Privacy Policy

This Privacy Policy and Cookies Statement describes how cLabs Inc. and its affiliated companies (referred to in this document as “cLabs,” “we,” “us” or “our”) collects, uses, shares and otherwise processes Personal Data (defined below) including:

• Visitors to our website(s), mobile applications and other online properties (“Site” or “Sites”)

• Any other individual about whom cLabs may obtain Personal Data

In this Privacy Policy, “Personal Data” means information that (either in isolation or in combination with other information held by cLabs) enables you to be identified as an individual or recognized directly or indirectly. We may collect Personal Data when you use our Sites.

Overview

Unless we specifically state otherwise, cLabs is the data processor of the Personal Data we process, and is therefore responsible for ensuring that the systems and processes we use are compliant with data protection laws, to the extent applicable to us.  cLabs personnel are required to comply with this Privacy Policy and complete data protection training, where appropriate.

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.

Marketing Choices

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

We may transfer your Personal Data to countries outside of your country of residence, including, but not limited to the European Economic Area (“EEA”), specifically Germany, as well as the United States, where cLabs’ offices and some of its IT systems (including email) are located. Personal Data is not processed outside of the countries listed in this Privacy Policy.

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.

Children’s Information

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.

Your Rights

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 privacy@clabs.co.

Changes To This Privacy Policy

We reserve the right to change and update this Privacy Policy from time to time. If we make changes, you will be notified of the change by the date at the top of Privacy Policy, which will reflect the last date updated.

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.