Privacy Policy

Last updated: June 2019

Welcome to Reclip (the “Platform”). The Platform is provided and controlled by Clip Technologies LTD (“Reclip”, “we” or “us”). We are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. By accessing or using our website, services, applications, products and content (that include but are not limited to the Platform) (collectively, the “Services”), you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it. If you do not agree with this policy in general or any part of it, you should not use our Services.

Our representative in the US is Clip Media Inc.

If you have any questions about how we use your personal data or about data protection in general please contact [email protected]

SUMMARY

What information do we collect about you?

We process information when you create an account, and use the Platform, such as your contact details, content you create, your location, and credit card details. We also collect technical and behavioural information about your use of the Platform. We also collect information contained in the content that you create and in the messages you send through our Platform, and information from your phone book if you allow us access to your phone book on your mobile device.

How will we use the information about you?

We use your information to improve and administer the Platform and allow you to use its functionalities.

Who do we share your information with?

We share your data with third party service providers who we rely on to operate our Platform. These providers include cloud storage providers, and other IT service providers. We may also share your information with law enforcement agencies, public authorities or government bodies as required by law. We may also request your explicit permission to share your content with prospective investors.

Your Rights

You may have rights in relation to your information.

How long do we keep hold of your information?

We retain your information for as long as it is necessary to fulfil (1) our contractual obligations and rights in relation to the information involved, (2) our legal obligation(s) under applicable law(s) and regulations to retain data for a certain period of time, taking into account statute of limitations under applicable law(s); (3) our legitimate business purposes; (4) and to conduct a defence in relation to disputes or potential disputes.

How will we notify you of any changes?

We will generally notify all users of any material changes to this policy, through a notice on our Platform. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of the Services after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.

1. The types of personal data we use

We may collect and use the following information about you:

3. How we use your personal data

We will use the information we collect about you in the following ways:

If you choose to share your precise location with us, we will also use your data to provide you with location based services, such as advertising and other personalised content and where you have chosen to receive personalised adverts from us and/or our partners, our legal basis is consent.

4. How we share your personal data

We will share your personal data and other information with the following selected third parties:

We will also share your information with any member, subsidiary, parent or affiliate of our corporate group, only for the purposes set out above, to assist in the improvement and optimisation of the Platform, in order to prevent illegal uses, increase user numbers, development, engineering and analysis of information or for our internal business purposes (How we use your personal data).

Where we transfer your personal data to countries outside the EEA, we do so under the Commission’s model contracts for the transfer of personal data to third countries (i.e. standard contractual clauses) pursuant to 2004/915/EC or 2010/87/EU (as appropriate)For a copy of these Standard Contractual Clauses, please contact us at [email protected]

We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if such use is reasonably necessary to:

We will also disclose your information to third parties:

5. Where we store your personal data

The personal data that we collect from you may be transferred to, and stored at, a destination outside of your country and the European Economic Area ("EEA"). Further information regarding the transfer of data outside of the EEA is available. Please contact us at [email protected] if you have any questions

6. Your Rights

In certain circumstances you have the right to access the personal data that we hold about you and to correct, update, or request deletion your personal data. Prior to the fulfilment of your request concerning your personal data, we will ask you to verify your identity before we can act upon your request.

You have the following rights:

As far as we process your personal data on the basis of our legitimate interests, you can object to processing at any time. You can find a detailed description of our processing activities and the legal basis in the sections above. If you object to such processing, we ask you to state the grounds of you objection in order for us to examine the processing of your personal data and decide whether to adjust the processing accordingly.

Please send an e-mail to us if you would like to exercise any of your rights [email protected] .

7. The security of your personal data

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, for example, by encryption, we cannot guarantee the security of your information transmitted through the Platform; any transmission is at your own risk.

We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

8. How long we keep your personal data

We use the following criteria to determine the period for which we will keep your personal data:

After you have terminated your use of our Services, we can store your information in an aggregated and anonymised format. Notwithstanding the foregoing, we can also retain any personal data as reasonably necessary to comply with our legal obligations, allow us to resolve and litigate disputes, and to enforce our agreements.

9. Information relating to children

The Platform is not directed at children under the age of 13. If you believe that we have personal data about or collected from a child under the relevant age, please contact us at [email protected]

10. Complaints

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at [email protected] and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority or follow the Dispute Process.

11. Changes

We will generally notify all users of any material changes to this policy, through a notice on our Platform. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of the Services after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.

12. Contact

Questions, comments and requests regarding this policy should be addressed to [email protected]