Privacy policy

 

1.     Introduction

Clarrow (“us”, “we”, or “our”) operates www.clarrow.com and the Clarrow mobile application (hereinafter referred to as “Service”).

Our Privacy Policy governs your visit to www.clarrow.com and the Clarrow mobile application, and explains how we collect, safeguard and disclose information that results from your use of the Service.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Our Terms and Conditions (“Terms”) govern all use of the Service and together with the Privacy Policy constitutes your agreement with us (“agreement”).

Use of Plaid

Clarrow uses Plaid Technologies, Inc. (“Plaid”) to gather End User’s data from financial institutions. By using our service, you grant Clarrow and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy.

2.     Definitions

SERVICE means the www.clarrow.com website and the Clarrow mobile application operated by Clarrow.

PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

USAGE DATA is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR THE SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the Services of various Service Providers in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

THE USER is the individual using the Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

3.     Information Collection and Use

We collect several different types of information for various purposes to provide and improve the Service to you.

4.     Types of Data Collected

Personal Data

When you visit the website or use one of our mobile applications, we collect your IP address, and standard web log information, such as your browser type and the pages you accessed on our website.

While using the Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

(a)   Email address

(b)   First name and last name

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link.

Finally, we may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with our customer support team or store results when you respond to a survey.

Usage Data

We may also collect information that your browser sends whenever you visit the Service or when you access the Service by or through a mobile device (“Usage Data”).

This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of the Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on the Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze the Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of the Service.

Examples of Cookies we use:

(a)   Session Cookies: We use Session Cookies to operate the Service.

(b)   Preference Cookies: We use Preference Cookies to remember your preferences and various settings.

(c)   Security Cookies: We use Security Cookies for security purposes.

(d)   Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

5.     Use of Data

Clarrow uses the collected data for various purposes:

(a)   To provide and maintain the Service;

(b)   To notify you about changes to the Service;

(c)   To allow you to participate in interactive features of the Service when you choose to do so;

(d)   To provide customer support;

(e)   To gather analysis or valuable information so that we can improve the Service;

(f)    To monitor the usage of the Service;

(g)   To detect, prevent and address technical issues;

(h)   To fulfill any other purpose for which you provide it;

(i)    To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

(j)    To provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;

(k)   To provide you with news, special offers and general information about other goods, the Services and events which we offer that are similar to those that you have already purchased or inquired about unless you have opted not to receive such information;

(l)    In any other way we may describe when you provide the information;

(m) For any other purpose with your consent.

6.     Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of the Service, or we are legally obligated to retain this data for longer time periods.

We store and process your personal information using third party servers located in secure data centers in the United States. This information is protected by physical, electronic and procedural safeguards in compliance with applicable U.S. federal and state regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

We utilize commercially reasonable physical, technical, and administrative security measures to help protect information under Clarrow control against loss, misuse, and alteration. For example, we use a combination of firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your online session, your personal information and to protect Clarrow accounts and systems from unauthorized access. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your Clarrow password with anyone.

If Clarrow learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Clarrow Platform, you agree that Clarrow may communicate with you electronically. Clarrow may post a notice on the website if a security breach occurs. We may also send an e-mail to you at the e-mail address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach) you should notify us.

7.     Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Clarrow will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

8.     Disclosure of Data

We may disclose personal information that we collect, or you provide:

(a)   Disclosure for Law Enforcement.

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

(b)   Business Transaction.

If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

(c)  Other cases.

Clarrow does not share your personal information with third parties for promotional or marketing purposes. We may share your personal information with:

(i)    To our subsidiaries and affiliates;

(ii)   To contractors, the Service providers, and other third parties we use to support our business;

(iii)  To fulfill the purpose for which you provide it;

(iv)  For any other purpose disclosed by us when you provide the information;

(v)   With your consent in any other cases;

9.     Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

10.  The Service Providers

We may employ third party companies and individuals to facilitate the Service (“Service Providers”), provide the Service on our behalf, perform service-related services or assist us in analyzing how the Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

11.  Analytics

We may use third-party Service Providers to monitor and analyze the use of the Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of the Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en.

We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

12.  Behavioral Remarketing

Clarrow uses remarketing services to advertise on third party websites to you after you visited the Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to the Service.

Google Ads (AdWords)

Google Ads (AdWords) remarketing the service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads.

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en.

Twitter

Twitter remarketing the Service is provided by Twitter Inc.

You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405.

You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy.

Facebook

Facebook remarketing the service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950.

To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217.

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation.

13.  Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

PayPal or Braintree:

Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full.

Stripe:

Their Privacy Policy can be viewed at: https://stripe.com/us/privacy.

Square:

Their Privacy Policy can be viewed at: https://squareup.com/us/en/legal/general/privacy.

14.  Links to Other Sites

The Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

15.  Children's Privacy

The Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

16.  How to Change your Information

You can review and update your personal information in your account settings at any time by logging in to your account. It is your responsibility to keep your personal information up to date by updating your profile in the mobile application or by contacting our Customer Support team at hello@clarrow.com. We are not responsible for costs or other issues arising from your failure to keep your personal information up to date.

We recommend that you change your password periodically or any time you have reason to believe your credentials may be compromised. You are responsible for maintaining the security of your Login ID and Password. You may not provide these credentials to any third party. If you believe that they have been stolen or been made known to others, you must contact us immediately at hello@clarrow.com, but in any event you should change your password immediately via the Service. You also agree that you control and limit access to the email account and mobile device. If your email address changes, you are responsible for informing us of that change. We are not responsible if someone else accesses your account through registration information they have obtained from you or your violation of this Privacy Policy or the Terms and Conditions.

You may request that we delete your account for the Service. To request deletion of your account, email hello@clarrow.com, requesting a deletion of your account. Merely deleting the mobile application from your device does not constitute a request to delete your account. Once your request to delete your account has been processed, we will promptly disconnect any connection we may have established to your Account Information and delete all account credentials. Please note that we may need to retain your data beyond your account deletion date as required by federal, state or local law.

17.  Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on the Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

18.  Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email: hello@clarrow.com

By visiting this page on our website: www.clarrow.com/privacy