Clueless in Life Privacy Policy

Last updated August 22, 2020

Welcome to Clueless in Life.

Thank you for choosing to be part of our community at Clueless in Life (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy.

When you visit our website https://www.cluelessinlife.com (the "Website"), and more generally, use any of our services (the "Services", which include the Website), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We comply with the requirements set by European privacy laws (General Data Protection Regulation). This means, amongst other things, that:

  • We clearly state which personal data we process and for what purposes. We do this through this privacy policy;

  • We restrict ourselves in the collection of personal data, processing only data that is required for legitimate purposes;

  • We always ask you for permission first to process your data whenever required;

  • We take the necessary security measures to ensure that your data is protected properly. We demand the same level of security from our partners;

  • We respect your right to inspect, correct or delete your personal data.
     

This privacy policy applies to all information collected through our Services (which, as described above, includes our Website), as well as any related services, sales, marketing or events.

Please read this privacy policy carefully as it will help you understand what we do with the information that we collect. If you still have questions or concerns after reading our privacy policy, please do not hesitate to contact us at info@cluelessinlife.com

1. WHAT INFORMATION DO WE COLLECT?


1.1 PERSONAL INFORMATION YOU DISCLOSE TO US

 

In Short: We collect information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website (such as by posting messages in our online forums or entering competitions, contests or giveaways) or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use.

 

Personal information we collect provided by you:

  • First and last name

  • E-mail address

  • Other similar information


1.2 INFORMATION AUTOMATICALLY COLLECTED

 

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Website.

We automatically collect certain information when you visit, use or navigate our website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about who and when you use our website and other technical information. This information is primarily needed to maintain the security and operation of our website, and for our internal analytics and reporting purposes.

 

Like many businesses, we also collect information through cookies and similar technologies. (You can read more about our use of cookies or similar technology here.)

 

The information we collect includes:

  • Log and Usage Data:
    This is service-related, diagnostic usage and performance information that our servers automatically collect. This may include your IP address (anonymized), device information, browser type and settings as well as information about the way you use our website (date/time, pages and files viewed, actions taken on the website, error reports, etc.)
     

  • Device Data:
    This includes information about your computer, phone, tablet or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system configuration information.
     

  • Location Data:
    We collect information data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type of settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Locations settings on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.

 

2. HOW DO WE USE YOUR INFORMATION?

In Short:  We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

  • To post testimonials: We post testimonials on our Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the consent of the testimonial. If you wish to update, or delete your testimonial, please contact us at info@cluelessinlife.com and be sure to include your name, testimonial location, and contact information.

  • Request feedback: We may use your information to request feedback and to contact you about your use of our Website.
     

  • To enable user-to-user communications: We may use your information in order to enable user-to-user communications with each user's consent.
     

  • To send administrative information to you: We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
     

  • To protect our Services: We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
     

  • To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
     

  • To respond to legal requests and prevent harm: If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
     

  • To send you marketing and promotional communications: We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Website, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see "WHAT ARE YOUR PRIVACY RIGHTS" below).

 

  • Deliver targeted advertising to you: We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

 

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short:  We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfil business obligations. We do not sell your data to third parties.

Clueless in Life does not sell your data to third parties. However, sometimes we must work with third parties to provide you with our services, carry out our agreements or to comply with legal obligations. In this case, we guarantee to have a General Data Protection agreement in place with our partners or third parties who process your data at our request. This is to ensure the same level of security and confidentiality.

 

We may process or share your data that we hold based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
     

  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
     

  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
     

  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
     

  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

  • Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
     

  • Other Users: When you share personal information (for example, by posting comments, contributions or other content to the Website) or otherwise interact with public areas of the Website, such personal information may be viewed by all users and may be publicly made available outside the Website in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Website, and view your profile.

 

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short:  We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

 

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short:  We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our Website.

The Website may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Website. You should review the policies of such third parties and contact them directly to respond to your questions.

 

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short:  We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 2 years.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short:  We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.

 

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You have the right to view, correct or delete your personal data.

 

8.1 VIEWING AND CORRECTING YOUR DATA

You can send a request for access, correction or data transfer of your personal data to info@cluelessinlife.com. You have the right withdraw your consent to data processing or to object to the processing of your personal data by Clueless in Life and you have the right to data portability. This means you can submit a request for us to send you all the data we have of you. We will send this to you in a computer file.

 

To ensure that the request for access, correction or data transfer is submitted by you, we ask you to send a copy your ID alongside the request. Cover your passport photo, MRZ (machine readable zone, the strip with the numbers at the bottom of the passport), passport number and citizen’s number. (You can do this with the use of an app, for example.) This is to protect your privacy.

When you send a request to us, we will forward and/or adjust your personal data and/or permission without undue delay.

8.2 THE RIGHT TO WITHDRAW CONSENT

 

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

8.3 THE RIGHT TO BE FORGOTTEN

 

We don’t like forgetting you, but the European General Data Protection Regulation (GDPR) grants you the ‘right to be forgotten’. This means that you have the right to ask us to delete all your data (provided that Clueless in Life has no legal obligation to store your data).

If you want to have your all data erased from our systems, please contact us via info@cluelessinlife.com.

To ensure that the request for deletion is submitted by you, we ask you to send a copy your ID alongside the request. Cover your passport photo, MRZ (machine readable zone, the strip with the numbers at the bottom of the passport), passport number and citizen’s number. (You can do this with the use of an app, for example.) This is to protect your privacy.

As soon as we have received this information, we will erase your data without undue delay from all our systems.

8.4 SUPERVISORY AUTHORITY OF PERSONAL DATA

 

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

 

If you are resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

 

If you are resident in the USA, at this time, there is no single principle data protection legislation nor body that governs it. If you believe we are unlawfully processing your personal information, you may notify your local authorities or if applicable the Federal Trade Commission (FTC).

 

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

 

10. PRIVACY OF CHILDREN

 

Clueless in Life does not consciously collect nor does it intend to collect data from website visitors younger than 13 years, unless we have permission from a parent or guardian. If we discover that we have unintentionally collected personal data of a child under the age of 13 without the consent of a parent or guardian, we will delete this information as soon as possible. If you believe that we have data of a minor without parental consent, please contact us at info@cluelessinlife.com. To prevent the collection of children’s data without parental consent we encourage parents to be involved in the online activities of their children.

 

11. DO WE MAKE UPDATES TO THIS POLICY?

In Short:  Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

 

12. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, please email us at info@cluelessinlife.com.

 
 

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