I. Overview
Clartt has developed this Privacy Policy to explain how we may collect, retain, process, share and transfer your Personal Data when you visit our website or use our services. This Privacy Policy applies to your Personal Data when you visit our website or use services, and does not apply to online websites or services that we do not own or control, including websites or services of other Clartt users. This Privacy Policy is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our website and services.
Please contact us if you have questions about our privacy practices that are not addressed in this Privacy Policy.
II. What Personal Data Do We Collect?
We may collect information about you when you visit our Site or use our Services, including the following:
Registration and use information: When you register to use our Services by establishing an Account, we will collect Personal Data as necessary to offer and fulfill the Services you request. Depending on the Services you choose, we may require you to provide us with your name, country, email address and other identification information to establish an Account. We may require you to provide us with additional Personal Data as you use our Services.
Transaction and experience information: When you use our Services or access our Site, for example, to make payments to merchants, to receive money, or to send money to friends and family, we collect information about the transaction, as well as other information associated with the transaction such as amount sent or requested, amount paid for products or services, merchant information, including information about any funding instruments used to complete the transaction, Device Information, Technical Usage Data, and Geo-location Information.
Participant information: When you use our Services or access our Site, we collect Personal Data you provide us about the other participants associated with the transaction.
Send or request money: When you send or request money through our Services, we collect Personal Data such as name, country, email address, other means of identification and financial account information about the participant who is receiving money from you or sending money to you. The extent of Personal Data required about a participant may vary depending on the Services you are using to make transactions.
III. Why Do We Retain Personal Data?
We retain Personal Data to fulfill our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your Account is suspended, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Privacy Policy.
IV. How Do We Process Personal Data?
We may Process your information for the following reasons:
To operate the Site and provide the Services, including to initiate a payment, send money, add value to an account; authenticate your access to an Account; communicate with you about your Account, the Site, the Services, or Clartt; create an account connection between your Account and a third-party account or platform; and perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes.
To manage our business needs, such as monitoring, analyzing, and improving the Services and the Site’s performance and functionality. For example, we analyze User behavior and perform research about the way you use our Services.
To manage risk and protect the Site, the Services and you from fraud by verifying your identity, and helping to detect and prevent fraud and abuse of the Site or Services.
To provide personalized Services offered by Clartt on third-party website and online services. We may use your Personal Data and other information collected in accordance with this Privacy Policy to provide a targeted display, feature or offer to you on third-party website. We may use cookies and other tracking technologies to provide these online services and/or work with other third-parties such as advertising or analytics companies to provide these online services.
To comply with our obligations and to enforce the terms of our Site and Services, including to comply with all applicable laws and regulations.
We will respond to your requests, for example to contact you about a question you submitted to our customer service team.
V. How Do We Use Cookies and Tracking Technologies?
When you visit our Site, use our Services, or visit a third-party website for which we provide online Services, we and our business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”) to recognize you as a User and to customize your online experiences, the Services you use, and other online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Site and Services. Certain aspects and features of our Services and Site are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Site and Services may be limited or not possible.
Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not respond to DNT signals.
Please review our Statement on Cookies and Tracking Technologies to learn more about how we use Cookies.
VI. What Privacy Choices Are Available To You?
You have choices when it comes to the privacy practices and communications described in this Privacy Policy. Many of your choices may be explained at the time you sign up for or use a Service or in the context of your use of a Site. You may be provided with instructions and prompts within the experiences as you navigate the Services. Choices Relating to the Personal Data We Collect Personal Data. You may decline to provide Personal Data when it is requested by Clartt, but certain Services or all of the Services may be unavailable to you.
As regards Location and other device level information. The device you use to access the Site or Services may collect information about you, including Geolocation Information and User usage data that Clartt may then collect and use.
For information about your ability to restrict the collection and use of such information, please use the settings available in the device.
VII. How Do We Protect Your Personal Data?
We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current.
VIII. Can Children Use Our Services?
The Site and Services are not directed to children under the age of 15. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Site and Services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of 15, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 15.
IX. What Else Should You Know?
Changes to This Privacy Policy: We may revise this Privacy Policy from time to time to reflect changes to our business, the Site or Services, or applicable laws. The revised Privacy Policy will be effective as of the published effective date.
If the revised version includes a substantial change, we will provide you with 30 days prior notice by posting notice of the change on the “Policy Update” page of our website. We also may notify Users of the change using email or other means.
X. Contact Us
You may contact us if you have general questions about our Privacy Policy and practices or questions about your Account information or Personal Data. We want to make sure your questions go to the right place.
XI. Definitions
Account means a Clartt member account.
Geolocation Information means information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. Some of our Services may ask you for permission to share your current location. Some of the Site and Services require this information to provide a specific product or online Service. If you do not agree to our collection of the geolocation information, our Site or Services may not function properly when you try to use them.
Guest Transaction means a person’s use of the Services without logging into and/or establishing an Account.
Clartt means Technology LTD. and subsidiaries or affiliates. In this Privacy Policy, Clartt is sometimes referred to as “we,” “us,” or “our,” depending on the context.
Personal Data means personal information that can be associated with an identified or identifiable person. “Personal Data” can include name, telephone number, email address, payment card number, other financial account information, account number, date of birth, and government-issued credentials (e.g., driver’s license number, national ID, passport, Social Security number and Taxpayer ID). Personal Data does not include information that does not identify a specific User.
Process means any method or way that we handle Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, disseminating or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data.
Services means any products, services, content, features, technologies, or functions, and all related website, applications and services offered to you by Clartt in connection with an Account or Guest Transaction.
Site means the website, mobile apps, official social media platforms, or other online properties through which Clartt offers the Services and which has posted or linked to this Privacy Policy.
Technical Usage Data means information we collect from your phone, computer or other device that you use to access the Site or Services. Technical Usage Data tells us how you use the Site and Services, such as what you have searched for and viewed on the Site and the way you use our Services, including your IP address, statistics regarding how pages are loaded or viewed, the website you visited before coming to the Site and other usage and browsing information collected through Cookies.
User means an individual who uses the Services or accesses the Site and has established a relationship with Clartt (for example, by opening an Account and agreeing to the Clartt User Agreement) or otherwise uses the Services as a Sender, Receiver or other type of participant to a transaction, including a Guest Transaction.
WHAT DOES CLARTT DO WITH YOUR PERSONAL INFORMATION?
Financial companies choose how they share your personal information. Federal law gives Why? Consumers give the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We collect your personal information, for example, when you open an account or provide account information.
How does Clartt collect my personal information?
When you use your credit or debit card or give us your contact information.
When you use your Clartt account to send or receive funds.