Privacy Policy

Version Effective Date: October 26, 2018
Version Number: 2.1.0

Data Controller Contact Information
Clay Pot Software LLC
legal@claypotsoftware.com

This document governs the Privacy Policy of our Services (as defined in the Terms and Conditions).

Our Privacy Policy tells you what personal data (PD) and non-personal data (NPD) we may collect from you, how we collect it, how we protect it, how we may share it, how you can access and change it, and how you can limit our sharing of it. Our Privacy Policy also explains certain legal rights that you have with respect to your personal data. Any capitalized terms not defined herein will have the same meaning as where they are defined elsewhere on our Services.

YOUR RIGHTS
When using our Site and submitting personal data to us, you may have certain rights under the General Data Protection Regulation (GDPR) and other laws. Depending on the legal basis for processing your personal data, you may have some or all of the following rights:

The right to be informed
You have the right to be informed about the personal data we collect from you, and how we process it.

The right of access
You have the right to get confirmation that your personal data is being processed and have the ability to access your personal data.

The right to rectification 
You have the right to have your personal data corrected if it is inaccurate or incomplete.

The right to erasure (right to be forgotten) 
You have the right to request the removal or deletion of your personal data if there is no compelling reason for us to continue processing it.

The right to restrict processing  
You have a right to ‘block’ or restrict the processing of your personal data. When your personal data is restricted, we are permitted to store your data, but not to process it further.

The right to data portability 
You have the right to request and get your personal data that you provided to us and use it for your own purposes. We will provide your data to you within 30 days of your request. To request your personal data, please contact us using the information at the top of this privacy notice.

 The right to object  
You have the right to object to us processing your personal data for the following reasons:

Processing was based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
Direct marketing (including profiling); and
Processing for purposes of scientific/historical research and statistics.
Rights in relation to automated decision-making and profiling.

Automated individual decision-making and profiling 
You will have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

Filing a Complaint with Authorities 
You have the right to file a complaint with supervisory authorities if your information has not been processed in compliance with the General Data Protection Regulation. If the supervisory authorities fail to address your complaint properly, you may have the right to a judicial remedy.

For details about your rights under the law, visit https://goo.gl/F41vAV

DEFINITIONS

“Non-personal data” (NPD) is information that is in no way personally identifiable.
“Personal data” (PD) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. PD is in many ways the same as Personally Identifiable Information (PII). However, PD is broader in scope and covers more data.
A “User” is someone who uses our Services.

TOPICS COVERED IN OUR PRIVACY POLICY

INFORMATION WE COLLECT
OUR USE OF COOKIES
HOW YOUR INFORMATION IS USED
RETAINING AND DESTROYING YOUR PD
 UPDATING YOUR PD
REVOKING YOUR CONSENT FOR USING YOUR PD
PROTECTING THE PRIVACY RIGHTS OF THIRD PARTIES
DO NOT TRACK SETTINGS
LINKS TO OTHER WEBSITES
PROTECTING CHILDREN’S PRIVACY
OUR EMAIL POLICY OUR SECURITY POLICY
IN-APP PURCHASES
TRANSFERRING PERSONAL DATA FROM THE EUROPEAN UNION
CHANGES TO OUR PRIVACY POLICY

 INFORMATION WE COLLECT
Generally, you control the amount and type of information that you provide to us when using our Services. If you do not provide us with enough PD, we may not be able to provide you with all the features of our Services.

Our Legal Basis for Collecting and Processing Your Personal Data (PD)
Our legal basis for collecting and processing your personal data (PD) is based on consent.

What Happens if you Don’t Give Us Your Personal Data (PD)
 If you do not provide us with enough PD, we may not be able to provide you with all the features of our Services.

We collect your PD in the following ways:

Automatic Information
We may automatically receive information from your computer or mobile device. This information includes the name of the website from which you accessed our Services, if any, as well as the name of the website you’ll visit when you leave our Services. This information also includes your IP address and the proxy server you use to access the Internet, your Internet service provider’s name, your web browser type, the type of mobile device, your operating system, and data about your activity when using the Services. We use all this information to analyze trends among our Users to help improve our Services.
Forms
Our Services may use forms. The information you enter into these forms may contain PD.
Device Permissions
Our Services may request permission to access certain functions of your mobile device. These functions include accessing your mobile device’s camera, photos, contacts, and/or calendar. You do not have to grant us permission to access your mobile device’s functions if you don’t want to.
Location Information
When you use our Services, we may collect and process information about your actual physical location. We may use several technologies, like GPS and IP tracking, to determine your location. These technologies may also provide us with information about nearby cell towers, Wi-Fi access points, and other devices.

OUR USE OF COOKIES
Our Services use cookies. A cookie is a small piece of data or a text file that is downloaded to your computer or mobile device when you access certain Services. Cookies may contain text that can be read by the web server that delivered the cookie to you. The text contained in the cookie generally consists of a sequence of letters and numbers that uniquely identify your computer or mobile device; it may contain other information as well.

BY AGREEING TO ACCEPT OUR USE OF COOKIES, YOU ARE GIVING US, AND THIRD PARTIES WE PARTNER WITH, PERMISSION TO PLACE, STORE, AND ACCESS SOME OR ALL OF THE COOKIES DESCRIBED BELOW ON YOUR COMPUTER OR MOBILE DEVICE.

Strictly Necessary Cookies
These cookies are necessary for proper functioning of the Services, such as displaying content, logging in, validating your session, responding to your request for services, and other functions. Most browsers can be set to disable the use of cookies. However, if you disable these cookies, you may not be able to access features on our Services correctly or at all.
Performance Cookies
These cookies collect information about the use of the Services, such as pages visited, traffic sources, Users’ interests, content management, and other measurements.
Functional Cookies
These cookies facilitate the operation and improve the functions of web pages. For example, functional cookies enable the Services to remember a User’s choices – such as their language, user name, and other personal choices while using the Services.
Media Cookies
These cookies can be used to improve performance and provide special features and content. They can be placed by our company or by third parties who provide services to us.
Advertising or Targeting Cookies
These cookies are usually placed and used by advertising companies to develop a profile of your browsing interests and serve advertisements to you that are related to your interests. You will see less website advertising if you disable these cookies.
Session Cookies
These cookies allow websites to link the actions of a User during a browser session. Session cookies also permit Users to be recognized as they navigate a website so that any item or page changes they make are remembered from page to page. Session cookies expire after a browser session; thus, they are not stored long term.
Persistent Cookies
These cookies are stored on a user’s computer or device in between browser sessions, which allows the user’s preferences or actions across a website (or, in some cases, across different websites) to be remembered. Persistent cookies may be used for a variety of purposes, including remembering users’ choices and preferences when using a website or to target advertising to them.

We may also use cookies for:

Identifying the areas of our Services that you have visited
Personalizing content that you see on our Services
Mobile Application and/or Site analytics
Remarketing our products or services to you
Remembering your preferences, settings, and login details
Targeted advertising and serving ads relevant to your interests
Affiliate marketing
Allowing you to post comments
Allowing you to share content with others and with social networks

Most browsers can be set to disable the use of cookies. However, if you disable cookies, you may not be able to access features on our Services correctly or at all.

Web Beacons
We may also use a technology called web beacons to collect general information about your use of our Services and your use of special promotions, emails, or text messages. The information, if any, we collect by web beacons allows us to statistically monitor the number of people who receive our communications and use our Services and to understand the behavior of our Users and visitors.

Analytics and Crash Reporting
Our Services use analytics and crash reporting services to collect information about the use of our Services. This includes collecting information such as number of Users, where Users come from, Users’ actions within the Services, and Users’ crash reports. We use the information we receive from analytics to improve our Services. We do not combine the information collected through the use of analytics with personally identifiable information.

Google Ad and Content Network Privacy Policy
Third-party vendors, including Google, use cookies and other technologies to serve ads to our Services. Google’s use of these technologies through AdMob enables it and its partners to serve ads to our Users based on their visits to our Services and other websites on the Internet. Users may opt out of seeing personalized ads by visiting http://www.aboutads.info/choices/.

Facebook Audience Network Privacy Policy
Third party vendors, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our Services and elsewhere on the internet and use that information to provide measurement services, target ads and as described in Facebook’s Data Policy (https://www.facebook.com/about/privacy/).

Users can opt-out of the collection and use of information for ad targeting by visiting https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.

Skimlinks Privacy Policy
Our Services use several Affiliate Advertising Programs (as defined in the Terms and Conditions), one of which is Skimlinks. Skimlinks requests that we include in our Privacy Policy the following information from their Privacy Policy:

What information does Skimlinks collect about Users through its technology and how does it use this information?
- Skimlinks stores Users’ IP addresses, from which they can determine a User’s approximate geographical location (e.g. country or region). Skimlinks needs this information to optimize the links that are created/monetized to suit the geography of the User, and to provide aggregate reporting to Publishers, Merchants and Advertisers on the location of users visiting Skimlinks Enabled Sites. Skimlinks also uses IP addresses as part of their efforts to reduce fraud and identify non-human browsing patterns.
- Skimlinks stores information about the device that a User uses to access sites within their Publisher network, such as the browser type, browser version, and type of device. This helps Skimlinks ensure they can diagnose and fix browser compatibility issues more swiftly, optimize their service to suit the preferred browsing environments, and provide aggregate reporting to Publishers, Merchants and Advertisers.
- Skimlinks stores non-identifiable information, using cookies and device identifiers, about the websites within their Publisher network that Users visit, which of their links Users click on, and whether Users make a purchase. This enables Skimlinks to provide Users with relevant and useful links and advertising to products and/or services in which they are likely to be interested, and to Merchants and Advertisers from whom they are likely to want to buy. Further information regarding the cookies Skimlinks utilises to collect this information can be found at http://skimlinks.com/user-cookies
- As part of the information available in standard web serving logs, Skimlinks also stores information about the referrer, i.e. the website page from which the User linked to the Skimlinks Enabled Site.
- To provide Publishers and Merchants with the Service, Skimlinks collects information on visits and sales on Skimlinks Enabled Sites, including but not limited to order value, products bought, and order identifiers. These are used to help Publishers, Merchants and Advertisers make better marketing and content creation decisions.
- At no time does Skimlinks know who a User is, nor does Skimlinks make any attempt to try and identify a User.
Skimlinks uses cookies to collect the information they need to optimise the product/Merchant links they monetize/create, and improve the service they provide to Publishers, Merchants, Advertisers and Users. Cookies also enable Skimlinks to carry out audience segmentation, ie Skimlinks divides Users into groups based upon defined criteria such as product usage, demographics, communication behaviour and media use. Skimlinks synchronises cookie identifiers with third parties in order to enrich the Service and offer personalized experiences across the web. As you browse Skimlinks Enabled Sites, cookies will be placed on your Computer so that Skimlinks can understand what you are interested in. These anonymous profiles allow for the customization of websites and targeting of content, including but not limited to advertising.
How can I disable Skimlinks cookies?
If you no longer want Skimlinks to store data about the websites you visit, the links you click and the Merchants you buy from, you can simply opt-out at https://optout.skimlinks.com/. This will mean Skimlinks will not drop Skimlinks cookies when you browse websites in their Publisher or Merchant network.

Please note: This opt-out facility relies on a cookie being set on your browser. By visiting the link above, you acknowledge that Skimlinks will be setting and maintaining the cookie on your browser in order to recognise you as an opted-out visitor. You must opt-out again if you clear that cookie from your browser (see allaboutcookies.org for more information), use a different internet browser, or use a different computer to access the internet.

U.S. visitors can understand more about cookies and their choices at these websites:

EU/EEA visitors can understand more about cookies and their choices at http://www.youronlinechoices.eu/.

More information about Skimlinks’ data collection is set out in their privacy policy at http://skimlinks.com/privacy-policy.

HOW YOUR INFORMATION IS USED 
We use the information we receive from you to:

Provide our products and services
Personalize and customize our content
Make improvements to our Services
Contact you with updates to our Services
Resolve problems and disputes
Contact you with marketing and advertising that we believe may be of interest to you

Communications and Emails
When we communicate with you about our Services, we will use the email address you provided to us as a User (if you provided us with one). We may also send you emails with promotional information about our Services or offers from us unless you have opted out of receiving such information.

Sharing Information with Third Parties
We do not sell or rent your PD to third parties for marketing purposes. However, for data aggregation purposes we may use your non-personal data (NPD), which might be sold to other parties at our discretion. Any such data aggregation would not contain any of your PD. We may provide your PD to third-party service providers we use or hire to provide services to us. These third-party service providers may include but are not limited to: payment processors, web analytics companies, advertising networks, call centers, data management services, help desk providers, accountants, law firms, auditors, shopping cart and email service providers, and shipping companies.

We also share your information with third parties by using Application Program Interfaces, or “APIs”, in order to provide certain functions within our Mobile Application. Such third parties may include but are not limited to HockeyApp, OneSignal, Dropbox, Google, Amazon and Facebook.

Legally Required Releases of Information
We may be legally required to disclose your PD if such disclosure is (a) required by subpoena, law, or another legal process; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce any binding legal agreements between you and us; (d) necessary to protect us from legal action or claims from third parties, including you and/or other Users; or (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, Users, employees or third parties.

Disclosures to Successors
If our business is sold or merges in whole or in part with another business that would become responsible for providing the Services to you, we retain the right to transfer your PD to the new business. The new business would retain the right to use your PD according to the terms of this Privacy Policy as well as to any changes to this Privacy Policy as instituted by the new business. We also retain the right to transfer your PD if our company files for bankruptcy and some or all of our assets are sold to another individual or business.

RETAINING AND DESTROYING YOUR PD 
We retain information that we collect from you (including your PD) only for as long as we need it for legal, business, or tax purposes. Your information may be retained in electronic form, paper form, or a combination of both. When your information is no longer needed, we will destroy, delete, or erase it within a reasonable period of time.

UPDATING YOUR PD
You can update your PD using services found on our Services. If no such services exist, you can contact us for assistance using the contact information found at the top of this notice. However, we may keep your PD, if any, as needed to enforce our agreements and to comply with any legal obligations.

REVOKING YOUR CONSENT FOR USING YOUR PD
You have the right to revoke your consent for us to use your PD at any time. Such an opt out will not affect disclosures otherwise permitted by law including but not limited to: (i) disclosures to business partners, (ii) disclosures to third-party service providers that provide certain services for our business, such as credit card processing, computer system services, shipping, data management services, (iii) disclosures to third parties as necessary to fulfill your requests, (iv) disclosures to governmental agencies or law enforcement departments, or as otherwise required to be made under applicable law, (v) previously completed disclosures to third parties, or (vi) disclosures to third parties in connection with subsequent contests or promotions you may choose to enter, or third-party offers you may choose to accept. If you want to revoke your consent for us to use your PD, send us an email with your request to: datacontroller@claypotsoftware.com.

PROTECTING THE PRIVACY RIGHTS OF THIRD PARTIES
If any posting you make on our Services contains information owned by or about third parties, you must make sure you have permission to include that information in your posting. While we are not legally liable for the actions of our Users, we will remove any postings about which we are notified, if such postings violate the privacy rights of others.

DO NOT TRACK SETTINGS
Some web browsers have settings that enable you to request that we do not track your movement within our Services. Our Services does not obey such settings when transmitted to and detected by our Services. You can turn off tracking features and other security settings in your browser by referring to your browser’s user manual.

LINKS TO OTHER WEBSITES
Our Services may contain links to other websites and applications. These websites and applications are not under our control and are not subject to our Privacy Policy. These websites and applications will likely have their own privacy policies. We have no responsibility for these websites and applications. You acknowledge that your use of and access to these websites and applications are solely at your risk. It is your responsibility to check the privacy policies of these websites and applications to see how they treat your PD.

If you click on, or otherwise follow, an Affiliate Link (as defined in the Terms and Conditions), and that click or follow leads to a purchase, Clay Pot Software LLC will, in most cases, receive an affiliate fee or commission. The price of any product or service is the same whether that product or service is reached by way of an Affiliate Link or not.

The Affiliate Advertising Programs (as defined in the Terms and Conditions) may include but are not limited to:

Amazon Services LLC Associates Program
Awin
CJ.Com
Ebay Partner Network
FlexOffers
Impact
iTunes Affiliate Program
Pepperjam
Rakuten Linkshare
ShareASale
Skimlinks
VigLink

PROTECTING CHILDREN’S PRIVACY
Even though our Services are not designed for use by anyone under the age of 17, we realize that a child under the age of 17 may attempt to access our Services. We do not knowingly collect PD from children under the age of 17. If you are a parent or guardian and believe that your child is using our Services, please contact us. Before we remove account information, if any, we may ask for proof of identification to prevent malicious removal of information. If we discover that a child is accessing our Services, we will delete his/her account information, if any, within a reasonable period of time. You acknowledge that we do not verify the age of our Users nor do we have any liability to do so.

OUR EMAIL POLICY
You can always opt out of receiving further email correspondence from us. We will not sell, rent, or trade your email address to any unaffiliated third party without your permission except in the sale or transfer of our business, or if our company files for bankruptcy.

OUR SECURITY POLICY
We have built our Services using industry-standard security measures and authentication tools to help protect the security of your PD. Unfortunately, we cannot guarantee against the loss or misuse of your PD or secure data transmission over the Internet because of its nature.

IN-APP PURCHASES
If you make an in-app purchase through our Services, all transactions are processed through the Apple App Store and are governed by the Apple App Store’s terms and conditions. We do not have access to your credit card number or any other PD at any point in the in-app purchase process.

TRANSFERRING PERSONAL DATA FROM THE EUROPEAN UNION
PD that we collect from you may be stored, processed, and transferred between any of the countries in which we operate, specifically the United States of America. The European Union has not found the United States and some other countries to have an adequate level of protection of PD under Article 45 of the GDPR. Our company relies on derogations for specific situations as defined in Article 49 of the GDPR. For European Union customers and Users, with your consent, your PD may be transferred outside the European Union to the United States. We will use your PD to provide the goods, services, and/or information you request from us to perform a contract with you or to satisfy a legitimate interest of our company in a manner that does not outweigh your freedoms and rights. Wherever we transfer, process or store your PD, we will take reasonable steps to protect it. We will use the information we collect from you in accordance with our privacy notice. By using our Services, you agree to the transfers of your PD described within this section.

CHANGES TO OUR PRIVACY POLICY
We reserve the right to change this Privacy Policy at any time. If our company decides to change this Privacy Policy, we will post those changes on our Services so that our Users and guests are always aware of what information we collect, use, and disclose. If at any time, we decide to disclose or use your PD in a method different from that specified at the time it was collected, we will provide advance notice by email sent to the email address you provided to us, if any. Otherwise, we will use and disclose our Users’ and guests’ PD in agreement with the Privacy Policy in effect when the information was collected. In all cases, your continued use of the Services after any change to this Privacy Policy will constitute your acceptance of such change.

QUESTIONS ABOUT OUR PRIVACY POLICY
If you have any questions about our Privacy Policy, please contact us using the information at the top of this Privacy Policy.

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