Privacy | My Site

Introduction

CLASP is strongly committed to maintaining the privacy of your personal data.

CLASP Privacy Policy will help you better understand how we collect, use and share your personal information.

By using clasp.finance website you consent to the data practices described in this privacy policy.

If we change our privacy practices, we may update this privacy policy. If any changes are significant, we will let you know (for example, through the email).

If you have any questions about this Privacy Policy or CLASP privacy practices, please contact us at jja@clasp.finance

Why we process your information

We generally process your information under the following legal basis:

· To fulfil our contractual obligation to you (for example, provide and maintain CLASP services) or in order to take steps at your request prior to entering into the contract

· Where we or someone we work with needs to use your personal information for a legitimate interest related to their business (for example, answer questions or provide other types of support, preventing risk and fraud, providing and improving services, developing new content, features and functionality)

· For compliance with legal obligation we may be subject to

What information we collect about you and why

We collect the following personal information about you when you access and use CLASP website, when you use our services or when you otherwise provide us with this information (for example, fill in application form for our services or contact us directly through email, phone or contact form on clasp.finance website):

1. What we collect:

· Contact information, including name, email, phone, skype name

· Company information, including company and brand name, website URL

· Additional personal information/attachments we may request or you choose to provide us

How we use it:

· If we need to verify your identity (for example, to protect you against identity theft or fraud); to verify that we are speaking with you if you contact us

· To provide you with our services (for example, to contact you about issues with the platform)

· To comply with legal requirements

2. What we collect:

· Information about how you access our website, including information about the device and browser you use, your network connection, your IP address. We collect some of this information by using cookies. A cookie is a small amount of information that’s downloaded to your computer or device when you visit certain websites allowing our web servers to recognise you.

How we use it:

· We only use essential first party cookies that help us provide you with the service and are essential for our website to work.

If personal information you provided to us or its processing purpose is not indicated in this privacy policy, it will be made clear to you at the point we ask you to provide your personal information.

When and why we share your information with others

While providing our services, we may share your personal information with third party processors, however, we share your personal information to as minimum third party processors as possible in order to lower the risks of your personal information being exposed. We also assess and review each third party processor we work within order to make sure they ensure similar and compliant privacy practices.

We may share your data with third party processors in the following cases:

1. In case of business transfers. Information may be disclosed and otherwise transferred to any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

2. When required by legal regulation and similar disclosures in order to (1) satisfy any applicable law, regulation, legal process, or governmental request; (2) enforce this Privacy Policy, including investigation of potential violations hereof; (3) detect, prevent, or otherwise address fraud, security, or technical issues; (4) respond to your requests; or (5) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organisations for fraud protection and spam/malware prevention.

3. When information transfer is consented by you.

How we protect your information:

We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of personal information, including access control to limited number of personnel to protect personal information in our possession against unauthorised access, destruction, loss, or misuse. We follow generally accepted industry standards to protect personal information during transmission and once received by us. However, we all know that no method of transmission over the Internet, and method of electronic storage, can be 100% secure. This means we cannot guarantee the absolute security of your personal information.

Data retention

We retain your personal information as long as we have ongoing legitimate interest to do so (for example, providing the services to you). We retain personal information after we cease providing Services to you to the extent necessary to comply with applicable legal requirements. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law. When we have no ongoing legitimate interest to process your personal information, we will either delete or anonymise it.

Children information

Our service is not directed to children under 18 and does not knowingly collect personal information from children under the age of 18. If you are under the age of 18, you must ask your parent or guardian for permission to use this website. If we learn that we have collected personal information of a child under 18, we will take the appropriate steps to erase such information from our database as soon as possible. If you learn that a child has provided us with personal information in violation of this Privacy Policy, you can inform us at hello@clasp.finance.

INTERNATIONAL DATA TRANSFERS

As an entity serving users across the world and providing CLASP services through the use of third party processors, we may transfer personal information to other countries than the country where the information was originally collected. When we transfer your personal information to other countries, we will protect that information and transfer it to countries that have strong data protection laws.

If you would like more information about where your information might be sent, please contact us.

Your rights over your information

You have the following rights with regard to the personal information we store and process about you:

· The right to access your personal information. You have the right to obtain from us confirmation as to whether or not personal information concerning you is processed, and, where that is the case, you have the right to request and get access to that personal data

· The right to request us to rectify or update your personal information that is inaccurate, incomplete, or outdated

· The right to request us to erase your personal information

· The right to request us to restrict the use of your personal information

· The right to request us to export to another company, where technically feasible, your personal information that we hold in order to provide services to you

· You may also have the right to object to the processing of your personal information on grounds relating to your particular situation

· Right to be Not Subject to Automated Individual Decision-Making. You have the right to not be subject to a decision based solely on automated processing

In order to exercise your data protection rights, you may contact us via email hello@clasp.finance. We take each request seriously. We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your personal information. If you are not happy with our response to a request, you can contact us to resolve the issue. You also have the right to contact your local data protection or privacy authority at any time.

For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file.

GDPR

Based on the European Parliament and Council Regulation No 2016/679 date on April 27, 2016 on the protection of natural person with regard to the processing of personal data and the free movement of such data, repealing the Directive 95/46/EC (General Data Protection Regulation) including Article 6 (b), by using this website I agree my personal and business data, referred to the Merchant application form and provided during further collaboration while managing Merchant application, to be processed, as well as to receive my personal and business data from the third parties during a period and purpose of managing Merchant application and collaborating in connection to it.

If you have any questions regarding these Privacy Policy, please contact us by email at jja@clasp.finance

Last Updated 12 January, 2023

When and why we share your information with others

​

Your rights over your information