As used in these Terms, "Cleo Nitz" means: Cleo Nitz, a French registered company at 38 rue Louis Poterat 76100 Rouen France.

We process Personal Data as a Processor on behalf of the Customer.

Definitions

"Controller" means an entity that determines the purposes and means of the Processing of Personal Data.

"Customer" means a person or entity that is registered with Cleo Nitz to use the Services.

"Data Protection Laws" means all data protection and privacy laws and regulations of the EU, EEA, and their member states, Switzerland and the United Kingdom, applicable to the Processing of Personal Data.

"GDPR" means (a) the Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the Processing of Personal Data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation), and (b) the United Kingdom General Data Protection Regulation.

"Personal Data" means any information relating to an identified or identifiable natural person.

"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, use, storage, adaptation or alteration, retrieval, consultation, alignment or combination, blocking, erasure or destruction. "Process", "Processes" and "Processed" shall be interpreted accordingly.

"Processor" means a natural or legal person, public authority, agency, or any other body which Processes Personal Data on behalf of the Controller.

"Services" means any product or service provided by Cleo Nitz.

“We”, “us”, and “our” refer to Cleo Nitz.

"You," "your," and "yours" refer to the user.

Data Processing

Consent: by accessing our Services, you accept our Privacy Policy and TOU, and you consent to our collection, storage and use as described in this Privacy Policy. Each time you visit our website, and any time you voluntarily provide us with information, you agree that you are consenting to our collection and use of the information that you provide, and you are consenting to receive emails or otherwise be contacted, as described in this Privacy Policy.

Performance of a contract: by utilizing our Services or accessing our platform, you expressly acknowledge our Processing of your Personal Data in compliance with applicable Data Protection Laws. The Processing of your Personal Data is grounded on the legal basis of contract performance between you and Cleo Nitz.

What information we Process

Cleo Nitz collects both “Personal Data” and “Non-Personal Data” about you and will Process this data for the duration of the Services:

Personal Data:

Email, IP addresses, browsing activity, web server logs.

At any time, you may log in and change this information, or remove it. You may decline to provide Personal Data to the Services, however, some of the Personal Data we ask you to provide, for example, the email address is mandatory for a Service. If you decline to provide it, we may not be able to provide that service to you.

Non-Personal Data:

The browser and device information: location, device type, model, number, type of browser or operating system, the time and date of access, screen resolution, plug-ins, add-ons and the version of the Services you are using, and other information that does not personally identify you.

Information from your use of the Services and information from other sources: we may receive information about how and when you use the Services, or other types of files associated with your account, and link it to other information we collect about you. Also, we may obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers, and our joint marketing partners. This information may include, for example, time, date, browser used, demographic information, device information (such as device type, model, number, type of browser or operating system), location, and online behavioral data (such as information about your use of social media websites, page view information and search results and links), actions you have taken, anonymous usage data, referring/exit pages and URLs, preferences you submit and preferences that are generated based on the data you submit and the number of clicks.

Purposes of Processing

Cleo Nitz uses collected information to provide general statistics regarding use of the Service, promote and analyze the Services, to provide customer support and send information about the Services, to send customized informational or promotional content and provide suggestions according to marketing preferences, to understand demographics, Customer interests and needs, and other trends among users, and for other business purposes.

We may combine Personal Data with other information we Process to customize informational content and enhance our ability to provide Services according to marketing preferences, restrictions or for advertising, targeting purposes, personalization of ads, or to develop and provide you with more relevant products and features in accordance with this Privacy Policy.

How we collect your information

Tracking technologies: in connection with the performance of the Services, Cleo Nitz uses:

Cookies: cookies are tiny files of data that a website transfers to your computer's hard disk for record-keeping purposes. Most web browsers are set to accept cookies, but you can change this in your browser settings. We use it to monitor visitor metrics to Cleo Nitz such as page views, time on site, number of visitors, etc.

Web beacons: we include single-pixel gifs (web beacons) in emails we send, which allow us to collect information about when you open the email and your IP address, your browser or email client type, and other similar details. We use the data from those web beacons to create reports, to capture the time spent on the Services, and pages visited.

Unique identifiers and similar tracking technologies: we may use other tracking technologies to administer the Services, track your movements around the Services, analyze trends, track behavior, serve targeted advertisements and gather demographic information, to measure the performance of our email campaigns and to improve our features for specific segments of Customers.

Log Data monitoring: we may collect log data whenever you access our tool. This data could include things like an IP address, browser type, and version, the pages you visit on Cleo Nitz, and other user statistics. When you access Cleo Nitz with a mobile device, log data may include the type of device, your mobile unique ID, the IP address of your device, mobile operating system, and other mobile statistics.

Third-party services: we may use third-party services, such as Google Analytics and Facebook, that collect and analyze log data to help us improve, and occasionally to use for targeted online advertising. Our third-party partners may use cookies or other tracking technologies to provide you advertising on other sites based on your browsing activities and interests. You can find more information about these practices, including how to opt out of receiving targeted advertising here: http://www.aboutads.info/choices/.

Based on the requirements of the California Online Privacy Protection Act, Cleo Nitz declares that it does not correspond to Do Not Track browser signals.

Transferring to third-party companies

We will never sell, rent, or lease your Personal Data to a third party, but we may share collected information for the purposes described in this Privacy Policy with third parties, including group companies, that help Cleo Nitz provide, improve, promote or support Services, that help with our business operations and assist in the delivery of our Services, or who perform services for us, in order to prevent damage to our property or for safety reasons, for example, hosting services, analytics, content delivery services, advertising partners, etc., in a manner that is consistent with this Privacy Policy. We may also share information with third parties if required to do so by law.

We may disclose Non-Personal Data for any purpose because this information cannot be used to identify you or another person.

Email communications & opting out

We may use your Personal Data to send you updates and other promotional communications. Every email will contain a link to be able to opt-out of receiving it.

Safety of your information

Cleo Nitz takes reasonable precautions, technical and organizational security measures to ensure a level of security appropriate to the risk, follows industry best practices in order to protect your Personal Data from any unauthorized or unlawful breach of security that leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to Personal Data and to preserve the security and confidentiality of the data. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such precautions. By using our Service, you acknowledge that you understand and agree to assume these risks.

The customer is responsible for reviewing the information made available by Cleo Nitz relating to its data security and making an independent determination as to whether the Services meet Customer’s requirements and legal obligations under Data Protection Laws. Also, Customer is responsible for its secure use of the Services, including securing its account authentication credentials, protecting the security of Personal Data when in transit to and from the Services and taking any appropriate steps to securely encrypt or backup any Personal Data uploaded to the Services.

Links to other websites

As part of the Service, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Service. Therefore, this Privacy Policy does not apply to your use of a third-party website accessed by selecting a link via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

Data Processing Addendum

We created our Data Processing Addendum to cover the GDPR requirements as they relate to email marketing and we encourage all our Customers to review it here.

Age of consent

By using the Service, you represent that you are at least 16 years of age.

California Consumer Privacy Act

According to The California Consumer Privacy Act (“CCPA”) residents of California, United States have specific rights regarding their Personal Data. California consumers have the right to 1) request that businesses disclose information about their collection and use of Personal Data over the past year; 2) ask such businesses to delete Personal Data; 3) opt-out of the sale of their Personal Data.

Cleo Nitz in terms of CCPA acts as a service provider and we process Personal Data on our Clients behalf. Please direct any requests for access or deletion of your Personal Data to our Clients with whom you have a direct relationship.

Cleo Nitz as a Controller

Cleo Nitz acts as a Controller of Personal Data of its employees, contractors, candidates, affiliates and other third parties that are not considered as a Customer. Cleo Nitz undertakes to comply with legal requirements when processing Personal Data as a Controller and implements appropriate technical and organizational measures to ensure a level of security of Personal Data as required under GDPR and applicable Data Protection Laws.

Changes

Cleo Nitz reserves the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy, we will post these changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it. All changes are effective immediately upon posting and we suggest that you check this Privacy Policy periodically if you are concerned about how your information is used.

Contacting Cleo Nitz

If you would like to request access to the information we hold about you, correct, modify, delete or update Personal Data that you have provided to us, or have any questions regarding this Privacy Policy or the practices of this site, wish to withdraw your consent for the continued collection, would like to object to your Personal Data being used, or have any additional questions:
Please contact us any time by mail at contact@cleonitz.com.