1. Who We Are
Clever DATA is a Data as a Service (DaaS) platform operated from the Republic of Ireland. In this Privacy Policy, "Clever DATA", "we", "us" and "our" refer to Clever DATA. We are the data controller in respect of the personal information we collect through this website and our service, and we comply with the General Data Protection Regulation (EU) 2016/679 as applied in Ireland and the Irish Data Protection Act 2018.
For the avoidance of doubt: Clever DATA is a data platform and is not a marketing agency, digital marketing agency or advertising agency. We do not run marketing campaigns on behalf of our clients - we provide them with audience data and the tools to use it.
2. What Information We Collect
2.1 Information you give us directly
- Account information - your name, email address, phone number, company name and password when you create an account.
- Onboarding answers - the answers you give to Dara, our AI voice onboarding assistant, or to a member of our onboarding team, during the 10-question conversation used to build your audience brief.
- Billing information - your billing address and VAT number where relevant. We do not store your full card details (see clause 2.3).
- Booking information - when you book a demo or call with us through our scheduling system, we collect the details you enter on the booking form (name, email, phone, and answers to our qualifying questions about your advertising).
- Communications - any emails, support tickets or messages you send us.
2.2 Information we collect automatically
- Device and browser data - your IP address, browser type and version, operating system and screen resolution.
- Usage data - pages you visit, time spent on each page, referral source, and the actions you take on our site.
- Cookies and similar technologies - see clause 6.
2.3 Information we do not collect or store
- Full payment card details - all card payments are processed by Stripe Payments Europe Ltd in a PCI-DSS compliant environment. Clever DATA only receives a tokenised reference to your card, never the full number, CVV or expiry.
- Special category data - we do not knowingly collect health data, biometric data, data revealing racial or ethnic origin, political opinions, religious beliefs, trade union membership, or data concerning sex life or sexual orientation.
3. How We Use Your Information
- To deliver the Service and build the audiences you request
- To operate and secure your account and verify your identity
- To process payments and send invoices
- To schedule and manage calls and demonstrations you have booked with us
- To communicate with you about your orders, renewals and service announcements
- To respond to your questions and support requests
- To improve our Service, including product development and user experience research (using aggregated or anonymised data wherever possible)
- To comply with our legal obligations and to detect, prevent and respond to fraud, misuse or security incidents
4. Legal Bases for Processing (GDPR)
Under the GDPR, we only process your personal data when we have a lawful basis to do so. The lawful bases we rely on are:
- Performance of a contract - to provide the Service you have signed up for.
- Legitimate interests - to run and improve our business, prevent fraud, secure our systems, and where appropriate, contact business prospects on our own terms with relevant commercial information.
- Consent - for optional cookies, analytics and marketing emails where consent is required.
- Legal obligation - to comply with tax, accounting, anti-money-laundering and other statutory duties.
You can withdraw your consent at any time where consent is the legal basis.
5. Who We Share Your Information With
We do not sell your personal data. We share personal data only with:
- Service providers who help us run the business - for example, hosting providers, email providers, our CRM, Stripe Payments Europe Ltd for payments, and GoHighLevel for bookings and appointment management. Each provider is bound by a written agreement to process your data only on our instructions.
- Licensed Data Providers - strictly for the purpose of fulfilling your specific audience request, and only the minimum information required to do so.
- Our professional advisers - lawyers, accountants and auditors bound by duties of confidentiality.
- Authorities - where required to comply with law, a court order or a regulatory investigation, or where it is necessary to protect our rights or the rights of others.
- A buyer or successor - if we merge, sell or transfer part of our business, your personal data may be transferred as part of that transaction, subject to equivalent protections.
6. Cookies and Tracking Technologies
We use cookies and similar technologies (pixels, local storage) for the following purposes:
- Strictly necessary cookies - required for the site to function, for example to keep you logged in or to remember your consent choices. These do not require your consent.
- Analytics cookies - help us understand how visitors use the site. Where these identify you, we ask for your consent first.
- Third-party cookies - our booking widget and payment flow set cookies provided by GoHighLevel and Stripe respectively, subject to their own privacy policies.
You can control cookies through your browser settings or through any consent banner we display on the site.
7. How Long We Keep Your Information
- Active account data - kept for as long as your account is active.
- Billing and tax records - kept for the period required by Irish tax law (currently six years from the end of the accounting period).
- Onboarding answers - kept for the lifetime of your account, and for up to 12 months after account closure, to allow for renewal and audit.
- Marketing preferences - kept until you opt out.
- Closed accounts - personal data is deleted or anonymised within a reasonable period after closure, unless retention is required by law.
8. Where Your Data is Processed
Clever DATA's servers and primary data processing take place within the European Economic Area (EEA). Some of our service providers (including Stripe, GoHighLevel, and certain Data Providers) may process data outside the EEA, including in the United States.
Where personal data is transferred outside the EEA, we rely on one of the following safeguards: (i) an adequacy decision of the European Commission, (ii) Standard Contractual Clauses, or (iii) another lawful transfer mechanism under the GDPR. We will make a copy of those safeguards available on request.
9. Your Rights Under GDPR
You have the following rights in respect of your personal data:
- Right of access - obtain a copy of the personal data we hold about you.
- Right to rectification - ask us to correct inaccurate or incomplete data.
- Right to erasure - ask us to delete your data, subject to our legal retention obligations.
- Right to restriction of processing - ask us to pause processing in certain circumstances.
- Right to data portability - receive your data in a portable format.
- Right to object - object to processing based on our legitimate interests, including direct marketing.
- Right to withdraw consent - at any time, where consent is the legal basis.
- Right to lodge a complaint - with the Irish Data Protection Commission at dataprotection.ie.
To exercise any of these rights, contact us through our contact page. We will respond within one month, as required by the GDPR. We may need to verify your identity before responding.
10. Security
We use industry-standard technical and organisational measures to protect your personal data, including encryption in transit (HTTPS/TLS), access controls, regular backups and staff training. However, no electronic transmission or storage is ever 100% secure, and we cannot guarantee absolute security.
If we become aware of a personal data breach likely to result in a risk to your rights and freedoms, we will notify the Irish Data Protection Commission within 72 hours and, where required, notify you without undue delay.
11. Children's Privacy
Clever DATA is a business-to-business service and is not directed to children under the age of 18. We do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us with personal data, please contact us and we will delete it.
12. Third-Party Links
Our website may link to third-party websites and platforms, including the websites of our social media presences, service providers and Data Providers. We are not responsible for the privacy practices of those third parties. We recommend you read the privacy policies of any third-party site you visit.
13. Changes to This Policy
We may update this Privacy Policy from time to time. When we do, we will post the revised policy on this page with a new effective date and version number. Material changes will be communicated to active Clients by email or through a prominent notice on the site. Your continued use of the Service after a change constitutes acceptance of the updated Policy.
14. Contact Us
For privacy questions, data subject requests, or any other matter relating to this Policy, please contact us through our contact page.
Clever DATA
An Irish company registered in the Republic of Ireland
Website: cleverdata.ie
This Privacy Policy is provided in English. In the event of any discrepancy with a translated version, the English text shall prevail.