This Privacy Policy is an integral and indivisible part of the Terms and Conditions (TOS) Clinkky together with the Terms of Use and Copyright Policy.

Important: To claim your rights about privacy and data protection, please contact us via email to contact@clinkky.com.

We know what it means for your privacy. That’s important to us. We are committed to providing transparency in our privacy practices and control of our Clinkky service related to data (as defined in the Terms of Use). We work in accordance with the Data Protection Act (Spain), the LPDP (Uruguay), COPPA (USA), Directive 95/46 / EC Regulation 2016/679 of the European Parliament and other rules related to personal data protection . In addition, Clinkky will not send messages or unsolicited emails to people outside the relationship with the user of our services and will adapt to the rules on control and prevention of SPAM, in accordance with the CAN-SPAM Act (US). By using the service, you accept the practices described in this Privacy Notice. If you disagree with the terms of this Privacy Notice, please do not use our services. If you wish to exercise your data protection rights, you must send an email to administracion@clinkky.com. Each time you use our services, you must confirm the date of its Privacy Notice and review the changes that have taken place since your last visit, which are considered updates.

PERSONAL INFORMATION COLLECTED BY CLINKKY
We do receive and store any information you enter on our service or you give us. The types of personal information collected may include personal user data as well as information regarding the use of our service, and navigation information, but NEVER the content exchanged by users. The personal information you provide will be used for the purpose of statistical analysis. We can also use this personal information in order to adapt the proposals of our range of services Clinkky to your needs, or for research on the effectiveness of our network and the development of new tools for you. By using the Service, Clinkky automatically receives and records information on our server and on the mobile platform. We treat this information as personal information in compliance with data protection and data pricavy laws, especially those concerning the personal data of minors, except when we are obliged to do so under applicable law. Unless otherwise stated in this Privacy Policy, Clinkky only uses this data globally and respects the privacy, privacy and data protection. We can provide comprehensive information to our partners about how our users, collectively use our service, so that our partners can understand how frequently and several circumstances, people use our application, but never identify a user.


SHARED INFORMATION
The personal information of our users is an integral part of our service. We do not sell or rent your personal information to anyone. Clinkky may share your personal information only as described in this Privacy Policy and related documents.

AGENTS AND EMPLOYEES OF OUR COMPANY
We may celebrate contracts with other companies and individuals to perform functions on our behalf and we could need to share your information with them to provide products or services. Our agents are entitled to use the information we share with them and to provide an adequate level of protection for personal data and sensitive data. Clinkky will celebrate contracts with its suppliers, demanding a policy of protection of personal data of users, based on these Terms of Service and applicable laws and encourage them to adopt our Code of Practice within a Non Disclosure Agreement regarding treatment of personal information and sensitive data.

COOKIES AND TRACKING TECHNOLOGY
Cookies are small data files that are stored on your computer, mobile phone or other device. We and our agents use tracking technologies within our platform to offer a wide range of products and services. By continuing to use our service through your computer or mobile device, you accept the use of our technology.

CHANGES IN PRIVACY POLICY
Clinkky may amend this Privacy Notice occasionally. The use of information we collect now is subject to the Privacy Policy in effect at the time of using such information. If we make any substantial change in the way we use your personal information, we will notify you when you access our service. Users are required to read the changes in this privacy notice to use the Service after the posting of such changes.

PRIVACY POLICY AND MINORS
This service does not allow the entry to persons under 13 years, except when under that age, they enter with the knowledge, consent and control of their parents or guardians. The service has no way to verify the age of entering users when they register, or the identity of persons entering, therefore, it is the sole responsibility of their parents or guardians to check if the child enters to the Service. However, if Clinkky warns that a user is a minor and has entered or registered in our services fraudulently, the company will act immediately according to what is described in the document TERMS OF USE, paragraph USE PUBLICATIONS AND COMMUNICATIONS PROHIBITED. Regarding the Children’s Online Privacy Protection Act (COPPA), Clinkky hereby announces that will collect personal information from minors, only for the purposes described in the Terms of Use and the purpose of the proper functioning of the service, adopting relevant and safety measures for it. Clinkky also adopts the Code of Practices for the Personal Data and Privacy Protection for the purpose of further compliance. In this line with current regulations, we adopt the following policy Clinkky data processing:

  1. Post this Privacy Policy, easily understood and easily accessible on the Web as well as in the App
  2. Request the informed consent from parents before children can give their data, and to use the services to collect personal information.
  3. Parents have the option to exercise their rights through email contact@clinkky.com.
  4. It is available to parents to access to all information collected from their minor children, by express request by email contact@clinkky.com.
  5. We do not share personal information with third parties from their children unless those third parties are a fundamental part of running Clinkky (Example: company servers or IT security company).
  6. We adopt security measures to safeguard personal information from children, during collection, communication, treatment and disposal of data, including encryption policies to ensure confidentiality and security. An agreement was adopted as set out in our internal Policy Privacy and Code of Practices, both available for consultation through the website Clinkky.
  7. Once completed the object of the collection, maintenance and processing of personal data from one holder, we will proceed to its destruction.
  8. It is included within the meaning of “Personal Information” for the purpose of extending the coverage of this policy, data related to 1) geolocation, 2) images, photos and videos, 3) audio, and 4) persistent identifiers performing that track the activity of users across your Internet browsing or Apps.

CONTACT
You can contact us regarding any questions about the service, through contact@clinkky.com.
We will do our best to answer your questions or concerns promptly.

ANEX
“FUNDAMENTAL RIGHTS, SENSITIVE DATA AND MINORS”

This Annex is an integral and indivisible part of the Terms of Use of Clinkky. The same refers to the special protection of sensitive data in the Law 18331 on Protection of Personal Data and Habeas Data, and the protection of other fundamental rights collected in the different constitutions, charters and supranational regulations (EU) in their respective countries, as well as COPPA and CalOPPA (both US) laws. Note that fundamental rights and especially sensitive data related or possibly related to the minority are especially protected and can not be violated under any circumstances. Also, due to its special protection, violation thereof is subject to more severe civil, administrative and criminal penalties. Clinkky supports and promotes the improvement and effectiveness in the application of this rules, and we can dictate and adopt self-regulatory codes whose purpose will be further application of these laws, especially those related to privacy and data protection of individuals. For this reason, the User agrees to refrain from using the Service for or harmful effects of the rights and interests of others or in any way damage, disable, overburden, or impair the Service or prevent the normal use or enjoyment of the Service by Users. In particular, the User agrees not to transmit, distribute or make available to third parties through the Service, information, messages, graphics, sound files and / or images, photographs, recordings, software and generally any kind of material, data or content that: (a) in any way is contrary, disparage or violates fundamental rights and civil liberties constitutionally recognized in international treaties and other legislations; (B) induce, incite or promote criminal, slanderous, defamatory, violent, pornographic (including the content established in the CAN-SPAM Act, USA) or in general, contrary to law, morality or Public order; (C) induce, incite or promote actions, attitudes or discriminatory ideas on grounds of age, sexual orientation, race, religion, beliefs, social class; (D) include criminal, violent, pornographic and / or child molestation, degrading or in general, contrary to law, morals or public order messages; (E) induces or could induce an unacceptable state of anxiety or fear; (F) induce or incite involvement in dangerous, risky or harmful to health and mental balance; (G) be false, ambiguous, inaccurate, exaggerated or invented, so deceptive about its purpose or the intentions or purposes of communicating (including Portrayal in a False Light); (H) are protected by any intellectual or industrial property belonging to third parties without having previously obtained from the owners permission to carry out the use made or intended; (I) violate the secrets of third parties; (J) infringe the right to honor, personal and family privacy or image of individuals; (K) infringe regulations on privacy of communications; (L) constitute, if any, illegal, deceptive or unfair and, in general constitute unfair competition; (M) cause its characteristics (such as format, extension, etc.) difficulties in the normal functioning of the Service; (N) HTML tags contain hidden information that may violate the terms of this contract.

Modified: October 2016