comments or requests regarding our use of cookies or how we use cookies on our site, please contact us at privacy@clara.co.

Changes to our Data & Privacy Protection Policy

We may change this Data & Privacy Protection Policy from time to time. If we make any substantive changes related to how we collect or use personal data, we will change the content last updated date below. Other changes including grammar or spelling corrections will automatically update the timestamp at the bottom of this document.

This Data & Privacy Protection Policy was last reviewed and updated in September 2019.