Privacy Policy of Clicks

Full policy

Owner and Data Controller

Clicks Pte. Ltd.
2 Venture Drive #14-02 Vision Exchange Singapore 608526

Owner contact email: support@clicks.realestate

Types of Data collected

Among the types of Personal Data that Clicks collects, by itself or through third parties, there are: first name; last name; phone number; email address; profile picture; social media accounts; username; password; Usage Data; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); device information; geography/region; number of Users; number of sessions; session duration; in-app purchases; Application opens; Application updates; launches; operating systems; Data communicated while using the service; IP address; various types of Data; country; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; session statistics; city; browser information; ZIP/Postal code; company name; date of birth; geographic position; language; precise location; coarse location; payment info; purchase history; billing address; browsing history.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Clicks.
Unless specified otherwise, all Data requested by Clicks is mandatory and failure to provide this Data may make it impossible for Clicks to provide its services. In cases where Clicks specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by Clicks or by the owners of third-party services used by Clicks serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through Clicks.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Clicks (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Hosting and backend infrastructure, Registration and authentication, Managing contacts and sending messages, Social features, Infrastructure monitoring, Analytics, Advertising, Tag Management, Displaying content from external platforms, Contacting the User, Collection of privacy-related preferences, Content commenting, Data transfer outside of the UK, Data transfer outside the EU, User database management, Traffic optimization and distribution, Spam and bots protection, Location-based interactions and Handling payments.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Advertising

  This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on Clicks, possibly based on User interests.
  This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
  Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside Clicks.
  For more information, please check the privacy policies of the relevant services.
  Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section in this document.

  Google Ads conversion tracking (Google LLC)

  Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Google Ads advertising network with actions performed on Clicks.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

  Google AdSense (Google LLC)

  Google AdSense is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. This service uses the “DoubleClick” Cookie, which tracks use of Clicks and User behavior concerning ads, products and services offered.
  Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

  In order to understand Google's use of data, consult Google's partner policy.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

  Google Ad Manager (Google LLC)

  Google Ad Manager is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
  In order to understand Google's use of Data, consult Google's partner policy.
  This service uses the “DoubleClick” Cookie, which tracks use of Clicks and User behavior concerning ads, products and services offered.  

  Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

• Analytics

  The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

  Google Analytics for Firebase (for apps) (Google LLC)

  Google Analytics for Firebase (for apps) or Firebase Analytics is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
  In order to understand Google's use of Data, consult Google's partner policy.

  Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.

  Clicks uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.

  Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.

  Personal Data processed: Application opens; Application updates; device information; geography/region; in-app purchases; launches; number of sessions; number of Users; operating systems; session duration; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; geolocation data.

  This processing constitutes:

  • a Sale in California

  Google Analytics 4 (Google LLC)

  Google Analytics 4 is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of Clicks, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
  In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.

  In order to understand Google's use of Data, consult Google's partner policy.

  Personal Data processed: number of Users; session statistics; Trackers; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

  Google Analytics Advertising Reporting Features (Google LLC)

  Google Analytics on Clicks has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).

  Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

  Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

  Google Analytics Demographics and Interests reports (Google LLC)

  Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for Clicks (demographics means age and gender Data).

  Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

  Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

  Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

  Google Analytics Granular location and device data collection (Google LLC)

  Google Analytics on Clicks has granular data collection activated which collects location and device data on a per-region basis. It allows the Owner to create and analyze User reports that rely on those metrics.

  Personal Data processed: browser information; city; device information; number of Users; session statistics; Trackers; Usage Data.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

  Google Looker Studio (Google LLC)

  Google Looker Studio is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that creates reports of data gathered in an aggregated way from different sources.

  Personal Data processed: city; company name; country; Data communicated while using the service; date of birth; device information; email address; first name; geographic position; language; last name; password; phone number; Usage Data; username; ZIP/Postal code.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; geolocation data; inferences drawn from other personal information.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

• Collection of privacy-related preferences

  This type of service allows Clicks to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.

  iubenda Consent Database (iubenda srl)

  The iubenda Consent Database allows to store and retrieve records of Users’ consent to the processing of Personal Data, and information and preferences expressed in relation to the provided consent.
  In order to do so, it makes use of a Tracker that temporarily stores pending information on the User’s device until it is processed by the API. The Tracker (a browser feature called localStorage) is at that point deleted.

  Personal Data processed: Data communicated while using the service; IP address; Trackers.

  Place of processing: Italy – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  iubenda Privacy Controls and Cookie Solution (iubenda srl)

  The iubenda Privacy Controls and Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information, and in particular to the use of Cookies and other Trackers on Clicks.

  Personal Data processed: IP address; Trackers.

  Place of processing: Italy – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

• Contacting the User

  Mailing list or newsletter (Clicks)

  By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Clicks. Your email address might also be added to this list as a result of signing up to Clicks or after making a purchase.

  Personal Data processed: email address; first name; last name; Trackers.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in the United States

  Phone contact (Clicks)

  Users that provided their phone number might be contacted for commercial or promotional purposes related to Clicks, as well as for fulfilling support requests.

  Personal Data processed: phone number.

  Category of Personal Information collected according to the CCPA: identifiers.

  This processing constitutes:

  • a Sale in California

• Content commenting

  Content commenting services allow Users to make and publish their comments on the contents of Clicks.
  Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
  If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

  Comment system managed directly (Clicks)

  Clicks has its own internal content comment system.

  Personal Data processed: email address; first name; username.

  Category of Personal Information collected according to the CCPA: identifiers.

  This processing constitutes:

  • a Sale in the United States
  • Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana

• Displaying content from external platforms

  This type of service allows you to view content hosted on external platforms directly from the pages of Clicks and interact with them. Such services are often referred to as widgets, which are small elements placed on a website or app. They provide specific information or perform a particular function and often allow for user interaction.
  This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

  Google Maps widget (Google LLC)

  Google Maps is a maps visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows Clicks to incorporate content of this kind on its pages.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

• Handling payments

  Unless otherwise specified, Clicks processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. Clicks isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

  Google Pay (Google LLC)

  Google Pay is a payment service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, which allows users to make online payments using their Google credentials.

  Personal Data processed: billing address; email address; first name; last name; payment info; phone number; purchase history; Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.

  Apple Pay (Apple Inc.)

  Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using their mobile phones.

  Personal Data processed: billing address; email address; first name; last name; payment info; phone number; purchase history; Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.

  Stripe (Stripe, Inc.)

  Stripe is a payment service provided by Stripe, Inc., Stripe Payments Europe, Limited, Stripe Payments UK, Ltd, Stripe Brasil Soluções de Pagamento - Instituição de Pagamento Ltda., Stripe Payments Canada, Ltd., Stripe India Private Ltd., Stripe Japan KK, Stripe Payments Malaysia Sdn. Bhd., Stripe Payments Mexico, S. de R.L. de C.V., Stripe New Zealand Limited, Stripe Payments Singapore Pte. Ltd. or by Stripe Payments (Thailand) Ltd., depending on how the Owner manages the Data processing.

  Personal Data processed: billing address; email address; first name; last name; payment info; purchase history; Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy; European Union – Privacy Policy; United Kingdom – Privacy Policy; Gibraltar – Privacy Policy; Hong Kong – Privacy Policy; Liechtenstein – Privacy Policy; Norway – Privacy Policy; Switzerland – Privacy Policy; United Arab Emirates – Privacy Policy; United Kingdom – Privacy Policy; Brazil – Privacy Policy; Canada – Privacy Policy; India – Privacy Policy; Japan – Privacy Policy; Malaysia – Privacy Policy; Mexico – Privacy Policy; New Zealand – Privacy Policy; Singapore – Privacy Policy; Thailand – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.

  Android Pay (Google LLC)

  Android Pay is a payment service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, which allows Users to make payments using their mobile phones.

  Personal Data processed: billing address; email address; first name; last name; payment info; phone number; purchase history; Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.

• Hosting and backend infrastructure

  This type of service has the purpose of hosting Data and files that enable Clicks to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Clicks.

  Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  Google Cloud Storage (Google LLC)

  Google Cloud Storage is a hosting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: Singapore – Privacy Policy; Singapore – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

  Firebase Cloud Firestore (Google LLC)

  Firebase Cloud Firestore is a hosting and backend service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

  Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: Singapore – Privacy Policy; Singapore – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  Firebase Cloud Functions (Google Ireland Limited)

  Firebase Cloud Functions is a hosting and backend service provided by Google Ireland Limited or by Google LLC, depending on how the Owner manages the Data processing.

  Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: Singapore – Privacy Policy; Singapore – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  Firebase Cloud Storage (Google Ireland Limited)

  Firebase Cloud Storage is a hosting service provided by Google Ireland Limited or by Google LLC, depending on how the Owner manages the Data processing.

  Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: Singapore – Privacy Policy; Singapore – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  Firebase Hosting (Google Ireland Limited)

  Firebase Hosting is a hosting service provided by Google Ireland Limited or by Google LLC, depending on how the Owner manages the Data processing.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: Singapore – Privacy Policy; Singapore – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

  Firebase Realtime Database (Google LLC)

  Firebase Realtime Database is a hosting and backend service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

  Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: Singapore – Privacy Policy; Singapore – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  Google BigQuery (Google LLC)

  Google BigQuery is a hosting and backend service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy; Brazil – Privacy Policy; Canada – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

• Infrastructure monitoring

  This type of service allows Clicks to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
  Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of Clicks.

  Firebase Performance Monitoring (Google Ireland Limited)

  Firebase Performance Monitoring is a monitoring service provided by Google Ireland Limited or by Google LLC, depending on how the Owner manages the Data processing.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: Singapore – Privacy Policy; Singapore – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

• Location-based interactions

  Geolocation (Clicks)

  Clicks may collect, use, and share User location Data in order to provide location-based services.
  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by Clicks.

  Personal Data processed: coarse location; geographic position; precise location.

  Category of Personal Information collected according to the CCPA: geolocation data.

  This processing constitutes:

  • a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
  • a Sharing in California
  • Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana

  Non-continuous geolocation (Clicks)

  Clicks may collect, use, and share User location Data in order to provide location-based services.
  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by Clicks.
  The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.

  Personal Data processed: coarse location; geographic position; precise location.

  Category of Personal Information collected according to the CCPA: geolocation data.

  This processing constitutes:

  • a Sharing in California

• Managing contacts and sending messages

  This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  Firebase Cloud Messaging (Google Ireland Limited)

  Firebase Cloud Messaging is a message sending service provided by Google Ireland Limited or by Google LLC, depending on how the Owner manages the Data processing. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: Singapore – Privacy Policy; Singapore – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

  Firebase Notifications (Google Ireland Limited)

  Firebase Notifications is a message sending service provided by Google Ireland Limited or by Google LLC, depending on how the Owner manages the Data processing. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: Singapore – Privacy Policy; Singapore – Privacy Policy; Switzerland – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

• Registration and authentication

  By registering or authenticating, Users allow Clicks to identify them and give them access to dedicated services.
  Depending on what is described below, third parties may provide registration and authentication services. In this case, Clicks will be able to access some Data, stored by these third-party services, for registration or identification purposes.
  Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

  Firebase Authentication (Google LLC)

  Firebase Authentication is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. To simplify the registration and authentication process, Firebase Authentication can make use of third-party identity providers and save the information on its platform.

  Personal Data processed: email address; first name; last name; password; phone number; profile picture; social media accounts; username.

  Place of processing: Singapore – Privacy Policy; Singapore – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; audio, electronic, visual, thermal, olfactory, or similar information.

• Social features

  Firebase Dynamic Links (Google Ireland Limited)

  Firebase Dynamic Links is a social feature provided by Google Ireland Limited or by Google LLC, depending on how the Owner manages the Data processing. Dynamic Links are tracked within Firebase or Google Analytics for Firebase, which informs the Owner about the details of the User journey to and within Clicks.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: Singapore – Privacy Policy; Singapore – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

  This processing constitutes:

  • a Sale in California

  Inviting and suggesting friends (Clicks)

  Clicks may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it.

  Personal Data processed: various types of Data.

  Category of Personal Information collected according to the CCPA: identifiers.

  This processing constitutes:

  • a Sale in California

  Public profile (Clicks)

  Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users' interactions with Clicks.

  Personal Data processed: country; first name; last name; phone number; username.

  Category of Personal Information collected according to the CCPA: identifiers.

  This processing constitutes:

  • a Sale in California

• Spam and bots protection

  This type of service analyzes the traffic of Clicks, potentially containing Users' Personal Data, with the purpose of filtering it from unwanted parts of traffic, messages and content that are recognized as spam or protecting it from malicious bots activities.

  Google reCAPTCHA (Google LLC)

  Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
  The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

  In order to understand Google's use of Data, consult Google's partner policy.

  Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information; inferences drawn from other personal information.

  Akamai Bot Manager (Akamai Technologies, Inc.)

  Akamai Bot Manager is a malicious bot protection and management service provided by Akamai Technologies, Inc.

  Personal Data processed: browser information; browsing history; clicks; geography/region; IP address; keypress events; language; motion sensor events; mouse movements; operating systems; scroll position; session statistics; touch events; Trackers; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information; geolocation data; inferences drawn from other personal information.

• Tag Management

  This type of service helps the Owner to manage the tags or scripts needed on Clicks in a centralized fashion.
  This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

  Google Tag Manager (Google LLC)

  Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

• Traffic optimization and distribution

  This type of service allows Clicks to distribute their content using servers located across different countries and to optimize their performance.
  Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Clicks and the User's browser.
  Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

  Google Cloud CDN (Google LLC)

  Google Cloud CDN is a traffic optimization and distribution service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

  Personal Data processed: Usage Data.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  Google Hosted Libraries (Google LLC)

  Google Hosted Libraries is a traffic optimization and distribution service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

  Personal Data processed: Usage Data.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

• User database management

  This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to Clicks, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving Clicks.
  Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Clicks.

  Brevo marketing automation (SendinBlue SAS)

  Brevo marketing automation is a User database management service provided by SendinBlue SAS.

  Personal Data processed: email address; Trackers; Usage Data.

  Place of processing: France – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Further information about the processing of Personal Data

• Push notifications

  Clicks may send push notifications to the User to achieve the purposes outlined in this privacy policy.

  Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for Clicks, some or all of the apps on the particular device.
  Users must be aware that disabling push notifications may negatively affect the utility of Clicks.

• Push notifications based on the User's geographic location

  Clicks may use the User's geographic location to send push notifications for the purposes outlined in this privacy policy.

  Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.

  Users must be aware that disabling push notifications may negatively affect the utility of Clicks.

• Push notifications for direct marketing

  Clicks may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by Clicks).

  Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for Clicks or all of the apps on the particular device.

  Users must be aware that disabling push notifications may negatively affect the utility of Clicks.

  Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.

Cookie Policy

Clicks uses Trackers. To learn more, Users may consult the Cookie Policy.

Transfer of Personal Data outside of the European Union

Data transfer abroad based on standard contractual clauses

If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

Transfer of Personal Data outside of the United Kingdom

Data transfer abroad based on standard contractual clauses (UK)

If this is the legal basis, the transfer of Personal Data from the UK to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.

This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation, which are recognized as valid also under UK law. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

Further information for Users in the United States

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running Clicks and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana.

For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term Personal Information (and Sensitive Personal Information).

Notice at collection

The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.

While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.

ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.

To know more about your rights in particular to opt out of certain processing activities and to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.

For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.

We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.

What are the sources of the Personal Information we collect?

We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use Clicks.

For example, you directly provide your Personal Information when you submit requests via any forms on Clicks. You also provide Personal Information indirectly when you navigate Clicks, as Personal Information about you is automatically observed and collected.

Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of Clicks and features thereof.

Your privacy rights under US state laws

You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:

• the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
• the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
• the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
• the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
• the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
• the right to non-discrimination.

Additional rights for Users residing in California

In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have:

• The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
• The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.

Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana

In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana you have

• The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
• The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. In Maryland, your Sensitive Personal Information will be collected or processed only if strictly necessary to provide or maintain a specific product or service requested by you.

In Minnesota and Maryland Users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer's personal data

* Note that in some states like Minnesota you have the following specific rights connected to profiling:

• The right to question the results of the profiling;
  
• The right to be informed of the reason that the profiling resulted in the decision; if feasible
  
• The right to be informed of what actions the consumer might have taken to secure a different decision and the actions that the consumer might take to secure a different decision in the future;
  
• The right to review personal data used in the profiling;
  
• If inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data;
  

Additional rights for users residing in Utah and Iowa

In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have:

• The right to opt out of the processing of your Personal Information for Targeted Advertising;
• The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

How to exercise your privacy rights under US state laws

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

How to exercise your rights to opt out

In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on Clicks.

If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.

Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).

We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Clicks or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, Clicks may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Clicks and any third-party services may collect files that record interaction with Clicks (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Clicks and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.