1. Introduction

Cliqued LLC (“Cliqued LLC”, “Cliqued LLC, “we”, “us” and “our”), operates a software-based connections and relationship building platform (the “Cliqued LLC Platform”), which provides users with reports, dashboards, cardstacks, monetization opportunities, and unique data insights that support the facilitation of business relationships, and social connections.

This privacy policy (“Privacy Policy”) has been implemented on behalf of Cliqued LLC. It is designed to help you understand the personal data we collect from you, why we collect it, what we do with it and how you can update, manage, and delete your personal data in the event your personal data is shared within the Cliqued LLC platform.

2. The Types of User Data that We Collect

We collect various types of user data in order to optimize our subscriber experience and improve our intelligence platform.

The different types of user data collected include:

Personal Data

Personal data or personal identifiable information (PII) refers to any information that can be used to directly or indirectly identify a person or specific individual. It could be as simple as a subscriber username and passwords, email addresses, or business contact or could include other identifiers such as an IP address, a cookie identifier, or other factors. Personal data includes but is not limited to:

• First Name and Last Name

• Phone Number

• Social Security Number

• Passport Number

• Driver’s License Number

• Date of Birth

• Address, State, Province, ZIP/Postal Code, City

• Email Address

• Employment Status

• Job Title/Job Level

Support Data

Cliqued LLC may process user names and contact details to allow us to communicate and provide customer support to our subscribers. Some information we collect includes:

• Username/Passwords

• Survey/Poll Responses

• Contract preferences

• Event Registration

Payment & Finance Data

We may collect and process credit/debit card or bank account details that contain personal data and information we receive from a customer. This information is used and processed for the sole purpose of receiving payments. Cliqued LLC uses a third-party service provider, Plaid and Finix, to manage credit card processing. Plaid and Finix is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf. You may review Plaid and Finix’s privacy policy on their websites.

• Billing Address

• Debit/Credit Card

• Bank Account Information

• Sensitive Information

• Health Data

• Financial Data

• Credit Data

• Gender

• Race/Ethnic Origin

• Marital Status/Parental Status

• Sexual Orientation

• Philosophical/Religious Beliefs

• Education Level/Student Status

• Political Affiliation

• Voter Registration

• Technical Data/Website Data

We use the information collected from our own website, social networks, and other business-to- business interactions or from data compilers.

• IP Address

• Browser Details

• Device Information

• Location Information

• Network Data

• Log and Usage Data

As part of the services Cliqued LLC provides to our customers, we may receive and process data provided by third parties under separate license agreements. If we receive such data, we will not generally make this data available to customers (unless they are the data controller of such data) and customers will only receive aggregated summaries that do not allow reverse engineering to identify any individuals. Cliqued LLC will not sell any user information but may aggregate and anonymize PII and offer for sell. 

3. How Do We Obtain Your Personal Data

We collect and process personal data that is provided to us directly from you. This happens for multiple reasons:

• when you contact us on our platform;

• when you complete a registration form on our website;

• when you provide us with your details about your business;

• when you provide us with user details in order to set up user accounts to provide our services; and 

• when you provide us with details in order to set up a contract for our services.

Although we do not specifically request personal data from third-party providers, in some cases we may receive data indirectly from our third party partners in order for us to send marketing material to individuals, that have consented to their details being shared with us and to receive marketing material, or where we have a legitimate interest in sending you our marketing material..

We take reasonable measures to ensure that when we receive personal data indirectly: (i) the third party providing your personal data has the necessary lawful basis to share your personal data with us; and (ii) we use any such data in compliance with terms and conditions set out by the third party providing it to us.

4. Why Do We Have Your Personal Data

We collect and process your data for multiple reasons, but mainly to:

• Improve upon our services through content optimization

• Develop content personalized to meet your business needs

• Provide service support related to account creation and management 

• Send marketing and promotional communications

• Deploy targeted advertising that provides further information about our services

• Protect our Services including fraud monitoring and prevention

• Identify usage trends within the intelligence platform

• Determine the effectiveness of our marketing and promotional campaigns

• Manage communications

• Manage event attendance

• To process and fulfill contractual obligations, particularly where you have subscribed for specific services

• Analyze customer needs and respond to complaints or claims related to the services 

• Map customer journey

• Gather customer feedback to help conduct our business more efficiently

• Other reasons why we collect your data is for internal purposes. For example, we use your user data for:

• Internal research

• Internal operations

• Auditing 

• Detecting security incidents

• Debugging

• Quality control, and legal compliance 

In all scenarios, we only use your personal data for the purpose it was collected unless we reasonably believe that we need to, and we have a lawful basis to do so, use such personal data for another, related purpose.

5. Sharing Your Personal Data

We only share your personal data if it is necessary to provide our services or to enhance your user experience. Whenever we share your personal data with a third-party provider we ensure that this is done so in accordance with applicable data protection laws by implementing appropriate measures to maintain the security and confidentiality of your personal data. We may share your personal data with the following categories of recipients:

Cliqued LLC partners, vendors, and consultants;

Third-party service providers that: (i) provide hosting services; (ii) provide data processing services; or (iii) process personal data for other purposes detailed in this Privacy Policy. 

These service providers include but are not limited to:

• IT service;

• Cloud computing;

• Data storage;

• Website hosting;

• Sales & marketing tools

• CRM services;

• Advertising networks;

• Finance and Accounting tools;

• Payment processors;

• Testing Tools

• Advisors, consultants, insurers, lawyers and other applicable professional bodies;

• Data analytics and search engine providers;

Any law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary, or we are compelled to disclose such personal data to comply with the law;

To a potential purchaser (and its agents and advisors) in connection with a proposed merger or acquisition of any part or all of our business, provided that the purchaser may not use your personal data for any purpose other than for the purposes detailed in this Privacy Policy; or

To any other person you have consented to us to share personal data with.

In all circumstances that we share personal data with a third party we only do so in accordance with this Privacy Policy and to the extent that it is required for them to provide their services to us.

6. Lawful Basis for Processing your Personal Data

Under the General Data Protection Regulation 2018 (“GDPR”), the lawful bases that we normally rely on for processing your personal data, detailed above, are:

Consent. You are able to withdraw your consent at any time. You can do this by contacting privacy@cliqued.com.

Contractual Obligation. Where processing is necessary for the performance of our contractual obligations to you.

Legitimate Interest. Where we have a legitimate interest in processing your personal data, if this is the case we will inform you of what our legitimate interest is at the time of collecting your personal data.

We may need to process your personal data in order to comply with applicable laws, in these circumstances we have a legal obligation to process your data, but we will inform you if this is the case.

In the unlikely event we store any Special Category Data (as defined by GDPR) the lawful basis for processing is determined by the category of personal data being processed. In the event this relates to Special Category Data contained in a dataset, we rely on your consent to process such personal data.

Where we undertake direct marketing, all of our direct marketing campaigns are conducted in accordance with applicable law; we only do so with your consent and/or where we have a legitimate interest to do so, but in any event, you have the option to opt out of any direct marketing at any time by clicking the unsubscribe link in our marketing material. Cliqued LLC has performed a legitimate assessment in respect of its direct marketing activities to former, existing, and prospective customers. In summary, Cliqued LLC has a legitimate interest in marketing its services to existing customers as they already receive services directly from Cliqued LLC and may benefit from other services that Cliqued LLC provides. 

7. How we Store Your Personal Data and for How Long

Cliqued LLC will retain your personal data only as long as necessary for the purposes for which it was collected; to provide you with services in accordance with our contractual obligations to you; and where required or permitted under law. Generally, this means your personal data will be retained until the end of your contractual relationship with us. In addition, such data may also be retained whilst Cliqued LLC has a legitimate business need to do so.

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

In relation to direct marketing, we will retain personal data (only to the extent necessary) to ensure we respect your direct marketing opt-out preferences.

8. Account Deletion

If you would like to permanently delete your account, you must send us a request in writing. Once we receive your request, we will permanently disable your account, and you will not be able gain access to your account again.  You can submit your account deletion request to: privacy@cliqued.com.  Please allow up to 30 days for your account to be deleted.

9. Security

No service is completely secure, but we believe the security of your information is a serious issue and we are committed to maintaining commercially reasonable and appropriate security measures to ensure that your personal information is protected both online and offline. Cliqued LLC has a dedicated Information Security team that manages our framework, policies and procedures based on ISO27001 principles (with supplementary controls added for NIST framework alignment) to protect your personal information.

The framework includes, but is not limited to the following measures: 

Two-factor authentication 

Utilizing third-party security technologies i.e. NinjaCat, Snowflake, WooCommerce, Stripe, Mailchimp

Background checks for employees and contractors and additional training on confidentiality, data privacy and security. 

Likewise, we also take measures to ensure third-party service providers that process personal data on our behalf also have appropriate security controls in place. While we strive to protect your data, we cannot guarantee that unauthorized access to your data, data loss or a data breach will never occur.

9. Policy Updates

This Privacy Policy is current as of this date. Any changes to this Privacy Policy or information on any material changes will be posted prominently on this website or emailed to the customer’s contact on file. We reserve the right to update or modify this Privacy Policy at any time and without prior notice. Any modifications will apply only to the personal data we collect after the posting of the Privacy Policy. 

If we make material changes to how we collect, use and disclose the personal data we have previously collected about you, we will endeavor to provide you prior notice, such as by emailing you or posting prominent notice throughout our website, and where required by applicable law provide you with the opportunity to opt out.

10. Additional Information for U.S. Residents in Certain States (Including California)

In addition to the data protection laws referred to in this Privacy Policy, we also comply with the relevant privacy laws in the United States, including, where applicable, the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (collectively, “CCPA”). The CCPA was implemented to enhance privacy rights and consumer protection for residents in California and therefore it applies to businesses that carry out business activities in California.

Collection of Personal Information

When we act as a “Service Provider” (as defined in the CCPA) or a “Processor” (as defined in applicable US state privacy laws), we may process “Personal Information” or “Personal Data” on behalf of our customers or dataset providers. In such case, we will provide reasonable assistance to that customer or dataset provider as necessary to enable them to respond to your requests for the exercise of your privacy rights – you should therefore submit your request directly to the relevant customer or dataset provider.

“Personal Information” is defined under US state privacy laws as information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  We shall refer to such information as “Personal Information” throughout this Section.

In accordance with applicable US state privacy laws, Personal Information does not include:

Publicly available information, such as government records or information that has lawfully been made available to the general public by the consumer or from widely distributed media; and

De-identified or aggregated information.

Section 2 above titled “The Types of User Data that We Collect” describes the types of Personal Information that we collect. We have collected within the last 12 months the following categories of Personal Information:

Identifiers, such as your name, alias, postal address, email address, IP address or other similar identifiers;

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as your contact information;

Characteristics of protected classifications under California or federal law, such as your gender;

Commercial information, such as transaction information;

Internet or network activity information, such as your interactions with our website;

Geolocation data, such as your approximate location based on your IP address;

Audio, electronic, visual, and similar information, such as call or video recordings;

Professional or employment-related information, such as your title or industry;

Sensitive personal information as defined in the CPRA, such as your account log-in in combination with the password or credentials to access the account (if you have an account with us); and

Inferences drawn from any of the above Personal Information to create a summary about you, for example of your preferences and characteristics.

We may use, process and disclose de-identified or aggregated and other non-identifiable information including related to our business and our services for quality control, analytics, research, development and other purposes. Such information will not identify you individually.

Where we use, disclose or process de-identified data (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device) we will maintain and use the information in de-identified form and not to attempt to re-identify the information, except in order to determine whether our de-identification processes are reasonable and adequate pursuant to applicable privacy laws.

Sources of Personal Information

Section 3 above titled, “How Do We Obtain Your Personal Data”, describes the sources of Personal Information that we collect.

Purposes of Processing Personal Information

Section 4 above titled, “Why Do We Have Your Personal Data”, describes the purposes of our use or processing of Personal Information.

Notwithstanding the purposes described above, we do not use or disclose sensitive personal information beyond the purposes authorized by applicable law (including the CCPA).  Accordingly, we only use and disclose sensitive personal information as reasonably necessary (i) to perform our services requested by you, (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents, (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct, (iv) to verify or maintain the quality and safety of our services, (v) for compliance with our legal obligations, and (vi) to our service providers who perform services on our behalf.

Disclosure of Personal Information

Section 5 above (titled “Sharing Your Personal Data”) describes the categories of recipients with whom we disclose Personal Information.

Certain US state privacy laws (such as the CCPA) define a “sale” as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration, and define “sharing” broadly, including as disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising.

As mentioned above, we are in most cases a Service Provider or a Processor to a business that has provided your personal information to us for processing. Accordingly, we do not “sell” or “share” (as defined by applicable laws) such Personal Information to any third party.

Where we determine the purposes and means of the processing that we perform, for example when you provide the information directly to us or on our website, we are a “Business” (as defined in the CCPA) or a “Controller” (as defined in applicable US state privacy laws). In such case, we may disclose certain identifiers and Internet and electronic network activity usage information to advertising and data analytics partners and social networks. We may do so for the purposes described in Section 4, including (i) to provide, analyze and improve our website, products, and other services and (ii) develop and manage our relationships with you and our business partners.

In this circumstance, we rely on such laws’ marketing exemption allowing us to: (i) store marketing information on third party systems, provided applicable terms are in place with our service provider; (ii) provide opt-outs from marketing communications, as opposed to requiring an opt-in; and (iii) follow applicable cookie consents on our website.

We do not sell or share sensitive personal information, nor do we sell or share any Personal Information about individuals who we know are under sixteen (16) years old.

Do Not Track Browser Settings

California law requires us to let you know how we respond to web browser “Do Not Track” (“DNT”) signals. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time. 

11. Our Policy On Children’s Information

Our website and our service are not intended for users under the age of 18 without express consent from parents or guardians, and we do not knowingly collect personal information relating to children, as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If a parent or guardian learns that a child has provided us with personal information, that child’s parent or guardian should email us at privacy@cliqued.com.

12. Your Data Protection Rights

When you subscribe to our services, you trust us with certain personal data. We understand that it is essential we work hard to protect your personal data and provide you with the access you need to feel in control of your personal data you provide to us.

In accordance with the applicable data protection laws in the European Union, you have the following rights with respect to your personal data, depending on the circumstances:

your right of access – you have the right to ask us for copies of your personal data;

your right to object to processing – you have the right to object to the processing of your personal data in certain circumstances;

your right to deletion – you have the right to ask us to erase or delete your personal data in certain circumstances;

your right to restriction of processing – you have the right to ask us to restrict the processing of your personal data in certain circumstances;

your right to rectification – you have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete;

your right to data portability – you have the right to ask that we transfer your personal data you gave us to another organization, or to you, in certain circumstances; and

your right to lodge a complaint with a supervisory authority. We will use our best efforts to address and settle any requests or complaints brought to our attention. In addition, you have the right to approach the competent data protection authority with requests or complaints. This can be the supervisory authority in the country or federal state where you live.

You are not required to pay any charge for exercising your rights. If you do make a request, we will respond to you within one month. Please contact us by email at privacy@cliqued.com.

13. Data Protection Rights for Residents in Certain U.S. States (including California)

Subject to certain limitations and exceptions under applicable law, verified residents in certain U.S. states (including California) may have, pursuant to applicable law, the following additional privacy rights with respect to their personal information.

Right to Know. You have the right to ask us to disclose to you (i) the categories of personal information that we collect, (ii) the categories of sources from which the personal information is collected, (iii) the business or commercial purpose for collecting, selling, or sharing personal information, (iv) the categories of third parties to whom we disclose personal information, and (v) a copy of the specific pieces of personal information we have collected about you.

Right to Access. You have a right to ask us to provide you with a copy of the specific pieces of personal information that we retain about you.

Right to Correct. Subject to certain conditions and exceptions, you have a right to request that we correct inaccurate personal information that we maintain about you, taking into account the nature and purposes of the processing of the personal information.

Right to Deletion. You have the right to ask us to delete personal information we have collected about you, in certain circumstances.

Right to Limit Use and Disclosure. Subject to certain conditions and exceptions, you have the right to limit the use and disclosure of sensitive personal information (as defined under applicable local laws). However, as stated above, we do not use or disclose your sensitive personal information for purposes except as described herein (and as permitted pursuant to applicable law, including where applicable, the CCPA).

Right to Non-Discrimination. You have the right not to be subject to discriminatory treatment for exercising rights under the applicable privacy laws.

Right to Opt-Out. Subject to applicable laws, you have the right to opt out of certain types of processing, including:

to opt out of the “sale” (as such term is defined under applicable law) of your personal information;

to opt out of targeted advertising by us (or for California residents, to opt out of the “sharing”, as defined by the CCPA, of your personal information); and

to opt out of any processing of personal information for purposes of making decisions that produce legal or similarly significant effects.

Right to Appeal.  If we deny your privacy rights request, you may, depending on applicable law, also appeal our decision by submitting your appeal by contacting us at legal@cliqued.com.

California’s “Shine the Light” law (Civil Code Section § 1798.83) also permits California residents to request, once a year and free of charge, certain information regarding our disclosure of personal information to third parties for their direct marketing purposes in the preceding calendar year.

Please note that the rights described above are not absolute, and where an exception under applicable law applies, we may be entitled to refuse requests in whole or in part. You may exercise any of the above privacy rights by contacting us by email at privacy@cliqued.com.

We will take steps to verify your request by matching the information provided by you with the information we have in our records. In particular, your request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

Describe your request with sufficient details that allows us to properly understand, evaluate, and respond to it.

In some cases, we may request additional information in order to verify your request or where necessary to process your request.

14. Updates to this Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time and without prior notice. Changes to this Privacy Policy will be posted on this website, along with information on any material changes. Any modifications will apply only to the personal data we collect after the posting of the Privacy Policy. If we make material changes to how we collect, use and disclose the personal data we have previously collected about you, we will endeavor to provide you prior notice by emailing you or posting prominently on our website, and where required by applicable law provide you with the opportunity to opt-out.

15. Our Contact Details

If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will arrange to supply you with the information you need in an alternative format that you can access. You can also access a printable version of this Privacy Policy here. 

Cookie Policy 

A “cookie” is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. These cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain other than the domain of the Website – for our advertising and marketing efforts. Under certain data protection regimes, cookies are considered personal data/personal information and therefore subject to legal regulation. 

A cookie can remain on your computer or mobile device for varying periods of time. For example, some cookies are ‘session cookies’, meaning that they exist only while your browser is open and are deleted automatically once you close your browser or. Other cookies are ‘persistent cookies’, meaning that they survive after your browser is closed until a defined expiration date. Persistent cookies are used by websites to recognize your computer when you open your browser and browse the internet during subsequent sessions.

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personal data/personal information.

Performance Cookies

These cookies allow us to count website visits and traffic sources so we can measure and improve the performance of our website. They help us to know which pages are the most and least popular and see how visitors move around the Website. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our website and will not be able to monitor its performance.

Functional Cookies

These cookies enable the Website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Targeting Cookies

These cookies may be set through our Website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal data/personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

We may also use other tracking technologies, such as pixel tags and web beacons, to better tailor the website in order to provide a better service. These technologies usually work in conjunction with cookies.

Social Media Cookies

On some pages of the Additional Sites, third parties that provide applications through the Additional Sites (such as LinkedIn and Google) may collect your IP address and set their own cookies in order to track the success of their applications or customize applications for you. These services will also authenticate your identity and provide you the option to share certain personal data/personal information with us such as your name and email address to pre-populate our sign-up form or provide feedback. 

For example, when you follow Cliqued LLC using a social media button on a Cliqued LLC Additional Site (e.g. Facebook, Instagram, Twitter or LinkedIn), the social network that has created the button will record that you have done this. Because of how cookies work, we cannot access these cookies, nor can the third parties access the data in cookies used by us. Some pages of the Additional Sites may also contain embedded content, such as video content from YouTube, and these sites may set their own cookies. Your interactions with these features are governed by the privacy notice of the company providing them.

Beacons and Widgets

Web beacons operate in a similar way to cookies and are placed on websites or in an e-mail in order to monitor the behavior of the user visiting the website or sending the e-mail.

3. How to amend your cookie preferences 

Our website is scanned with our cookie management tool regularly to maintain a list as accurate as possible. You may review the current list of cookies and amend your preferences via Cookies Settings at any time. You can opt-out of each cookie category except strictly necessary cookies. 

Please also note that if you choose to reject or remove cookies, doing so may prevent certain features or services of the Website and/or Additional Sites from working properly and therefore affect your experience. Since your cookie opt-out preferences are also stored in a cookie in your website browser, please also note that if you delete all cookies, use a different browser, or buy a new computer, you may need to renew your opt-out choices.