1. Overview and Scope
2. Roles and Responsibilities
The following roles and responsibilities are to be developed and subsequently assigned to authorized personnel within Cladfy regarding privacy practices: Chief Privacy Officer: Responsibilities include providing overall direction, guidance, leadership, and support on methods and tools for the implementation of a security and privacy-related program. The Chief Privacy Officer will conduct resource and investment planning to implement the management, operational, technical, and privacy requirements of the program. Privacy Committee: Responsibilities include approving and monitoring adherence to this policy, analyzing the organization’s environment, and the legal requirements with which it must comply. Additional responsibilities include: Execute the privacy operations of the firm, including monitoring the system used to solicit, evaluate, and respond to individual privacy complaints and problems. Evaluate implemented privacy controls; Assessing existing policies and procedures that address privacy areas; Working with appropriate departments to ensure compliance with privacy policies and procedures; Recommending and monitoring, in conjunction with the relevant departments, the development of internal systems and controls to carry out the organization’s privacy objectives; Report to the Chief Privacy Officer on the effectiveness of the privacy controls/program in meeting applicable regulatory requirements and standards.
3. Personal Information
"Personal Information," as used in this policy, is information that specifically identifies an individual, such as an individual’s name, social security number, telephone number, or e-mail address. Personal information also includes information about an individual’s activities, such as information about his or her activity on the Site or credit history, and demographic information, such as date of birth, gender, address, geographic area, and preferences, when any of this information is linked to personal information that identifies that individual. Personal information does not include "aggregate" or other non-personally identifiable information. Aggregate information is information that we collect about a group or category of products, services, or users that is not personally identifiable or from which individual identities are removed. We may use and disclose aggregate information, and other non-personally identifiable information, for various purposes.
4. Collection of Information
4.1 Passive Information Collection
When you use the Service, some information may be automatically collected, such as your IP address, browser type, system type, the content and pages that you access on the Site, "referring URL" (i.e., the page from which you navigated to the Site), the pages you navigate to on the Site, and from which you leave the Site, as well as the time you spend on the Site. We collect this information passively using technologies such as standard server logs, cookies, and clear GIFs (also known as "Web beacons"). We use passively collected information to administer, operate, and improve the Site and our other services and systems, and to provide services and content that are tailored to you. If we link or associate any information gathered through passive means with personal information, we treat the combined information as personal information under this policy. Otherwise, we use information collected by passive means in a non-personally identifiable form only. Also, please be aware that third parties may set cookies on your hard drive or use other means of passively collecting information about your use of their services or content. We do not have access to, or control over, these third-party means of passive data collection.
4.2 Collection of Voluntarily Provided Information
We may collect personal information that our users provide to us in a variety of ways through our Service. For instance, when you request information about our services or otherwise communicate with us, we collect the personal information that is provided to us. We may collect personal information such as name, e-mail address, city, state, country, other demographic information, and your interests and preferences in these manners.
4.3 Information from Other Sources
We may receive information about you, including personal information, from third parties, and may combine this information with other personal information we maintain about you. If we do so, this policy governs any combined information that we keep in a personally identifiable format.
4.4 Bank and Mobile Money Statements
Cladfy collects Bank and Mobile Money Statements to:
- Provide insights: Cladfy automatically analyzes the Bank and Mobile Money Statements to provide insights into customer behavior, spending patterns, and other trends. This information can be used by businesses to improve their products and services, and by individuals to make better financial decisions.
- Assess creditworthiness: Cladfy automatically analyzes the Bank and Mobile Money Statements to assess creditworthiness. This information can be used by lenders to make informed decisions about whether or not to grant a loan. Cladfy uses a variety of methods to analyze Bank and Mobile Money Statements, including algorithms and automated decision-making systems. These methods allow Cladfy to identify patterns and trends in the Bank and Mobile Money Statements, which Cladfy then uses to generate insights and endorsements. For example, Cladfy may use its algorithms to identify spending patterns or to identify businesses that are likely to be successful.
4.5 Personally identifiable data, contact information, and financial data. Cladfy collects personally identifiable data, contact information, and financial data from its users in a variety of ways, including:
- When users create an account, they are required to provide their name, email address, and mailing address.
- When users book a service, they are required to provide their contact information, such as their phone number and address.
- When users make a payment, they are required to provide their financial information, such as their credit card number and billing address.
Cladfy uses the data it collects to:
- Provide its users with the services they have requested.
- Contact users with important information about their services, such as changes to their appointments or billing information.
- Improve its services by analyzing user data and trends.
- Conduct marketing and promotional activities.
- Process payments of the service fees.
5. Use of Personal Information
We use personal information to provide services and information that you request; to enhance, improve, operate, and maintain the Site and Service, our programs, services, website, and other systems; to prevent fraudulent use of our Site and Service; to tailor your user experience; to maintain a record of our dealings with you, and for other administrative purposes. We may also use the personal information you provide to contact you regarding our products and services. We allow you to opt-out from receiving marketing communications from us as described in the "Choice" section.
6. Disclosure of Personal Information
We will not disclose your personal information to third parties without your consent, other than as described in this policy. We may disclose personal information to the following types of third parties for the following purposes:
- Third-party service providers: These are service providers that assist us in our work, service providers that assist us in our work, such as data storage and processing facilities, payment processing service providers, customer support providers, and marketing agencies. We limit the personal information provided to these service providers to that which is reasonably necessary for them to perform their functions.
- Law enforcement agencies and other government entities: We may disclose personal information to law enforcement agencies and other government entities if we believe that doing so is legally required or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others.
- Merger, acquisition, debt financing, sale of company assets, or similar transaction: In the event of a merger, acquisition, debt financing, sale of company assets, or similar transaction, we may disclose personal information to the parties involved in the transaction.
- Insolvency, bankruptcy, or receivership: In the event of an insolvency, bankruptcy, or receivership, personal information may be disclosed to third parties as one of our business assets.
If you receive commercial emails or other types of communications from us, you may unsubscribe at any time by following the instructions contained within the communication, by sending us an email, or by writing to us at the address given at the end of this policy. Please note that service updates and newsletters are considered to be necessary communications, and you may not be able to opt out of receiving them. However, you can limit the number of these communications you receive by updating your preferences in your account settings.
For your convenience, the Site may contain links to other Web sites, products, or services that we do not own or operate. If you choose to visit or use any third-party products or services, please be aware that this policy will not apply to your activities or any information you disclose while using third-party products or services or otherwise interacting with third parties. These third-party products and services may include social media platforms, e-commerce websites, and online advertising platforms. There are a number of risks associated with using third-party products and services. For example, third-party products and services may collect and use your personal information in ways that are not consistent with this policy. Additionally, third-party products and services may be more susceptible to cyberattacks and data breaches. We encourage you to carefully review the privacy policies of any third-party products or services that you choose to use before providing them with any personal information.
Children’s safety is important to us, and we encourage parents and guardians to take an active interest in the online activities of their children. Our Services are not directed to children under the age of 18, and we do not knowingly collect Personal Information from children under the age of 18 without obtaining parental consent. If we learn that we have collected Personal Information from a child under the age of 18 on our Services, we will delete that information as quickly as possible. If you believe that we may have collected any such Personal Information on our Services, please notify us at email@example.com.
Cladfy protects the Personal Information it collects with reasonable and appropriate physical, electronic, and procedural safeguards. We use the following security measures to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction:
- Encryption: We encrypt all personal data at rest and in transit using industry-standard encryption algorithms.
- Access controls: We restrict access to personal data to authorized employees and contractors on a need-to-know basis.
- Firewalls and intrusion detection systems: We use firewalls and intrusion detection systems to protect our networks from unauthorized access.
- Security incident response plan: We have a security incident response plan in place to quickly and effectively respond to any security incidents that may occur.
Please note that no data security measures can be guaranteed to be completely effective. Consequently, we cannot ensure or warrant the security of any personal information or other information. You transmit information to us at your own risk.
11. Data Subject Access Rights
Cladfy respects the data subject access rights of its users. Users can request to access, correct, or delete their personal data by contacting Cladfy customer support. Cladfy will respond to all requests within a reasonable timeframe. If a user requests to access their personal data, Cladfy will provide the user with a copy of their personal data in a clear and concise format. If a user requests to have their personal data corrected, Cladfy will take all reasonable steps to do so.
12. Data Retention and Deletion
If Customer wishes to permanently delete their account and or personal data erasure, Customer must contact Company via electronic mail using firstname.lastname@example.org. Customer must include their full name, contact information, and account details in the request. The company will process the Customer’s request within 30 days. During this time, the Customer will have access to all their Data for electronic retrieval. Customer can download their data. However, Cladfy may not be able to delete all of a user's personal data if it is necessary for Cladfy to retain the personal data in order to comply with its legal obligations. For example, Cladfy may need to retain personal data for tax or accounting purposes.
13. Updates to this Policy
We may occasionally update this Policy. When we do, we will also revise the "last updated" date at the beginning of the policy. We will send an email to you notifying you of any changes to the Policy. Your continued use of this Service after such changes will be subject to the then-current policy. We encourage you to periodically review this policy to stay informed about how we collect, use, and disclose personal information.
14. Contacting Us
15. Policy Administration
15.1 Ownership and Review The Policy Owner owns this Policy and is responsible for reviewing the Policy for updates annually or following major changes to Cladfy’s compliance environment. The Policy Approver retains approving authority over this Policy.
15.2 Monitoring and Enforcement Cladfy periodically monitors adherence to this Policy to help ensure compliance with applicable laws, requirements, and contractual agreements that apply to Client and consumer Data. Cladfy may also establish enforcement mechanisms, including disciplinary actions, to help ensure compliance with this Policy.