This privacy policy applies between you, the user of this Website and ClevPicks, the owner and provider of this Website. ClevPicks takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website. Please review this Privacy Policy before you use the Website or any of the services or features offered on or through the Site. By using the Website and its services and features, you agree to be bound by this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Site or its services and features.

1. Information Collected

ClevPicks may collect certain personal information from you when you register to use the Website or its services and features. We may also collect additional personal information, including your physical address, in order to deliver products. We may also collect certain non-‐personally identifiable information from users of our site, such as their Internet protocol address, the type of browser and operating system they use, the domain name of your Internet service provider, and the web pages, content and advertisements you may have visited, viewed or clicked on. We collect this information in several ways, including the following:

• Web Server Logs: Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent at this site, and the websites visited just before and just after our site.

• IP Addresses: Our system may also collect your IP address, which is a numerical address that is used to identify a computer connected to the Internet. We may use your IP address to help diagnose problems with our server, to administer our site, to deliver web pages to you upon request, to tailor our site to the interests of our users, and to measure traffic within our site.

• Public Posting: If you post in the comments of a blog post on the Website (or anywhere on social media), you should be aware that any information you share is visible to other users. Personally identifiable information you submit to one of these forums can be read, collected, or used by other individuals to send you unsolicited messages. ClevPicks is not responsible for the personally identifiable information you choose to submit in these forums. For example, if you choose to make information, which was previously non‐public, available by enabling certain user features, (such as blog comments) ClevPicks will collect that information from your interaction and the information will become publicly available.

2. Our Use of Data

Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

a) internal record keeping.

b) improvement of our products/services.

c) in each case, in accordance with this privacy policy.

d) We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).

e) We may use your Data to show you ClevPicks adverts and other content on other websites. If you do not want us to use your data to show you ClevPicks adverts and other content on other websites, please turn off the relevant cookies.

3. Keep Data Secure

3.1 We will use technical and organizational measures to safeguard your Data, for example:

a) access to your account is controlled by a password and a user name that is unique to you.

b) we store your Data on secure servers.

3.2 Technical and organizational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorized access to your Data, please let us know immediately by contacting us at [email protected].

4. Data Retention

4.1 Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfill the purposes outlined in this privacy policy or until you request that the Data be deleted.

4.2 Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

5. Your Rights

5.1 You have the following rights in relation to your Data:

a) Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

b) Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.

c) Right to erase – the right to request that we delete or remove your Data from our systems.

d) Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.

e) Right to data portability – the right to request that we move, copy or transfer your Data.

f) Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.

5.2 To make inquiries exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us at [email protected]

5.3 If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.

5.4 It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.