Clever Content Privacy Policy

Posted: Sept. 3rd, 2020

Effective: Sept. 3rd, 2020

Our Privacy Policy now separately describes the information collection practices of Clever Content’s corporate website, our other owned websites, and the proprietary technology that we use to perform services for our customers.

Introduction

  1. Corporate Website at www.clever-content.com
  2. Information Collected by the Corporate Website
  3. About Personal Data
  4. About Usage Data and Tracking Data
  5. Your Choices on the Corporate Website
  6. Service Providers
  7. Transfer of Information
  8. Clever Content Technology
    1. Information Collected by Clever Content Technology About Users
    2. About Usage Data and Tracking Data
    3. User Choices for the Clever Content Technology
    4. Transfer of Information
    5. Service Providers
  9. Other Information
    1. About Data Security
    2. Links to Other Sites
    3. Children’s Privacy
    4. Recourse, Privacy Complaints by European Union and Swiss Residents: Privacy Shield
    5. How to Contact Clever Content

    Introduction

    Clever Content (legally known as LongTail Ad Solutions, Inc.) is a leading publisher monetization platform and a video generation platform (collectively, the “Clever Content Technology”). Our customers are businesses that use the Clever Content Technology to host, embed and stream, and deliver advertising to, digital video over the web (collectively, the “Clever Content Services”).

    Clever Content has prepared this Privacy Policy to describe our practices regarding the information we collect from:

    • Visitors to our website located at www.clever-content.com (the “Corporate Website”), including all subdomains,
    • Users who watch our customers’ videos on websites, apps, mobile apps, and other software powered by the Clever Content Technology (each, a “Customer Property”) using a desktop or laptop PC, mobile phone, tablet, connected TV, set-top box, kiosk, virtual reality hardware, or other device, and
    • Visitors to our other owned-and-operated websites (each, a “Clever Content Website”), including www.jwshowcase.com and tv.clever-content.com.

    This Privacy Policy does not describe the information collection practices of our customers that use the Clever Content Technology on their Customer Properties. We are a third-party service provider to our customers. We recommend that you refer to our customers’ privacy policies to learn about their information collection practices.

    Changes to this Privacy Policy. Clever Content will update this Privacy Policy to reflect changes to our practices. We will post all Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice. The Privacy Policy posted on this page will say when that version went into effect. If you visit the Corporate Website or view a video on a Customer Property after a change, then you will have accepted Clever Content’s new Privacy Policy. You are advised to review our Privacy Policy periodically for any changes.

    A. Corporate Website at www.clever-content.com

    1. INFORMATION COLLECTED BY THE CORPORATE WEBSITE

    Our Corporate Website provides information about our company, business, and the services we provide. It is also the portal used by our customers to sign into the customer dashboard for the Clever Content Services.

    The Corporate Website collects Personal Data, Usage Data, and Tracking Data when you visit the site at www.clever-content.com. As used in our discussion about the Corporate Website in this Section A:

    • “Personal Data” is the information about an individual that can be used to identify that individual. If you access the Corporate Website from the EEA, Switzerland or the UK, we use a different definition of Personal Data to comply with the General Data Protection Regulation (GDPR).

    • “Tracking Data” is the information collected by cookies and similar tracking technologies (e.g., pixel tags, web beacons, or scripts) that we use to keep track of visitor activity on the Corporate Website. (Note that the Tracking Data collected by the Clever Content Technology is different, and is discussed in Section B.)

      • Cookies are small files that contain a small amount of data, typically including a unique identifier. They are generally placed on your browser by a website or other browser-based service. Our Corporate Website uses cookies.
      • Other tracking technologies, in the context of the Corporate Website, include pixel tags, web beacons, and scripts, and are used to track usage and performance. (See Section B below for the tracking technologies used by the Clever Content Technology.)

    • “Usage Data”, in the context of the Corporate Website, is the information that your browser sends to Clever Content’s servers when you visit the Corporate Website.

    As with other Internet services, our web servers gather information automatically each time your browser or device interacts with the Corporate Website, and store that information in “log files.” The information stored in our web servers’ log files includes information that we call Personal Data, Usage Data and Tracking Data, and that we describe more fully in the following sections.

    Note for visitors who access the Corporate Website from the EEA, Switzerland or the UK:

    • Personal Data. In the EEA, Switzerland and the UK, Personal Data is defined differently than in the U.S., and means a variety of data that identifies or can identify a particular unique user or device (e.g., names, addresses, cookie identifiers, mobile device identifiers, precise location data and biometric data). For visitors who access the Corporate Website from the EEA, Switzerland, or the UK, elements of Usage Data and Tracking Data – such as a visitor’s full Internet Protocol (IP) address, and the information that we associate with a unique identifier (like a cookie or other tracking technology) – are Personal Data under the General Data Protection Regulation (GDPR).
    • Legal grounds for processing your Personal Data when accessing the Corporate Website. For visitors who access the Corporate Website from the EEA, Switzerland, or the UK, we process your Personal Data for the purposes set out in Section A.2. on one or more of the following legal grounds:
      • You provided your consent;
      • It is necessary for our contractual relationship;
      • The processing is necessary for us to comply with our legal or regulatory obligations; and/or
      • The processing is in our or a relevant data controllers’ legitimate interest, for instance, where we use data to protect the security and integrity of our systems and to provide services or other benefits.

    Note for California Residents who visit our C orporate Website(s):

    If you have provided us with your personal information (for instance, if we met you at a trade show or you sign up to receive product emails), you have certain rights as to which you may contact us directly. Please contact us at privacy@clever-content.com if you would to exercise any of the following rights under the CCPA:

    • If you would like to know the personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting your personal information (we do not sell this information); or the categories of third parties with whom we shared personal information, please contact us at privacy@clever-content.com;
    • If you would like us to delete information we have about you, please likewise contact us at privacy@clever-content.com;
    • If you would like to “opt out” of receiving marketing from us, e.g., emails about our service or product enhancements, please likewise contact us at privacy@clever-content.com;
    • If you would like to “opt out” of any ad targeting that occurs from our website(s) – for instance, if we “retarget” consumers who visit our website with an ad about a webinar or event we are holding or products we offer – please go to either the NAI opt-out portal or the DAA opt-out portal, two industry website that offer consumer choices regarding personalized advertising. This type of advertising is offered by third party service providers we may work with, most (or all) of whom are listed on the above “opt out” websites.

    2. ABOUT PERSONAL DATA

    1. Personal Data Collected by the Corporate Website. Personal Data includes your name, email address, postal address, and telephone number. It also includes any information that we have associated with your Personal Data.

      The Corporate Website collects Personal Data from you when you engage in any of the following:

      • Request information about a product or service on the Corporate Website.
      • Register on the Corporate Website for emails, newsletters or other communications.
      • As an employee or authorized agent of a Clever Content Service, use a login account on the Corporate Website to access the customer dashboard for the Clever Content Technology.

      We may combine Personal Data that you submit on or through the Corporate Website with information that we collect from and about you from other sources, offline and online.

    2. How We May Use Personal Data. We use the Personal Data that you provide on the Corporate Website for the following activities:

      • Provide the services that you request.
      • Send you administrative information, including information regarding changes to the Corporate Website’s terms, conditions and policies.
      • Personalize your experience on the Corporate Website (including through the use of cookies and similar technologies).
      • Send you messages that you request.
      • Target you to receive ads and other marketing messages from us about the Clever Content Services.
      • For our business purposes, such as data analysis, audits, developing new products, enhancing the Corporate Website, improving our services, and identifying usage trends and determining the effectiveness of our marketing.
      • As we believe appropriate (a) to comply with applicable law and legal process, including to respond to valid requests by public authorities (e.g., a court, government agency, or law enforcement), (b) to enforce our terms and conditions, (c) to prevent or investigate possible wrongdoing in connection with the Corporate Website, Clever Content Technology, Clever Content Services or the like, (d) to protect our operations or those of our affiliates, (e) to protect our rights, property, privacy, safety, or that of our affiliates, you or others, or (f) to allow us to pursue available remedies or limit the damages that we may sustain (these purposes, collectively, the “Compliance Purposes”).

    3. When We May Disclose Personal Data. The Personal Data that you provide to the Corporate Website may be disclosed:

      • Service Providers. To our third-party service providers who provide services such as hosting, data analysis, IT infrastructure, IT services, customer service, email delivery, payment processing, billing and collections, data enhancement, order fulfillment, auditing, security, fraud, and other services to enable them to provide such services. These third parties have access to your Personal Data only to perform these tasks on our behalf.
      • Transfer of Business. To a third party to which we have transferred our business, assets or stock if Clever Content is involved in a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of some or all of our business, assets or stock, including during due diligence related to any such transaction (and also including in connection with any bankruptcy or similar proceeding).
      • s we believe appropriate for Compliance Purposes.

    4. How Long We Retain Personal Data. We retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required for the security or integrity of the Corporate Website, or to comply with our legal obligations, resolve disputes, or enforce our legal agreements or policies.

    5. No Sensitive Information. Please do not disclose through the Corporate Website any sensitive Personal Data (e.g., social security numbers, detailed financial information, health information, information related to racial or ethnic origin, political opinions, religion or other beliefs, criminal background or trade union membership).

    6. ABOUT USAGE DATA AND TRACKING DATA

      1. Usage Data and Tracking Data Collected by the Corporate Website. The Usage Data and Tracking Data collected by the Corporate Website include:

        • Information collected through cookies, pixel tags and other tracking technologies.
        • Browser type and version.
        • Your Internet Protocol (IP) address.
        • If you are accessing the Corporate Website through a mobile phone, tablet, connected TV, set-top box, kiosk, virtual reality hardware, or other device: the type of device, unique device ID, device IP address, device operating system, and diagnostic data.
        • Information about how you interact with the Corporate Website, such as the date and time of your visit, the pages that you visit, and the time spent on those pages.
        • Other aggregated information.

      2. How We May Collect Usage Data and Tracking Data. Usage Data and Tracking Data are collected by the Corporate Website:

        • When your browser or device sends it. Standard information is sent by most browsers. This information includes your device type, screen resolution, operating system version, and Internet browser type and version.
        • Through web technologies. We and our service providers may use cookies, pixel tags, web beacons, and other similar technologies to, among other things, facilitate your ongoing access to and use of the Corporate Website, present you with more tailored information about our products and services, and collect and store information about your use of the Corporate Website.
        • When you volunteer it. You may volunteer demographic information, as well as other information, such as your preferred means of communication.
        • Through activity reports. Information about how you interact with the Corporate Website is collected with every visit, and is used to determine usage levels, diagnose server problems, and operate and maintain the Corporate Website.
        • By aggregating information. We may aggregate or de-identify information collected by the Corporate Website.

      3. How We May Use and Disclose Usage Data and Tracking Data. We may use and disclose Usage Data and Tracking Data collected on the Corporate Website for any purpose permitted by applicable law.

        Note: If we are required by law to treat any element of Usage Data or Tracking Data as Personal Data, then we will handle those elements as Personal Data. If we combine any Usage Data or Tracking Data with Personal Data, we will treat the combined information as Personal Data as long as it is combined.

    7. YOUR CHOICES ON THE CORPORATE WEBSITE REGARDING YOUR PERSONAL DATA

      1. Your Choices Regarding Cookies. If you do not want cookies on the Corporate Website to collect information about you, there is a simple procedure on most devices that allows you to decline the use of cookies. To learn more about cookies, please visit www.allaboutcookies.org/. However, if you choose to decline cookies, then some or all of the features, functionality and promotions available through the Corporate Website may not be available to you.

      2. How You Can Access, Change or Delete the Personal Data About You Collected by The Corporate Website. If you have a login to the Corporate Website (i.e., you are a Clever Content customer), you can log into your account to access, delete, or make changes to the Personal Data we have on file for your account.

        If you do not have a login to the Corporate Website (e.g., a prospective customer or a website visitor) and would like to access, change, or delete the Personal Data that you have previously provided to the Corporate Website, you can contact us by emailing us at privacy@clever-content.com to make the requested changes. We will comply with your request as soon as reasonably practicable. If you have requested that some Personal Data be deleted, note that we may need to retain some of the information for backup or Compliance Purposes. In addition, there could remain residual traces of the deleted Personal Data in our databases and other records. We are not responsible for changing or deleting information from the databases of third parties that have previously accessed your information.

      3. Your Choices Regarding Messaging. You may opt out from receiving marketing-related messages from us either by using the unsubscribe mechanism provided in the message or by emailing us at privacy@clever-content.com. If you opt out from receiving marketing-related messages from us, we may still send administrative messages to you. You cannot opt out from receiving administrative messages.

        You have the right to lodge a complaint with a supervisory authority as to our processing of data. However, we hope that you will first consult with us, by emailing us at privacy@clever-content.com or writing us at LongTail Ad Solutions, Inc., d/b/a Clever Content, 2 Park Avenue, 10th Floor, New York, NY 10016 so that we may work with you to resolve any complaint or concern you might have.

        The Corporate Website does not support the Do Not Track browser setting.

    1. SERVICE PROVIDERS We use third party companies and individuals to provide services and functionality for the Corporate Website. These service providers may have access to your Personal Data in order to perform tasks on our behalf (e.g., to send you information that you request or that we believe is of interest to you).

    Clever Content uses third-party advertising companies to advertise Clever Content and the Clever Content Services. We allow these service providers to use their tracking technologies on the Corporate Website so that we can target ads about Clever Content to you when you are elsewhere on the Internet. This process is sometimes referred to as interest-based advertising or online behavioral advertising. If you want more information about these third-party advertising companies, or if you wish to opt out of this type of advertising, please visit the ad industry choice mechanism at www.aboutads.info/choices/.

    6. TRANSFER OF INFORMATION. As Clever Content works with global companies and technologies, we may need to transfer your Personal Data outside of the country from which it was originally provided. This may be intra-group or to third parties that we work with who are likely located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

    Note for visitors who access the Corporate Website from the EEA, Switzerland or the UK: If we transfer Personal Data outside of the EEA, Switzerland or the UK, we will take steps to make sure that appropriate safeguards are in place to protect your Personal Data. Clever Content is Privacy Shield certified.

    B. Clever Content Technology

    1. INFORMATION COLLECTED BY Clever Content TECHNOLOGY ABOUT USERS Our customers are primarily web publishers (each, a “Customer”) that deploy Clever Content Technology on their Customer Properties to provide their visitors (each, a “User”) with a high-quality video viewing experience. In Section B, we describe the information that is collected from Users who view videos and ads on a Customer Property. The Clever Content Technology collects Usage Data and Tracking Data from Users. Note that the Tracking Technologies used in the Clever Content Technology are different from the Tracking Technologies used on the Corporate Website. 2. ABOUT USAGE DATA AND TRACKING DATA

    1. Usage Data and Tracking Data Collected by the Clever Content Technology. The Clever Content Technology collects Usage Data and Tracking Data from a User when he or she views video on a Customer Property. As used in our discussion about the Clever Content Technology in this Section B:
      “Usage Data” is the information that a User’s browser automatically sends to Clever Content’s servers when a User accesses video or sees an ad on a Customer Property. This information includes a User’s device type, screen resolution, operating system version, and Internet browser type and version.

      “Tracking Data” is the information collected by the Clever Content Technology from Users who access videos on a Customer Property, and consists primarily of the following:

      • Proprietary tracking technologies used by the Clever Content Technology for video delivery and performance reporting. These tracking technologies include the following:
        • Local ID, which is stored on a User’s computer to identify a User’s player on a given Customer Property.
        • Global ID, which is stored on a User’s browser and Clever Content’s servers and identifies a User across different players and Customer Properties. The Clever Content Technology does not assign a Global ID to Users whose Internet Protocol (IP) addresses are based in the EEA, Switzerland and the UK.
        • Viewer ID, which is stored on Clever Content’s servers to identify a User.
      • Other tracking technologies include pixel tags, web beacons, and scripts, and are used for ad delivery and reporting.

      As with other Internet services, our web servers gather information automatically each time a User’s browser or device interacts with the Clever Content Technology, and store that information in “log files.” The information stored in our web servers’ log files includes Usage Data and Tracking Data. The Usage Data and Tracking Data collected by the Clever Content Technology include:

      • Information collected through tracking technologies.
      • Browser type and version.
      • User’s Internet Protocol (IP) address.
      • Unique identifiers set by our tracking technologies to identify video players, Users, and video sessions.
      • If a User is accessing the Clever Content Technology through a mobile phone, tablet, connected TV, set-top box, kiosk, virtual reality hardware, or other device: the type of device, unique device ID, device IP address, device operating system, and diagnostic data.
      • Information about how a User interacts with the Clever Content Technology, such as the date and time of a User’s visit, the videos watched, and the time spent watching those videos.
      • Other aggregated information.

      Note for visitors who access the Clever Content Technology from the EEA, Switzerland or the UK:

        • Personal Data. As previously noted, some elements of Usage Data and Tracking Data – for example, a visitor’s full Internet Protocol (IP) address, and the information that we associate with a unique identifier (like a cookie or other tracking technology) – are Personal Data under the General Data Protection Regulation (GDPR), and we treat those elements as Personal Data when collected by the Clever Content Technology from Users whose IP addresses are based in the EEA, Switzerland or the UK. Note that the Clever Content Technology does not assign a Global ID to a User accessing the Clever Content Technology from an EEA, Swiss or UK IP address. We will retain those elements of Usage Data and Tracking Data that are Personal Data under the GDPR for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required for the security or integrity of the Clever Content Services or Clever Content Technology, or to comply with our legal obligations, resolve disputes, or enforce our legal agreements or policies.
      • Legal grounds for processing Personal Data on Customer Properties. For Users who access the Clever Content Technology from IP addresses in the EEA, Switzerland, or the UK, we process the elements of Usage Data and Tracking Data that are considered Personal Data under the GDPR. The GDPR makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process Personal Data on behalf of other organizations (known as “data processors”). When we handle Personal Data strictly on behalf of our customers in order to provide our services to them, as is the case with the Clever Content Technology, we are a data processor and our customers, as the data controllers, have primary responsibility for your Personal Data and are responsible for obtaining a legal basis to collect such data. If you have questions about Personal Data that is used primarily by a Customer Property on which the Clever Content Technology is embedded or utilized, you should contact those companies with your questions about how they handle your Personal Data.

        With that in mind, if you have concerns about Clever Content, you may contact our privacy officer, at privacy@clever-content.com.

        **Note for California Residents who visit our Customer Properties** Similar to the above, when our technology is employed on a website (or a mobile property or other service), we generally act as a “service provider” to the website provider for purposes of the California Consumer Privacy Act – i.e., providing them services to help them display, curate and/or integrate content shown through our player technology. Thus, if you If you have questions about personal information collected or used by a Customer Property on which the Clever Content Technology is embedded or utilized, you should contact the particular website or content provider that you are engaging with. (If you have questions about information that we collect when you visit our Corporate Website(s), please go to SectionA(1).
    2. How We May Use Usage Data and Tracking Data. We use Usage Data and Tracking Data collected by the Clever Content Technology for the following purposes:
      • Deliver video to Customer Properties, and ads on behalf of advertisers.
      • Recommend videos that a User may enjoy.
      • Prepare reports and analytics for our customers.
      • For our other business purposes, such as data analysis, identifying usage trends, diagnosing technical problems, operating, maintaining, enhancing and improving the Clever Content Technology and Clever Content Service, and developing new products and services.
      • As we believe appropriate for Compliance Purposes.
    3. When We May Disclose Usage and Tracking Data. We may disclose Usage Data and Tracking Data collected by the Clever Content Technology for the following purposes:
      • Service Providers. To third-party service providers who provide services such as hosting, data analysis, IT infrastructure, IT services, customer service, auditing, security, fraud, and other similar functions to us or our Customers. These third parties have access to User Usage and Tracking Data to perform these tasks on our behalf.
      • Transfer of Business. To a third party to which we have transferred our business, assets or stock in the event that Clever Content is involved in a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of some or all of our business, assets or stock, including during due diligence related to any such transaction (and also including in connection with any bankruptcy or similar proceeding).
      • As we believe appropriate for Compliance Purposes.

    3. USER CHOICES FOR THE Clever Content TECHNOLOGY

    1. For Users who access the Clever Content Technology from the EEA, Switzerland, and the UK: The Do Not Track Browser Setting. Certain versions of the Clever Content Technology support Do Not Track for Users in the EEA, Switzerland, and the UK. Do Not Track is a preference Users can set in their web browser to inform websites that they do not want to be tracked. Users can enable or disable Do Not Track by visiting the Preferences or Settings page of their web browser. We make reasonable efforts to maintain compatibility between our technology and Do Not Track functionality across different web browsers. However, you should be aware that, despite our reasonable efforts, there may be circumstances in which a particular Do Not Track setting is not recognized and honored.

      Note that even if a User enables and Clever Content recognizes Do Not Track, the Clever Content Technology will continue to collect Usage Data about each visit to a Customer Property, because Usage Data are automatically sent by the User’s web browser. However, the Usage Data will not be associated with a unique identifier, and the Clever Content Technology will not be able to associate such User Data collected with User.

    2. Check Our Customers’ Privacy Policy. Users interact with the Clever Content Technology, because our Customers have implemented the Clever Content Technology in their Customer Properties. We recommend that Users check the privacy policy of the Customer Properties that they visit for information about the user choices available from our Customers. Many Customer Properties use third-party advertising companies for interest-based advertising or online behavioral advertising. If you want more information about these third-party advertising companies, please visit the ad industry choice mechanism at www.aboutads.info/choices/.

    4. FOR USERS WHO ACCESS THE Clever Content TECHNOLOGY FROM THE EEA, SWITZERLAND, AND THE UK: TRANSFER OF INFORMATION. See Section A.6 for information regarding those elements of Usage Data and Tracking Data that are Personal Information under the GDPR. 5. SERVICE PROVIDERS. We work with third parties that provide services and functionality for the Clever Content Technology. These service providers may have access to Usage Data and Tracking Data of the Clever Content Technology in order to perform tasks on our behalf. Occasionally, we may give our service providers explicit permission to use the Usage Data or Tracking Data to enhance the fraud-detection, security, or other features of their services. 2. SERVICE PROVIDERS. We use third-party advertising companies to facilitate advertising on the videos served. We allow these service providers to use their tracking technologies so that ads appear on a Video . If you want more information about these third-party advertising companies, please visit the ad industry choice mechanism at www.aboutads.info/choices/.

    D. Other Information

    1. ABOUT DATA SECURITY. Clever Content employs security measures to prevent the loss, misuse or alteration of information collected by the Corporate Website, Clever Content Websites, and Clever Content Technology. However, no data transmission over the Internet or data security system can be guaranteed to be 100% secure. 2. LINKS TO OTHER SITES. Our Corporate Website, Clever Content Websites, and Clever Content Technology may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. 3. CHILDREN’S PRIVACY. The Corporate Website, Clever Content Websites, and Clever Content Technology are not targeted to anyone under the age of 13 (“Child”). We do not knowingly collect Personal Data from anyone under the age of 13, unless agreed in writing with a particular Customer. If we know that the Personal Data we have collected is from or about a Child, we place that Personal Data in a separate category for restrictive handling. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from a Child without verification of parental consent, we will take steps to remove that information from our servers. 4. RECOURSE, PRIVACY COMPLAINTS BY EUROPEAN UNION AND SWISS RESIDENTS: PRIVACY SHIELD. Clever Content complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States, respectively. Clever Content has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. Clever Content is subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to our adherence to Privacy Shield. If Clever Content transfers Personal Data received from the European Union or Switzerland to a third party acting as its agent, it remains responsible for how that Personal Information is processed – which means that it will remain liable under the Privacy Shield Principles if any third party acting as its agent processes your Personal Information in a manner that is inconsistent with the Privacy Shield Principles, unless it can prove that it was not responsible for the event giving rise to the damage. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov. You have the right to access your Personal Data; for information about the choices and means Clever Content offers individuals for limiting the use and disclosure of their Personal Data, please see Section A.2.g above. In compliance with the EU-US and Swiss-US Privacy Shield Principles, Clever Content commits to resolve complaints about your privacy and our collection or use of your Personal Data. In the hope that we can resolve any complaints or questions that you have in a fair an amicable way, we ask that European Union and Swiss individuals with inquiries or complaints regarding this privacy policy first contact us via email at: privacy@clever-content.com. Clever Content has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

    E. How to Contact Clever Content

    If you have any questions about this Privacy Policy, please contact us at:
    privacy@clever-content.com