CLEVER ADS SOLUTIONS PRIVACY POLICY

Version control: 1.2, last modified: December 14, 2020

Clear Invest LTD, together with its subsidiaries, affiliates, employees, officers, and directors, as applicable (collectively the “Company,” we, us, or our) is a company that provides software development kit (hereinafter the “SDK”) solution for marketing purposes, which together with the features and services provided therein shall be defined as the “Services”.

The Company respects the privacy of its users (both parents and children, and collectively user or you, your, yours). We believe it is important for you to make informed decisions regarding the use of our Services based on your understanding of what information we collect through the use of our Apps, what we do with such information, how we process it, with whom we share it, as well as your rights and choices regarding your information processed by us. For this purpose, we have drafted this Clever Ads Solutions Privacy Policy (hereinafter the “Privacy Policy”), which will further describe and detail our privacy practices while you use or otherwise interact with our Apps; but before that, we would like to explain the basis on which we process data:

For more details regarding the terms and conditions for use of the Apps, please read our Clever Ads Solutions Terms of Use (hereinafter the “Terms”), a current copy of which is available at https://cleveradssolutions.com/terms-of-use. Note that this Privacy Policy is an integral part of the Terms and all terms shall be used in the same meanings as defined in the Terms, unless otherwise specified herein.

Our Privacy Policy and our privacy practices adhere to the United States Children’s Online Privacy Protection Act (hereinafter the “COPPA”), to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter the “GDPR”),  as well as other applicable laws.

  1. SUBJECT
  1. This Privacy Policy applies to our Services, including but not limited to:
  1. our Site available at: https://cleveradssolutions.com, which is intended as a general audience website that enables visitors to learn more about our Services, and further applicable content and tools that you or other business partners (hereinafter “Partners”) can use;
  2. our SDK as described in the Clever Ads Solutions Terms of Use implemented by you for the purpose of delivering children’s content-safe advertisements to users who download, use, or otherwise interact with your Apps.
  1. Please note that, this Privacy Policy applies solely to our privacy practices related to our Services, and it does not apply to the practices of companies that the Company does not own or control or to people it does not employ or manage, as well as to our your or other Partners’ privacy practices. Thus, we encourage you to review each App’s privacy policy in order to be aware of our Partners’ data collection and use practices while using their Apps.
  1. ACCOUNT
  1. In order to use certain features of the Services, you may be prompted to create a designated account (hereinafter the “Account”). By creating an Account, you provide your consent to the collection, use and disclosure of the Personal Information as described in this Privacy Policy, and as needed. If at any time you do not want to be bound by this Privacy Policy, you shall deactivate your Account by emailing your request to: [email protected] or removing the SDK from your application.
  2. You represent and warrant that you are solely responsible for maintaining the confidentiality of your Account details and password, and for any and all activity made under the Account. You represent and warrant that you will not provide inaccurate, misleading or false information to the Company.
  1. TYPES OF INFORMATION WE COLLECT
  1. We may collect different categories of information from you, either Non-Personal Information or Personal Information as defined below, depending on the nature of your interaction with the Services, all as detailed below.
  2. The first type of information is non-identifiable information that may be made available or gathered through your use of the Services; to clarify, we are not aware of your identity based on such information and it cannot be deduced from different types of such information (hereinafter “Non-Personal Information”). The Non-Personal Information that is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information such as: device brand, screen size, UDID, type of operating system, type of device, language preference, the time and date you access our Services, your actions within our Services (e.g., registration, pages viewed, etc.), the URLs from which you were directed to our Services, search queries within our Services, etc., and approximate geo-location limited to determining your country.
  3. The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Personal Information includes information voluntarily provided by you as well as certain identifiers, such as Internet Protocol (hereinafter “IP”) addresses, or mobile advertising identifiers, including but not limited to Google Advertising ID and Apple IDFA (hereinafter the “Identifiers”). Note that the Identifiers are considered “Personal Information” in many jurisdictions (such as under GDPR, as well as under COPPA), thus, the Company treats Identifiers as such and complies with applicable laws. With regards to our use of Identifiers and your ability to opt-out of such data collection, please see the table below (under Identifiers), as well the “mobile opt out” provision below.
  4. You are not required by law to provide us with certain Personal Information. You can always refuse to provide certain Personal Information; however, you acknowledge that such refusal may prevent you from engaging in certain activities on the Site or Services.
  5. In the event we combine Personal Information with Non-Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
  6. The table below details the information we collect from the users of the Site, why we collect it and how we use it:

Type of Information

How Do We Use It

In the event you contact us for support or other inquiries, either through the online form available in the Site, by sending us an email or by other means of communications we make available, you will provide us with your email address and may provide us with your name.

We will use this information solely for the purpose of responding to your inquiries and providing you with the support you have requested.

In the event you wish to report us regarding abusive content or copyrights infringement you will be required to provide us with your name and email address and may be asked to provide your mailing address.

We will use this information solely for the purpose of communicating with you regarding your report.

In the event you are interested in joining our team, and wish to submit your CV to published job offers, you will be required to provide us with your name, email address, and CV. You may also be asked to provide us with your phone number, location (City) and LinkedIn profile.

Your provision of personal information in connection with recruiting is voluntary, and you determine the extent of information you provide us. We do not request or require sensitive personal information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. We will use the information you have provided solely to communicate with you, to manage our recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements. If you are hired, the information may be used in connection with employment and corporate management.

Identifiers

We may collect Identifiers from visitors of our Site. We will use it in order to fulfil our legitimate interests of operating, managing our Site, customizing and improving our Site and the content available therein.

We also collect certain technical Non-Personal Information (as detailed below) which relates to your use of the Site, the amount of time you spent viewing certain portions of the Site, etc.

We use this technical Non-Personal Information for the purpose of: (i) our legitimate interests of operating, providing, maintaining, protecting, managing, customizing and improving our Site and Services and the way in which we offer them; (ii) enhancing your experience with the Services; (iii) our legitimate interests of auditing and tracking usage statistics and traffic flow, and detecting fraud, security or technical issues in connection with the Services; (iv) perform research, for analytical and statistical purposes, to improve our Services.

  1. The table below details the information we collect from the users of the SDK, why we collect it and how we use it:

Type of Information

How Do We Use It?

In order to use our SDK and related services, you will be required to create the Account. During the registration flow you may provide us with certain information such as: full name, email address, company name and applicable URLs. Further, during the registration process the Partner will be required to create a password, at which time you thereby represent and warrant that you are responsible for maintaining the confidentiality of your details and password. You represent and warrant that you will not provide inaccurate, misleading or false information to the Company.

You may also choose to sign in with your Facebook or Google account.  The information we will receive depends on your privacy settings with the network and you should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Services.

We will use this information for the purpose of performing our contract with you, provide you with the Services you have requested, and designate your account in order to display the applicable information on your account dashboard. We will use the email address in order to send you needed information related to the Services and our business engagement (e.g., send you a Welcome message, to notify you regarding any updates to our Products, changes in our requirements or privacy practices, and additional occasional communications related to the Services) as well as verify your identity.

If you voluntarily subscribe to our newsletter you will be asked to provide us with your email address. You can unsubscribe at any time using the unsubscribe option within the body of the newsletter or by contacting customer support at [email protected].

We will use your email address in order to send you information related to our Services and to keep you up to date regarding new Products, related news, updates, etc. 

We also collect certain technical Non-Personal Information (as detailed below) that relates to your use of the Site including your Publisher Account, the amount of time you spent viewing certain portions of the Site, etc.

 

We use this technical Non-Personal Information for the purpose of: (i) our legitimate interests of operating, providing, maintaining, protecting, managing and customizing our Site and Services and the way in which we offer them; (ii) enhancing your experience with the Services; (iii)  our legitimate interests of auditing and tracking usage statistics and traffic flow, and detecting fraud, security or technical issues in connection with the Services; (iv) perform research, and gather demographic information for analytical and statistical purposes, to improve our Services.

  1. Our SDK, which is integrated into a Apps, is a piece of software that allows you and other Partners to provide end users (hereinafter the “End Users”) with customized advertisements designated to children, both in terms of children’s safe content, as well as in terms of data collection. Meaning, we will not collect through our SDK any Personal Data without parental consent, except as permitted under applicable law and detailed below. In addition, we do NOT use any Personal Information collected for profiling and we do NOT use behavioral advertising or cross device tracking. We serve solely contextual ads (e.g. if the User is interacting with a painting app, we will present advertisements related to painting). In case we need to collect any other Personal Information, which is not listed here, you shall ensure parental consent is obtained before doing so, in the event required by applicable law. If you are the End User, we may collect the following information:

Type of Information

How Do We Use It?

Approximate GEO location data

We will use this information solely in order to determine the User’s country and to target the applicable advertising campaign. Meaning, if the User is located in a country where the official language is Spanish, the advertisement represented shall be in that language.

Identifiers

 

  • We will use the Identifiers we collect for two purposes: (i) targeting the applicable advertising campaign (for example, to enable ad frequency capping); and (ii) maintaining or internally analyzing the functioning of our Services.
  • In any event, we use the Identifier solely for internal support purposes and/or in compliance with COPPA regulations

We also collect certain technical Non-Personal Information (as detailed below) which relates to the Users use of the App.

 

We use this technical Non-Personal Information for the purpose of: (i) our legitimate interests of operating, providing, maintaining, protecting, managing, customizing and improving our Services and the way in which we offer them; (ii) enhancing your experience with the Services; (iii)  our legitimate interests of auditing and tracking usage statistics and traffic flow, and detecting fraud, security or technical issues in connection with the Services; (iv) perform research, for analytical and statistical purposes, to improve our Services.

  1. Should we need to collect additional Personal Information other than the Personal Information detailed above, we will send a parent an applicable request and obtain consent prior to collection, if required under applicable law.
  2. We may use data in an aggregated, non-specific format for analytical purposes. Information is anonymous and aggregated and we will not link statistical information to any Personal Information. We may share such statistical information with our partners, without restriction. We also compile demographic data and usage-related information for a variety of uses in an aggregated or anonymized manner intended to remove or obscure any personal information which can identify any individual user.
  1. CHILDREN’S INFORMATION
  1. We will not knowingly collect and store personal information/personal data as defined in COPPA and/or GDPR (collectively “Personal Information”) directly from:
  1. US resident children under 13 (thirteen) years of age without parental consent, except as permitted under COPPA;
  2. EU resident children under 16 (sixteen) years of age without parental consent, except as permitted under EU applicable law.
  1. If we believe that we have collected and stored Personal Information from a child without the necessary parental consent or other legal basis to do so, we will delete the Personal Information provided as soon as feasibly possible and notify the parent or legal guardian. If you are aware that your child has provided us with Personal Information not in accordance with the terms of this Privacy Policy, please contact us at: [email protected].
  2. To learn more about COPPA, we recommend that you review this one-page informational guide from the kidSAFE Seal Program http://www.kidsafeseal.com/knowaboutcoppa.html.
  3. BY USING THE SERVICES INCLUDING PARTNERS’ APPS, YOU HEREBY AGREE TO THE TERMS OF THIS PRIVACY POLICY AND TO THE COLLECTION AND USE OF CERTAIN INFORMATION, AS DESCRIBED IN THIS POLICY. ANY USE OR CONTINUED USE OF THE SERVICES CONSTITUTES YOUR AGREEMENT AND CONSENT TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THESE TERMS, PLEASE DO NOT USE THE SERVICES.
  4. PLEASE BE AWARE THAT ALL NECESSARY CONSENTS FOR THE USE OF OUR SERVICES FROM PARENTS OR LEGAL GUARDIANS OF CHILDREN SHALL BE OBTAINED BY YOU. ALL NOTIFICATIONS AND OTHER CORRESPONDENCE WITH PARENTS AND LEGAL GUARDIANS SHALL BE PERFORMED BY YOU. YOU WARRANT AND REPRESENT THAT YOU USE OUR SERVICES COMPLIANT TO REGULATORY REQUIREMENTS. WE TREAT ALL INFORMATION PROVIDED BY YOU AND YOUR ACTIONS IN THE COURSE OF CONSUMPTION OF OUR SERVICES AS FULFILLING REQUIREMENTS OF THE AFOREMENTIONED LEGISLATION. WE EXCPRESSLY DISCLAIM ALL LIABIITY FOR YOUR FAILURE TO MEET THE REGULATORY REQUIREMENTS.
  1. HOW WE COLLECT INFORMATION
  1. Depending on the nature of your interaction with the Services, we may collect information as follows:
  1. Automatically, when the information transmitted from the device is collected automatically;
  2. Provided by you voluntarily, meaning, if and when you manually choose to provide us with information such as through a registration process, newsletter registration, contact us communications, etc.
  1. COOKIES AND SDK
  1. You may integrate our SDK into the Apps to serve third-party child-appropriate advertisements. As detailed above, we do NOT use any Personal Information collected for profiling and/or behavioral advertisement. For more information, please see https://cleveradssolutions.com/privacy-policy, which details the types of information collected by our SDK or when you use our Site.
  2. In addition, our Site through which you are able to access your Account may include cookies that might include your IP address, such as:
  1. Google Analytics: The Google Analytics cookie is placed to track and analyze the use of our Services, for internal analytic purposes. To learn more about how Google uses data from our use of Google Analytics Cookies, we recommend that you review Google’s policies located at: https://policies.google.com/technologies/partner-sites. We also encourage you to review Google Analytics currently available opt-outs for the web tool available at: https://tools.google.com/dlpage/gaoptout/ and, https://adssettings.google.com/authenticated.
  2. Hubspot: The Hubspot privacy policy can be found at: https://legal.hubspot.com/privacy-policy. We use Hubspot technology to provide and perform our direct marketing services.
  3. Mailchimp: The Mailchimp privacy policy can be found at: https://mailchimp.com/legal/privacy/. We use Mailchimp technology to provide and perform our direct marketing services.
  1. DISCLOSURE OF INFORMATION
  1. We do not disclose, share, sell, rent or otherwise distribute any of your or child’s Personal Information with or to any independent third parties unless as specified herein:
  1. Authorized Disclosures

We may disclose Personal Information to third parties when you consent to a particular disclosure. Please note that once we share your information with another third party, that information becomes subject to the other third party’s privacy practices.

  1. Business Transfers

We may transfer our databases containing Personal Information if we sell our business or any part of it. In that event, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy.

  1. Law Enforcement related disclosure

We may be required to share information, including Personal Information, collected if the information is required by law to prevent, investigate, or take action regarding illegal activities, situations involving potential threats to physical safety, rights, property or of any person, suspected fraud and violations of our terms and agreements and in response to legal process, court orders, subpoenas, or to establish or exercise our legal rights or defend against legal claims.

  1. Partners, Service Providers, Affiliates, and Subcontractors

We may disclose information, including Personal Information, we collect from and/or about you to our trusted affiliates, personnel, licensors, contractors, service providers, subcontractors and business partners who may use such information to help us provide you with the Services; for example, we may share the email addresses of users who have registered to our newsletter, in order to provide them with direct marketing services. We authorize these third-party service providers to use Personal Information only for the purpose of providing the specific services requested by us.

  1. Identifiers

We may share Identifiers for the purpose of operating our business and providing the Services, meaning to serve the advertisements through our SDK, as well as to calculate payments, detect fraud, security or technical issues in connection with the Services.

  1. DATA RETENTION
  1. We retain this collected information as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until individuals express a preference to opt-out or delete their Personal Information.
  2. We may, at our sole discretion, delete or amend information from our systems, without notice, once we deem it is no longer needed for such purposes.
  1. HOW WE PROTECT INFORMATION
  1. The Company is committed to protecting your and children’s Personal Information. Thus, the Company has implemented technical, physical and administrative security measures to protect the Personal Information submitted to and collected by us, both during transmission and once we receive it.
  2. In addition, the Company limits access to the information on its servers, and it is password-protected as well as encrypted. For additional information regarding the Company’s security measures, please see: https://cleveradssolutions.com/security-policy. You should be aware, however, that there is no data that is transmitted over the Internet that can be guaranteed fully secure in transmission or safe from theft or illegal capture.
  1. YOUR RIGHTS, CHOICES, AND CONTROL OF PERSONAL INFORMATION:
  1. Your Rights
  1. Our users have a right to know what information we hold about them and their child and, in some cases, to have such information communicated to them. Our users may also ask for our confirmation as to whether or not we process their or their child’s Personal Information. Subject to the limitations in applicable law, users may also be entitled to obtain from us the Personal Information they have provided to us in a structured, commonly-used, and machine-readable format, and may have the right to transmit such Personal Information to another party. The principal rights under applicable data protection laws in relation to Personal Information are as follows:
  1. the right to access any information which is provided by the user;
  2. the right to rectification;
  3. the right to erasure;
  4. the right to restrict processing;
  5. the right to object to processing;
  6. the right to data portability;
  7. the right to complain to a supervisory authority; and
  8. the right to withdraw consent, to the extent applicable.
  1. With purpose of complying with legislator requirements and handling your requests, we designate a dedicated data protection officer (hereinafter the “Data Protection Officer”) [email protected].
  2. We provide our users with the ability to exercise certain choices and controls in connection with our treatment of their Personal Information, depending on their relationship with us. If you wish to exercise any or all of the above rights, please contact our Data Protection Officer at: [email protected], and let us know that you wish to exercise your right of access and specify what Personal Information you would like to receive or delete, including if you wish to delete the Account. Where we are not able to provide you with the information you have requested, we will endeavor to explain the reasoning for this. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to 30 (thirty) calendar days in accordance with applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.
  3. Unsubscribe from Direct Marketing
  1. You may revoke permission to receive promotional messages at any time by contacting customer support at [email protected] or by following the unsubscribe link located at the bottom of each communication. Please note that even if you unsubscribe, we reserve the right to send you service-related communications, announcements and administrative messages.
  1. Opt-out
  1. You may easily opt out of certain automatic data collection, sharing process and targeted advertising services related to our Service. Please note that even if you opt-out, you will still receive content and advertising. Opting-out simply means that the advertisements you do receive may not be contextual.
  2. Mobile Opt-out:
  1. You may limit the disclosure of certain information collected from your mobile device by adjusting the settings on your mobile device. You should review your device settings and instructions. Notwithstanding, we provide the following instructions solely for informational purposes as they might be revised by the device supplier: For iOS mobile devices, go to “Settings” from your device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking.” For Android mobile devices, go to “Google Settings” on your device; select “Ads”; and check the box labeled “Opt Out of Interest-Based Ads.” Please read your device-specific information to learn how to opt-out:
  2. Android https://support.google.com/ads/answer/2662922 
  3. iOS https://support.apple.com/en-il/HT205223 
  1. Industry Standards
  1. You may opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s (“NAI”) website and the Digital Advertising Alliance’s (“DAA”) website.
  1. Note that once you opt out, part of the Services provided by us might no longer be available and some features may not work if you revoke the data transfer.
  1. If you have any additional complaints about your privacy rights, please contact our Data Protection Officer. Please note that you have the right at any time to contact your local data protection authority.
  1. THIRD-PARTY SITES AND SERVICES
  1. This Privacy Policy applies solely to the information collected by the Company through the Services and does not apply to any other websites, applications or services.
  2. Portions of the Services (including, without limitation, advertisements) may involve linking to or using third-party services (hereinafter the “Third-Party Services”) such as various icons, shortcuts, applications or other means of access. Though we make best efforts to review such Services and ensure their suitability for children, we have no control over Third-Party Services and all use of such services is at your own risk.
  3. We cannot accept responsibility for the privacy practices of any such Third-Party Services and we are not responsible for content made available by them.
  4. The Company does not endorse any Third-Party Services and we urge you to exercise caution in using them and to carefully review their privacy practices.
  5. Our software products include features from our partners, such as social media interaction tools and in-game advertising. A list of these Third-Party Services is available below. These partners may access your Personal Information and operate under their own privacy policies. We are not responsible for the privacy policies or the content of sites we link to and we have no control over the use or protection of information provided by you to, or collected by, those websites. Whenever you click the link to a co-branded website or to a linked website, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third party and you should familiarize yourself with the privacy policy published by such third party. We encourage you to check their privacy policies to learn more about their data processing practices:

11.5.1 Google AdMob https://policies.google.com/technologies/ads 

11.5.2. Unity and Unity Analytics https://unity3d.com/ru/legal/gdpr  and https://unity3d.com/ru/legal/privacy-policy 

11.5.3. Unity Ads https://unity3d.com/legal/privacy-policy

11.5.4. Clever Ads Solutions (ClearInvestHouseAds) https://cleveradssolutions.com/privacy-policy 

11.5.5. Firebase Analytics https://firebase.google.com/support/privacy  and https://policies.google.com/privacy 

11.5.6. AppLovin https://www.applovin.com/privacy/ 

11.5.7. ChartBoost https://answers.chartboost.com/en-us/articles/200780269 

11.5.8. Vungle https://vungle.com/privacy/ 

11.5.9. StartApp https://www.startapp.com/policy/privacy-policy/ 

11.5.10. Kidoz https://kidoz.net/privacy-policy/ 

11.5.11. AppBrain https://www.appbrain.com/info/help/privacy/index.html 

11.5.12. SuperAwesome https://www.superawesome.com/privacy-hub/privacy-policy/ 

11.5.13. InMobi Ads https://www.inmobi.com/privacy-policy/ 

11.5.14. My.com https://legal.my.com/us/mytarget/privacy/ 

11.5.15. Mobfox https://www.mobfox.com/privacy-policy/ 

11.5.16. Facebook Ads https://developers.facebook.com/docs/audience-network/policy/ 

11.5.17. AdColony https://www.adcolony.com/privacy-policy/ 

11.5.18. ironSource https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/ 

11.5.19. Verizon Media https://www.verizonmedia.com/policies/us/en/verizonmedia/privacy/ 

11.5.20. Amazon Advertising https://advertising.amazon.com/legal/privacy-notice 

11.5.21. Yandex Ads https://yandex.com/legal/mobileads_sdk_agreement/ 

       

  1. CHANGES TO THIS PRIVACY POLICY
  1. This Privacy Policy may change from time to time and we will post the amended terms and notify you by email in the event of substantial changes.
  2. Amended terms will take effect immediately for new users, and 10 (ten) days after they are posted for existing users.
  3. You should review the Privacy Policy periodically to remain informed of any changes
  4. You agree to accept posting of a revised Privacy Policy as an actual notice to you.
  5. Your continued use of the Services following any changes to this Privacy Policy have been posted as of the “last modified” date above, or, if applicable, after you have been notified, signifies your acceptance of those changes.
  6. If you do not agree to the revised Privacy Policy, please refrain from using our Services and contact us by sending an email to: [email protected].
  1. COMMENTS AND QUESTIONS
  1. If you have any comments or questions about our Privacy Policy, please contact us at:

Clear Invest LTD

New Horizon Building

Ground Floor 3

1/2 Miles Philip S.W. Goldson Highway

Belize City

Belize

You can also contact us via email at: [email protected] 

  1. DATA PROTECTION OFFICER
  1. If you have any requests regarding the data collected under this Privacy Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at: [email protected] indicating “Data Protection Officer” in a subject line.
  2. Please be sure to include your information in any correspondence to us so that we can respond to your inquiry in a timely manner.