The User: The person using the Sites and the services.

1 - Personal Data

CliperPay.com acts as the data controller for your personal data.

We have established this Privacy Policy to outline the procedures for processing the information collected through the Site, elucidating the reasons why certain personal data about you must be collected. It is imperative that you thoroughly review this Privacy Policy before engaging with the Site.

We prioritize the security and confidentiality of your personal data and commit to upholding these standards.

2.Why We Process Your Data

Ensuring the security of customer data is our foremost concern.

Consequently, we process only the essential user data required to maintain the website. Automatically collected information is solely utilized to identify potential instances of misuse and compile statistical data regarding website usage. This statistical information is not aggregated in a manner that would personally identify any specific user within the system.

You can explore the website anonymously without disclosing your identity or providing information that could identify you as a particular individual. However, if you wish to access certain features of the website, subscribe to our newsletter, or submit details via a form, you may need to provide personal data, such as your email, first name, last name, city of residence, organization, or telephone number.

While the provision of personal data is optional, choosing not to do so may limit your ability to fully utilize some of the website’s features. For instance, you may be unable to receive our newsletter or contact us directly through the website. If you have uncertainties about mandatory information, feel free to reach out to us at https://www.cliperpay.com/contact-us.

3.Your Rights

If you are a resident of India, you are entitled to the following rights regarding your personal data:

1. The right to be informed.
2. The right of access.
3. The right to rectification.
4. The right to erasure.
5. The right to restrict processing.
6. The right to data portability.
7. The right to object.
8. Rights in relation to automated decision-making and profiling.

Should you wish to exercise these rights, please contact us using the information provided below.

Furthermore, if you are a resident of India, please be aware that we process your information to fulfil contracts we may have with you (e.g., if you place an order through the Site) or for our legitimate business interests as outlined above. Additionally, please note that your information may be transferred outside of India, including to Canada, Europe and the United States.

4 - Nature of the Data Collected

When you visit the Site, we automatically collect certain information about your device.

This includes details about your web browser, IP address, time zone, and some of the installed cookies on your device. Additionally, as you navigate the Site, we gather information about the specific web pages or products you view, the websites or search terms that lead you to the Site, and how you engage with the Site.

We refer to this information collected automatically as “Device Information.” Furthermore, we may collect the personal data you voluntarily provide to us (such as Name, Surname, Address, payment information, etc.) during registration to fulfill the agreement.

In the course of using the Sites, the Publisher may collect the following categories of data about its Users:

• Data related to marital status, identity, identification, etc.
• Data related to personal life (lifestyle, family situation, excluding sensitive or dangerous data)
• Data related to professional life (CV, education, professional training, awards, etc.)
• Connection data (IP addresses, event logs, etc.)

Enhance the statement based on the specific types of data collected and processed by your website.

5 - Communication of Personal Data to Third Parties

No Communication to Third Parties

We want to assure you that your data will not be disclosed to third parties. However, it's important to note that in certain circumstances, your information may be disclosed as required by law, regulation, or pursuant to a decision from a competent regulatory or judicial authority.

We prioritize the confidentiality and security of your data, and any potential disclosure will strictly adhere to legal and regulatory obligations. Our commitment is to safeguard your information with the utmost care and transparency.

6 - Advance Notice for Communication of Personal Data to Third Parties in the Event of a Merger/Acquisition

Merger, Acquisition, or Other Form of Asset Transfer

In the event of our involvement in a merger, acquisition, or any other form of asset transfer, we are committed to ensuring the confidentiality of your personal data. We will provide you with advance notice before any transfer occurs or if new confidentiality rules are to be applied. This commitment is part of our dedication to keeping you informed and maintaining the security and privacy of your data during any organizational changes.

7 - Data Aggregation

Aggregation with Non-Personal Data

We may engage in the publication, disclosure, and utilization of Aggregate Information, which comprises data about all our users or specific groups/categories of users. This information is combined in a way that prevents the identification of individual users. It is employed for industry and market analysis, demographic profiling, promotional and advertising endeavours, and other business-related purposes.

Aggregation with Personal Data from User's Social Accounts

In instances where you link your account to another service for cross-mailing purposes, that service might share your profile information, login details, and any other authorized information with us. We may aggregate this information with data from all our other users, groups, and accounts, as well as available personal data about the user. Our intent is to enhance the overall user experience while maintaining the confidentiality and privacy of individual information.

8 - Collection of Identity Data

Use of a Pseudonym

Registration on the sites is possible without prior identification. It can be completed without the need for you to provide any personal data such as your name, first name, address, etc. You have the option to use a pseudonym of your choice, enhancing your privacy and providing you with the flexibility to interact with the sites without revealing personal details.

9 - Collection of Identification Data

Utilization of User's Identifier for Connection and Business Propositions

We employ your electronic identifiers, such as login credentials and email addresses, to facilitate the discovery of existing connections and to present commercial offers. Your contact information may be utilized to allow others to locate your account, including through third-party services and client applications. This enhances connectivity and enables a seamless exploration of potential contacts and business opportunities.

10 - Collection of Technical Data

Gathering Profiling and Technical Data for Service Provision

Certain technical data from your device is automatically gathered by the Site, encompassing your IP address, Internet service provider, hardware and software configurations, browser type, and language. This data collection is essential for delivering the services provided by the Site.

Technical Data Collection for Advertising, Marketing, and Statistical Purposes

The Site automatically collects and logs technical data from your device for advertising, commercial, and statistical objectives. This information aids in personalizing and consistently enhancing your Site experience. Importantly, no personal data (such as name, address) that can be linked to technical data is collected or stored. The aggregated data collected may be utilized for statistical analysis and may be shared with third parties for relevant purposes.

11 - Cookies

Cookie Retention Period

In adherence to CNIL recommendations, cookies are retained for a maximum of 13 months from their initial deposit on the User's device, aligning with the duration of the User's consent to use these cookies. The lifespan of cookies remains constant and is not extended with each visit. Renewal of the User's consent is required at the end of this period.

Purpose of Cookies

Cookies may be employed for statistical purposes, particularly to enhance User services by analysing information related to access frequency, page personalization, operations conducted, and consulted information.

You are notified that the Publisher may install cookies on your device, recording information about service navigation (consulted pages, date and time of visits, etc.), which can be accessed during subsequent visits.

User's Right to Refuse Cookies

You acknowledge being informed about the Publisher's use of cookies. If you prefer to prohibit cookie usage on your device, most browsers offer settings options to disable them.

12 - Information Security

Reasonable Safeguards Taken, but No Guarantees Made

While we implement reasonable safeguards to secure the information you provide on computer servers in a controlled and secure environment, protected from unauthorized access, use, or disclosure, it's essential to note that no data transmission over the Internet or wireless network can be guaranteed. We maintain a combination of administrative, technical, and physical safeguards to protect against unauthorized access, use, modification, and disclosure of personal data within our control and custody. However, the inherent nature of online data transmission poses certain inherent risks.

13 - Retention of Technical Data

Duration of Technical Data Retention

Technical data is retained for the duration strictly necessary to achieve the purposes mentioned above. We adhere to a responsible data retention policy, ensuring that technical information is kept only for the required timeframe in alignment with our specified objectives.

14 - Retention Period for Personal Data and Anonymization

Retention of Data for the Duration of the Contractual Relationship

In accordance with Article 6-5° of Law No. 78-17 of January 6, 1978, concerning data processing, files, and freedoms, personal data undergoing processing is not retained beyond the time necessary for the execution of obligations defined at the time of contract conclusion or the predetermined duration of the contractual relationship.

Retention of Anonymized Data Beyond the Contractual Relationship/After Account Deletion

We retain personal data for the period strictly necessary to fulfill the purposes described in this Privacy Policy. Subsequently, the data will be anonymized and retained for statistical purposes and service improvement.

Deletion of Data After Account Deletion

Mechanisms for purging data are implemented to ensure the effective deletion of data once the conservation or archiving period necessary for the achievement of determined or imposed purposes is reached. As per Law No. 78-17 of January 6, 1978, regarding data processing, files, and freedoms, you also have the right to delete your data, which you can exercise at any time by contacting the Publisher.

Deletion of Data After 3 Years of Inactivity

For security reasons, if there is no login activity on the Sites for a period of three years, you will receive an email inviting you to log in as soon as possible; otherwise, your data will be deleted from our databases.

15 - Account Deletion

Deletion of Account on Request

Users have the option to delete their account at any time by submitting a simple request to the Publisher or using the account deletion menu in the account settings if applicable.

Account Deletion in the Event of a Breach of the Privacy Policy

In the event of a violation of any provision(s) of the Privacy Policy or any other document incorporated herein by reference, the Publisher reserves the right to terminate or restrict your use of and access to the services, your account, and all Sites at its sole discretion without prior notice.

16 - Indications in the Event of a Security Breach Detected by the Publisher

Informing the User of a Security Breach

We commit to implementing all appropriate technical and organizational measures to ensure a level of security suitable for the risks of accidental, unauthorized, or illegal access, disclosure, alteration, loss, or destruction of your personal data. In the event that we become aware of unlawful access to your personal data stored on our servers or those of our service providers, or of unauthorized access resulting in the risks identified above, we undertake to:

1. Notify you of the incident as soon as possible.
2. Examine the causes of the incident and inform you.
3. Take reasonable steps to mitigate any adverse effects and damages that may result from the incident.

17 - Limitation of Liability

The commitments outlined in the above section regarding the notification of security breaches shall not be construed as an admission of fault or liability for the occurrence of the breach in question under any circumstances.

18 - Links to Other Websites

Our website may feature links to other websites that are not owned or controlled by us. Please note that we are not responsible for the privacy practices of such other websites or third parties. We recommend exercising caution and reviewing the privacy statements of each website you visit, especially when leaving our site and providing personal information.

Children's Privacy

Our Services are not intended for children under the age of 13, and we do not knowingly collect Personal Information from them. If we become aware that a child under 13 has provided us with Personal Information, we will promptly delete such information from our systems. If you are a parent or guardian and become aware that your child has provided us with Personal Information without your consent, please contact us using one of the methods listed below. We take children's privacy seriously and will take immediate steps to address any such incidents.

19 - Transfer of Personal Data Abroad

The Publisher commits to adhering to the applicable regulations regarding the transfer of data to foreign countries, as outlined below:

• Transfer to Countries with an Equivalent Level of Protection: The Publisher transfers Users' personal data to countries acknowledged for providing an equivalent level of protection.
• Transfer to Countries without Recognized Adequate Protection: In cases where the Publisher transfers personal data of its Users outside of countries recognized by the CNIL as having an adequate level of protection, the Publisher has obtained authorization from the CNIL for such transfers.

For a comprehensive list of these countries, please refer to CNIL's resource on Data Protection Around the World: CNIL - Data Protection Around the World.

20 - Changes to the Privacy Policy

Notification and Level of Confidentiality

In the event of any modifications to this Privacy Policy, we commit to maintaining a high level of confidentiality. We assure you that we will not significantly decrease the level of confidentiality without prior notification to the individuals concerned.

We pledge to keep you informed of any substantial changes to this Privacy Policy and affirm our commitment not to substantially diminish the confidentiality of your data without notifying you and securing your consent.

21 - Applicable Law and Dispute Resolution

Applicable Law

The Privacy Policy and the relationship between the Publisher and the User in the context of providing and using the Service shall be governed by the laws of India.

Dispute Resolution

You expressly agree that any dispute arising from this Privacy Policy, including its interpretation or performance, shall be subject to arbitration under the rules of a mutually agreed-upon arbitration platform, to which you unconditionally consent.

22 - Data Portability

Portability of Your Data

The Publisher is committed to providing you with the option to receive all your data upon request. This ensures that you have enhanced control over your data and the ability to reuse it. The data will be supplied in an open and easily reusable format.

23 - Legal Disclosure

Disclosure in Accordance with Legal Requirements

We will disclose any information we collect, use, or receive as required or permitted by law. This includes compliance with a subpoena or similar legal process. We will make such disclosures in good faith when it is necessary to protect our rights, ensure your safety, or the safety of others, investigate fraud, or respond to a government request.

24 - Contact Information

If you have any questions or concerns regarding this Policy or if you wish to inquire about your individual rights and Personal Information, please feel free to reach out to us via email at https://www.cliperpay.com/contact-us . We are here to assist you.