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SURVEHEY PRIVACY POLICY 

By accessing or using SurveHey Rewards (the “Application”), an application owned and maintained by Aclaro Inc. (“Company”, “we,” “us” or “our”), you consent to the information collection, disclosure and use practices described in this Privacy Policy. This Privacy Policy applies to all Services provided by us and sets out how we may collect, use and disclose information in relation to users of the Application. 

We use advanced machine learning algorithms to help businesses in the automotive sector create stronger relationships with their current and potential customers. In order to achieve our objective, we develop AI solutions for businesses to predict customer behaviors, purchasing needs, loan risk repayment and loan qualification. (“Services”) The purpose of our application is to do B2B Marketing, have social presence and to capture leads. We use social activity, job history, payment history, demographics of potential as well as existing customers of our clients (“Business Clients”). 

The way we handle customer’s data as provided to us by our Business Clients is regulated by the separate Terms and Conditions. This Privacy Policy only applies to Application users, Business Clients, and any/all other users of the application. By using the application or Services, you agree to this Privacy Policy, without modification, and acknowledge reading it. 

Use of the application, including all materials presented herein and all Services provided by us, is subject to separate Terms and Conditions and the following Privacy Policy.  

  1. Information We Collect 
    1. Your privacy is important to us and we have taken steps to ensure that we do not collect more information from you than is necessary for us to provide you with our services and to protect your account.We may process the following categories of personal data about you: 
      1. Communication Data may include any communication that you send to us whether that be through the contact form on our Application, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims. 
      2. Client Data may include data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We use your email to communicate with you about your order and to manage our customer relationship with you. When you contact us through any of the communication modes as mentioned hereinabove, your email address may be added to our mailing list from which you can unsubscribe at any time using the unsubscribe link in each email or by contacting us at support@aclaro.io 
      3. User Data may include data about how you use our Application and any online services together with any data that you post for publication on our Application or through other online services. We process this data to operate our Application and ensure relevant content is provided to you, to ensure the security of our Application, to maintain back-ups of our Application and/or databases and to enable publication and administration of our Application, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our Application and our business. 
      4. Technical Data may include data about your use of our Application and online services such as your IP address, your login data, details about your browser, length of visit to pages on our Application, page views and navigation paths, details about the number of times you use our Application, time zone settings and other technology on the devices you use to access our Application. The source of this data is from our analytics tracking system. We process this data to analyses your use of our Application and other online services, to administer and protect our business and Application, to deliver relevant application content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our Application and our business and to grow our business and to decide our marketing strategy. 
      5. Marketing Data may include data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant application content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy. 
        We may use Client Data, User Data, Technical Data and Marketing Data (the “Data”) to deliver relevant Application content and advertisements to you and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. 
    2. Consent and its Withdrawal 
      1. When you use our Application you provide us consent to use your Data as per this Privacy Policy. In order to provide you with the Services, it is necessary for us to collect all relevant and necessary Data about you from you. 
      2. If you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at support@aclaro.io 
    3. How We Use and Process the Data 
      1. The Data collected by us from you may be used to provide you with Services and better understand your needs related services and programs, to correspond with you and reply to your questions with about our services. 
      2. We will not rent or sell your Data to others. We may store the Data in locations outside the direct control of the Company (for instance, on servers or databases co-located with hosting providers). 
      3. If you provide any Data to us, you are deemed to have authorized us to collect, retain and use that data for the following purposes: 
        1. verifying your identity; 
        2. providing you with customer service and responding to your queries, feedback, or disputes; 
        3. making such disclosures as may be required for any of the above purposes or as required by law, regulations and guidelines or in respect of any investigations, claims or potential claims brought on or against us; 
        4. provide and maintain the Services; 
        5. notify you about changes to our Services; 
      4. We shall ensure that: 
        1. The Data collected and processed for and on our behalf by any party is collected and processed fairly and lawfully; 
        2. You are always made fully aware of the reasons for the collection of Data and are given details of the purpose(s) for which the data will be used; 
        3. The Data is only collected to the extent that is necessary to fulfil the purpose(s) for which it is required; 
        4. No Data is held for any longer than necessary in light of the purpose(s) for which it is required. 
        5. Whenever cookies or similar technologies are used online by us, they shall be used strictly in accordance with the law; 
        6. You are informed if any data submitted by you online cannot be fully deleted at your request under normal circumstances and how to request that the we delete any other copies of that data, where it is within your right to do so; 
        7. All Data is held in a safe and secure manner taking all appropriate technical and organisational measures to protect the data; 
        8. All data is transferred securely, whether it is transmitted electronically or in hard copy. 
        9. You can fully exercise your rights with ease and without hindrance. 
    4. Disclosure of Data 
      1. We shall not be able to keep your Data private in response to legal process i.e., a court order or a subpoena, a law enforcement agency’s request. If, in our view, it is deemed appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, or as otherwise required by law, we may be compelled to disclose the Data and Personal Data. Moreover, in case of takeover, merger or acquisition, we reserve a right to transfer your data to new platform. 
      2. We may disclose the  Data in the good faith belief that such action is necessary to: 
        1. We may disclose the  Data in the good faith belief that such action is necessary to: 
        2. We may disclose the  Data in the good faith belief that such action is necessary to: 
        3. comply with a legal obligation 
        4. protect and defend our rights or property  
        5. prevent or investigate possible wrongdoing  
        6. protect the personal safety of users of the Service or the public 
        7. protect against legal liability 
        8. When necessary, we may also disclose and transfer your Data to our professional advisers, law enforcement agencies, insurers, government and regulatory and other organizations. 
    5. Data Storage 
      1. Your Data may be stored and processed at the servers in the United States, Europe, or any other country in which the Application or its subsidiaries, affiliates or service providers maintain facilities. 
      2. The Application may transfer Data to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. 
      3. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information. 
      4. We will only retain your Data preferably for 7 years or for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, see section regarding insurance requirement and reporting requirements. When deciding what the correct time is to keep the Data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements. 
    6. How We Protect Your Information 
      1. We store all the Data submitted by you through the Application at a secure database. 
      2. We are concerned with protecting your privacy and data, but we cannot ensure or warrant the security of any data you transmit to or guarantee that your Data may not be accessed, disclosed, altered or destroyed by breach of any of our industry standard physical, technical or managerial safeguards. 
      3. No method of transmission over the Internet or method of electronic Therefore, we cannot guarantee its absolute security. If you have any questions about security of our Application, you can contact us at support@aclaro.io 
      4. Any Data supplied by you will be retained by us and will be accessible by our employees, any service providers engaged by us and third parties. 
    7. The rights of Users 
      1. You may exercise certain rights regarding your Data processed by us. In particular, you have the right to do the following: 
        1. Withdraw consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your Data. 
        2. Object to processing of Data. You have the right to object to the processing of your Data if the processing is carried out on a legal basis other than consent.  
        3. Access to the Data. You have the right to learn if Data is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing. 
        4. Verify and seek rectification. You have the right to verify the accuracy of your Personal and other Data and ask for it to be updated or corrected. 
        5. Restrict the processing of your Data. You have the right, under certain circumstances, to restrict the processing of Data. In this case, we will not process your Data for any purpose other than storing it. 
        6. Have the Data deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of the Data from us.
      2. You may initiate request with us at support@aclaro.io to exercise any of the above mentioned rights. We shall review your request and, in our own discretion, honor your request, if deemed necessary by us, within reasonable time.    
    8. Compliance with the GDPR 
      1. For users based in the European Union (EU), the Application shall make all reasonable efforts to ensure that it complies with The General Data Protection Regulation (GDPR) (EU) 2016/679 as set forth by the European Union regarding the collection, use, and retention of Data from European Union member countries. The Application shall make all reasonable efforts to adhere to the requirements of notice, choice, onward transfer, security, data integrity, access and enforcement. 
    9. Cookies 
      1. This Application uses cookies to better the users experience while using the Application. Where applicable this Application uses a cookie control system allowing the user on their first visit to the Application to allow or disallow the use of cookies on their computer / device. 
      2. Cookies are small files saved to the user’s computers’ or mobile devices’ hard drive or memory that track, save and store information about the user’s interactions and usage of the Application. This allows the Application, through its server to provide the users with a tailored experience within this Application. 
      3. Users are advised that if they wish to deny the use and saving of cookies from this Application on to their mobile devices hard drive they should take necessary steps within their web browsers security settings to block all cookies from this Application and its external serving vendors.
      4. We may gather certain information automatically and store it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and click stream data. We may use this information, which does not identify individual users, to analyze trends, to administer the Application, to track users movements around the Application and to gather demographic information about our user base as a whole.  
      5. We may track the referring URL (the web page you left before coming to the Application) and the pages, links, and graphics of the Application you visited. We do so because it allows us to evaluate the reputation and responsiveness of specific web pages and any promotional programs we may be running. 
    10. Third Party Links 
      1. The Application may contain links to third-party websites, plug-ins and applications. Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you on our Application. Other applications accessible through our site via links or otherwise have their own policies in regard to privacy. We are not responsible for the privacy policies or practices of third parties. When you leave our Application, we encourage you to read the privacy notice of every website you visit. 
    11. Changes to this Privacy Statement 
      1. We may modify these this Privacy Policy from time to time, and any such change shall be reflected on the Application with the updated version of the Privacy Policy and you agree to be bound to any changes to the updated version of Privacy Policy when you use the Application or its services.
      2. You acknowledge and agree that it is your responsibility to review this Application and this Policy periodically and to be aware of any modifications. Updates to this Policy will be posted on this page.  
      3. Also, occasionally there may be information on the Application that contains typographical errors, inaccuracies or omissions that may relate to service descriptions, pricing, availability, and various other information, and the Application reserves the right to correct any errors, inaccuracies or omissions and to change or update the information at any time, without prior notice.
    12. Contact US 
      1.  If you have questions about our Privacy Policy, please contact us via email: legal@aclaro.io