Privacy Policy

Updated: 10th of May 2024 - Version number: 1.8

This Website www.clepher.com (the “Website”) is the property of Clepher (“Clepher” ). Clepher is a sub-brand of Marketing Released B.V. (“MR”). MR is registered at the Chamber of Commerce in The Netherlands under number 62865668. This is the Privacy Policy of Clepher (“Clepher,” “We,” “Us” or “Our”). Our Privacy Policy explains how We collect, use, share and protect information in relation to Our mobile services, Our website www.clepher.com, and any software provided on or in connection with Clepher services (collectively, the “Service”), and Your choices about the collection and use of your Personal Data. By using the Service, You understand and agree to the collection and use of information in accordance with this Privacy Policy.

We will NEVER sell your personal data to anyone.

Clepher enables the visitors of its site, clepher.com, to be in control of their personal data. We also provide controls that allow Clepher’s Customers and its End Users to have control over the privacy of personal data that is captured by Our Service. This Privacy Policy provides information about how Clepher processes and protects this data.

At Clepher we consider the privacy of our visitors, and the security of their personal information, to be extremely important. This Privacy Policy document describes, in detail, the types of personal information we collect and record at clepher.com, and how we use this information. We consider data protection and privacy to be of the utmost importance. We never sell personal data and we carry out all processing operations in strict compliance with the EU General Data Protection Regulation (“GDPR”).

If you are a Subscriber of a Chatbot which is created by Our Customer(s), and utilize running services, provided by Our Customer(s) (“Clepher Enabled Chatbot”), the ‘End Users’ section of this Privacy Policy applies to you.

For the purpose of this Privacy Policy, personal data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (the “Personal Data”).

What kind of Personal Data is processed and for what purpose?

Among the types of Personal Data that Clepher collects, by itself or through third parties, there are: Trackers; Usage Data; email address; first name; last name; date of birth; physical address; city; country; phone number; ZIP/Postal code; gender; state; company name; marital status; profession; Data communicated while using the service; payment info; order ID; data relating to the point of sale; user subscriptions; billing address; shipping address; browsing history; clicks; search history; page views; User ID; IP address; browser information; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); province; county; latitude (of city); longitude (of city); metro area; geography/region; device information; app information; device logs; operating systems; language; launches; number of sessions; session duration; scroll-to-page interactions; mouse movements; scroll position; keypress events; motion sensor events; touch events; video views; session statistics; interaction events; page events; custom events; Application opens; username; password; VAT Number; Tax ID; fax number; Social Security number (SSN); picture; prefix ; profile picture; workplace; website; budget; academic background; number of employees; Twitter handle; field of activity; house number; various types of Data; contact info; purchase history; geographic position; screenshots; number of Users; name; calendar information; answers to questions; social media accounts; user content; Email; state identification card; identification document; income information; job position; biometric data; time zone; interests; children; household income; education history; homeownership status; referral URL; Data communicated in order to use the Service; job title; work history; job skills; industry; company size; company revenue; contact details; in-app purchases; invoicing information; product interaction; customer support; contents of the email or message; account log-in; login history; primary account information; date of the message; time the message was sent; sender of the message; in-app messages ; diagnostic events; layout details; positional information.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Clepher. Unless specified otherwise, all Data requested by Clepher is mandatory and failure to provide this Data may make it impossible for Clepher to provide its services. In cases where Clepher specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies – or of other tracking tools — by Clepher or by the owners of third-party services used by Clepher serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through Clepher. Some data will be collected automatically by Our Site. Other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out below, for example, when signing up for an Account. Depending upon your use of Our Site and Our Service, We may collect some or all of the following data:

Personal Data
While using our service, we ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

Email address
First name and last name
Address, State, Province, ZIP/Postal code, City
Usage Data and Cookies

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Usage Data
When you visit our website we store the name of your internet service provider, the website from which you visited us from, the parts of our site you visit, the date and duration of your visit, and information from the device (device type, operating system, screen resolution, language, country you are located in, and web browser type) you used during your visit. We capture and store your IP address. We process this usage data to facilitate your access to our services (e.g. to adjust our services to the device you are using), and to recognize and stop any misuse. We also process usage data in an anonymized form for statistical purposes and to improve our site.

Cookies
Clepher uses cookies to process information including standard internet log information and details of the visitor’s behavioral patterns upon visiting our site. This is done to provide you with a better experience and to facilitate the use of certain functions. Cookies are small data files transferred onto computers or devices by sites for record-keeping purposes and to enhance functionality on our site. Clepher stores this information in a pseudonymized user profile. Clepher does not process this information to identify individual users or to match it with further data on an individual user. Cookies are stored on your individual device and you have full control over their use. You may deactivate or restrict the transmission of cookies by changing the settings of your web browser. Cookies that are already stored may be deleted at any time. Should you visit Clepher’s site with cookies deactivated, you may possibly not be able to use all of the functions on our site to the full extent. For more info about the cookies we make use of, see our Cookie Policy.

Contact with us via email
On our site you have the opportunity to contact us to ask us questions, for example via the contact form, we ask you for your contact information (e.g. name, email address etc.). We use this data solely in connection with answering the queries we receive. If you receive emails from us, we may use certain analytics tools, to capture data such as when you open our email or click on any links or banners our email contains. This data helps us to gauge the effectiveness of our communications and marketing campaigns.

Clepher Account
When you sign up for (and open) an account with Clepher, or sign up for content or offers, we may ask you to provide us with information such as your name, email address and details about your organization. As otherwise detailed in this Privacy Policy, we will solely process this information to provide you with the service you signed up for. Please refer to our Terms of Service for further details on registering and using the services offered by Clepher. You may deactivate your Clepher account and/or unsubscribe from receiving content or offers from us at any time. Following termination of your account, we may retain your personal data (in part or in whole) in order to meet any regulatory and reporting requirements for the timeframes stipulated by law and in order to be able to address customer service issues. Any other Personal Data we would have been processing on your behalf would be deleted permanently within 30 calendar days. We collect several different types of information for various purposes to provide and improve our service to you.

For what purpose is the data collected?

Clepher uses the collected data for various purposes:

To provide and maintain our service
To notify you about changes to our Service
To allow you to participate in interactive features of our service when you choose to do so
To provide customer support
To gather analysis or valuable information so that we can improve our service
To monitor the usage of our Service
To detect, prevent and address technical issues
To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

How do we protect your information?

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. We are committed to protecting your personal information against unauthorized use or disclosure.

Duration of Processing

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Data from the third-party services Clepher integrates with is retained until Our Customer(s) wishes to remove that data, or until their account is removed. Clepher will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Access and Disclosure to Third Parties

We use a select number of trusted external service providers for certain technical data analysis, processing and/or storage offerings. These service providers are carefully selected and meet high data protection and security standards. We only share information with them that is required for the services offered and we contractually bind them to keep any information we share with them as confidential and to process Personal Data only according to our instructions. We will only pass your data on to third parties without your express consent if we are obliged to do so by statutory law or an instruction by a public authority or court as outlined in our Terms of Service.

If Clepher is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy. Under certain circumstances, Clepher may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Clepher may disclose your Personal Data in the good faith belief that such action is necessary to:

To comply with a legal obligation
To protect and defend the rights or property of Clepher
To prevent or investigate possible wrongdoing in connection with the Service
To protect the personal safety of users of the Service or the public
To protect against legal liability

Third-party applications, websites and services

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. We are not responsible for the practices employed by any applications, websites or services linked to or from Our Service, including the information or content contained within them. Please remember that when You use a link to go from Our Service to another application, website or service, Our Privacy Policy does not apply to those third-party applications, websites or services. Your browsing and interaction on any third-party application, website or service, including those that have a link on Our Services, are subject to that third party’s own rules and policies.

However, We employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how Our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Facebook permissions asked by Clepher

Clepher may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows Clepher to connect with the User's account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

The permissions asked are the following:

Basic information

By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

Business Management API

Read and write with Business Management API.

Instagram basic

Allows reading an Instagram account profile information and media.

Instagram manage comments

Allows the creation, deletion and hiding of comments on behalf of the Instagram account linked to a Page. Also allows reading and responding to public media and comments that a business has been photo tagged in or @mentioned in.

Instagram manage insights

Provides access to insights for the Instagram account linked to a Facebook Page. Also gives the possibility to discover and read the profile information and media of other business profiles.

Page Messaging

Send and receive messages through a Facebook Page.

Pages manage engagement

Allows creating, editing and deleting comments posted on the page.

Pages manage posts

Allows the creation, editing and deletion of the User’s Page posts.

Show List of Managed Pages

Provides the access to show the list of the Pages that the User manages.

Whatsapp business management

Allows reading and/or managing WhatsApp business assets owned or granted access to by other businesses through this permission. These business assets include WhatsApp business accounts, phone numbers and message templates.

Access to third-party accounts

This type of service allows Clepher to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.

Facebook account access

This service allows Clepher to connect with the User's account on the Facebook social network, provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing.

Permissions asked: Business Management API; Instagram basic; Instagram manage comments; Instagram manage insights; Page Messaging; Pages manage engagement; Pages manage posts; Show List of Managed Pages; Whatsapp business management.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Google Drive account access

This service allows Clepher to connect with the User's account on Google Drive, provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

Personal Data processed: Data communicated while using the service; device information; email address; first name; last name; password; Trackers; Usage Data; username.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on Clepher, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside Clepher.
For more information, please check the privacy policies of the relevant services.
Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section in this document.

Meta ads conversion tracking (Meta pixel)

Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Meta Audience Network with actions performed on Clepher. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.

Meta Lookalike Audience

Meta Lookalike Audience is an advertising and behavioral targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that uses Data collected through Meta's Custom Audience in order to display ads to Users with similar behavior to Users who are already in a Custom Audience list on the basis of their past use of Clepher or engagement with relevant content across Meta's apps and services.
On the basis of these Data, personalized ads will be shown to Users suggested by Meta Lookalike Audience.

Users can opt out of Meta's use of Trackers for ads personalization by visiting this opt-out page.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.

Direct Email Marketing (DEM) (Clepher)

Clepher uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by Clepher.

Personal Data processed: email address; first name; last name.

Direct marketing via SMS (Clepher)

Clepher uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by Clepher.

Personal Data processed: first name; last name; phone number.

Google Ad Manager

Google Ad Manager is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
In order to understand Google's use of Data, consult Google's partner policy.
This service uses the “DoubleClick” Cookie, which tracks use of Clepher and User behavior concerning ads, products and services offered.

Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Google Ads Audience Expansion

Google Ads Audience Expansion is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows the Owner to expand the available target audience by finding Users who have interests, demographics or online behaviour similar to an existing audience selected by the Owner.
Users can opt out of Google's use of personalized advertising by visiting Google's Ads Settings.

Personal Data processed: children; clicks; date of birth; education history; gender; homeownership status; household income; interests; marital status; page views; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Google Ads conversion tracking

Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Google Ads advertising network with actions performed on Clepher.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Google Ads Customer Match

Google Ads Customer Match is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows matching Data that Users have shared with the Owner to existing Google accounts in order to target them or similar Users with personalized ads.
Users can opt out of Google's use of personalized advertising by visiting Google's Ads Settings.

Personal Data processed: country; email address; first name; last name; phone number; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); User ID; ZIP/Postal code.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Google Ads Optimized Targeting

Google Ads Optimized Targeting is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows the Owner to optimize the available target audience by finding new Users who have interests, demographics or online behavior similar to Users who have recently engaged with the Owner’s content and ads.
Users can opt out of Google's use of personalized advertising by visiting Google's Ads Settings.

Personal Data processed: children; clicks; date of birth; education history; email address; first name; gender; homeownership status; household income; interests; last name; marital status; page views; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Google Ads Similar audiences

Similar audiences is an advertising and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that uses Data from Google Ads Remarketing in order to display ads to Users with similar behavior to Users who are already on the remarketing list due to their past use of Clepher.
On the basis of this Data, personalized ads will be shown to Users suggested by Google Ads Similar audiences.

Users who don't want to be included in Similar audiences can opt out and disable the use of advertising Trackers by going to: Google Ad Settings.

In order to understand Google's use of Data, consult Google's partner policy.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Google Ads Smart Bidding (Google LLC)

Google Ads Smart Bidding is an advertising service provided by Google LLC that maximizes conversions by using various bidding strategies. These strategies may include optimizing bids based on Customer Match lists as well as the User’s device information and behavioral activity.
Users can opt out of Google's use of personalized advertising by visiting Google's Ads Settings.

Personal Data processed: device information; email address; first name; geographic position; language; last name; page views; referral URL; search history; Usage Data.

Place of processing: United States – Privacy Policy.

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Meta Events Manager

Meta Events Manager is an analytics service provided by Meta Platforms Ireland Limited or by Meta Platforms, Inc., depending on how the Owner manages the Data processing. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on Clepher.

Personal Data processed: billing address; browser information; browsing history; city; clicks; country; Data communicated while using the service; data relating to the point of sale; date of birth; email address; first name; gender; IP address; last name; order ID; page views; payment info; phone number; search history; shipping address; state; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; User ID; user subscriptions; ZIP/Postal code.

Place of processing: Ireland – Privacy Policy – Opt out; United States – Privacy Policy – Opt out.

Google Analytics (Universal Analytics)

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Google Analytics (Universal Analytics) with anonymized IP

Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of Clepher, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Cloudflare Web Analytics (Cloudflare, Inc.)

Cloudflare Web Analytics is an anonymized analytics service provided by Cloudflare, Inc. that gives the Owner insight into the use of Clepher by Users without needing to identify them. Further information may be found here and within the service's privacy policy.

Personal Data processed: device information; language; Usage Data.

Place of processing: United States – Privacy Policy.

Google Analytics 4

Google Analytics 4 is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of Clepher, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.

Personal Data processed: number of Users; session statistics; Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

ProfitWell Metrics (200 OK LLC)

ProfitWell Metrics is an analytics service provided by 200 OK LLC, that allows the Owner to analyze revenue and Users’ (commercial) activity on Clepher.

Personal Data processed: Data communicated while using the service; email address; first name; language; last name; payment info; phone number; physical address; Usage Data; User ID.

Place of processing: United States – Privacy Policy – Opt out.

Google Analytics Advertising Reporting Features

Google Analytics on Clepher has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).

Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Google Analytics Demographics and Interests reports

Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for Clepher (demographics means age and gender Data).

Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Google Analytics Granular location and device data collection

Google Analytics on Clepher has granular data collection activated which collects location and device data on a per-region basis. It allows the Owner to create and analyze User reports that rely on those metrics.

Personal Data processed: browser information; city; device information; number of Users; session statistics; Trackers; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Analytics collected directly (Clepher)

Clepher uses an internal analytics system that does not involve third parties.

Personal Data processed: Trackers; Usage Data.

Backup saving and management

This type of service allows the Owner to save and manage backups of Clepher on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to Clepher.

Backup on Google Drive

Google Drive is a service to save and manage backups provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Building and running Clepher

Key components of Clepher are built and run directly by the Owner by making use of the software listed below.

WordPress (self-hosted) (Clepher)

Clepher is built and run by the Owner via a CMS software (Content Management System) called WordPress.

Personal Data processed: billing address; city; company name; contact info; country; Data communicated while using the service; date of birth; device information; email address; first name; gender; geographic position; language; last name; password; payment info; phone number; physical address; profession; purchase history; screenshots; shipping address; Usage Data; username; VAT Number; workplace; ZIP/Postal code.

Collection of privacy-related preferences

This type of service allows Clepher to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.

iubenda Privacy Controls and Cookie Solution (iubenda srl)

The iubenda Privacy Controls and Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information, and in particular to the use of Cookies and other Trackers on Clepher.

Personal Data processed: IP address; Trackers.

Place of processing: Italy – Privacy Policy.

iubenda Consent Database (iubenda srl)

The iubenda Consent Database allows to store and retrieve records of Users’ consent to the processing of Personal Data, and information and preferences expressed in relation to the provided consent.
In order to do so, it makes use of a Tracker that temporarily stores pending information on the User’s device until it is processed by the API. The Tracker (a browser feature called localStorage) is at that point deleted.

Personal Data processed: Data communicated while using the service; IP address; Trackers.

Place of processing: Italy – Privacy Policy.

Communication

ElasticEmail

ElasticEmail is a service that helps to send out transactional email messages.

Contacting the User

Mailing list or newsletter (Clepher)

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Clepher. Your email address might also be added to this list as a result of signing up to Clepher or after making a purchase.

Personal Data processed: city; company name; country; county; date of birth; email address; first name; gender; last name; phone number; physical address; profession; state; Trackers; Usage Data; website.

Contact form (Clepher)

By filling in the contact form with their Data, the User authorizes Clepher to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data processed: city; company name; country; county; date of birth; email address; fax number; field of activity; first name; gender; last name; number of employees; phone number; physical address; profession; state; Tax ID; Trackers; Usage Data; User ID; various types of Data; VAT Number; website; ZIP/Postal code.

Phone contact (Clepher)

Users that provided their phone number might be contacted for commercial or promotional purposes related to Clepher, as well as for fulfilling support requests.

Personal Data processed: phone number.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of Clepher and interact with them. Such services are often referred to as widgets, which are small elements placed on a website or app. They provide specific information or perform a particular function and often allow for user interaction.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Maps widget

Google Maps is a maps visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows Clepher to incorporate content of this kind on its pages.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Vimeo video (Vimeo, LLC)

Vimeo is a video content visualization service provided by Vimeo, LLC that allows Clepher to incorporate content of this kind on its pages.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy.

Google Fonts

Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows Clepher to incorporate content of this kind on its pages.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Calendly widget (Calendly, LLC)

Calendly widget is a calendar content visualization service provided by Calendly, LLC that allows Clepher to incorporate content of this kind on its pages.

Personal Data processed: calendar information; device information; email address; geographic position; name; phone number; Trackers.

Place of processing: United States – Privacy Policy.

YouTube IFrame Player

YouTube IFrame Player is a video content visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows Clepher to incorporate content of this kind on its pages.

Through this Service, Clepher may collect Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document.

Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.

Personal Data processed: Data communicated in order to use the Service; Data communicated while using the service; device information; password; Trackers; Usage Data; User ID; username.

Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.

YouTube video widget

YouTube is a video content visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows Clepher to incorporate content of this kind on its pages.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Gravatar

Gravatar is an image visualization service provided by Automattic Inc. or by Aut O’Mattic A8C Ireland Ltd., depending on how the Owner manages the Data processing, that allows Clepher to incorporate content of this kind on its pages.
Please note that if Gravatar images are used for comment forms, the commenter's email address or parts of it may be sent to Gravatar - even if the commenter has not signed up for that service.

Personal Data processed: email address; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Font Awesome (Fonticons, Inc. )

Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows Clepher to incorporate content of this kind on its pages.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy.

Handling activities related to productivity

This type of service helps the Owner to manage tasks, collaboration and, in general, activities related to productivity. In using this type of service, Data of Users will be processed and may be retained, depending on the purpose of the activity in question.
These services may be integrated with a wide range of third-party services disclosed within this privacy policy to enable the Owner to import or export Data needed for the relative activity.

Calendly (Calendly, LLC)

Calendly is a service provided by Calendly, LLC, that facilitates online scheduling of appointments.

Personal Data processed: calendar information; device information; email address; geographic position; name; phone number; Trackers.

Place of processing: United States – Privacy Policy.

Confluence

Confluence is an online text-editing and collaboration service provided by Atlassian Pty Ltd or by Atlassian, Inc., depending on how the Owner manages the Data processing.

Personal Data processed: city; company name; country; Data communicated while using the service; date of birth; device information; email address; first name; gender; geographic position; last name; password; phone number; physical address; profession; profile picture; screenshots; Trackers; Usage Data; username; VAT Number; workplace.

Place of processing: Australia – Privacy Policy; United States – Privacy Policy.

Gmail

Gmail is a service that manages email communication provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. Such email communication is not scanned by Google for advertising purposes. In addition, Google does not collect or use data inside this service for advertising purposes in any other way.

Personal Data processed: city; company name; country; Data communicated while using the service; date of birth; email address; first name; gender; geographic position; last name; password; phone number; physical address; profession; profile picture; screenshots; Trackers; Usage Data; username; VAT Number; workplace.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Google Sheets

Google Sheets is an online spreadsheet and collaboration service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Google Docs

Google Docs is an online text-editing and collaboration service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

Personal Data processed: city; company name; Data communicated while using the service; date of birth; device information; email address; first name; gender; geographic position; last name; password; phone number; physical address; profession; profile picture; screenshots; Trackers; Usage Data; username; VAT Number; workplace.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Google Workspace

Google Workspace is an integrated suite of cloud-based productivity, collaboration and storage services provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. Gmail or other G Suite services are not scanned by Google for advertising purposes. In addition, Google does not collect or use data inside these services for advertising purposes in any other way.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Handling payments

Unless otherwise specified, Clepher processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. Clepher isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

PayKickstart

PayKickstart is a checkout system that handles payments and affiliate tracking.

PayPal (PayPal Inc.)

PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

Personal Data processed: billing address; biometric data; browser information; company name; data relating to the point of sale; device information; email address; first name; geographic position; identification document; income information; IP address; job position; last name; latitude (of city); longitude (of city); operating systems; order ID; password; payment info; phone number; profession; profile picture; purchase history; shipping address; state identification card; Tax ID; time zone; Trackers; Usage Data; username; various types of Data as specified in the privacy policy of the service.

Place of processing: See the PayPal privacy policy – Privacy Policy.

Stripe

Stripe is a payment service provided by Stripe, Inc. or by Stripe Payments Europe, Limited, depending on how the Owner manages the Data processing.

Personal Data processed: billing address; email address; first name; last name; payment info; purchase history; Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy; European Union – Privacy Policy.

Google Pay

Google Pay is a payment service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, which allows users to make online payments using their Google credentials.

Personal Data processed: billing address; email address; first name; last name; payment info; phone number; purchase history; shipping address; Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Heat mapping and session recording

Heat mapping services are used to display the areas of Clepher that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.

Smartlook (Smartsupp.com, s.r.o.)

Smartlook is a session recording and heat mapping service provided by Smartsupp.com, s.r.o.

Personal Data processed: Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: Czech Republic – Privacy Policy.

Microsoft Clarity (Microsoft Corporation)

Microsoft Clarity is a session recording and heat mapping service provided by Microsoft Corporation.
Microsoft processes or receives Personal Data via Microsoft Clarity, which in turn may be used for any purpose in accordance with the Microsoft Privacy Statement, including improving and providing Microsoft Advertising.

Personal Data processed: clicks; country; custom events; device information; diagnostic events; interaction events; layout details; mouse movements; page events; positional information; scroll-to-page interactions; session duration; time zone; Trackers; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Hosting and backend infrastructure

This type of service has the purpose of hosting Data and files that enable Clepher to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Clepher.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Amazon Web Services (AWS) (Amazon Web Services, Inc.)

Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Google Cloud

Google Cloud is a cloud computing platform provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Google Cloud Storage (Google LLC)

Google Cloud Storage is a hosting service provided by Google LLC.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

OpenAI API (OpenAI, L.L.C.)

The OpenAI API provided by OpenAI, L.L.C. is a service that helps the Owner to automate tasks through its AI engine.

Personal Data processed: city; company name; country; Data communicated while using the service; date of birth; device information; email address; first name; gender; geographic position; language; last name; password; phone number; picture; profession; screenshots; Trackers; Usage Data; username; VAT Number; workplace; ZIP/Postal code.

Place of processing: United States – Privacy Policy.

MongoDB Cloud (MongoDB, Inc.)

MongoDB Cloud is a hosting and backend service provided by MongoDB, Inc.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Infrastructure monitoring

This type of service allows Clepher to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of Clepher.

Web Performance (Web Performance, Inc.)

Web Performance is a monitoring service provided by Web Performance, Inc.Web Performance is a monitoring service provided by Web Performance, Inc.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy.

Uptime Robot (Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.)

Uptime Robot is a monitoring service provided by Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Turkey – Privacy Policy.

Interaction with data collection platforms and other third parties

This type of service allows Users to interact with data collection platforms or other services directly from the pages of Clepher for the purpose of saving and reusing data.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

Direct marketing via popups (Clepher)

Clepher uses popups to interact with the User to propose services and products which may be provided by third parties or that are unrelated to the product or services provided by Clepher.

Personal Data processed: Email; gender; name; Trackers; various types of Data.

Google Forms (embedded)

Google Forms (embedded) is a service for interacting with the Google data collection platform provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

Personal Data processed: answers to questions; company name; country; Data communicated while using the service; date of birth; email address; first name; gender; language; last name; password; phone number; physical address; picture; profession; profile picture; state; Trackers; Usage Data; username; VAT Number; ZIP/Postal code.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of Clepher.
The interaction and information obtained through Clepher are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on Clepher isn’t being connected back to the User’s profile.

Facebook Like button and social widgets

The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

PayPal button and widgets (PayPal Inc.)

The PayPal button and widgets are services allowing interaction with the PayPal platform provided by PayPal Inc.

Personal Data processed: Trackers; Usage Data.

Place of processing: See the PayPal privacy policy – Privacy Policy.

YouTube button and social widgets

The YouTube button and social widgets are services allowing interaction with the YouTube social network provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

LinkedIn button and social widgets (LinkedIn Corporation)

The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy.

X Post button and social widgets (X Corp.)

The X Post button and social widgets are services allowing interaction with the X social network provided by X Corp.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy.

Pinterest “Pin it” button and social widgets (Pinterest, Inc.)

The Pinterest “Pin it” button and social widgets are services allowing interaction with the Pinterest platform provided by Pinterest Inc.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy.

AddToAny (AddToAny LLC)

AddToAny is a service provided by AddToAny LLC, which displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of Clepher.
Depending on the configuration, this service can display widgets belonging to third parties such as the managers of social networks where interactions are shared. In this case, also the third parties that provide the widget will be informed of interactions and Usage Data on the pages where this service is installed.
Data collected through the service may be used to help deliver interest-based advertising. Users can opt out of third-party interest-based advertising by visiting the Network Advertising Initiative opt-out page.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Sendgrid (Sendgrid)

Sendgrid is an email address management and message sending service provided by Sendgrid Inc.

Personal Data processed: company name; country; date of birth; email address; first name; gender; last name; phone number; physical address; Trackers; Usage Data; username.

Place of processing: United States – Privacy Policy.

Brevo SMS (SendinBlue SAS)

Brevo SMS is a phone numbers management and communication service provided by SendinBlue SAS.

Personal Data processed: phone number; Trackers; Usage Data.

Place of processing: France – Privacy Policy.

Twilio (Twilio, Inc.)

Twilio is a phone numbers management and communication service provided by Twilio, Inc.

Personal Data processed: phone number.

Place of processing: United States – Privacy Policy.

Vonage (Vonage Holdings Corp.)

Vonage is a phone numbers management and communication service provided by Vonage Holdings Corp.

Personal Data processed: phone number.

Place of processing: United States – Privacy Policy; United Kingdom – Privacy Policy.

Managing data collection and online surveys

This type of service allows Clepher to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.

These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.

Meta lead ads

Meta lead ads is an advertising and data collection service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that allows form-based ads to be shown to Users pre-populated with Personal Data from their Facebook profiles, such as names and email addresses. Depending on the type of advertisement, Users may be requested to provide further information.

Form submission results in the collection and processing of these Data by the Owner under this privacy policy, and only for the specific purpose outlined on the form and/or inside this privacy policy, where provided.

Users may exercise their rights, at any time, including the right to withdraw their consent to the processing of their Data, as specified in the section containing information about User rights in this privacy policy.

Personal Data processed: city; company name; country; Data communicated while using the service; date of birth; email address; first name; gender; last name; marital status; phone number; physical address; profession; state; Trackers; Usage Data; ZIP/Postal code.

Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.

Data provided via online forms, managed directly (Clepher)

Clepher makes use of online forms that can be used to collect Data about Users.

Personal Data processed: answers to questions; billing address; city; company name; contact info; country; date of birth; email address; first name; gender; language; last name; marital status; name; payment info; phone number; physical address; profession; profile picture; social media accounts; Trackers; Usage Data; user content; workplace.

Google Forms

Google Forms is a form builder and data collection platform provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

Personal Data processed: answers to questions; city; company name; contact info; country; Data communicated while using the service; date of birth; email address; first name; gender; language; last name; password; phone number; physical address; profession; state; Trackers; Usage Data; username; VAT Number; workplace; ZIP/Postal code.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Typeform (TYPEFORM S.L)

Typeform is a form builder and data collection platform provided by TYPEFORM S.L.

Personal Data processed: company name; country; Data communicated while using the service; date of birth; email address; first name; gender; geographic position; last name; number of employees; password; phone number; physical address; profession; state; Tax ID; Trackers; Usage Data; username; various types of Data as specified in the privacy policy of the service; VAT Number; website.

Place of processing: Spain – Privacy Policy.

Managing support and contact requests

This type of service allows Clepher to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

WhatsApp Business customer support

WhatsApp Business customer support is a customer support service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing.

Personal Data processed: account log-in; answers to questions; app information; billing address; browser information; browsing history; city; contents of the email or message; country; county; custom events; customer support; Data communicated while using the service; data relating to the point of sale; date of the message; device information; device logs; first name; geography/region; in-app messages ; in-app purchases; interaction events; invoicing information; IP address; language; last name; latitude (of city); login history; longitude (of city); metro area; operating systems; order ID; password; payment info; phone number; primary account information; product interaction; profile picture; province; purchase history; sender of the message; shipping address; state; time the message was sent; time zone; Trackers; Usage Data; user content; username; ZIP/Postal code.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Managing web conferencing and online telephony

This type of service allows Clepher to manage the deployment, administration, hosting, recording, distribution and analysis of online telephony and web conferencing in order to communicate with Users.
The Personal Data collected depend on the information provided by the Users while using the respective service.

Zoom (Zoom Video Communications, Inc.)

Zoom is a web conferencing management service provided by Zoom Video Communications, Inc.

Personal Data processed: biometric data; contact details; Data communicated while using the service; first name; geography/region; last name; Trackers; Usage Data; user content; User ID.

Place of processing: United States – Privacy Policy – Opt out.

Marketing

UpViral

UpViral allows creation of marketing campaigns such as giveaways and contests

Registration and authentication

By registering or authenticating, Users allow Clepher to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, Clepher will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

Direct registration and profiling (Clepher)

By registering or authenticating directly through Clepher, Users allow Clepher to identify them and give them access to dedicated services. The Owner may process Data collected when Users register or authenticate also for targeting and profiling purposes; to find out more, Users can contact the Owner using the contact details provided in this document.

Personal Data processed: billing address; budget; company name; country; county; data relating to the point of sale; date of birth; email address; fax number; field of activity; first name; gender; geographic position; house number; language; last name; marital status; number of employees; password; phone number; physical address; picture; prefix ; profession; profile picture; shipping address; state; Tax ID; Trackers; Twitter handle; Usage Data; User ID; username; various types of Data; VAT Number; website; workplace; ZIP/Postal code.

Facebook Authentication

Facebook Authentication is a registration and authentication service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the Facebook social network.

Personal Data processed: Trackers; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Facebook Oauth

Facebook Oauth is a registration and authentication service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the Facebook social network.

Personal Data processed: Trackers; various types of Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Log In with PayPal (PayPal Inc.)

Log In with PayPal is a registration and authentication service provided by PayPal Inc. and is connected to the PayPal network.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: See the PayPal privacy policy – Privacy Policy.

Adherence to the Google API Services User Data Policy and Limited Use Requirements (Clepher)

Clepher‘s use or transfer to other apps of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Registration and authentication provided directly by Clepher

By registering or authenticating, Users allow Clepher to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.

Direct registration (Clepher)

The User registers by filling out the registration form and providing the Personal Data directly to Clepher.

Personal Data processed: academic background; billing address; budget; city; company name; country; county; date of birth; email address; fax number; field of activity; first name; gender; house number; language; last name; number of employees; password; phone number; physical address; picture; prefix ; profession; profile picture; Social Security number (SSN); state; Tax ID; Trackers; Twitter handle; Usage Data; User ID; username; various types of Data; VAT Number; website; workplace; ZIP/Postal code.

Remarketing and behavioral targeting

This type of service allows Clepher and its partners to inform, optimize and serve advertising based on past use of Clepher by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section in this document.

Meta Custom Audience

Meta Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of Clepher with the Meta Audience Network.

Users can opt out of Meta's use of Trackers for ads personalization by visiting this opt-out page.

Personal Data processed: email address; Trackers.

Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.

Facebook Remarketing

Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of Clepher with the Meta Audience Network.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Google Ad Manager Audience Extension

Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that tracks the visitors of Clepher and allows selected advertising partners to display targeted ads across the web to them.

In order to understand Google's use of Data, consult Google's partner policy.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Google Ads Remarketing

Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of Clepher with the Google Ads advertising network and the DoubleClick Cookie.

In order to understand Google's use of Data, consult Google's partner policy.

Users can opt out of Google's use of Trackers for ads personalization by visiting Google's Ads Settings.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Remarketing with Google Analytics

Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the tracking activity performed by Google Analytics and its Trackers with the Google Ads advertising network and the Doubleclick Cookie.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

X Custom Audiences (X Corp.)

X Custom Audiences is a remarketing and behavioral targeting service provided by X Corp. that connects the activity of Clepher with the X advertising network.

Users can opt out from interest-based ads by going to: Personalization and Data.

Personal Data processed: email address; Trackers.

Place of processing: United States – Privacy Policy.

X Ads remarketing (X Corp.)

X Ads remarketing is a remarketing and behavioral targeting service provided by X Corp. that connects the activity of Clepher with the X advertising network.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy.

TikTok Remarketing

TikTok Remarketing is a remarketing and behavioral targeting service provided by TikTok Inc. or by TikTok Technology Limited, depending on how the Owner manages the Data processing, that connects the activity of Clepher with the TikTok advertising network.

Personal Data processed: device information; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

LinkedIn lookalike audiences

LinkedIn lookalike audiences is an advertising and behavioral targeting service provided by LinkedIn Corporation or by LinkedIn Ireland Unlimited Company, depending on how the Owner manages the Data processing, that uses Data collected through LinkedIn's Matched Audiences in order to display ads to Users with similar behavior to Users who are already in a Matched Audiences list on the basis of their past use of Clepher or engagement with relevant content across LinkedIn's apps and services.
On the basis of these Data, personalized ads will be shown to Users suggested by LinkedIn lookalike audiences.

Personal Data processed: academic background; company name; company revenue; company size; country; date of birth; education history; email address; first name; gender; geographic position; geography/region; industry; interests; IP address; job position; job skills; job title; last name; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; work history.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

LinkedIn Matched Audiences

LinkedIn Matched Audiences is a remarketing and behavioral targeting service provided by LinkedIn Corporation or by LinkedIn Ireland Unlimited Company, depending on how the Owner manages the Data processing, that connects the activity of Clepher with the LinkedIn advertising network.

Users can opt out of LinkedIn's use of Trackers for ads personalization by adjusting their LinkedIn Ads settings.

Personal Data processed: academic background; company name; country; education history; geographic position; geography/region; industry; interests; IP address; job position; job skills; job title; Trackers; Usage Data; work history.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

LinkedIn Website Retargeting (LinkedIn Corporation)

LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of Clepher with the LinkedIn advertising network.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Social features

Inviting and suggesting friends (Clepher)

Clepher may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it.

Personal Data processed: various types of Data.

Spam and bots protection

This type of service analyzes the traffic of Clepher, potentially containing Users' Personal Data, with the purpose of filtering it from unwanted parts of traffic, messages and content that are recognized as spam or protecting it from malicious bots activities.

Cloudflare Bot Management (Cloudflare, Inc.)

Cloudflare Bot Management is a malicious bot protection and management service provided by Cloudflare, Inc.

Personal Data processed: app information; Application opens; browser information; browsing history; city; clicks; country; county; custom events; device information; device logs; geography/region; interaction events; IP address; keypress events; language; latitude (of city); launches; longitude (of city); metro area; motion sensor events; mouse movements; number of sessions; operating systems; page events; page views; province; scroll position; scroll-to-page interactions; search history; session duration; session statistics; state; touch events; Trackers; Usage Data; video views; ZIP/Postal code.

Place of processing: United States – Privacy Policy.

Google reCAPTCHA

Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Tag Management

This type of service helps the Owner to manage the tags or scripts needed on Clepher in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

Google Tag Manager

Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Traffic optimization and distribution

This type of service allows Clepher to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Clepher and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

Cloudflare (Cloudflare, Inc.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through Clepher, i.e., communication between Clepher and the User's browser, while also allowing analytical data from Clepher to be collected.

Personal Data processed: Trackers; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Bunny CDN (BunnyWay d.o.o.)

Bunny CDN is a traffic optimization and distribution service provided by BunnyWay d.o.o.

Personal Data processed: Usage Data.

Place of processing: Slovenia – Privacy Policy.

User database management

This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to Clepher, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving Clepher.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Clepher.

ActiveCampaign (ActiveCampaign, Inc.)

ActiveCampaign is a User database management service provided by ActiveCampaign, Inc.

Personal Data processed: email address; Trackers; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

We want to Communicate with You

We may occasionally send you notification emails about updates to our product, legal documents, offer customer support or marketing emails. Except for cases where we are required to do so by law (e.g. notifying you of a data breach), you shall have the opportunity to unsubscribe from receiving these messages free of charge.

Your Data, Your Rights

You have a right to be informed of Personal Data processed by Clepher, a right to rectification/correction, erasure and restriction of processing. You also have the right to receive from Clepher a structured, common and machine-readable format of Personal Data you provided to us. Moreover, You can access the My Data section (coming soon - please send your request to [email protected] for now) section to see, modify and/or delete your Personal Data. Note, we can only identify you with your email address and we can only adhere to your request and provide information if we have Personal Data about you through you having made contact with Us directly and/or you using our site and/or service. We cannot provide, rectify or delete any data that we store on behalf of our users or customers.

To exercise any of the rights mentioned in this Privacy Policy and/or in the event of questions or comments relating to the use of Personal Data you may contact Clepher’s support team: [email protected].

Where you have provided consent, you may withdraw it at any time, without affecting the lawfulness of the processing that was carried out prior to withdrawing it. Whenever you withdraw consent, you acknowledge and accept that this may have a negative influence on the quality of the Clepher Site and/or Services. You further agree that Clepher shall not be held liable with respect to any loss and/or damage to your Personal Data if you choose to withdraw consent.

Where Personal Data is processed for the above purposes on the basis of Clepher’s legitimate interests, under the GDPR, you may object to such processing at any time. To do so please contact: [email protected]. In addition, you have the right to lodge a complaint with the data protection authority in your jurisdiction.

Children’s privacy

Our Service does not address anyone under the age of 13 (“Children”). We do not knowingly collect personally identifiable information from children under 13. If You are a parent or guardian and You are aware that Your Children has provided Us with personal information, please contact Us. If We become aware that We have collected personal information from a child under age 13 without verification of parental consent, We take steps to remove that information from Our servers.

Changes to this privacy policy

We may modify or update Our Privacy Policy from time to time. We may revise this Privacy Policy from time to time. The most current version of this Privacy Policy will govern our practices for collecting, processing, and disclosing personal data. We will provide notice of any modifications by posting a written notice on our site. If you have an account with us, we will notify you of any material modifications by sending you an email to the email address associated with your account unless you have unsubscribed from all email communications. Your use of the site and/or Services following the effective date of any modifications to the Privacy Policy will constitute your acceptance of the Privacy Policy, as modified. All changes to this Privacy Policy automatically take effect on the sooner of the day you use the site and/or services, or 30 calendar days after they are initially posted on our site. Your use of the site and/or services following the effective date of any modifications to this Privacy Policy will constitute your acceptance of the Privacy Policy, as modified.

End Users

If you are an End User (Subscriber) of a Chatbot created with Clepher, this section applies to you.

This section should always be read in conjunction with the specific Privacy Policy of Our Customer(s), the creator(s) of a Clepher Enabled Chatbot which will contain further details regarding the processing of your Personal Data by Our Customer(s). Clepher is a service that allows its customers to build Chatbots for Messenger. To get a detailed understanding about what Clepher is We suggest navigating to Our public Knowledge Base.

Clepher has no direct relationship with the End Users whose Personal Data is processed by Our Service. An End User who seeks access, or who seeks to correct, amend, or delete Personal Data from Chatbots provided by Our Customer(s), the creator(s) of a Clepher Enabled Chatbot, should direct their request to Our Customer (which in this case is the Data Controller, the person or organisation who created the Chatbot you as End User subscribed/opted-in to). As Data Processor, We at Clepher, aim to provide Our Customer(s) (the Data Controller/s) with the best tools to make your Personal Data manageable.

Governing Law and Dispute Resolution

This Privacy Policy forms an integral part of Our Terms & Conditions. The Governing Law and Dispute Resolution mechanism found in Our Terms & Conditions shall also apply to Our Privacy Policy.

How to contact Us

If you have any questions, any concern, about this Privacy Policy of the Service, please send an email containing a detailed description of Your concerns. Clepher will do its best to resolve such issues within a reasonable time frame. Please Contact Us, or send mail to;

Contact Information:

Attention: Clepher
Marketing Released B.V.
Pauwenkamp, 3607GK
Maarssen, The Netherlands
[email protected]