Privacy Policy of Clout

Clout collects some Personal Data from its Users.

Owner and Data Controller

Clout is a division of The Wyld Bunch Ltd, 4 Grovelands Boundary Way, Hemel Hempstead, Hertfordshire, England, HP2 7TE Owner contact email: info@justaddclout.com

Owner and Data Controller

Among the types of Personal Data that Clout collects, by itself or through third parties, there are: email address, first name, last name, date of birth, phone number, address, company name, country, Cookies, city, website, various types of Data, Usage Data, gender, profession and Data communicated while using the service.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

>Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Clout.

Unless specified otherwise, all Data requested by Clout is mandatory and failure to provide this Data may make it impossible for Clout to provide its services. In cases where Clout specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by Clout or by the – or of other tracking tools – by Clout or by the owners of third-party services used by Clout serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through Clout and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Clout (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time. Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;

• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
• The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Infrastructure monitoring, Hosting and backend infrastructure, Managing contacts and sending messages, Contacting the User, Analytics, Access to third-party accounts, Registration and authentication, Displaying content from external platforms, Interaction with live chat platforms and Handling payments. Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Infrastructure monitoring, Hosting and backend infrastructure, Managing contacts and sending messages, Contacting the User, Analytics, Access to third-party accounts, Registration and authentication, Displaying content from external platforms, Interaction with live chat platforms and Handling payments. Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Facebook permissions asked by Clout

Clout may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows Clout to connect with the User's account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

The permissions asked are the following:

Basic information

By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

About Me

Provides access to the 'About Me' section of the profile.

Birthday

Provides access to the birthday.

Insights

Provides read access to the Insights data for pages, applications, and domains the user owns.

Manage Pages

Enables the application to retrieve access_tokens for Pages and Applications that the User administrates.

Show List of Managed Pages

Provides the access to show the list of the Pages that the User manages. Website

Provides access to the User's web site URL.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Access to third-party accounts

This type of service allows Clout to access Data from your account on a third-party service and perform actions with it.

These services are not activated automatically, but require explicit authorization by the User.

Twitter account access (Twitter, Inc.)

This service allows Clout to connect with the User's account on the Twitter social network, provided by Twitter, Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States –Privacy Policy. Privacy Shield participant.

Facebook account access (Clout)

This service allows Clout to connect with the User's account on the Facebook social network, provided by Facebook, Inc.

Permissions asked: About Me, Birthday, Insights, Manage Pages, Show List of Managed Pages and Website. Place of processing: United States –Privacy Policy. Privacy Shield participant.

Stripe account access (Stripe Inc)

This service allows Clout to connect with the User's account on Stripe, provided by Stripe, Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United States –Privacy Policy. Privacy Shield participant.

Analytics

The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour. Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc.

(“Google”). Google utilizes the Data collected to track and examine the use of Clout, to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies and Usage Data. Place of processing: United States –Privacy Policy – Opt Out. Privacy Shield participant.

Contacting the User

Mailing list or newsletter (Clout)

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Clout. Your email address might also be added to this list as a result of signing up to Clout or after making a purchase.

Personal Data collected: city, Cookies, country, date of birth, email address, first name, last name and website.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of Clout and interact with them.

This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

YouTube video widget (Google Inc.)

YouTube is a video content visualization service provided by Google Inc. that allows Clout to incorporate content of this kind on its pages.

Personal Data collected: Cookies and Usage Data. Place of processing: United States –Privacy Policy. Privacy Shield participant.

YouTube video widget without cookies (Google Inc.)

YouTube is a video content visualization service provided by Google Inc.

that allows Clout to incorporate content of this kind on its pages. This widget is set up in a way that ensures that YouTube won't store information and cookies about Users on Clout unless they play the video.

Personal Data collected: Usage Data. Place of processing: United States –Privacy Policy Privacy Shield participant.

Handling payments

Payment processing services enable Clout to process payments by credit card, bank transfer or other means. To ensure greater security, Clout shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.

Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

Stripe (Stripe Inc)

Stripe is a payment service provided by Stripe Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United States –Privacy Policy. Privacy Shield participant.

Hosting and backend infrastructure

This type of service has the purpose of hosting Data and files that enable Clout to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Clout. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored. Amazon Web Services (AWS) (Amazon Web Services, Inc.) Amazon Web Services is a hosting and backend service provided by Amazon.com Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland –Privacy Policy; United Kingdom –Privacy Policy; Privacy Shield participant.

DigitalOcean (DigitalOcean Inc.)

DigitalOcean is a hosting service provided by DigitalOcean Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States –Privacy Policy; United Kingdom –Privacy Policy; Privacy Shield participant.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Mailchimp (The Rocket Science Group, LLC.)

Mailchimp is an email address management and message sending service provided by The Rocket Science Group, LLC.

Personal Data collected: address, company name, Cookies, country, date of birth, email address, first name, last name and phone number.

Place of processing: United States –⦁ Privacy Policy. Privacy Shield participant.

Mailgun (Mailgun, Inc.)

Mailgun is an email address management and message sending service provided by Mailgun, Inc.

Personal Data collected: address, Cookies, country, date of birth, email address, first name, gender, last name, phone number, profession, Usage Data and various types of Data. Place of processing: United States –⦁ Privacy Policy.

Registration and authentication

By registering or authenticating, Users allow Clout to identify them and give them access to dedicated services.

Depending on what is described below, third parties may provide registration and authentication services. In this case, Clout will be able to access some Data, stored by these third-party services, for registration or identification purposes.

Twitter OAuth (Twitter, Inc.)

Twitter Oauth is a registration and authentication service provided by Twitter, Inc. and is connected to the Twitter social network.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States –⦁ Privacy Policy. Privacy Shield participant.

Stripe OAuth (Stripe Inc)

Stripe OAuth is a registration and authentication service provided by Stripe, Inc. and is connected to the Stripe network.

⦁Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United States –⦁ Privacy Policy. Privacy Shield participant.

Further information about Personal Data

⦁ Selling goods and services online

The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery. The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by Clout depends on the payment system used.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following: Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below. Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing. Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected. Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it. Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner. Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof. Lodge a complaint. Users have the right to bring a claim before their competent data protection authority. Details about the right to object to processing Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document. How to exercise these rights Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Clout uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Clout or the related Services.

use of Clout or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, Clout may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Clout and any third-party services may collect files that record interaction with Clout (System logs) use other Personal Data (such as the IP Address) for this purpose. Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

Clout does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within Clout and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through Clout (or third-party services employed in Clout), which can include: the IP addresses or domain names of the computers utilized by the Users who use Clout, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using Clout who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Clout. The Data Controller, unless otherwise specified, is the Owner of Clout.

Clout (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by Clout as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies

Small sets of data stored in the User's device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to Clout, if not stated otherwise within this document.