Clear invest LTD Applications
[Last Modified: May 31, 2019]
Clear invest LTD. (together with its subsidiaries, affiliates, employees, officers and directors, as applicable – collectively “Company” or “we” or “us” or “our“) is a mobile-driven company that provides a kid-safe environment and family-friendly designated products and mobile technology and other child friendly mobile applications (collectively “App(s)” and together with the features and services provided therein shall be defined as the “Services”).
Where you sign up for any of our Services, we process personal data in order to perform our contract with you;
If we have a legitimate interest in processing data, such as for direct marketing or online identifiers when you access our Website or interact with our Services, subject to applicable law provisions; or
We will also process personal data where you have provided us with consent to do so.
order to use certain features of the KID Mode App, you as parent will
be requested to create a designated Parent Clear
By creating an Account, you provide your consent to the collection,
use and disclosure of your child’s Personal Information as
any time you do not want you or your child to be bound by these
terms, you must deactivate your Account by emailing your request
uninstalling the App from your mobile device. You represent and
warrant that you are solely responsible for maintaining the
confidentiality of your Account details and password, and for any and
all activity made under the Account. You represent and warrant that
you will not provide inaccurate, misleading or false information to
and that you will provide only your own or your child’s
information. Following the creation of your Account, you will be able
to access your designated dashboard, activate parental controls to
your preference and view certain child usage information (some
features will require payment).
During Registration, and subject to applicable legal requirements, the parent will be requested to provide consent to the processing of the child’s Personal Information related to the child’s use of the App (as detailed herein). Following which, a verification email will be sent to the email address provided through registration. The parent will be required to follow the instructions detailed in the verification email and activate the Account within the period defined therein (“Pending Period”). In the event the parent does not activate the Account within the Pending Period, the Account will be blocked until the parent either requests to resend the verification email and subsequently activates the account, or chooses to proceed solely as a guest (meaning, some features will not be available). In this latter case, the parent account and all child profiles under the parent account will be removed from the Clear invest LTD database and all user activity information previously collected will be deleted and no additional data will be collected for that user.
In either event, following the Pending Period, Clear invest LTD will cease to collect any information related to the specific user’s use of the App. In addition, in the event the parent does not activate the Account within the given time period even after having requested a new verification email and parent does not choose to proceed as a Guest, in other words, there is no user activity at all for this account, Clear invest LTD will delete the Personal Information related to the child’s use of the App. The Account will remain Active until either User chooses to use Clear invest LTD as a Guest or Parent requests to close Account.
We may collect different categories of information from you, either Personal or Non-Personal Information (as defined below) depending on the nature of your interaction with the Services, all as detailed below.
The first type of information is non-identifiable information that may be made available or gathered through your use of the Services; to clarify, we are not aware of your identity based on such information (“Non-Personal Information”). The Non-Personal Information that is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information such as: device brand, screen size, UDID, type of operating system, type of device, language preference, the time and date you access our Services, your actions within our Services (e.g., registration, pages viewed, etc.), the URLs from which you were directed to our Services, search queries within our Services, etc., and approximate geo-location (Country).
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Personal Information includes information voluntarily provided by you as well as certain identifiers, such as Internet Protocol (“IP”) addresses, or mobile advertising identifiers – Google Advertising ID and Apple IDFA (“Identifiers”). Note that the Identifiers are considered “Personal Information” in many jurisdictions (such as the EEA, as well as under COPPA), thus, Clear invest LTD treats Identifiers as such and complies with applicable laws. With regards to our use of Identifiers and your ability to opt-out of such data collection, please see the table below (under Identifiers), as well the “mobile opt out” provision below.
You are not required by law to provide us with certain Personal Information. You can always refuse to provide certain Personal Information; however, you acknowledge that such refusal may prevent you from engaging in certain activities on the Website or Services.
In the event we combine Personal Information with Non-Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
The table below details the information we collect, why we collect it and how we use it:
Type of Information
How Do We Use It?
To use KID Mode App and related services, you as parent will be required to create an Account. During the registration flow you will be requested to provide us with a valid email address as well as choose your Account’s designated parent password.
We will use this information for the purpose of performing our contract with the parent, provide the requested Services, and designate the Account through which you will be able to access the dashboard and use the tools provided therein. We will also use the email address in order to send the parent needed information related to our Services and additional occasional promotional communications related to the Services, as well as verify your identity.
To create the child(ren)’s “KID Profile” you as parent will be requested to provide your child’s gender, first name and birth month and year.
We will use such information to personalize the child’s experience, including providing direct access to third-party apps and content that we find to be appropriate and relevant for the child, based on age and language.
If you contact us for support or other inquiries through any means of communication available in our Services you will be required to provide us with a valid email address and may provide us with your name.
We will use this information solely for the purpose of responding to your inquiries directly on a one-time basis and providing you with the support you have requested.
If you voluntarily subscribe to our newsletter you will be asked to provide us with a valid email address. You can unsubscribe at any time using the unsubscribe option within the body of the newsletter or by contacting customer support at [email protected].
We will use the email address in order to send the information related to our Services and to keep you up to date regarding new Products, related news, updates, etc.
We will use the Identifiers we collect for two purposes: (i) our Apps incorporate advertisements presented through our Clear invest LTD SDK (which is designated for children). Thus, we use the Identifiers to target the applicable advertising campaign (for example, to enable ad frequency capping); Note that, we do NOT use any Personal Information collected, including Identifiers (e.g., Google Advertising ID and Apple IDFA) for profiling (e.g., behavioral advertising) or cross device tracking. Ads served are solely contextual (e.g., if the User is interacting with a painting app, we will present advertisements related to painting); please see the “mobile opt-out” provision below; and (ii) maintaining or internally analyzing the functioning of our Services.
In any event, we use the Identifier solely for internal support purposes and/or in compliance with COPPA regulations.
Approximate GEO location data
We will use this information solely to determine the user’s country to provide applicable content and target advertising campaign.
Prior to the KID Mode App installation process, you will be requested to provide access permission to your device’s Camera, Storage, Phone Use, and Microphone Use.
Access is required to use certain features of the Services such as to enable the child to use the camera through the KID Mode App and to use Voice Search feature. We will NOT save nor collect any voice records or any photos stored on the device. As part of our child-safe environment, we need to access Phone Use to block children’s use.
Prior to the KID Mode App installation process, you will be requested to provide permission to access the list of applications installed on your device.
We will use this information solely for the purpose of recommending you content you do not have already as well as to create a safer environment for your child and display only child-appropriate apps and content.
We also collect certain technical Non-Personal Information (as detailed below) that relates to your use of the Services, the amount of time you spent viewing certain portions of the Services, etc.
We use this technical Non-Personal Information for the purpose of: (i) our legitimate interests of operating, providing, maintaining, protecting, managing, customizing and improving our Apps and Services and the way in which we offer them; (ii) providing you with your child’s content usage information through the dashboard; (iii) enhancing the experience with the Services; (iv) our legitimate interests of auditing and tracking usage statistics and traffic flow, and detecting fraud, security or technical issues in connection with the Services; (v) perform research, for analytical and statistical purposes, to improve our Services.
Should we need to collect additional Personal Information other than the Personal Information detailed above, we will send a parent an applicable request and obtain consent prior to collection, if required under applicable law.
We may use data in an aggregated, non-specific format for analytical purposes. This information is anonymous and will not be linked to any Personal Information. We may share such statistical information with our partners, without restriction.
Depending on the nature of your interaction with the Services, Clear invest LTD may collect information as follows: (I) Automatically – Clear invest LTD collects information automatically transmitted from the device; (ii) Provided by you voluntarily – meaning, if and when you choose to provide us with information such as through a registration process, newsletter registration, contact us communications, etc.
We may integrate our Clear invest LTD Software Developer Kit (“SDK”) into the Apps to serve third-party child-appropriate advertisements. As detailed above, we do NOT use any Personal Information collected for profiling. For more information, which details the types of information collected by our SDK or when you use our Website.
In addition, our Website (through which you are able to access your parent Account and the dashboard) may include cookies that might include your IP address, such as:
Google Analytics: The Google Analytics cookie is placed to track and analyze the use of our Services, for internal analytic purposes. To learn more about how Google uses data from our use of Google Analytics Cookies, we recommend that you review Google’s policies located at:google.com/policies/privacy/partners. We also encourage you to review Google Analytics currently available opt-outs for the web tool available at: https://tools.google.com/dlpage/gaoptout/
at: https://legal.hubspot.com/privacy-policy. We use Hubspot technology to provide and perform our direct marketing services.
at: https://mailchimp.com/legal/privacy/. We use Mailchimp technology to provide and perform our direct marketing services.
We do not disclose, share, sell, rent or otherwise distribute any of your or your child’s Personal Information with or to any independent third parties unless as specified herein:
Authorized Disclosures – we may disclose Personal Information to third parties when you consent to a particular disclosure. Please note that once we share your information with another third party, that information becomes subject to the other third party’s privacy practices.
Law Enforcement related disclosure – we may be required to share information (including Personal Information) collected if the information is required by law to prevent, investigate, or take action regarding illegal activities, situations involving potential threats to physical safety, rights, property or of any person, suspected fraud and violations of our terms and agreements and in response to legal process, court orders, subpoenas, or to establish or exercise our legal rights.
Business Partners, Service Providers, Affiliates, and Subcontractors – we may disclose information (including Personal Information) to our trusted affiliates, personnel, licensors, contractors, service providers, subcontractors and business partners who may use such information to help us provide you with the Services. For example, we will share the email addresses of users who have registered to our Newsletter, in order to provide them with direct marketing services. We authorize these third-party service providers to use Personal Information only for the purpose of providing the specific services.
Identifiers – we may share Identifiers for the purpose of operating our business and providing the Services, meaning to serve the advertisements through our SDK, as well as to detect fraud, security or technical issues in connection with the Services.
We retain this collected information as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until individuals express a preference to opt-out or delete their Personal Information. We may, at our sole discretion, delete or amend information from our systems, without notice, once we deem it is no longer needed for such purposes.
Clear invest LTD is committed to protecting your and your child’s Personal Information. Thus, Clear invest LTD has implemented technical, physical and administrative security measures to protect the Personal Information submitted to and collected by us, both during transmission and once we receive it. In addition, Clear invest LTD limits access to the information on its servers, and it is password-protected as well as encrypted.
Our users have a right to know what information we hold about them and their child and, in some cases, to have such information communicated to them. Our users may also ask for our confirmation as to whether or not we process their or their child’s Personal Information. Subject to the limitations in applicable law, users may also be entitled to obtain from us the Personal Information they have provided to us in a structured, commonly-used, and machine-readable format, and may have the right to transmit such Personal Information to another party. The principal rights under applicable data protection laws in relation to Personal Information are as follows:
the right to access any information which is provided by the user;
the right to rectification;
the right to erasure;
the right to restrict processing;
the right to object to processing;
the right to data portability;
the right to complain to a supervisory authority; and
the right to withdraw consent (to the extent applicable).
We provide our users with the ability to exercise certain choices and controls in connection with our treatment of their Personal Information, depending on their relationship with us. If you wish to exercise any or all of the above rights, please contact us by email at: [email protected] and let us know that you wish to exercise your right of access and specify what Personal Information you would like to receive or delete (including if you wish to delete the Account). Where we are not able to provide you with the information you have requested, we will endeavor to explain the reasoning for this. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month in accordance with applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.
Unsubscribe from Direct Marketing
You may revoke permission to receive promotional messages at any time by contacting customer support at [email protected] or by following the unsubscribe link located at the bottom of each communication. Please note that even if you unsubscribe, we reserve the right to send you service-related communications, announcements and administrative messages.
Opt – Out
You may easily opt out of certain automatic data collection, sharing process and targeted advertising services related to our Service. Please note that even if you opt-out, you will still receive content and advertising. Opting-out simply means that the advertisements you do receive may not be contextual.
You may limit the disclosure of certain information collected from your mobile device by adjusting the settings on your mobile device. You should review your device settings and instructions. Notwithstanding, we provide the following instructions solely for informational purposes (as they might be revised by the device supplier): For iOS mobile devices, go to “Settings” from your device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking.” For Android mobile devices, go to “Google Settings” on your device; select “Ads”; and check the box labeled “Opt Out of Interest-Based Ads.” Please read your device-specific information to learn how to opt-out:
You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser.
Please refer to the support page of the browser you are using. In this regard, following are some links that you may find useful:
Google Chrome: https://support.google.com/chrome/answer/95647?hl=en;
Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies;
Opera: http://www.opera.com/help/tutorials/security/cookies/ ;
You may opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s (“NAI”) website – NAI consumer opt-out and the Digital Advertising Alliance’s (“DAA”) website – DAA opt-out page.
Note that once you opt out, part of the Services provided by us might no longer be available and some features may not work if you revoke the data transfer.
If you have any additional complaints about your privacy rights, please contact our Data Protection Officer. Please note that you have the right at any time to contact your local data protection authority.
Clear invest LTD.
New Horizon Building, Ground Floor 3 1/2 Miles Philip S.W. Goldson Highway, Belize City, Belize
You can also contact us via email at: [email protected].
Please be sure to include your information in any correspondence to us so that we can respond to your inquiry in a timely manner.
Security policy http://policy.clearinvest-ltd.com/security_policy.html