Privacy Policy

Cludo values the privacy of its Customers and its Customers’ Users. Data protection and confidentiality is a high priority for Cludo. This Privacy Policy explains how information about you is collected, used and disclosed by Cludo when we process personal data as part of our Services or when you otherwise interact with us.

This Policy only applies to personal data and other information collected by us from (i): visitors to our website and (ii): Customers that use our Services. While providing our Services to Customers, we may receive information related to the Customers’ Users, and other third parties.

We may amend this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the Policy. Depending on the specific amendments, we may provide you with additional notice. We encourage you to review the Privacy Policy whenever you access our website or through one of the links to the Privacy Policy we provide in our communication, etc.

Below we provide the following information:

• We are the data controller – how do you contact us
• Cludo as data processor
• Collection of personal data
• Purposes and legal basis for the processing of personal data
• Transfer and disclosure of personal data
• Transfer to third countries
• Location of data storage
• Retention period
• Cookies
• Security
• Links to third party websites
• Your rights
• How to complain about the processing

1. Data controller and contact information

Cludo ApS

Frederikskaj 4
2450 København, Denmark

CVR: 36 72 68 49

DK: +45 3529 4680

E-mail address: privacy@cludo.com

2. Cludo as data processor

When providing our Services to Customers, we may need to receive information related to the Customers’ Users, and other third parties. When a Customer chooses to use our services, we strictly follow the Customer’s instructions in collecting and processing the Customer’s website data in accordance with the specific services that the Customer has chosen.

Please note that in relation to the processing of these personal data, the Customer is considered as the data controller and Cludo is considered as a data processor.

Our use of personal data on behalf of our Customers is governed by our contract with that Customer, our general data processing terms and conditions and the Customer’s own privacy policy.

3. Collection of personal data

Personal data we hold and process include:

• Contact details (such as name, address, phone number, email address)
• Cludo-Account information. This is information you provide to create a Cludo Account (such as first and last name, phone number, email address, password, country/location)
• Payment information (such as the last four digits, the country of issuance, and the expiration date of the payment card), if you sign up for paid services.
• Information relating to our Customer’s orders and subscriptions (such as order history, information on subscriptions, incidents and complaints)
• Metadata (such as details of your visits to the Website, traffic data, location data, IP address and other online identifiers, browser information, session data, preferences, settings, weblogs and other communication data), which we monitor during your interaction with the website.
• Information collected by cookies.
• Search statistics of our Customers’ Users to improve our search platform.

4. Purposes and legal basis for processing personal data

Our legal basis for processing personal data is that: i) the processing is necessary to perform a contract with you or in preparation of entering a contract with you, ii) we must comply with various legal obligations and requirements, and iii) it is in our legitimate interests and these interests are not overridden by the interests or fundamental rights and freedoms of the data subject.

These legitimate interests include being able to communicate with you, manage our business operations and IT-infrastructure, manage complaints and queries, prevent and detect crime, process payments, ensure network and information security, improve our products and services. We collect search statistic of our Customers’ Users to improve our search platform, and in this case the data processing will be performed until the termination of the agreement between the Customer and Cludo. This is not an exhaustive list.

The purposes for which we use your personal data may differ based on the services we provide and the type of communication between us. The main purposes include using personal data to:

• Carry out our obligation arising from any contracts entered between you and us, and to provide you with the information, products, services that you requested from us, and to notify you about changes to our services.
• Manage your Cludo Account.
• Process your payment transactions.
• Deliver security protection, prevent, detect and investigate crime.
• Manage our business operations and IT infrastructure, in line with our internal policies and procedures, including those related to billing and collections; IT system operation; data and website hosting; data analytics; and auditing.
• Manage complaints, feedback and queries, and handle requests for data access or correction, or the exercise of other rights relating to Personal Data.
• Comply with applicable laws and regulatory obligations, for example comply with legal process and court orders; and respond to requests from public and government authorities.
• Improve our products and services. We may anonymise, de-identify and/or aggregate the information that we collect, and use these data for statistical and analytical purposes to improve our products and services.
• Commercial, statistical and market research purposes. We may anonymise, de-identify and/or aggregate the information that we collect, and use these data for commercial, statistical and market research purposes, including but not limited to sharing anonymised data with our current and prospective Customers, business partners, affiliates, and other third parties.

5. Transfer and disclosure of personal data

We transfer data to our service providers (such as IT-service provider and payment provider) as necessary to provide any service that you have requested or authorised and to complete transactions.

We disclose data when required by law or to respond to legal process; to prevent and detect crime and maintain the security of our Services; and to protect the rights or property of Cludo.

We may also disclose your personal data with other parties in connection with corporate transactions: in the event of a merger, reorganisation, acquisition, joint venture, assignment, spin-off, transfer or sale or disposition of all or any portion of our business, including in connection with any bankruptcy or similar proceedings.

We may publish search-trends in the market (only anonymised aggregated data is used).

6. Transfer to third countries

Under specific circumstances Cludo transfers personal data to recipients located outside of the EU/EEA:

7. Location of data storage

Default location:

In principle, the host servers on which Cludo processes and stores its databases are located:

• Exclusively within the European Union, if the client is based in the European Union
• In the United States, if the client is based in the United States, Australia, or the rest of the world.

The Client can request Cludo to not use the default location by sending us a request on privacy@cludo.com.

8. Retention Period

Cludo will retain your personal data for the period necessary to fulfil purposes outlined in this Policy including mandatory registration and documentation requirements, unless longer retention period is required or permitted by law.

9. Cookies

• We use cookies on our website to help optimise and enhance your experience. You can read more about the use of cookies in our Cookie Policy, which you can find at the following link: Cludo Cookie Policy.

A website visitor may refuse to accept browser cookies by activating the appropriate setting on her or his browser. For more information on cookies and how a website visitor can remove them according to the type of the browser used, refer to www.allaboutcookies.org.

10. Security

We have implemented technical and organisational security measures designed to secure your Personal Data from accidental loss and from unauthorised access, use, alteration and disclosure. This includes encryption of data and use of pseudonymisation whenever applicable.

Cludo takes reasonable measures to protect the website from computer virus, worms, Trojan horses or other threats, however, please note that no website, internet transmission, computer system or wireless connection is completely secure, and Cludo disclaims any responsibility for or liability related to loss due to harmful programs received from the website or by means of files downloaded from the website.

11. Links to third party websites

Our web site may contain links to other websites not operated or controlled by Cludo (third party sites). We are not responsible for the content of third party sites or for the procedures such third parties have for the collection and processing of personal data. When you visit third party websites, you should therefore make sure to read the website owner's privacy policy and other relevant policies.

12. Your Rights

You have the right to access personal data about you that we process, but with certain legislative exceptions. You also have the right to object to the collection and further processing of your personal data. Furthermore, you have the right to have your personal data rectified, erased or blocked. Moreover, you have the right to have this information transmitted to another data controller (data portability).

If you want us to update, amend or delete the personal data that we have recorded about you, if you wish to get access to the data being processed about you, or if you have any questions regarding the content of this Privacy Policy, please contact us at privacy@cludo.com

13. Complaints

If you wish to make a complaint about our processing of your personal data, please contact us as indicated above, as it gives us an opportunity to fix the problem. You may also lodge a complaint with the Danish Data Protection Agency (“Datatilsynet”), Borgergade 28, 5., 1300 Copenhagen K, Denmark.

14. Governing Law and Jurisdiction

Any disputes relating to or arising from the use of this Site shall to the widest possible extent be settled by Danish Courts in accordance with Danish Law.