Privacy Policy

Cloto, Inc. (the “Company”, “we”, “us”, “our”) is always committed to protecting the privacy of users/guests and their personal information (unrelated to business designation and affiliation) in its possession and adheres to applicable privacy laws.

Application

The undermentioned privacy policy outlined is an overview of our privacy procedures regulating the oversight of our Product(s) and Service(s) but inapplicable to personal information related to current, past or present contractors or employees of Cloto, Inc.

Opt-out Process

We may collect, use, disclose and retain personal information for the following purposes:

• to open and maintain an account with us;
• to offer and provide licenses, products and services;
• to process orders for products/services;
• to process payments;
• to carry out customer surveys, in order to evaluate the needs, wants and satisfaction levels of our customers and to analyze and manage our business;
• to provide and administer services and monitor your purchases, fees paid and payable, payment history, parties to transactions, payments and payment card usage;
• to verify your identity as an authorized user concerning any accounts, and to implement, carry out and maintain security measures aimed at protecting our customers from identity theft, fraud and unauthorized access to accounts;
• to comply with legal or regulatory requirements (including those related to security);
• to promote and market products and services offered by us;
• to provide for the purchase and license to online products/services for purchase;
• to respond to inquiries from you;

Except as required for the foregoing, or as required or permitted by applicable law, Cloto does not disclose personal information to third parties without your prior consent.

Information collected when you use the site

In certain circumstances the personal information we collect and maintain may include:

• your name, address, telephone number, email address or other information to contact or identify you;
• information about the goods or services provided to or by you;
• information about your transactions with us, including bills, credit history, payment preference, billing and credit card information, and other details and preferences;
• information from communications with you, including your feedback and requests for customer care;
• where required by law to do so;
• site activity information and cookies (see below)
• location information of your mobile device when any one of our Apps is open on your device
• voluntary information provided by you, which may include reviews and ratings, referrals, special order instructions, feedback, and other actions performed on the Website or App

Consent

If you choose to voluntarily submit personal information to us, we will consider that you have consented to our collection, use and disclosure of this personal information for purposes reasonably related to your providing the information and for the purposes set out in this Policy.If you choose to voluntarily submit personal information to us, we will consider that you have consented to our collection, use and disclosure of this personal information for purposes reasonably related to your providing the information and for the purposes set out in this Policy.Where we use the services of third parties in our business they may provide us with your personal information. In such a situation, we will make reasonable efforts to have such parties assure us that this provision of your information is permitted.Subject to the above, we will usually ask for your consent when we collect your personal information. Sometimes this may happen after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not disclosed in this Policy or elsewhere to you, we will make efforts to let you know about that purpose before use or disclosure. We may utilize the services of third-party service providers and third-party independent courier contractors. We may share your information to facilitate the Service. This may include sending emails or text notifications, processing payments, placing orders, sending delivery instructions, and providing superior customer service. We require that our third-parties commit to use this information for the sole purpose of fulfilling the Service.You may modify or revoke your consent at any time, with reasonable notice, subject to applicable laws and contracts signed by you, by sending a written message to our Privacy Officer. In some circumstances, a modification or revocation of consent may limit or prevent us from providing products or services to, or acquiring products or services from you. We assume, unless you tell us otherwise, that by continuing to deal with us after having had this Policy made available to you that you consent to the collection, use and disclosure of your personal information as set out and for the purposes described in this Policy, where such consent is required by law.

Use of Cookies

What are Cookies?: we use a browser feature called a cookie to collect information anonymously and track user patterns on the site. A cookie is a small text file that is placed on your hard disk by a web site and contain a unique identification number that identifies your browser, but not you, to our computers each time you visit the site. Cookies tell us which pages of our web site are visited and by how many people. The information that cookies collect includes the date and time of your visit, your registration information, session identification number, and your navigational history and preferences.

How to refuse cookies: The use of cookies is an industry standard and many major browsers are initially set up to accept them. You can reset your browser to either refuse to accept all cookies or to notify you when you have received a cookie. However, if you refuse to accept cookies, you may not be able to use some of the features available on the site.

Third-party cookies: Some third-party services providers may use cookies on our site. We have no control over those cookies and they are not covered by this privacy policy. Cookies allow us to identify registered users when they return to the site, eliminating the need for you to repeatedly enter the same information.

Accuracy and Completeness

When we collect, use or disclose personal information, we will make reasonable efforts to ensure that it is accurate, up to date, and complete. This may involve requesting further information or updates from you. We do request that you advise us of changes to your personal information so that our records may remain current.

Retention and Destruction

The law allows us, for legal or business purposes, to retain personal information for as long as is reasonable. Upon expiry of an appropriate retention period, bearing in mind reasonable legal and business requirements, personal information will either be destroyed in a secure manner or made anonymous. You should be aware that there may be legally required minimum retention periods, which we must and do observe.Should any consent, where consent is required, to our collection, use, disclosure or retention of personal information be revoked, the law also allows us to continue to retain the information for as long as is reasonable for legal or business purposes. In the event that revocation of any required consent may have consequences to the individual concerned, we will advise the individual of the consequences of revoking their consent where it is reasonable in the circumstances to do so.

Security of Personal Information

We recognize our legal obligations to protect personal information collected during the course of carrying on business. We have therefore made reasonable arrangements to secure against the unauthorized access, collection, use, disclosure, copying, modification, disposal, or destruction of personal information. All interactions with our services use the Transport Layer Security/Secure Sockets Layer (TLS/SSL) protocol. We use a third-party, industry-accepted Payment Gateway to securely process credit card transactions.

Other Websites

Please note that our website and our online services may contain links to other websites which are provided as a convenience for visitors to our website or users of our services only. Any third party websites will have their own privacy policies and practices, and we cannot be responsible for such third parties or their websites.

Requests for Access to Personal Information

The law permits individuals to submit written requests to us to provide them with:

• access to their personal information, if any, under our custody or control;
• information about the purposes for which their personal information under our custody or control has been and is being used by us; and
• the names of persons or entities to whom, and the circumstances in which, their personal information has been and is being disclosed by us.

We would also note that your ability to access your personal information under our control is not absolute and we reserve all our legal rights to not disclose personal information should we be of the view that it is not appropriate or reasonable to do so.

Responses to Requests for Access to Personal Information

Our response to requests for access to personal information will in all cases be in writing, and will confirm whether we are providing all or part of the requested information, whether or not we are allowing access or providing copies, and, if access is being provided, when that will be given.If access or copies are refused by us, we will provide written reasons for such refusal and the section of The Personal Information Protection and Electronic Documents Act on which that refusal is based, along with the name of person at Cloto who can answer questions about the refusal, and particulars of how the requesting individual can ask the Information and Privacy Commissioner of Canada to review our decision.

Requests for Correction of Personal Information

The law permits individuals to submit written requests to us to correct errors or omissions in their personal information where that information is in our custody or control. We do require that all such requests be in writing, with no exceptions, and email is not considered to be in writing. We reserve the right to require sufficient information and detail from the individual in question in order to properly locate the information and provide a response.In the event that an individual alleges inaccuracies, errors or omissions in the personal information in our custody or control, we will either:

• correct the personal information and, if reasonable to do so, send correction notifications to any other organizations to whom we disclosed the incorrect information; or
• decide not to correct the personal information but annotate the personal information that a correction was requested but not made.

Corrections or amendments will not be made to opinions, including expert or professional opinions, as opposed to factual information, which may be corrected if in error.

Amendment of Policy

We reserve the right to amend this Policy from time to time as required and without notice by posting an amended version on our website.

Contacting or Communicating with Us

If you have any questions with respect to our policies concerning the handling of your personal information, or if you wish to request access to, or correction of, your personal information under our care and control, please contact us at: admin@cloto.ca.

Our Corporate Address: