Last Updated: December 13, 2022
Table of contents:
1.What information we collect, why we collect it, and how it is used
2.How we protect and retain your Personal Information
3.How we share your Personal Information
6.Interaction with third party products
8.Specific provisions applicable under California privacy law
Clyr’s Services is intended to create a leading expense management solution to help business owners manage their business expenses efficiently.
1.WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
(i)We Process the Following Personal Information:
a.Information You Provide Directly to Us. We collect the following information you provide directly to us:
1)When you register and make use of our Services:
In certain cases, we may request access or permission to certain features from your mobile device, including your mobile device’s calendar, contacts, SMS messages, and other similar features. If you wish to change our access or permissions, you may do so in your device’s settings.
If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and log-in process.
When you instruct us to connect to and integrate the Services with your existing third party financial institutions, such as accounting platforms, bank accounts and credit cards, among others (“Financial Institutions”), we may receive information that includes, amongst others: the name of the account holder and the associated account number, your bookkeeping data and records, transactions data, bank account feeds, and any other information shared with us by you and/or the Financial Institutions directly or via third party service providers.
2)When you are browsing and making use of our Website, we collect the information submitted by you to the website forms including, without limitation, full name, email address, phone number, comments and messages (including, support requests or any other contact us or chat communication/conversation) and any other personal information you submit or provide us with.
b.Information from Other Sources.
3)Automatic Data Collection. We may automatically collect certain information through your use of the Services via cookies, pixel tags, local storage, and other technologies (“Technologies”), when you visit, use or navigate the Services and/or the Website. This information is primarily needed to maintain the security and operation of our Services and the Website, and for our internal analytics and reporting purposes. See below further information:
i.Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Services and/or the Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Services and/or the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
ii.Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Services and/or the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
iii.Location Data. We may allow third parties to collect your IP address and to give us the location data (such as information about your device’s location), which will be only on a country and state level.
4)Lead generation. Clyr may also obtain information about you from other sources, including publicly – or commercially- available information, and through third-party data platforms, partners, marketing events, conferences and service providers.
(ii) We process information for the following purposes:
a.To provide you with Services. We will use the information, including, without limitation, for the following purposes: (i) allow you to create an account; (ii) to provide you with the Services and to process your requests; (iii) share your information with our partners and and/or third parties involved in the Services (for example, cloud providers) as well as with partners (e.g., to offer you specific benefits or programs); (iv) communicate with you about your use of the Services and for support purposes; (v) fulfill any instruction and/or request made by you in the context of the Services (vi) track transactions conducted by you; (vii) send you push notifications regarding your account or certain features of the Services; (viii) send you more information about our products, services and offerings; (ix) to personalize your experience with our Services; (x) to allow you to connect to and integrate the Services with your Financial Institutions ; and (xi) to generally administer the Services. We may also use your information to contact you about incomplete applications or other forms and submissions available through the Services.
b.For administrative purposes. Clyr may use your information (i) to respond to your questions, comments, and other requests for customer support, or information, including information about potential or future services; (ii) for internal quality control purposes, including, troubleshooting; (iii) to establish a business relationship; (iv) to generally administer Services; (v) for our internal analytics; (vi) reporting purposes; and (vii) to request feedback and contact you about your use of the Services; and (viii) to post testimonials on our Services that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at [email protected] and be sure to include your name, testimonial location, and contact information.
c.To market the Services. Clyr may use information to market the Services. Such use includes (i) notifying you about offers and services that may be of interest to you; (ii) tailoring content, advertisements, and offers for you, including, targeting and re-targeting practices; (iii) conducting market research; (iv) developing and marketing new products and services, and to measure interest in Persona’s services; (v) other purposes disclosed at the time you provide information; and (vi) as you otherwise consent;
d.Security purposes. Some of the abovementioned information will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; and for security purposes. Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims, including, without limitation, to enforce our rights and your obligations under the relevant agreement of the Services.
e.De-identified and aggregated information use. In certain cases, we may or will anonymize or de-identify your Information and further use it for internal and external purposes, including, without limitation, to analyze and improve Clyr services (including through the use of artificial intelligence) and for research purposes. We may use this anonymous or de-identified information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them and/or to develop new product features and improve existing offerings).
f.Cookies and Similar Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services may use Technologies to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Services. If you would like to opt out of the Technologies we employ on the Services, you may do so by blocking, deleting, or disabling them as your browser or device permits.
(iii) Transaction Data via Fidel – Collection, Use, and Monitoring:
a. Transaction Monitoring. By registering a payment card in connection with transaction monitoring, you authorize Persona to share your payment card information with the Payment Card Networks so it knows you are enrolled and participating in Persona. You authorize the Payment Card Networks to monitor transactions on your registered card(s) in order to enable your usage of real-time transaction data for all transactions made on an enrolled card linked through the Persona Platform. You may opt out of transaction monitoring on the payment card(s) you have registered by navigating to your settings menu to remove your linked card(s).
- Allow companies and users to view, track and annotate transactions on cards that belong to them for the purpose of tracking and managing personal and business expenses in order to assist and save time when performing tasks such as matching transactions with receipts and reconciling the books.
- To create a record of the transaction data and thereafter maintain and use data in connection with operating the Platform;
- To provide information in order to respond to a request from a government authority or a payment organization involved in a transaction with you or a merchant. You authorize the sharing, exchange, and use of transaction data described above and herein by and among Persona and Persona’s Third Party Service Providers and applicable Payment Card Networks.
2. HOW WE PROTECT AND RETAIN YOUR PERSONAL INFORMATION
2.1. Security. We have implemented and maintain reasonable technical, organizational and security measures designed to protect your information. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
2.2. Retention of your information. Your information will be stored until we delete our records, and we proactively delete it, or if you send a valid deletion request. Please note that in some circumstances we may store your information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your information or dealings.
3. HOW WE SHARE YOUR PERSONAL INFORMATION
We may share your information as follows:
3.3.The information Clyr gathers is shared with our partners and other third parties related to the provision of our Services. We may also share information with our affiliated companies about you.
3.4.We use third-party service providers to process your information for the purposes outlined above, including, without limitation:
3.4.1.With cloud service providers for hosting purposes;
3.4.2.With websites and web content creation platforms in order to help us manage our Website;
3.4.3.With email providers, marketing, CRM, and other similar tool providers;
3.4.4.With analytic companies, in order to help us understand and analyze the information we collect in accordance with this policy;
3.4.5.With Financial Institutions, in order to help us offer streamlined expense management services; and
3.5.To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations, and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory, and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Persona, our Services, customers, employees, property, and the public.
3.6.If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your information in connection with the foregoing events.
3.7.Where you have otherwise provided your consent to us for sharing or transferring your information.
4.YOUR PRIVACY RIGHTS
4.8.Rights: You can exercise your rights by contacting us at [email protected]. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we need further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
4.9. Deleting your account: Should you ever decide to delete your account, you may do so by emailing [email protected]. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.
4.10. Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject “BLOCK” to [email protected]. Please note that the email must come from the email account you wish to block OR if you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt. Please note that we may still communicate with you, for example, to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes
5. USE BY CHILDREN. We do not offer our products or services for use by children and, therefore, we do not knowingly collect information from, and/or about children under the age of 18. If you are under the age of 18, do not provide any information to us without the involvement of a parent or a guardian. In the event that we become aware that you provide information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at [email protected].
6. INTERACTION WITH THIRD PARTY PRODUCTS. We enable you to interact with third party websites, mobile software applications and products or services that are not owned, or controlled, by us (each, a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.
7. ANALYTIC TOOLS/COOKIES
• Through our Services we may allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. We may allow access to other data collected by the services to share information that may be useful, relevant, valuable or otherwise of interest to you.
• We reserve the right to remove or add new analytic tools, cookies, pixels and other tracking technologies.
8. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW
8.11.California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]. Please note that we are only required to respond to one request per customer each year.
8.12.Our California Do Not Track Notice: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, but we may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.
8.13.Deletion Of Content From California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. To remove, please send an email to [email protected],io. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
9. CONTACT US. If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at [email protected].