Terms & Conditions Privacy Policy Data Deletion Instructions

Clob Privacy Policy

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This policy was last revised on May 29th, 2024.

By using our services, you will share certain information with us. Therefore, we want to be clear about the information we collect, how we use it, who we share it with, and the options we provide for accessing, updating, and deleting such information. To this end, we have drafted this privacy policy (hereinafter, the "Privacy Policy").

Introduction

This Privacy Policy describes how Clob, operated by BeThere SpA, a company incorporated in Chile, collects, uses, and shares information about you when you use our mobile application, website, and any other related services (collectively referred to as the "Service").

What information do we collect?

We collect three types of information:

• 1. Information you provide to us.
• 2. Information we collect when you use our services.
• 3. Information we collect from third parties.

1. Information you provide to us.

When you interact with our services, we collect the information that you provide us. For example, to use our application, you need to create an account, so we may need to collect some important details about you, such as your name, username, email address, gender, interests, and date of birth. We may also ask you to provide us with additional information that will be publicly visible on our services, such as a profile picture.

Likewise, we collect any information you send through our application, related to the event you want to organize and its guests. Users who have access to see that event, according to their preferences when creating it, can always save that content or copy it outside the application. Therefore, the same common sense that applies to the internet in general also applies to our services: do not send messages or share content that you wouldn't want someone to save or share.

When you communicate with us through customer service or other avenues, we collect any information you provide or that we need to resolve your question.

2. Information we collect when you use our services.

When you use our services, we collect information about which of those services you have used and how you have used them. We might know, for example, whether or not you attended an event, whether you shared it with other people and/or forwarded the invitation, whether you saw a specific ad for a certain period, or whether you sent any messages to your friends. Below is a more detailed explanation of the type of information we collect when you use our services:

• Content information. We collect content you create on our services, and information about the events you create as well as the information you provide to create them.
• Device information. We collect information about the devices you use. For example, we collect the following: Information about your software, such as the operating system version, language, and time zone.
• Photos. We limit access to and storage of your photos and images only to what is essential to provide our services. Below, we detail how we handle photos and images on our platform:
  • Limited Access: We do not have access to the photos or the camera of your device beyond the photo upload functions of the application. You can only voluntarily upload photos to set up your profile picture or as a cover image for an event.
  • Selective Storage: We only store the photos you decide to upload as your profile picture or as a cover image for your events. We do not store or have access to any other photo on your device.
  • Event Image Options: If you choose not to upload an image from your device for an event cover, we offer you the option to choose public images from Unsplash as an alternative.
  • Profile Photo: For the profile photo, you can only choose and upload your own photo. If you choose not to upload a profile photo, we will not store any image in its place.
  • Full Control: You have total control over the photos you decide to share with us, and you can delete or change these photos at any time through your account or event settings.
• Location information.
  • Initial Location Storage: During the onboarding process, we save information you provide about the country you are from to optimize the user experience and offer relevant content. If you are from Chile, we additionally store the region and city you are from. This information allows us to fine-tune the personalization of services and content to offer you more relevant information and events.
  • Real-Time Location Use: We use your real-time location to show you nearby events, but we do not store this information. We do not retain data about your exact location.
  • Location Permission: You have the option not to allow access to the location, but if you decide not to do so, you will not be able to use the map discovery feature that shows business events near you. However, you will still have access to events to which you have been invited by friends, even if you do not have the location option activated.
  • User Control: The user has total control over location permissions and can choose to enable or disable the location at any time through the device settings.

3. Information we collect from third parties.

We may collect information about you from other users and third parties. If you link your account to another service (such as third-party applications), we may receive information from the other service, for example, the data you allow us to receive from the third party.

Use of Google User Data

Our application uses the Google API Service to allow users to create an account or sign in easily using their Google account. When you choose to sign in with Google, we collect and use your public profile information and email address provided by Google.

We use this information solely for the purpose of creating and managing your account within our application. We do not store or share this information with any third parties, and access to this information is limited to what is necessary for the functionality of our application.

Your privacy and the security of your data are important to us. We adhere to Google's API Service: User Data Policy, and our use of Google user data is limited to what is described in this privacy policy.

How Do We Use the Information?

What do we do with the information we collect?

• Develop, operate, improve, provide, and maintain our products and services.
• Send you communications, including email or push notifications when allowed. For example, we may use email or push notifications to respond to support requests or to share information about our products, services, and promotional offers that we think may interest you.
• Monitor and analyze trends and usage.
• Personalize our services, among other things, by suggesting friends, profile information, helping users find each other in the app, on third-party apps and services, or personalizing the content we show you, including ads.
• Offer and improve our advertising services, targeting and measuring ads, including through the use of precise location information (if you have given us permission to collect that information), both within and outside our services. We can also store information about your use of third-party apps and websites on your device to do this.
• Enhance the security and protection of our products and services.
• Verify your identity and prevent fraud or other unauthorized or illegal activities.
• Use the information we collect through cookies and other technologies to enhance our services and your experience with them.
• Enforce, research, and report behaviors that violate our Terms and Conditions and other usage policies, respond to law enforcement requests, and comply with legal requirements.

How Do We Share Information?

We may share information about you in the following ways:

• With Other Users. We may share the following information with other app users:
  • Personal information, such as your username, name, and profile picture.
  • Information about how you have interacted with our services, the names of users you are friends with, how close you are to your app contacts, and other information that will help other users understand your connections with others using our services. For example, since it may not be clear whether a new friend request comes from someone you really know, we may share whether you and the requester have mutual friends in the app.
  • Information about your device, such as the operating system and device type, to help you use the app correctly and receive content in the optimal display format.
  • Any additional information you have indicated we should share. For example, we will share your information when you connect your Clob account to a third-party app, and if you share information or content from Clob with that app.
• Content that you post or send. The extent to which your content is shared depends on your personal settings and the type of service you use. For example, you can send an event to only one selected friend, but any user may view the events you post if they have been allowed to access such content.
• With All Clob Users, Our Business Partners, and the General Public. We may share the following information with all users, and with our business partners and the general public:
  • Public information, such as name, username, profile pictures, public profile.
  • Personal data, including your e-mail address.
  • Public content such as events configured to be visible to everyone, as well as any content that you send to a naturally public service, and other multi-source services. This content can be viewed, used, and shared by the general public both on our services and on other services, including through search results, on websites, in apps, and in offline broadcasts.
• With Third Parties. We can share information with third parties in the following ways:
  • We can share information about you with third parties providing services on our behalf, including to facilitate payments and measure and optimize the performance of ads and offer more relevant ads, including on third-party websites and apps.
  • We can share information about you with business partners who provide services and features on our services.
  • We can share information about you, such as device and usage information, to help us and third parties prevent fraud.
  • Provide measurement, analysis, and commercial services. Our systems perform automated and, on some occasions, manual processing (with human intervention) of the information we collect and store about you and others.
• We can share information about you for legal, protection, and security reasons. We can share information about you if we have sufficient reasons to believe that such information must be disclosed for the following:
  • Comply with a legal procedure, government request, or valid applicable laws, rules, or norms.
  • Investigate, remedy, or resolve possible violations of our Terms and Conditions.
  • Protect our rights, property, or safety, as well as those of our users and other people.
  • Detect and resolve any fraud or security-related issues.
• We can share information about you as part of a merger or acquisition. If Clob is involved in a merger, asset sale, financing, liquidation or bankruptcy, or in the total or partial acquisition of our business by another company, we can share your information with that company before and after closing the transaction.
• Non-Personal Information. Also, we can share aggregated data that does not allow knowing your personal identity or from which all identity markers have been removed with third parties providing services or carrying out projects for us.

Third-Party Content and Integrations

Our services may have third-party content and integrations. Some examples include third-party integrations in payment gateways. Through these integrations, you might be delivering information to the third party and to Clob. We are not responsible for the way such third parties collect or use the information. As always, we recommend reviewing the privacy policies of all third-party services you visit or use, including those third parties you interact with through our services.

How Long Do We Retain Your Information?

Clob allows you to organize events that will occur in the near future. This means that most events, as well as messages exchanged for such events, and any other service provided by Clob related to it, will automatically be deleted by default from our servers after the event has occurred, that is, by the date indicated in the application for the occurrence of the event in question. Other content, such as information related to an event you have actually attended, will be stored for a longer period. If you ever decide to stop using Clob, you can ask us to delete your account. While our systems are designed to carry out our deletion practices automatically, we cannot guarantee that such deletion will occur within a specific time frame. There might be legal requirements to store data, and we may have to suspend such deletion practices if we receive valid legal process asking us to preserve content, if we receive reports of abuse or other Terms and Conditions violations, or if third parties or our automated systems detect abuse or other Terms and Conditions violations in the account or content created by you. Finally, we may also retain certain information as a backup or for security for a limited period or as required by law.

Control Over Your Information

We want you to have control over your information, and for this, we provide you with the following tools:

• Access, correction, and portability. You can access and edit most of your account's basic information directly in our application. Since your privacy is important to us, we may ask you to verify your identity or provide additional information before allowing access or updating your personal information. We may also reject your request for access or update of personal information for various reasons, for example, if the request risks the privacy of other users or is illegal.
• Revoking permissions. In most cases, if you allow us to use your information, you can simply revoke permission by changing the settings in the app. By doing so, some services may lose their full functionality.
• Deletion. If you ever want to delete your account, you can do so directly in the app.
• Communication with other Users. It is also important for us that you have control over with whom you communicate. For this, we have created a series of tools in settings, which allow you to specify whether you would like to receive invitations only from your friends or from all users and whether you want to block another user so that they cannot communicate with you or see your events.

Child Safety Standards

At Clob, we are committed to keeping our platform free from child sexual abuse and exploitation (CSAE). We strictly prohibit any content or behavior that sexually exploits, abuses, or endangers minors.

• We do not allow child sexual abuse material (CSAM) or any form of child exploitation including grooming, sextortion, or trafficking.
• Users can report inappropriate content through our in-app reporting system or by emailing contact@clob.co with the subject 'Child Safety Report'.
• We investigate all reports immediately and take action including content removal, account suspension, and cooperation with authorities.
• We comply with all applicable child protection laws. Child Safety Contact: contact@clob.co

Account Deletion Process

At Clob, we value your privacy and your right to control your own information. If you decide that you no longer wish to use Clob, we offer an option for you to request the permanent deletion of your account.

How to Carry Out Data Deletion

To carry out the deletion of your account and all your associated personal data, you can follow the detailed instructions at Clob Data Deletion Instructions.

If you experience problems or prefer a more direct approach, you can also send us an email at contact@clob.co, requesting the deletion of your account and your personal data, and we will take care of it for you.

Consequences of Data Deletion

Upon deleting your account:

• All information associated with your account will be permanently deleted and cannot be recovered.
• We do not offer a data retention period after deletion, so the deletion of your account is irreversible.
• Any data we have previously collected will be immediately deleted.

Cessation of Data Collection

Upon requesting the deletion of your data:

• We will immediately cease any future data collection.
• We will delete all your stored personal data that we have collected before your request.

For any questions or inquiries about the data deletion process, do not hesitate to contact us through contact@clob.co.

International Data Transfers

We may collect your personal information, transfer it, store it, and process it in the United States and other countries different from the one in which you reside. Whenever we share information outside of your place of residence, when legally required to do so, we ensure that an appropriate transfer mechanism exists. We also ensure that third parties with whom we share information also have an appropriate transfer mechanism.

Children

Our services are not intended for or directed at individuals under 16 years of age. And that's why we deliberately do not collect personal data from any person under 16 years of age. In some cases, this means that we will not be able to offer certain features to these users. If we need consent as a legal basis to process their information and their country requires parental consent, we may require the consent of one of their parents before collecting and using such information.

Privacy Policy Modifications

We may modify this Privacy Policy periodically. However, when we do, we will notify you in one way or another. Sometimes we will communicate it through a change in the date at the top of the Privacy Policy that is available on our website and in the mobile application. At other times, we will include additional notice (such as a statement on the homepage of our websites or a notification in the app).

If you have questions about any aspect of our Privacy Policy, contact us at contact@clob.co.