PRIVACY POLICY

Last updated April 27, 2023

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us.

In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you
participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you
make, and the products and features you use. The personal information we collect may

include the following:
-names
-phone numbers
-email addresses
-mailing addresses
-billing addresses

Sensitive Information. When necessary, with your consent or as otherwise permitted
by applicable law, we process the following categories of sensitive information:
-financial data

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/es-419-us/privacy.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our

Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or
contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar

technologies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and
performance information our servers automatically collect when you access or use
our Services and which we record in log files. Depending on how you interact with
us, this log data may include your IP address, device information, browser type, and
settings and information about your activity in the Services (such as the date/time
stamps associated with your usage, pages and files viewed, searches, and other
actions you take such as which features you use), device event information (such
as system activity, error reports (sometimes called "crash dumps"), and hardware
settings).

Device Data. We collect device data such as information about your computer,
phone, tablet, or other device you use to access the Services. Depending on the
device used, this device data may include information such as your IP address (or
proxy server), device and application identification numbers, location, browser type,
hardware model, Internet service provider and/or mobile carrier, operating system,
and system configuration information.

Location Data. We collect location data such as information about your device's
location, which can be either precise or imprecise. How much information we collect
depends on the type and settings of the device you use to access the Services. For
example, we may use GPS and other technologies to collect geolocation data that
tells us your current location (based on your IP address). You can opt out of
allowing us to collect this information either by refusing access to the information or
by disabling your Location setting on your device. However, if you choose to opt out,
you may not be able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our
Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To deliver and facilitate delivery of services to the user. We may process your
information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may process your
information to respond to your inquiries and solve any potential issues you might
have with the requested service.

To send administrative information to you. We may process your information to
send you details about our products and services, changes to our terms and
policies, and other similar information.

To request feedback. We may process your information when necessary to
request feedback and to contact you about your use of our Services.

To send you marketing and promotional communications. We may process the
personal information you send to us for our marketing purposes, if this is in
accordance with your marketing preferences. You can opt out of our marketing
emails at any time. For more information, see "WHAT ARE YOUR PRIVACY
RIGHTS?" below).

To deliver targeted advertising to you. We may process your information to
develop and display personalized content and advertising tailored to your interests,
location, and more.

To post testimonials. We post testimonials on our Services that may contain
personal information.

To evaluate and improve our Services, products, marketing, and your
experience. We may process your information when we believe it is necessary to
identify usage trends, determine the effectiveness of our promotional campaigns,
and to evaluate and improve our Services, products, marketing, and your
experience.

To comply with our legal obligations. We may process your information to
comply with our legal obligations, respond to legal requests, and exercise, establish,
or defend our legal rights.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary
and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like
with your consent, to comply with laws, to provide you with services to enter into
or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate
business interests.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be
obtained in a timely way.

For investigations and fraud detection and prevention

For business transactions provided certain conditions are met

If it is contained in a witness statement and the collection is necessary to assess,
process, or settle an insurance claim

For identifying injured, ill, or deceased persons and communicating with next of kin

If we have reasonable grounds to believe an individual has been, is, or may be
victim of financial abuse

If it is reasonable to expect collection and use with consent would compromise the
availability or the accuracy of the information and the collection is reasonable for
purposes related to investigating a breach of an agreement or a contravention of the
laws of Canada or a province

If disclosure is required to comply with a subpoena, warrant, court order, or rules of
the court relating to the production of records

If it was produced by an individual in the course of their employment, business, or
profession and the collection is consistent with the purposes for which the
information was produced

If the collection is solely for journalistic, artistic, or literary purposes

If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section
and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share
your data with third-party vendors, service providers, contractors, or agents ("third
parties") who perform services for us or on our behalf and require access to such
information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as
follows:

-Ad Networks

-Payment Processors

-Sales & Marketing Tools

-Data Analytics Services

-Finance & Accounting Tools

We also may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with,
or during negotiations of, any merger, sale of company assets, financing, or
acquisition of all or a portion of our business to another company.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes
outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the
purposes set out in this privacy notice, unless a longer retention period is required or
permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize such information, or, if this is not
possible (for example, because your personal information has been stored in backup
archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our

Services is at your own risk. You should only access the Services within a secure
environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By
using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at todd@cleverera.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as Canada, you have rights that allow you greater
access to and control over your personal information. You may review, change, or
terminate your account at any time.

In some regions (like Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data
protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your
personal information, you also have the right to complain to your Member State data
protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and
Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal
information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe
from our marketing and promotional communications at any time by clicking on the
unsubscribe link in the emails that we send, replying "STOP" or "UNSUBSCRIBE" to the
SMS messages that we send, or by contacting us using the details provided in the
section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then
be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other nonmarketing purposes.

Cookies and similar technologies: Most Web browsers are set to accept cookies by
default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services.

If you have questions or comments about your privacy rights, you may email us at todd@cleverera.com.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us
at todd@cleverera.com.

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you,
change that information, or delete it. To request to review, update, or delete your
personal information, please fill out and submit a data subject access request.

© 2024 Clever Era, LLC - All Rights Reserved.
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