Privacy Policy

This privacy policy (”Privacy Policy”) governs how we, Clear Value Ltd. (”Clear Value” ”we”, ”our” or ”us”) use Personal Information (defined below) that we collect, receive and store pertaining to you (”User”, ”you”) in connection with the following use cases:

When you browse or visit our website, (https://claritus.io) (“Website”)

When you make use of, or interact with our platform which is available through our Website and mobile application (”Platform”).

When you sign up for an account or login to our Platform
When you make use of the platform for its intended use (e.g., to view your financial information and to gain insights into such information)
The Website together with the Platform is referred to herein as the ”Services”.

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Information.

This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below. If there will be any significant changes made to the use of your Personal Information in a manner different from that stated at the time of collection, we will notify you by posting a notice through our Services or by other means.

  1. INTRODUCTION

    We have implemented this Privacy Policy because your privacy, and the privacy of other users, is important to us. This Privacy Policy explains our online information practices and the choices you can make about the way your Personal Information is collected and used in connection with the Services. “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address, a home or other physical address, or other contact information.

  2. TERMS OF USE

    This Privacy Policy forms part of our End User License Agreement which is available at https://claritus.io/terms (“Terms”). Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms.

  3. You are not legally obligated to provide us Personal Information, and you hereby confirm that providing us Personal Information is at your own free will. By using the Services, you consent to the terms of this Privacy Policy and to our collection, processing and sharing of Personal Information for the purposes set forth herein. If you do not agree to this Privacy Policy, please do not access or otherwise use the Services. We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy on our Website and/or Platform, and your continued use of the Services thereafter means that you accept those changes.

  4. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
    Information we collectWhy is the Information collected and for what purposes?Third parties with whom we share your InformationConsequences of not providing the Information
    When you browse or visit our Website
    Cookies, analytic tools and log filesMarketing, analytics and statistics3rd party platforms such as for the following purposes:
    • Google Analytics (analytics tool)
    • Facebook Pixel (analytics)
    • Intercom
    • AWS (cloud)
    Cannot access certain Website and Platform features may not be available
    When you sign up for an account or login to our Platform
    • Full name
    • Email address
    • Any other information you choose to share with us (such as your asset allocation)
    • To create an account
    • To login to the Platform
    • To enjoy features available to registered users of the Platform
    3rd party platforms such as for the following purposes:
    • Intercom (support)
    • Google Analytics (analytics tool)
    • Facebook Pixel (analytics)
    • AWS (cloud)
    • Cannot create an account
    • Cannot login to the Platform
    • Cannot enjoy all the features available on the Platform
    • Full name
    • Email address
    To send marketing communications including regular email updates and emails relating to transactions3rd party platforms such as for the following purposes:
    • Sendgrid (to send regular email updates or emails relating to transactions)
    • Google Analytics (analytics tool)
    • Facebook Pixel (analytics)
    • AWS (cloud)
    Cannot send you marketing communications including regular email updates and emails relating to transactions
    When you make use of the Platform for its intended use (e.g., to view your financial information and to gain insights into such information)
    • Full name
    • Email address
    • Any other information you choose to share with us (such as your asset allocation)
    • To create an account
    • To login to the Platform
    • To enjoy features available to registered users of the Platform
    3rd party platforms such as for the following purposes:
    • Envestment Yodlee (link accounts (bank and brokerage) and process financial information)
    • Google Analytics (analytics tool)
    • Facebook Pixel (analytics)
    • AWS (cloud)

    Finally, please note that some of the abovementioned Personal Information will be used for fraud detection and prevention, and for security purposes.

  5. HOW WE PROTECT AND STORE YOUR INFORMATION
    1. Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. 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. Retention of your Personal Information. We shall retain your personal information until we no longer need it and proactively delete it or you send a valid deletion request. Without derogating from the foregoing, in some circumstances we may store your Personal 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, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.

  6. HOW WE SHARE YOUR PERSONAL INFORMATION

    In addition to the recipients described in Section 4, we may share your information as follows:

    • To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
    • If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. 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 or assign Personal Information in connection with the foregoing events.
    • Where you have provided your consent to us sharing the Personal Information (e.g., where you provide us with marketing consents or opt-in to optional additional Services or functionality); and
    • Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.

    If you want to receive the list of recipients of your Personal Information, please make your request by contacting us to privacy@claritus.io

  7. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION
    • We will use your Personal Information to provide and improve our Services, to send you marketing/advertisement communications that we believe may be of interest to you, to contact you in connection with the Services and certain programs or offerings that you may have registered for, and to identify and authenticate your access to the parts of the Services that you are authorized to access.
    • We may use your designated email address to: (i) send you updates or news regarding the Services and our products; and/or (ii) respond to a “Contact Us” or administrative request (for example, to change your password).
    • We may transfer your Personal Information to our local or foreign subsidiaries or affiliated companies for the purpose of storing or processing such information on our behalf. Such information may be transferred to other countries (including US). We require that these parties agree to process such information in compliance with our Privacy Policy.
    • We may share your Personal Information with our third party service providers and partners, but only to assist us with our business operations and to provide our Services to you and other users. Such information may be transferred to other countries. We use commercially reasonable efforts to only engage or interact with third party service providers and partners that post a privacy policy governing their processing of Personal Information.
    • We may disclose your Personal Information or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our Terms, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of Clear Value, our users, yourself or the public.
  8. USE BY CHILDREN

    We do not offer our products or Services for use by children. If you are under 18, you may not use the Services. We do not knowingly collect information from, and/or about children.

  9. HOW CAN I DELETE MY ACCOUNT?

    Should you ever decide to delete your Account, you may do so by emailing help@claritus.io. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.

  10. The Platform enables you to view your financial information as retrieved from third party financial institutions that you have chosen, as may be available in the Platform from time to time. Without derogating from any provision in our End User License Agreement, we are not responsible for the privacy practices of such financial institutions.

    The Platform may enable you to interact with or contain links to your Third Party Account and other third party websites 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 may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

  11. LOG FILES

    We make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the Services, track users’ movement around the Services, and gather demographic information.

  12. COOKIES AND OTHER TRACKING TECHNOLOGIES

    Our Services utilizes “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide our Services and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Services. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

  13. ANALYTICS TOOLS
    • Google Analytics. The Services uses a tool called “Google Analytics” to collect information about use of the Services. Google Analytics collects information such as how often users visit our Services, what pages they visit when they do so, and what other sites they used prior to coming to this Services. We use the information we get from Google Analytics to maintain and improve the Services and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to our Services is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes Information specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your Information from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

    • Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.

  14. ACCESS/ACCURACY

    To the extent that you do provide us with Personal Information, we wish to maintain accurate Personal Information. If you would like to delete or correct any of your other Personal Information that we may be storing, you may submit an access request by sending an email to help@claritus.io. Your email should include adequate details of your request.

  15. CALIFORNIA PRIVACY RIGHTS

    California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to help@claritus.io. Please note that we are only required to respond to one request per customer each year.

  16. OUR CALIFORNIA DO NOT TRACK NOTICE

    We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party web sites or online services. 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

  17. CONTACT US

    If you have any questions, concerns or complaints regarding our compliance with this notice and the Information protection laws, or if you wish to exercise your rights, we encourage you to first contact us at help@claritus.io.

Last updated: April 12, 2020