LAST UPDATED: 29/10/2022
1. Contact information
General contact info:
ClowdWork has appointed a data protection officer (DPO). You may contact ClowdWork’s DPO Alexandra Gamarra at email@example.com.
2. Applicability and eligibility
3. Personal data we collect
We rely on a number of legal bases to process the information we receive about you from your use of the Services, including where:
Where we process your information on the basis of consent, we will clearly obtain your opt-in consent. Where given, you may withdraw your consent at any time by contacting us at firstname.lastname@example.org. Where we process your information on the basis of legitimate interests, we do so where the processing is necessary for your legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.
Information we may collect about you includes:
Account Information: you may register for an account with us (a “Services Account”). We will collect certain information about you in connection with your registration for a Services Account, which may include Personal Data and other information such as a username and password.
To register for a Services Account, we will ask you to provide the following:
To register your organization for a Services Account, we will ask you to provide the following:
Payment Transaction Information: We may collect information related to purchases made through the Services. You may provide certain information to complete payments via the Services, including your credit or debit card number, card expiration date, CVV code, billing address, and ACH bank information (collectively, “Payment Information”), along with your name and billing, delivery and shipping address, to complete payment transactions through certain services.
Please note we work with Service Providers (as defined below) to handle payment transactions. We do not collect or maintain your credit card or other financial account information; this information is handled for us by our Service Providers. You are subject to the privacy policies and terms and conditions of our Service Providers when utilizing a third-party service through our Services. Please review the Service Providers’ privacy policies and terms and conditions before using their services.
Correspondence Information: If you sign up, email us, subscribe to our blog, newsletters, or mailing lists, we may keep your message, email address, and contact information to respond to your requests, provide the requested products or Services, and to provide notifications or other correspondences to you. We do not share or sell any Personal Data to other organizations for commercial purposes.
If you do not want to receive communications from us in the future, please let us know by sending us an e-mail requesting the same to email@example.com or by following the unsubscribe instructions found in any e-mail we send. If you supply us with your postal address, you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not wish to receive such mailings, please let us know by contacting us at firstname.lastname@example.org.
Please note requests to remove your email address from our lists may take some time to fulfill. We may also still contact you as needed to provide important announcements or notifications regarding the Services.
Support Information: You may provide information to us via a support request submitted through the Services. We will use this information to assist you with your support request. Please do not submit any information to us via a support submission, including confidential or sensitive information that you do not wish for our Service Providers to have access to or use in the future.
Form Information: We may use forms to request certain information from you on the Services, such as your contact information to assist with contacts or service requests. This information may include Personal Data.
User contributions: You also may provide information to be posted on public areas of the Services, or transmitted to other users of the Services or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. We cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
We do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
4. Information collected automatically
We use automatic data collection and analytics technologies to collect aggregate and user-specific information about your equipment, domain name, patterns of use, communication data and the resources that you access and use on the Services, including your IP address, browsing and navigation patterns. This information is used to improve our Services.
We generally process information collected automatically on the legal basis of our legitimate interests in assessing the use of our Services. Where appropriate, we may rely on alternate legal bases, such as your consent to certain types of processing.
Information we collect automatically through your use of the Services includes:
Internet browser: Your Internet browser automatically transmits certain anonymous information when you use certain Services. As you navigate through our Services, we and our partners who include third-party Service Providers (as defined below) we engage to help provide our Services, may use automated means to collect various types of information about you, your computer or other device used to access our Services.
A representative, non-exhaustive list of the types of automatically collected information may include:
We, along with our Service Providers, may use and combine such collected anonymous information to provide better service to site visitors, tailor the site based on your preferences, compile and analyze statistics and trends, monitor website activity and performance and otherwise administer and improve the site for your use. However, such information is not combined with your Personal Data collected.
Information collected by and from social media services and other third-party platforms: Our users can engage in content on or through social media services or other third-party platforms, such as Facebook, or other third-party social media plug-ins, integrations and applications. When you engage in our content on or through social media services or other third-party platforms, plug-ins, integrations or applications, you may allow us to have access to certain information in your profile. This may include your:
For a description on how social media services and other third-party platforms, plug-ins, integrations or applications handle your information, please refer to their respective privacy policies and terms and conditions, which may permit you to modify your privacy settings.
When we interact with you through our content on third party websites, applications, integrations or platforms, we may obtain any information regarding your interaction with that content, such as content you have viewed and information about advertisements within the content you have been shown or may have clicked on.
Analytics information: We use data analytics to ensure site functionality and improve the Services. This software may record information such as how often you use the Services, what happens within the Services, aggregated usage, performance data, app errors and debugging information, and where the Services were downloaded from.
Log file information: When you use our Services, we may receive log file information such as your
We receive log file data when you interact with our Services, for example, when you visit our website, sign in to our Services, or interact with our email notifications. We use log file data to provide, understand, and improve our Services, and to customize the content we show you. We may link this log file to other information we collect about you via the Services.
Information collected by our desktop applications (Mac, Windows and Linux): We may also collect screenshots, applications currently being worked on, web URLs visited, time you are active, the operating system you are using, whether or not you have an input device such as a monitor, whether your mouse is actively moving or not, the names of projects or tasks being worked on, the amount of time worked on those tasks, the browser version you are using, and whether your keyboard is being typed on.
Note: ClowdWork is not a keylogging program. It does not know what you are typing; rather, ClowdWork merely records whether your keyboard is active or inactive. All ClowdWork screenshots are uploaded via SSL over the standard HTTPS port (443). We do not upload keystrokes. (We do not even store keystrokes locally.) We upload the total seconds within a 10 min block that there was “activity” and the total seconds “worked” roughly every 10 minutes. This is done via a separate queue within the client which uses SSL (port 443).
Other web technologies: Our Service Providers (defined below) may also use other standard web-based technologies to analyze your movements while accessing our Services. The technologies include web “beacons,” “pixel tags,” and “clear gifs.” These technologies help us ascertain the effectiveness of our product and service campaigns and marketing programs, allow us to customize the services offered on or through our websites, and help determine the best use for websites content, and product and service offerings. Some of this information, including the IP address, may be stored on our Service Provider’s server logs, and may be available for extended periods of time.
5. How ClowdWork shares your personal data
We will share your information in the following circumstances on the legal basis of the legitimate interests of providing the requested Services:
Service Providers: We use third parties to support our business and provide services such as receiving, processing and fulfilling orders, encrypting credit card data as a further measure of securing the data, processing credit card payments, processing product reviews, technical support, and providing comparative performance information relative to our site (“Service Providers”). These third parties have only limited access to your information and may use your information only to perform these tasks on our behalf. Information we share to our Service Providers may include both information you provide to us and information we collect about you, including Personal Data and information from data collection tools like cookies, web beacons, and log files.
We may disclose the personal data that you have provided to us to Service Providers that we have engaged to perform business-related functions on our behalf, but only:
Business transactions: We may purchase other businesses or their assets, sell our business assets, or be involved in a bankruptcy, merger, acquisition, reorganization or sale of assets (a “Business Transaction”). Your information, including Personal Data, may be among assets sold or transferred as part of a Business Transaction. In some cases, we may choose to buy or sell assets. Such transactions may be necessary and in our legitimate interests, particularly our interest in making decisions that enables our organization to develop over the long term.
We may disclose your information in connection with the sale or merger of ClowdWork or any transaction that involves the sale or assignment of some or all of our assets.
Aggregated Non-Personal Data: We may disclose aggregated, non-personal data received from providing the Services, including information that does not identify any individual, without restriction. We may share demographic information with business partners, but it will be aggregated and de-personalized, so that personal data is not revealed.
6. Your rights and choices
You may benefit from a number of rights in relation to your information that we process. Some rights apply only in certain limited cases, depending on your location. If you would like to manage, change, limit, or delete your personal data, you can do so by contacting us at email@example.com. Upon request, we will provide you with information about whether we hold any of your personal data. In certain cases where we process your information, you may also have a right to restrict or limit the ways in which we use your personal data. In certain circumstances, you also have the right to request the deletion of your personal data, and to obtain a copy of your personal data in an easily accessible format.
To the extent that such rights are mandated by the laws applicable to the individual data subject, such as all data subjects residing in the European Union (“EU”), the following rights may apply:
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
If we process your information based on our legitimate interests as explained in this policy, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your data for direct marketing purposes, you can always object using the unsubscribe link in such communications or changing your account settings.
Where you have provided consent to certain data processing, you have the right to withdraw that consent at any time by contacting us at firstname.lastname@example.org. A withdrawal of consent will not affect the validity of our use of your personal data up until the point you have withdrawn your consent.
If you no longer wish to use the Services or receive service-related messages (except for legally required notices), then you may contact us using the information above.
If you use ClowdWork in your capacity as an employee, your employer has direct access to your data. If you are an independent contractor, the person or entity with whom you contract has direct access to your data. In addition, ClowdWork employees may have access to your data for testing or the general improvement of our software, to notify you about changes to our website or any products or services we offer or provide through it, or to fulfill the purpose for which you provided it. See our terms of service at https://ClowdWork.com/terms for additional information in this regard.
Access to the information we have collected about you: We provide certain tools and settings within the Services to help you access, correct, delete, or modify your personal data associated with the Services. You may also contact us regarding the information we have collected about you, including regarding the nature and accuracy of the data that has been collected about you, to request an update, modification, or deletion of your information, to opt-out of certain Services uses of your information, or to withdraw any consent you may have granted to us. Please note that if you choose to delete your information or opt-out of the collection and use of your information, you understand that certain features, including but not limited to access to the Services, may no longer be available to you.
Data retention: We will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as an account is active or as needed to provide the Services to you. We will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy. We also retain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for site safety and security, to improve site functionality, or we are legally obligated to retain them for longer time periods. We may delete your personal data from our systems as part of a data retention plan. Following termination or deactivation of a Services Account, we may retain your information and content for a commercially reasonable time for backup, archival, and audit purposes.
Opting-out of communications from us: Users may opt-out of receiving certain communications from us by following the unsubscribe process described in email communication, or by contacting us using the contact information provided above. However, please note you may not opt-out of certain Services-related communications, such as account verification, changes or updates to features of the Services, or technical and security notices.
Do Not Track: We do not currently employ a process for automatically responding to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms. Per industry standards, third parties may be able to collect information, including personal data, about your online activities over time and across different websites or online services when you use Services. You may opt out of online behavioral ads at http://www.aboutads.info/choices/. You also may limit certain tracking by disabling cookies in your Internet browser.
7. Data security
The security of your personal data is important to us. We take reasonable efforts to secure and protect the privacy, accuracy, and reliability of your information and to protect it from loss, misuse, unauthorized access, disclosure, alteration and destruction. We implement security measures as we deem appropriate and consistent with industry standards. As no data security protocol is impenetrable, we cannot guarantee the security of our systems or databases, nor can we guarantee that personal data we collect about you will not be breached, intercepted, destroyed, accessed, or otherwise disclosed without authorization. Accordingly, any information you transfer to or from Services is provided at your own risk.
Please do your part to help us keep your information secure. Services Account information is protected by a password. It is important that you protect against unauthorized access to your account and information by choosing your password carefully and by keeping your password and computer secure, such as by signing out after using the Services. You are responsible for maintaining the confidentiality of your password and Services Account, and are fully responsible for all activities that occur under your password or Services Account. We specifically reserve the right to terminate your access to the Services and any contract you have with us related to the Services in the event it learns or suspects you have disclosed your Services Account or password information to an unauthorized third party.
We make reasonable efforts to ensure that our other Service Providers have implemented physical, electronic, and procedural security measures to assist with safeguarding your personal data, and to help protect against unauthorized access and disclosure. Only our authorized personnel and our Service Providers who perform legitimate business functions for ClowdWork are authorized to access your personal data. Notwithstanding our efforts, the Internet has inherent security risks. ClowdWork cannot promise, and you should not expect, that your personal data, personal searches, and other communications will always remain secure. You should take care with regard to how you handle and disclose your personal data or any username or password that you are required to use to access services on our websites.
8. Data Protection Responsibilities
Where you act for a company processing Personal Data, or where you provide us the Personal Data of individuals, you are acting as a data controller, and ClowdWork is the data processor. As a data controller, you are responsible for protecting the Personal Data you process and complying with all relevant legal requirements when you use the Services. This includes applicable data protection and privacy laws that govern the ways in which you can use Personal Data. Data controllers are also responsible for protecting Personal Data they provide to their data processors and must have a written agreement in place governing the details of the processing.
9. Data integrity
ClowdWork will only process personal data in a way that is compatible with and relevant for the purpose for which it was collected or authorized by you. To the extent necessary for those purposes, ClowdWork will take reasonable steps to ensure that personal data is accurate, complete, current and reliable for its intended use.
Please be advised information we collect about you via the Services may be transferred, processed and/or accessed by us in the United States, or another country where we, or our Service Providers operate. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal data, may differ from those that apply in the country in which you reside.
12. Children and data collection
ClowdWork’s websites are general audience websites. The Services are not directed toward children who are under the age of 18. You may not use the Services if you are under the age of 18. If you are under the age of 18, you should not provide any information on our Services.
We do not knowingly collect Personal Data from children or minors. If ClowdWork or its Service Providers become aware that a child or minor has provided us with Personal Data without parental consent, that information may be deleted from our databases. If you have questions about Personal Data that may have been submitted by a child, please email us at email@example.com.
If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using (an independent resourced mechanism) as a third-party resolution provider.