Global Privacy Policy

Effective Date: December 1, 2023
At CleverTone, we develop technology and services to help you reclaim your time and improve your overall sense of well-being and balance. To do this, we learn about your goals and priorities, take care of the things you don’t have time for, and give you time to focus on the things that matter most. Your trust in us, including the privacy and security of your Personal Data, stands at the center of our commitment to you. For purposes of this privacy policy (the “Privacy Policy”), “Personal Data” means any information relating to an identified or identifiable natural person, and in any event, as defined by applicable law.

CleverTone, a Vekser, Inc. company and a Florida corporation, with its principal place of business at 514 N. California Ave. Beaumont CA 92223; is the controller of your Personal Data. For information about joint use, please refer to the “Joint Use of Your Data” section in the Addendum.
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Scope
Here we explain how and why we collect, store, handle, and share your Personal Data when you use our websites, mobile applications, software, products, and services (collectively, the “CleverTone Services” or “Services”). We also outline the controls and choices you have around when and how you choose to share your Personal Data. This Privacy Policy applies to site visitors, job applicants, and consumer users of the Services.
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Revisions to the Privacy Policy‍
We may revise this Privacy Policy from time to time to reflect changes to our Services or legal, regulatory, or operational requirements. If we make a material change, we will provide advance notice (e.g., by email) before such changes go into effect. If you object to any changes, you may stop using our Services. Your continued use of our Services after any changes go into effect indicates your acknowledgment and acceptance of those changes.
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What Information We Collect
When you use our Services, we collect the following types of Personal Data about you to provide, protect, improve, and promote our Services:
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* Account information: We collect information that you provide when you do things like sign up for an account, purchase a subscription, and set up two-factor authentication, such as your name, email address, phone number, and physical address.
* Payment Information: If you sign up for a CleverTone Services subscription or request a to-do that requires paying a third party, we may request payment information from you, such as credit card type, certain digits of your card number, expiration date, and billing address. We use Stripe as our payment processor, so Stripe will store any payment information you provide. However, we may obtain limited information about your payment card from our payment processor, such as the last four digits, the country of issuance, and the expiration date. Stripe uses and processes your payment information in accordance with Stripe’s Privacy Policy.
* Information you voluntarily provide: You may voluntarily provide certain information to us when you use the Services. For instance, when you send to-do’s to your CleverTone Specialist, you may provide information needed to execute on your to-do’s, such as your budget, preferences, names of friends or family, or relevant timelines, photos, or videos. You may also choose to enable certain settings or permissions on your device, such as access to the camera or photo library, to use certain features of the Services. You may also voluntarily provide information about yourself when you contact us for support or when you apply for a job with us.
* Information you allow others to provide us: If you direct us to reach out to third parties to help execute on a to-do, we may collect information about you from those third parties as well. For example, if you ask your CleverTone Specialist to arrange to pick up an order you placed with a third party, we may collect information regarding your order details from that third party in the course of executing that to-do.
* Contact information: You may choose to share your contacts with us to make it easier for your CleverTone Specialist to help you with your to-do’s – for example, send invites to birthday parties, send holiday cards, etc. If you do, we’ll store those contacts on our servers for you to use.
* Interactions with your CleverTone Specialist: To better understand your personal goals, priorities, and preferences and help execute your to-do’s, we collect and record your interactions with your CleverTone Specialist, including in-app chats, voice and video calls, SMS messages, as well as any photos, videos, or other media you share with your CleverTone Specialist. If you direct your CleverTone Specialist to reach out to others to help you execute on a to-do, we will collect and record those interactions as well. We’ll use this information to personalize our Services to your specific needs, including training our algorithms to allow us to execute on your to-do’s more efficiently.
* Product usage information: We collect information about the way you use our Services, such as actions you take in your account and the way you use our website and mobile app. We use this information to do things like diagnose and troubleshoot issues with our Services, as well identify ways to improve our Services.
* Cookies and other tracking technologies: We use tracking technologies like cookies, web beacons, and pixel tags (together, “cookies”) to provide, improve, protect, and promote our Services. For example, cookies help us remember your preferences, understand how you interact with our Services, and improve them based on that information. We may also use third-party service providers - e.g. payment processors - who set cookies and similar technologies to when you are on our Services or on other devices, apps, websites, or in the emails you may receive from them. You can learn more about how cookies and other tracking technologies work, as well as how to exercise control over cookies in our Cookie Policy.
* Device information: We collect information from and about the devices you use to access our Services. This includes things like IP addresses, operating system, the type of browser and device you use, language settings, and identifiers associated with your device.
* Location information: We may derive information about your location based on your IP address and use it to provide and protect our Services. For example, we use your location information to determine whether our Services are available in your area.
* Third Parties: We may also obtain information about you from third parties, including for instance: Corporate Affiliates (as defined below), joint marketing partners, lead providers, and fraud and risk mitigation vendors.

How We Use Your Personal Data
‍We may use your Personal Data for the following purposes:
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To provide and personalize our Services: We use your Personal Data to provide and personalize our Services (i.e., to fulfill our contractual obligations to you). For example, we use your payment information to process your subscription payments, as well as any payments you make to third parties in connection with a to-do. We also use and analyze your information to tailor our Services to your specific needs, such as personalizing the content and features you see when using our Services, training our CleverTone Specialists to better support you and other subscribers, and developing our algorithms to help us execute on to-do’s more efficiently.
* To understand, troubleshoot, and fix issues with our Services: We may use your Personal Data – such as feedback you provide or bugs that you report to us – to identify and troubleshoot issues and make sure our Services are working properly.
* To evaluate and develop new features, technologies, and improvements to our Services: We use your Personal Data to better understand how you use our Services and to develop new features and technologies that we think might benefit you or other users. For example, we may use your Personal Data to conduct research into what features you and other members would like to see in our Services.
* To communicate with you: We use your Personal Data to communicate with you, provide customer service, respond to your communications and requests, and contact you about your use of our Services. For example, your CleverTone Specialist may send you messages or other notifications about the status of your to-do’s. We may also contact you about changes to your account, such as confirmation of payment, upcoming subscription renewals, or cancellations.
* To promote our Services: We will occasionally send you news about features, upgrades, and promotional offers related to our Services that may be of interest to you. These communications may be by various methods, including email, in-product notifications, and push notifications. Please see the “Your preferences and privacy rights” section below to learn how to set or change your communications preference.
* To protect you, others, and our business: We use your Personal Data to protect you, others, and our business, including (a) detecting, investigating, and preventing spam, fraud, and other abusive behavior; (b) enforcing our Terms of Service and other policies; and (c) protecting our systems from malware and other security risks.
* To comply with our legal obligations and law enforcement requests: Our Services are subject to certain laws and regulations which may require us to process your Personal Data. For example, we may process your Personal Data to fulfill our contractual obligations with third parties; establish, exercise, or defend legal claims; or respond to requests from law enforcement.
* To further our legitimate business purposes: We may also use your Personal Data to further our legitimate interests and business purposes, such as conducting business planning and analysis, auditing, reporting, and forecasting.
* To carry out your instructions: We may also use your personal data for other purposes to which you have consented.

Limits on Use of Your Google User Data: Notwithstanding anything else in this Privacy Policy, if you provide CleverTone access to your Google Calendar data, our use of that data will adhere to the Google API Services User Data Policy and will be subject to these restrictions, as required by Google:
* We will only use our access to read, write, or modify your Google Calendar data to perform the specific services that you request from us (for example, scheduling or canceling an event on your calendar, looking for free time on your calendar), and we will not transfer the Google Calendar data to others unless doing so is necessary to perform such services, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
* We will not use this Google Calendar data for serving advertisements.
* We will not allow humans to read the Google Calendar data unless doing so is necessary to perform the services or tasks that you’ve requested of our specialists or guides, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for our internal operations and even then only when the data have been aggregated and anonymized.
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Thanks for your interest in sharing your photo with CleverTone.
As we commented, we love your image and want to share it with the world. But first, we need your permission to use your photo in this way. Please review the terms and conditions below. If you agree with the fine print, respond to our request with #CleverToneRepost.
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Grant to CleverTone
By responding to our request with the hashtag #CleverToneRepost, you hereby grant to CleverTone and Vekser Inc., its affiliates, subsidiaries, franchisees, advertising and promotional agencies, and their agents and representatives (collectively, “CleverTone”), the irrevocable, unrestricted, royalty-free worldwide right to use, publish, display, broadcast, edit, modify and distribute any materials, content, illustrations, photos, videos, comments, or information relating to the Photo (hereinafter, “Material”), including those bearing your name, voice, image, likeness, and/or any other identifiable representation of yourself (collectively, “Your Likeness”). These Materials may appear in any form, style, color or medium whatsoever now known or later developed (including, without limitation, photographs, videotapes, films, sound recordings, software, drawings, prints, broadcast, in-store displays, internet, email, catalog and electronic media).
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Warranties and Representations
By responding to our request with the hashtag #CleverToneRepost, you warrant and represent that: (a) you are the author of the Material and own all rights to use it or, alternatively, have the right to grant us the rights described above; (b) you have paid or will pay in full any fees or other payments that may be related to the use of the Material; (c) the Material does not infringe upon the copyrights, trademarks, rights of privacy, publicity or other intellectual property or other rights of any person or entity; (d) publication of the Material via various media including Web posting, will not infringe on the rights of any third parties; (e) you have obtained permission from all persons whose name, voice, image, likeness and/or any other identifiable representation are included in the Material. You will indemnify and hold harmless CleverTone from any claims to the contrary.
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Reservation of Rights
CleverTone reserves the right to alter, change or modify the Material, in its sole discretion. You hereby waive any right you may have to inspect or approve the finished materials or any part or element thereof that incorporates Your Likeness.
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Acknowledgment and Agreement
By responding to our request with the hashtag #CleverToneRepost, you hereby acknowledge and agree to the above in consideration of the opportunity given to you by CleverTone to appear or have your Material appear in our promotional materials. You acknowledge that you have fully read and understand this document and that you have had any questions regarding its effect or the meaning of its terms answered to my satisfaction. You certify that you are at least 18 years of age.
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Who We Share Your Data With
We may share your data with the following third parties to provide, protect, improve, and promote our Services:
* CleverTone service providers: We may share your Personal Data with third-party service providers working on behalf of CleverTone to do things like provide customer support, IT services, and payment processing.
* CleverTone Partners and third-party merchants: To help execute on your to-do’s, we may share your data with third-party service providers (“CleverTone Partners”) or merchants. For example, if you need your dishwasher replaced, your CleverTone Specialist may share your information with a CleverTone Partner who can deliver and install the new machine in your home. Or if you ask your CleverTone Specialist to purchase goods on your behalf – for example, tickets to a concert, or decorations for a birthday party – we will share your data with third-party merchants to fulfill your request. Remember that we will share your data only to help execute on a to-do you’ve requested, and we’ll keep the sharing proportionate to the needs of the to-do. Note that the third-party CleverTone Partner or merchant’s handling of your information will be governed by their own terms and privacy policy.
* Other users of the Services: If you choose to provide feedback about a CleverTone Partner or CleverTone Specialist, we may share your feedback with other Services users so that they can make more informed decisions about who they choose to work on their to-do’s. We may also share aggregated data about how you and other users have used the Services so that others can understand trends in user activity.
* Advertising partners: We work with advertising partners to deliver more relevant ads and promotional messages to you related to our Services, which may include interest-based advertising, contextual advertising, and generic advertising displayed on other websites or services. In doing so, we may process and share your Personal Data with our advertising partners to evaluate the effectiveness of our own advertising and deliver ads that are more relevant to your interests or preferences.
* Law enforcement and the public interest: We may disclose your data to third parties if we determine, at our sole discretion, that such disclosure is reasonably necessary to: (a) comply with a legal obligation under applicable law or respond to valid legal process or appropriate government request; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of CleverTone, the Services, or other members; (d) protect CleverTone’s rights, property, safety, or interest; or (e) perform a task carried out in the public interest.
* Corporate Affiliates of CleverTone: CleverTone shares infrastructure, systems, and technology with its Corporate Affiliates to provide, improve, protect, and promote our Services. “Corporate Affiliate” means a company or other business entity that is controlling, controlled by, or under common control with CleverTone. We reserve the right to share your data with our Corporate Affiliates for these purposes, as permitted by applicable law and in accordance with their terms and policies.
* Parties in connection with a corporate transaction: We will share your Personal Data with third parties in connection with a corporate transaction, such as a merger, sale of all or a portion of company assets or shares, reorganization, change of control, or acquisition of all or a portion of our business by another company. In the event of a corporate transaction, CleverTone will continue to ensure the confidentiality of your Personal Data and will give you reasonable notice before your Personal Data is shared with a third party or becomes subject to a different privacy policy.
* With your consent: There may be circumstances where we will share information about you with third parties at your request.
* With your employer: If you sign up for the CleverTone Services as a benefit or perk through your employer, CleverTone will share certain information about you with your employer, including your name, email address, when you activated your subscription, as well as aggregated information about how you and other employees at your company use the Services. This allows your employer to understand how employees are utilizing the CleverTone Services through an employer-sponsored or subsidized program. Note that we will not share with your employer information about specific to-do’s that you request through the Services, or information about your or your family’s preferences.
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We may also use your Personal Data to generate de-identified and/or aggregated data, which we may use and share for any lawful purpose. For example, we may share your Personal Data on a de-identified or aggregated basis with CleverTone Partners, CleverTone business partners, and academic researchers so they can understand general trends about our Services and its users.
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Retention And Deletion Of Your Data
We will retain your Personal Data until you request deletion. Please note that we may retain some information if necessary to comply with our legal obligations, prevent fraud, assist in investigations, resolve disputes, enforce our agreements, or pursue legitimate business purposes.
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Transfer to Other Countries
To provide you with our Services and carry out the activities specified in this Privacy Policy, we may store, process, and transmit data in the United States and globally – including places outside your country. Your Personal Data, therefore, may be subject to privacy laws that are different from those in your country.
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Children
Our Services are not intended for children under 13 years of age, and we do not knowingly collect Personal Data from children under 13. If you are a parent or guardian of a child under 13 and become aware that your child has provided Personal Data to us without your consent, you may review and request deletion of your child’s Personal Data by contacting CleverTone at privacy@CleverTone.com. If we learn that we have collected Personal Data from a child under 13, we will take reasonable steps to delete that Personal Data.
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Your Preferences and Privacy Rights
You can control how you receive the following communications from us:
* Email marketing: You can stop receiving marketing emails from us by clicking on the “unsubscribe” link provided at the bottom of each marketing email, or by opting out of them on your Account Settings page. Note that you may not opt out of services-related emails (e.g., information about your subscription, orders, changes to your account, updates to our Terms or this Privacy Policy, and technical and security notices).
* Text messages: By providing your mobile phone number to request our Services, you consent to receiving transactional, informational, and account-related text messages from us and acknowledge that you are responsible for all messaging and data charges that may apply. You can opt out of receiving text messages from us by following the instructions in individual text messages or by contacting CleverTone directly at privacy@CleverTone.com.
* Cookies: You can disable the use of cookies by modifying your browser settings, but note that this may limit your ability to use our Services. Due to a lack of an agreed upon standard for interpreting Do Not Track (DNT) signals, our systems currently do not respond to DNT signals from browsers visiting our websites. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others. You can find information on how to exercise control over cookies in our Cookie Policy.

What are Cookies?
Cookies are small text files placed in browsers or on devices that help websites, mobile apps, and service providers recognize you and remember things about you, such as your preferences or your past usage of the services. Other technologies – such as pixel tags, web beacons, local storage, and advertising identifiers – perform similar functions. We refer to all these technologies as “Cookies” for ease of reference.

How does CleverTone Use Cookies?
Like many online service providers, we use Cookies, including third party Cookies, to provide, protect, improve, and promote our Services. Our use of Cookies falls into the four following categories:
* Operationally-necessary cookies: These types of cookies are essential in order to operate our Services. They allow you to access and make use of our Services, applications, and tools, such as keeping you logged in, identifying irregular website behavior, preventing fraudulent activity, and improving security.
* Performance-related cookies: These types of cookies are used to assess the performance of our Services and help us understand how users engage with our Services so we can improve and customize your experience.
* Functionality-related cookies: These types of cookies allow us to offer you enhanced functionality when accessing our Services. For example, they help identify you when you sign into our Services or keep track of your specified preferences, interests, or past items viewed.
* Advertising- or targeting-related cookies: These types of cookies are used by us and our partners to better understand your preferences and interest in our Services. We and our partners use this information to deliver content and advertisements that are relevant to your interests on our Services as well as third-party websites.

‍Your Choices
You can control the data collected through Cookies in a number of ways:
* Browser settings: You can set your browser not to accept cookies, though this may limit your ability to use our Services. Many browser extensions also provide features that create transparency and choice around Cookies on the web. Please note that, due to a lack of an agreed upon standard for interpreting Do Not Track (DNT) signals, our Services do not currently respond to DNT signals from browsers.
* Mobile Identifiers: Most mobile device operating systems allow you to restrict the use of certain device identifiers for targeted advertising. Additionally, some mobile operating systems allow you to reset or rotate the advertising identifier associated with your device. You can find more information on how to opt out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.
* Self-regulatory: The online advertising industry also provides websites from which you may opt out of receiving targeted ads from marketers and advertising technology companies that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative and the Digital Advertising Alliance. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.
* Google Analytics: You can opt-out of having your site activity available to Google Analytics by installing the Google Analytics opt-out browser add-on.
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Interest-based advertising: You can visit the Network Advertising Initiative’s Consumer Opt-Out link, or the Digital Advertising Alliance’s Consumer Opt-Out link to opt out of receiving tailored advertising from companies that participate in these programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ad Settings page. Please note that if you choose to opt out, you may still see advertisements from us, but these ads will not be as relevant to you.
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Mobile device notifications: We may send you push notifications through our mobile app. You may opt out of receiving these notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile app. You may opt out of this collection by changing the settings on your mobile device.
You may also have a right to control your Personal Data and how it’s collected, used, and shared. In accordance with applicable law, you may have the following rights:
* The right to access or know: the right to be informed of, and request access to, Personal Data we process about you.
* The right to rectification: the right to request that we amend or update your Personal Data where it is inaccurate or incomplete.
* The right to erasure: the right to request that we delete your Personal Data.
* The right to restrict processing: depending on the processing activity, you have a right to ask that we stop processing all or some of your Personal Data.
* The right to object: depending on the processing activity, you have a right to ask that we stop or limit processing your Personal Data.
* The right to take your data elsewhere: the right to request a copy of your Personal Data in electronic format and transmit it for use with another service provider.
* The right to withdraw your consent: the right to withdraw previously-given consent.
If you would like to exercise your rights over your Personal Data, please reach out to CleverTone at privacy@CleverTone.com. Note that we may require additional information to verify your identity and may deny your request if we’re unable to do so.
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Third Party Websites and Services
Our Services may contain links to websites and services that are owned or operated by third parties. CleverTone is not responsible for the privacy practices or content of such websites and services. Any Personal Data you provide to these third-party websites and services is at your own risk.
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Security
We implement reasonable physical, technical, and organizational measures designed to help safeguard your Personal Data against loss, theft, unauthorized access, use, and modification. However, please note that no system is ever completely secure, and we cannot guarantee the security of our systems 100%.
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Questions
If you have any questions about this Privacy Policy, please contact us at privacy@CleverTone.com or by mail at: CleverTone, 78 SW 7th Street, Miami Fl. 33130