Valid as of July 15, 2021
Visitors to our website(s), mobile applications and other online properties (“Site” or “Sites”)
Any other individual about whom cLabs may obtain Personal Data
Collection of Personal Data
cLabs collects information that you provide directly to us when you use our products, browse our Site, register to receive newsletter requests or other information, provide feedback through surveys, participate in any interactive features on our Sites including contests, promotions, challenges, activities or events. We also collect data provided by job applicants or others on our Sites or offline means in connection with employment or consulting opportunities, which may also be subject to other Policies. We may also collect Computer Internet Protocol (IP) address, unique device identifier (“UDID”), cookies, web beacons, web server logs and other technologies and other data linked to a device, and data about usage of our Sites (Usage Data). A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.
With your consent, cLabs may access an encrypted version of your contacts' phone number which will be used by our service to find who of your contacts are already on Valora. However, no personal information will be shared with anyone directly, including cLabs.
Other types of information we may collect include your name, email address, username, password, phone number, location and any other information you choose to provide. We may use these automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner may include your device IP address, identifiers associated with your devices, types of devices connected to our services, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Site.
cLabs may require certain information from time to time for purposes of meeting its know-your-customer and customer due diligence requirements specifically to comply with anti-money laundering and countering financing of terrorism obligations.
Use of Personal Data
We use the Personal Data that we collect:
To make our products and Sites more intuitive and easier to use we use device data, cookies and other information that you may provide. This data is necessary for our legitimate interests in monitoring how our products and Sites are used to help us improve these products and Sites, and the information and tools available on these products and Sites.
To provide relevant marketing including providing you with information about events or services that may be of interest to you. It is necessary for our legitimate interests to process this information in order to provide you with tailored and relevant marketing, updates and invitations.
To consider individuals for employment and contractor opportunities and manage on-boarding processes we use job applicant data. The processing is necessary for the purposes of recruitment and on-boarding.
To carry out any other purpose for which the information was collected.
We may also use automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner may include your device IP address, identifiers associated with your devices, types of devices connected to our services, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Site. The information we collect through cookies and similar technologies helps cLabs (1) remember your information so you will not have to re-enter it; (2) understand how you use and interact with our products and website; (3) measure the usability of our products and website and the effectiveness of our communications; and (4) otherwise manage and enhance our products and website, and help ensure they are working properly. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our website.
You have control regarding our use of Personal Data for direct marketing. In certain markets, you will need to expressly consent before receiving marketing. In all markets, you can choose to not receive marketing communications at any time. If you no longer wish to receive marketing communications from cLabs, or remain on a mailing list to which you previously subscribed, or receive any other marketing communication, please follow the unsubscribe link in the relevant communications or contact us as specified below.
How we share your information
With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;
If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of us or any third-party;
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;
With your consent or at your direction; and
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
Legal Bases For Processing (For EEA and other Users)
If you are an individual from the European Economic Area (“EEA”) or a jurisdiction with similar data protection regimes, we collect and process your Personal Data only where we have legal basis for doing so under applicable laws. The legal basis depends on the Services you use and how you use them. This means we collect and use your personal data only:
To operate our business, including to improve and develop our services, for fraud prevention purposes, improve user experience, or other legitimate interest;
To fulfill contractual responsibilities; and/or
As otherwise in compliance with law.
If you have any questions about the legal basis for processing, please contact us at the address listed in the “Contact Us” section.
Transfer of Personal Data To Other Countries
How We Protect Your Information
Protecting your information is important to us. We maintain administrative, technical and physical safeguards designed to protect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use of Personal Data.
How Long We Retain Your Information
We strive to only keep your Personal Data only for the period of time needed for legitimate business purposes. In certain circumstances, however, legal or regulatory obligations may require us to retain records for a longer than we otherwise would.
Our Services are not directed to children under the age of 18. If you learn that a child under the age of 18 has provided us with personal information without consent, please contact us.
If you are resident in countries with applicable data privacy laws you have have the right, subject to certain exceptions, to request a copy of the Personal Data we are processing about you, to require that any incomplete or inaccurate Personal Data is amended, to request that we delete your Personal Data (although we may not be able to delete certain data due to legal or other obligations), to object to the use of your Personal Data or to withdraw consent. You may also have a right to lodge a complaint with the local data protection authority if you believe that we have not complied with the applicable data protection laws. You may also contact us to address and resolve concerns you may have about our use of your Personal Data. Please contact us at email@example.com.
Third-Party Services, Applications, and Websites
Certain third-party services, websites, or applications you use, or navigate to from our Services may have separate user terms and privacy policies that are independent of this Policy. This includes, for example, websites owned and operated by our customers or partners. We are not responsible for the privacy practices of these third-party services or applications. We recommend carefully reviewing the user terms and privacy statement of each third-party service, website, and/or application prior to use.