This Privacy Statement (“Statement”) applies to all websites, including clickbakers.com, domains, services, applications, and products (“CLICKBAKERS sites” or “services”) owned or provided by Clickbakers, L.P., with its registered seat at Future Net Group Ltd., Suite 13, Oliaji Trade Centre, Francis Rachel Street, Victoria, Mahe, Republic of Seychelles ("CLICKBAKERS"), except that a privacy policy or statement specific to a particular CLICKBAKERS site, program, product, or service may supersede or supplement this Statement.

This Statement (together with our terms and conditions of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

CLICKBAKERS takes seriously the trust you place in us. To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of the information, CLICKBAKERS utilizes reasonable and appropriate physical, technical, and administrative procedures to safeguard the information we collect and process. CLICKBAKERS retains data only as required or permitted by local law and while it has a legitimate business purpose.

CLICKBAKERS is the data controller for the purposes the Regulation 2016/679 of the European Parliament and of 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) ("GDPR"). You can reach us at info@clickbakers.com

No data protection officer is currently appointed.

Personal Data. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Special Categories of Personal Data. We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Failure to Provide Personal Data. If you do not provide your personal data related to the performance of a contract with you, we may not be able to deliver products and provide certain services you require, or guarantee a level of service.

Anonymous Data. We may also collect some information that is not personal data because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use CLICKBARKERS sites, products or services.

Accuracy. We strive to keep your personal data accurately recorded. We have implemented technology, management processes and policies to help maintain data accuracy.

Links to Non-CLICKBAKERS sites. CLICKBAKERS sites or services may provide links to third-party applications, products, services, or websites for your convenience and information. If you access those links, you will leave the CLICKBAKERS site. CLICKBAKERS does not control those third party sites or their privacy practices, which may differ from CLICKBAKERS’ practices. We do not endorse or make any representations about third-party sites. The personal data you choose to provide to or that is collected by these third parties is not covered by this Statement. We encourage you to review the privacy policy of any site you interact with before allowing the collection and use of your personal data.

Social Networks. We may also provide social media features that enable you to share information with your social networks and to interact with CLICKBAKERS on various social media sites. Your use of these features may result in the collection or sharing of information about you, depending on the feature. We encourage you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the information that may be collected, used, and shared by those sites. If you post, comment, indicate interest or complaint, or share personal data, including photographs, to any public forum on an CLICKBAKERS site, social network, blog, or other such forum, please be aware that any information you submit can be read, viewed, collected, or used by other users of these forums, and could be used to contact you, send you unsolicited messages, or for purposes that neither you nor CLICKBAKERS have control over. CLICKBAKERS is not responsible for the personal data you choose to provide in these forums.

Collection. CLICKBAKERS collects, exports, and uses personal data. Such collection is done with appropriate notice and based on legal basis, along with required filings with data protection authorities, where required. CLICKBAKERS may collect your personal data through your access and use of website, web-based applications, or mobile applications, during conversations or correspondence with CLICKBAKERS representatives, or when you purchase goods or services or complete an online application form, namely:

Legal Basis. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer • Identity
• Contact
Performance of a contract with you.
To process your subscription and deliver products and services:

• Administration of user account
• Manage payments
• To answer any question you may raise or respond to any comments you may send to us
• To assist you in completing a transaction or order
• To provide you with access to protected areas of our website
• To keep your contact details up to date and provide updated details to CLICKBAKERS
providers and suppliers where necessary
• Collect and recover money owed to us
• Identity
• Contact
• Financial
• Transaction
• Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
• Notifying you about changes to our terms and conditions or privacy statement
• Asking you to leave a review or take a survey
• Identity
• Contact
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To perform credit worthiness assessment • Identity
• Contact
• Financial
To make suggestions and recommendations to you about services that may be of interest to you
• Notifying you of any promotional offers, compatible tips, announcements, updates, special offers, surveys, new products and services.
• Identity
• Contact
• Profile
• Usage
• Marketing and Communications Data
Necessary for our legitimate interests (to develop our products/services and grow our business)
Consent to the processing (if freely given, specific, informed and unambiguous)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). • Identity
• Contact
• Usage
• Technical
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation
To deliver relevant website content, personalize some CLICKBAKERS sites and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. • Identity
• Contact
• Profile
• Usage
• Technical
• Marketing and Communications Data
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences. • Technical
• Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To improve and develop products, services and support including through quality control, research and data analysis activities.
To assess and improve the performance and operation of CLICKBAKERS sites.
• Technical
• Usage
Necessary for our legitimate interests (to improve our services and develop our business)
To measure performance of marketing initiatives, ads, and websites “powered by” another company on CLICKBAKERS’s behalf. • Technical
• Usage
Necessary for our legitimate interests (to monitor performance of marketing of CLICKBAKERS group)
To prevent and detect security threats, fraud or other malicious activity. • Identity
• Contact
• Profile
• Usage
• Technical
• Marketing and Communications Data
Necessary for our legitimate interests (security)
Necessary to comply with a legal obligation
To process and respond to any request, objections or complaint made by you. • Identity
• Contact
Necessary to comply with a legal obligation
Identity Data includes full name, Zip/Postal Code, Country, email address, password, educational and employment background, job interest data

Contact Data includes email address and contact preferences.

Financial Data includes credit/debit card details.
Transaction Data includes details about payments to and from you and other details of services you have purchased from us.

Technical Data includes internet protocol (IP) address, physical location, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

Profile Data includes your username and password, orders made by you, your interests, preferences, feedback and survey responses, information you provide to us through our service center, customer surveys or visits by our representatives from time to time.
Usage Data includes information about how you use our website, products and services, product functionality, product and service preferences.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences, (telephone number).

Credit Worthiness Assessment. If you apply for instant credit, we may ask you to provide additional personal data such as salary, government issued identification number, banking/financial account information, and other information (for example from credit reporting agencies) to authenticate you and verify credit worthiness. This information will be used by our financial services providers in determining whether to extend you credit and how much to extend. Revenue or others financial information, government issued identification number and other sensitive personal data are used for purpose of our financial services providers.

Payment Processing. Credit card information is used only for payment processing and fraud prevention. When collecting or transferring sensitive information such as credit card information we use a variety of additional security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. The personal data you provide us is stored on computer systems located in controlled facilities which have limited access. When we transmit highly confidential information (such as credit card number or password) over the internet, we protect it through the use of encryption, such as the Secure Socket Layer (SSL) protocol. As part of real-time payment processing, CLICKBAKERS subscribes to fraud management services. This service provides CLICKBAKERS with an extra level of security to guard against credit card fraud and to protect your financial data.

General Provisions. CLICKBAKERS will not sell, rent or lease your personal data to others except as described in this Statement. CLICKBAKERS shares personal data in the ways described below. When we share your data with our service providers, your data may be processed or stored both in and outside your country of residence and both in and outside the European Economic Area (EEA). In any case, your data may be transferred only to non-EEA countries offering adequate protection according to European law or under specific contractual arrangements to ensure adherence to European personal data protection rules and standards.

Our Suppliers. CLICKBAKERS retains service providers and suppliers to manage or support its business operations, provide professional services, deliver complete products, services and customer solutions and to assist CLICKBAKERS with marketing and communication initiatives. These providers and suppliers may be located in the US or other overseas locations and include, for example, credit card processors, debt collectors, providers of customer support and live-help, marketing and communications, hosting and IT service providers, email service providers, automated data processors, shipping agents, management and support of CLICKBAKERS sites, order fulfillment and delivery. Suppliers and service providers are required by contract to keep confidential and secure the information received on behalf of CLICKBAKERS and may not use it for any purpose other than to carry out the services they are performing for CLICKBAKERS.

Marketing. From time to time, CLICKBAKERS participates in marketing initiatives with other companies. From time to time, third parties may provide its services as an integrations to CLICKBAKERS sites. As part of these initiatives or services by third parties, certain CLICKBAKERS services and marketing communications may be delivered at the same time as those from other companies. Some of these services and communications offer you the option to share personal data with both CLICKBAKERS and the other companies participating in these initiatives. For example, you may receive marketing communications from CLICKBAKERS and other companies or have the opportunity to register online for software products from multiple companies. If you choose to provide personal data only to CLICKBAKERS, CLICKBAKERS will not share this information with the other companies participating in that marketing initiative. If you choose to provide personal data to the other companies, that personal data will be handled according to the privacy policy of those companies, which may differ from CLICKBAKERS’s policies and practices.

CLICKBAKERS Group. CLICKBAKERS may also transfer your personal data to other CLICKBAKERS-owned business entities for the purposes described in this Statement.

List of Entities. The list of service providers, suppliers, CLICKBAKERS-owned business entities and other third parties to which CLICKBAKERS may transfer your personal data may change from time to time. The current list will be provided to you upon your written request.

Legal Duty. Except as described in this Statement, CLICKBAKERS will not share the personal data you provide to CLICKBAKERS with non-CLICKBAKERS third parties without your permission, unless to: (i) respond to duly authorized information requests of police and governmental authorities; (ii) comply with any law, regulation, subpoena, or court order; (iii) investigate and help prevent security threats, fraud or other malicious activity; (iv) enforce/protect the rights and properties of CLICKBAKERS or its subsidiaries; or (v) protect the rights or personal safety of CLICKBAKERS, our employees, and third parties on or using CLICKBAKERS property when allowed and in line with the requirements of applicable law.

Business Transactions. Circumstances may arise where, whether for strategic or other business reasons, CLICKBAKERS decides to sell, buy, merge or otherwise reorganize businesses in some countries. Such a transaction may involve the disclosure of personal data to prospective or actual purchasers, or the receipt of it from sellers. It is CLICKBAKERS’s practice to seek appropriate protection for information in these types of transactions.

Subscriptions. CLICKBAKERS gives you the choice of receiving a variety of information that complements our products and services. You can subscribe to receive certain product- and service-specific information and also choose to receive CLICKBAKERS general communications. We give you a choice regarding delivery of CLICKBAKERS general communications by postal mail, email, telephone, or mobile device. You can make or change your choices about receiving either subscription or general communications at the data collection point or by using other methods, which are listed in the following sections. This option does not apply to communications primarily for the purpose of administering order completion, contracts, support, product safety warnings, driver updates, or other administrative and transactional notices where the primary purpose of these communications is not promotional in nature. Subscription communications include email newsletters, software updates, etc. that may be expressly requested by you or which you consented to receive. After you request such communications, you may opt out of receiving them by using one of the following methods: Select the email "opt out" or "unsubscribe" link, or follow the opt-out instructions included in each email subscription communication.

We keep your personal data for a limited period of time in line with our data retention policy. The specific retention period will vary according to the reason for processing your personal data. After this period, your data will be permanently erased or otherwise irreversibly rendered anonymous.

Your personal data are retained in accordance with the following criteria:

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

You have the right to:

If you wish to exercise any of the rights set out above, please email us at info@clickbakers.com

The following sections provide additional information about commonly-used web technology tools.

Cookie. A “cookie” is a small data file transferred by a website to your computer’s hard drive. CLICKBAKERS or its service providers send cookies when you surf our site or sites where our ads appear, make purchases, request or personalize information, or register yourself for certain services.

Automatic Data Collection Tools. CLICKBAKERS may also use other automatic data collection tools, which include web beacons, flash cookies, and embedded web links. These tools collect certain traffic information that your browser sends to a website, such as your browser type and language, access times, and the address of the website from which you arrived. They may also collect information about your Internet Protocol (IP) address, unique device identifier, clickstream behavior (i.e., the pages you view, the links you click, and other actions you take in connection with CLICKBAKERS sites or “powered by” websites) and product information. CLICKBAKERS may also use some of these automatic data collection tools in connection with certain emails and communications sent from CLICKBAKERS and therefore may collect information using these tools when you open the email or click on a link contained in the email.

Consent with Cookies. Before the use cookies and similar technologies (e.g. web beacons, flash cookies, etc.) the data subject must provide his/her consent with the use of cookies and similar technologies on our site, sites that are “powered by” another company on CLICKBAKERS’s behalf, or sites where our ads appear may give us access to information about your browsing behavior, which we may use to personalize your experience. For consent to be valid, it must be informed, specific, freely given and must constitute a real indication of the individual's wishes.

Exempted Cookies. However, some cookies are exempt from the requirement of consent. Consent is not required if the cookie is (i) used for the sole purpose of carrying out the transmission of a communication, and (ii) strictly necessary in order for the provider of an information society service explicitly required by the user to provide that service.

Session and Persistent Cookies. Cookies are typically classified as either “session” cookies or “persistent” cookies. Session cookies do not stay on your computer after you close your browser. Persistent cookies remain on your computer until you delete them or they expire. Most browsers automatically accept cookies by default, but you can usually refuse cookies or selectively accept cookies by adjusting the preferences in your browser. If you turn off cookies, there may be some features of our site that will not be available to you and some Web pages may not display properly.

Specific Preferences. In certain countries you may also adjust your CLICKBAKERS.com and associated cookie preferences by using a preference manager tool which is available from the site you are visiting. You can find information on popular browsers and how to adjust your cookie preferences in the help and support section of your browser.

Changes to this Statement. If we modify this Statement, we will post the revised statement here, with an updated revision date. If we make significant changes to our Statement that materially alter our privacy practices, we may also notify you by other means, such as sending an email or posting a notice on our site and/or social media pages prior to the changes taking effect. This Statement was last updated on January 1, 2019.

Contacting us. We value your opinions. If you have comments or questions about our Statement please send them to info@clickbakers.com