Clicki Privacy Policy Version 1.4 Effective Date: 01/01/2024

Introduction

At Clicki, Inc. ("Clicki", "we", "us", or "our"), we recognize that privacy is fundamental to building trust with our users. This Privacy Policy outlines how we collect, use, share, and safeguard the personal information of individuals using our referral marketing platform. We operate in accordance with various data protection laws, including:

• The General Data Protection Regulation (GDPR): Protects the privacy of individuals in the European Union (EU) and the European Economic Area (EEA).

• The California Consumer Privacy Act (CCPA): Grants California residents specific rights regarding their personal information.

• The Personal Information Protection and Electronic Documents Act (PIPEDA): Canada's federal privacy law governing the collection, use, and disclosure of personal information.

Scope

This Privacy Policy applies to the following groups of individuals:

• Promoters: Those who sign up for Clicki's platform to participate in referral marketing campaigns.

• Businesses: Local businesses partnering with Clicki to execute promotional campaigns.

• Website Visitors: Individuals who browse the Clicki website without registering as Promoters or initiating business relationships.

Definitions

• Personal Information (or Personal Data): Any information that relates to an identified or reasonably identifiable individual. This includes, but is not limited to, names, email addresses, physical addresses, IP addresses, geolocation data, financial information, and unique identifiers.

• Processing: Any operation or set of operations performed on personal data, including collection, storage, use, disclosure, transfer, or deletion.

Types of Information Collected

We collect the following types of personal information:

• Promoters:

  • Identifiers: Name, email address, phone number, physical address, IP address.

  • Financial Information: Payment details (processed securely through third-party providers), earnings history.

  • Geolocation Data: Precise location if agreed upon to verify campaign participation within specified areas.

  • Commercial Information: Clicks, leads, campaign participation history.

• Businesses:

  • Business Contact Information: Name, email, phone number, business address.

  • Commercial Information: Campaign details, content preferences, budget, radius specifications.

• Website Visitors:

  • Technical Data: IP address, browser type, device information, pages visited, time spent on site.

  • Cookies & Tracking: We use cookies and similar technologies to analyze website usage and provide personalization. Please see our Cookie Policy for details on managing these technologies.

How We Collect Information

• Directly from You: You provide information when registering as a Promoter, creating a Business account, filling out forms, participating in campaigns, or contacting Clicki support.

• From Business Partners: We receive necessary information from Businesses to facilitate campaigns, verify clicks, and process rewards.

• Automatically: Usage data is collected as you engage with the Clicki platform. Cookies and similar technologies are employed (with your consent where required by law).

How We Use Your Information

We use your personal information for the following purposes:

• Core Platform Functionality:

  • Connecting Promoters with relevant Campaigns.

  • Processing payments and rewards to Promoters.

  • Facilitating communication between Promoters and Businesses.

  • Administering accounts and providing customer support.

  • Monitoring campaign performance and effectiveness.

• Service Improvement & Analytics:

  • Internal analysis to enhance our services and understand platform usage patterns (excluding sharing for external marketing purposes).

• Personalization (with Consent): To tailor your experience on the Clicki platform (only with your explicit consent).

• Direct Marketing (with Opt-Out): To send you updates, new opportunities, and relevant Clicki-related communications. You will always have the right to opt out of these communications.

• Security & Fraud Prevention: To detect and mitigate fraudulent activity, abuse, and security threats on the platform, protecting Clicki, Promoters, and Businesses.

• Legal Compliance: Where necessary, to comply with applicable laws, tax regulations, respond to legal requests, or protect the vital interests of Clicki or any person.

How We Share Your Information

We may share your personal information in the following limited circumstances:

Service Providers: We engage trusted service providers to assist in operating our platform and providing services such as payment processing, analytics, cloud hosting, and customer support. These providers have access to your information strictly on a need-to-know basis and are contractually bound to protect it.

• Businesses (Essential Data Sharing): We share necessary information with the Businesses you engage with for the purpose of campaign execution, click verification, and reward processing.

• Legal Obligations: We may disclose your information where we believe in good faith that it's necessary to:

  • Comply with legal process, court orders, or subpoenas.

  • Protect the rights, property, or safety of Clicki, our users, or the public.

  • Enforce our Terms of Service.

• Business Changes: In the event of a merger, acquisition, reorganization, or sale of Clicki assets, your information may be transferred as part of the transaction, subject to standard confidentiality and data protection provisions.

Data Security

We prioritize the security of your personal information and implement the following measures:

• Technical Safeguards: Encryption in transit and at rest, firewalls, vulnerability scanning, secure data centers, and access controls.

• Organizational Measures: Employee training on data privacy, incident response protocols, and limited access to personal information.

• Regular Reviews: Periodic security assessments and ongoing improvement of our security posture.

• No Guarantees: While we strive to protect your information, remember that no system is entirely immune to security risks. In the event of a data breach, we will promptly notify affected users and relevant authorities as required by law.

Your Privacy Rights

Depending on your location and applicable laws, you may have the following privacy rights:

General Rights

• Access & Portability: You can request a copy of your personal information held by Clicki and, where feasible, receive it in a structured, machine-readable format.

• Rectification: You have the right to correct inaccurate personal information about you.

• Erasure (Right to be Forgotten): Under certain conditions, you may request that we delete your personal information.

• Restriction of Processing: You can request that we temporarily or permanently cease processing some or all of your personal information.

• Objection & Withdrawal of Consent: You may object to certain uses of your data, including direct marketing. Where processing is based on consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing prior to withdrawal.

GDPR-Specific Rights

The GDPR grants individuals in the EU and EEA additional rights, including:

• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority if you believe your data privacy rights have been violated.

CCPA-Specific Rights

The CCPA provides California residents with the following rights:

• Right to Know: You can request details about the specific pieces of personal information we collect, use, disclose, and, under certain circumstances, "sell" (as broadly defined under the CCPA).

• Right to Delete: You may request that we delete your personal information, subject to certain exceptions.

• Right to Opt-Out of "Sale": If Clicki is deemed to "sell" personal information under the CCPA, you have the right to opt-out of such "sale".

• Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

Children's Privacy

Clicki's services are not intended for children under the age of 13 (or 16 in certain jurisdictions). If you are a parent or guardian and believe Clicki has collected information from a child in our audience, please contact us immediately at [insert privacy email address] so we can delete it.

Do Not Sell My Personal Information (CCPA)

[Insert a clear statement about whether or not Clicki engages in what CCPA considers the "sale" of information. If applicable, provide a prominent "Do Not Sell My Personal Information" link and a clear opt-out mechanism.]

International Data Transfers

Where Clicki transfers personal information outside your jurisdiction, we implement safeguards to ensure an adequate level of protection. These mechanisms may include Standard Contractual Clauses approved by regulatory bodies or other approved legal frameworks.

Cookie Policy

Clicki uses cookies and similar tracking technologies. A detailed Cookie Policy [provide a link], outlines the types of cookies used, their purposes, and how you can manage your preferences.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy to reflect changes in our practices, services, or applicable laws. Significant updates will be communicated via email or noticeable website postings. Please review the Effective Date at the top of this Policy for the most recent version.

Contact Us

If you have questions, concerns, or requests related to your privacy, please contact us at: growth@clicki.io