Privacy Policy

Last updated: 1.12.2021

CleverBooks Privacy Policy

CleverBooks Company (“us”, “we”, or “our”) operates https://www.cleverbooks.eu (the “Site”,CleverBooks mobile applications). This page informs you of our policies regarding the collection, use, and disclosure of Personal Information we receive from users of the Site and mobile applications purchased through Google Play or Apple Store under CleverBooks company name and logo.

Cleverbooks acts as Data Controller of the personal data processing. The corporate details of the Data Controller are as follows: CleverBooks Ltd., Registered in the Republic of Ireland, Company number 614080, contact email on privacy issues dpo [at] cleverbooks [dot] eu

We use your Personal Information only for providing and improving the Site, mobile applications, user experience. By using the Site and Mobile Applications of CleverBooks, you agree to the collection and use of information in accordance with this policy. We are a law-abiding company that conducts our business in compliance to the prevailing regulation regarding data protection and security and we commit to protect the security and privacy of your personal data because we build long customer relationships based on trust and mutual understanding as a part of our company’s mission and vision.

By Using this Website You agree to the below.

HyperText Transfer Protocol Secure (HTTPS)

HyperText Transfer Protocol Secure (HTTPS) is an extension of the Hypertext Transfer Protocol (HTTP). CleverBooks website is secured with the HTTPS certificate. The principal motivations for HTTPS are authentication of the accessed website, protection of the privacy and integrity of the exchanged data while in transit. It protects against man-in-the-middle attacks. The bidirectional encryption of communications between a client and server protects against eavesdropping and tampering of the communication,.In practice, this provides a reasonable assurance that one is communicating without interference by attackers with the website that one intended to communicate with, as opposed to an impostor.

The authentication aspect of HTTPS requires a trusted third party to sign server side digital certificates. HTTPS is now used more often by web users than the original non-secure HTTP, primarily to protect page authenticity on all types of websites; secure accounts; and to keep private user communications, identity, and web browsing.This will become especially important in year 2 when the forum (including user accounts and user generated content) will be integrated in the website.

CleverBooks also uses SSL certificate.

How your personal information may be collected

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from You. For example, from the forms you complete on our Service, preferences you express or provide through our Service, or from your purchases on our Service.
  • Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.

We collect information about visitors who comment on Sites that use our Akismet anti-spam service. The information we collect depends on how the User sets up Akismet for the Site, but typically includes the commenter’s IP address, user agent, referrer, and Site URL (along with other information directly provided by the commenter such as their name, username, email address, and the comment itself).

Privacy and Cookies Policy

Pursuant to article no. 13 of the Regulation EU n. 2016/679 (GDPR), and in general in observance of the principle of transparency set forth in the above Regulation, personal data will be processed with automated tools for the management of web services connected with the CleverBooks website.

Data, Cookies
CleverBooks collects User information. We use technologies like cookies (small files stored by your browser), unique device identifiers to anonymously identify your computer or device so we can deliver a better experience. Our systems also log information like your browser, operating system, and IP address.

Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Site or a third-party to recognize you and make your next visit easier and the Site more useful to you. Essentially, cookies are a user’s identification card for the CleverBooks servers. Web beacons are small graphic files linked to our servers that allow us to track your use of our Site and related functionalities. Cookies and web beacons allow CleverBooks to serve you better and more efficiently,and to personalize your experience on our Site. Cookies can be “persistent” or “session” cookies.

What are your choices regarding cookies

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use some or all of the features we offer. You may not be able to log in, store your preferences, and some of our pages might not display properly.

By submitting your personal information, you hereby approve the practices described in this Privacy Policy. Upon registering as a User on CleverBooks website/ CleverBooks online store/ downloading any of CleverBooks’ mobile applications, CleverBooks will collect personal data of the User in the form of the full name, e-mail address, and other information deemed necessary. By providing such information/data, the User understands that CleverBooks can ask and receive each information / personal data of the User for the continuity and security of this site, mobile applications and continuous improvement of customer experience. We do not knowingly contact or collect personal information from children under 13. If you believe we have inadvertently collected such information, please contact us so we can promptly obtain parental consent or remove the information.

CleverBooks will collect and process complete reports on each transaction, offer or other financial relationship with the User, and regarding the User’s order fulfilment on CleverBooks website.

We also may collect personally identifiable information that you provide to us, such as your name, address, phone number or email address. With your permission, we may also access other personal information on your devices, such as your phone book, calendar or messages, in order to provide services to you. If authorized by you, we may also access profile and other information from services like Facebook. Our systems are not designed to associate personal information with your activities (such as pages you view or things you click on or search for). Note that we use the camera on your mobile device for the performance of the application (s) CleverBooks has provided to you. We do not use camera on your mobile device for any other purposes and we do not have any access to your media files store on your mobile device or remotely could be accessed from your mobile device on which any of CleverBooks’ applications installed.
CleverBooks is committed to protect each information/data of the User submitted to CleverBooks and/or collected by CleverBooks, utilized electronically by CleverBooks.

However, CleverBooks does not guarantee the confidentiality of such User submitted information, in the event that there are other parties obtaining or utilizing the User’s information against the law and without permission from CleverBooks.

Security: We use physical, technical, and administrative measures to safeguard information in our possession against loss, theft and unauthorized use, disclosure, or modification. Please note, however, that no data transmission or storage can be guaranteed to be 100% secure. As a result, while we strive to protect the information we maintain, we cannot ensure or warrant the security of any information that you transmit to us.

Types of processed data, purpose and legal basis for the processing

Legal basis for processing: The legal basis for the processing of personal data will be (i) the performance of a contract for the benefit of the data subject in those processing in which personal data is necessary for the use of the app and its different functionalities; and (ii) consent from the data subject for those additional purposes that require your consent. CleverBooks will not process any personal data that requires consent before obtaining your prior explicit consent. You may withdraw your consent at any time.

Browsing data: When users browse the website, it acquires some navigation data, whose transmission is implicit in the internet communication protocols. Data are not collected to be associated to the identified people concerned. Data may be used to obtain aggregated and anonymous statistical information on website usage and to check its correct operation. Data are stored only for as long as it is necessary. Data may be used to ascertain the responsibility of users in case of potential digital crimes affecting the website. Data provided voluntarily by users – The optional, voluntary and explicit transmission of personal data, including email address, required in the website related web services (e.g. subscribing to newsletters) entails the subsequent acquisition of such data for the sole purpose of replying/responding to the users’ requests and managing the web services. Specific policies will be progressively posted or displayed on the website pages designed for special on-demand services.

Cookies: Cookies active on this website do not record personal data. CleverBooks website uses Google Analytics, a data analysis service provided by Google, Inc. (“Google”) to improve the usability of web services and the communications with users, to assess user internationalization levels, to promote institutional activities according to the various communication target groups. Google may disclose the data collected to third parties, if required by law. Data are collected for education related services purposes only and shall never be transferred to third parties for commercial purposes. For further information see Google terms. The website uses the following cookies:

Technical Cookies & Cookies that allow:

  1. Website navigation and usability;
  2. Aggregated collection of information on number of users and how users visit the website (“Google analytics”);
  3. Browsing in function of selected criteria (e.g. language, “functionalities cookies”) to improve user experience.

These cookies are not used for purposes other than those described above and therefore their installation does not require your consent.

Third-party profiling cookies: These cookies are installed by parties other than CleverBooks and need your consent to be installed. If you refuse consent, they will be not installed. We may allow third-parties from other providers that need your consent; if not given they will not be installed. Please follow the links below to view the privacy policies of the above third parties where you will be allowed to consent to the installation of such cookies. Please note that if you do not express your preference and continue your navigation in the website, you will consent to the use of such cookies.

To disable, remove or block cookies you can use your browser’s settings or the DNT option (Do Not Track), if applicable. CleverBooks does not guarantee the full operation of the website when cookies have been disabled. How to disable cookies from browsers:

Method and length of data processing: Personal data shall be processed:

  • with automatic tools;
  • by individuals authorized to perform such tasks by the Law;
  • by using proper measures to ensure confidentiality and avoid access by non-authorized third parties;
  • only for the time necessary to achieve the purposes for which they were collected. 
  • Certain data may be maintained for a maximum retention period of [7] years in order to comply with legal, compliance and tax applicable requirements.

Payment Data

CleverBooks uses third-party services for payment processing (e.g. payment processors). CleverBooks will not store or collect your payment card details. That information is provided directly to Our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

When you use Our Service to pay a product and/or service via bank transfer, CleverBooks Order Team will ask you to provide information to facilitate this transaction.

To better understand how a provider uses and stores the data shared with them, check their privacy policies directly:

Location
We do not store or share your precise location.

Access, Deletion
You can request to see or delete your personal data. You also contact us by email to request to see or delete this information. And you can uninstall our mobile application from your device at any time. We remove personally identifiable information (such as your name, address, email or phone number) and other preferences associated with your account promptly after you delete your account. We may retain other data for a maximum retention period of [7] years in order to comply with legal, compliance and tax applicable requirements.

Information Sharing
We generally do not share personally identifiable information (such as name, address, email or phone) with other companies for marketing purposes, therefore, we can guarantee your information confidentiality apart from the events listed below:

  • If CleverBooks will get acquired/bought/merged by/with a third party, the user information might be shared
  • If CleverBooks will be obliged to disclose/share user information for legal purposes.
  • Analytics companies may access anonymous data (such as your IP address or device ID) to help us understand how our services are used. They use this data solely on our behalf. They do not share it except in aggregate form; no data is shared as to any individual user.

Information Protection

We take reasonable steps to secure your personally identifiable information against unauthorized access or disclosure. We encrypt transmission of data on pages where you provide payment information. However, no security or encryption method can be guaranteed to protect information from hackers or human error. Information we collect may be stored or processed on computers located in any country where we do business. When so required by applicable laws and regulations, CleverBooks will implement the relevant safeguards to the international data transfer by entering into the relevant agreements with third parties in accordance with the terms and conditions provided under the Standard Contractual Clauses approved by the European Commission. We take reasonable administrative, physical and electronic measures designed to safeguard and protect your information from unauthorized access or disclosure. This includes utilizing Secure Sockets Layer (SSL) software, which encrypts the personal information you input, and storing your information in encrypted form behind a firewall designed to block access from outside our network. However, no security or encryption method can be guaranteed to protect information from hackers or human error.

Contact
If you have any questions or concerns about our privacy policies, please contact us: dpo@cleverbooks.eu

Complaint, suggestions
If you have any complaints/suggestions or concerns about our privacy policies, please contact us: dpo@cleverbooks.eu

Privacy Policy Amendment
This Privacy Policy may be amended and/or updated from time to time without prior notice unless significant changes affecting your privacy or data protection rights are introduced. Note, that it does not influence user experience. We may make changes to this policy at our sole discretion. By continuing to access or use our website after those changes become effective, you agree to be bound by the revised Privacy Policy.

Rights of the person concerned: 

Pursuant to Section III of the GDPR, the person concerned shall be entitled to exercise their right to:

  1. access personal data (you will therefore have the right to have free information about the personal data held by the Data Controller, as well as to obtain a copy thereof in an accessible format);
  2. amend incorrect, inaccurate or old data (upon your request, where the data do not express evaluation elements);
  3. withdraw consent (if you had consented to the processing, you may withdraw your consent at any time and upon such revocation of consent your data shall no longer be processed);
  4. cancel their personal data – right to be forgotten (for example, in case of withdrawal of consent, if there is no other legal basis for data processing);
  5. restrict data processing (in certain cases – dispute the accuracy of the data, within the timeframe necessary for verification; dispute the lawfulness of the processing with refusal to the cancellation; your need to use the data to exercise your defense rights, while they are no longer useful for the purposes of the processing; in the event that the processing has been denied, while the necessary checks are being carried out – the data will be stored in such a manner that they may be restored if need be, but, in the meantime, cannot be consulted by the Controller if not in relation to the validity of your request for restriction);
  6. deny consent to the processing due to legitimate reasons (under certain circumstances, you may in any case object to the processing of data, and in any case you may refuse processing for direct marketing purposes);
  7. data portability (upon your request, the data shall be transmitted to the subject indicated by you in such a format that they can be easily consulted and used);
  8. advance a dispute to the Supervisory Authority (Privacy Authority).

Exercise of users’ data protection rights:  You may contact us via email at dpo@cleverbooks.eu, in order to assert your rights, namely: the confirmation of the existence of data concerning yourself and their origin and processing and the purposes thereof; the cancellation, transformation into anonymous form or the blocking of data processed in violation of the law; the updating, rectification or integration of data; certification that the operations have been brought to the attention of those to whom the data were communicated or disseminated. You may also object at any time to the possible profiling of your personal data.

Questions: If you have any questions about this policy or your privacy on the Services, please contact us at dpo@cleverbooks.eu.