Last updated: Jan 1, 2025
This Privacy Policy explains how Clonden (“Company,” “we,” “us,” or “our”) collects, uses, discloses, and protects information about you when you access or use our website at https://www.clonden.com (the “Website”), and describes your privacy rights and how applicable laws protect you.
By using the Website, you acknowledge that you have read and understood this Privacy Policy.
1) Controller and Contact Details
Controller: Clonden
Email: support@clonden.com
If you have questions about this Privacy Policy or our data practices, contact us at the email above.
2) Definitions
- Account means a unique account created for you to access certain features of the Website.
- Cookies are small text files stored on your device to help operate and enhance the Website.
- Device means any device that can access the Website (e.g., computer, smartphone, tablet).
- Personal Data means any information that identifies or relates to an identifiable natural person.
- Service means the Website and related features we provide through it.
- Service Provider means a third party that processes data on our behalf (e.g., hosting, analytics).
- Usage Data means data collected automatically through the Website (e.g., page views, IP address).
3) What We Collect
3.1 Information You Provide Voluntarily
When you contact us (e.g., by email or form), you may provide:
- Identification and contact details (e.g., name, email).
- The content of your message and related metadata.
3.2 Information Collected Automatically (Usage Data)
When you use the Website, we may automatically collect:
- Technical data: IP address (processed for geolocation and security at collection time), browser type/version, OS, Device identifiers.
- Usage data: pages viewed, time/date stamps, session duration, referrers, interaction data.
- Mobile data (if applicable): device model, OS, mobile browser, approximate location (derived from IP).
We may aggregate or de-identify data so it can no longer reasonably identify you. Aggregated/de-identified data is not Personal Data.
4) Purposes and Legal Bases
We process Personal Data for the purposes below. Where required by law, we rely on your consent; otherwise, we rely on our legitimate interests (Art. 6(1)(f) GDPR), performance of a contract (Art. 6(1)(b)), or legal obligations (Art. 6(1)(c)).
- Operate and secure the Website (e.g., load balancing, fraud prevention, incident response). Legal basis: legitimate interests.
- Respond to your inquiries and provide support. Legal basis: legitimate interests; performance of a contract where applicable.
- Analytics and product improvement (Google Analytics 4) to understand usage and enhance content and UX. Legal basis: consent where required by ePrivacy/TTDSG for non-essential cookies/identifiers; otherwise legitimate interests. See Section 5 and 6.
- Compliance and enforcement, including exercise/defense of legal claims. Legal basis: legal obligations; legitimate interests.
5) Cookies and Similar Technologies
We use cookies and similar technologies (e.g., tags, pixels) to operate and improve the Website.
5.1 Types of Cookies
- Strictly necessary (essential) – required for the Website to function (e.g., page navigation, security).
- Preferences (functional) – remember choices (e.g., language).
- Analytics (GA4) – help us understand how the Website is used (e.g., most viewed pages, navigation paths).
5.2 Your Choices
Where required by law, we request your consent before setting non-essential cookies/identifiers (including analytics). You can manage or withdraw your consent any time via the cookie banner/settings on the Website and by adjusting your browser settings. Blocking certain cookies may impact your experience.
For more details, see our Cookie Settings or Cookie Policy (if provided separately).
6) Google Analytics 4 (GA4)
We use Google Analytics 4 to measure and analyze Website usage. GA4 collects events (e.g., page views, clicks, scrolls), technical information (browser/OS), and coarse location derived from IP at collection time. According to Google’s current implementation, GA4 does not log or store full IP addresses; IP is used to derive approximate location and then discarded.
Controller/Processor roles: We act as the controller for our use of GA4; Google provides analytics services as our processor (Google Ireland Limited for EEA/UK, with Google LLC in the United States as sub-processor).
Legal basis:
- Consent (where required by ePrivacy/TTDSG) for setting non-essential cookies/identifiers.
- Otherwise legitimate interests in understanding and improving our Website.
Retention: We currently configure GA4 event data retention for 14 months (unless you withdraw consent earlier). Aggregated reports may be retained longer in de-identified form.
Transfers: GA4 may involve international transfers (see Section 7). Appropriate safeguards (e.g., Standard Contractual Clauses) apply.
Controls:
- Use the Website’s cookie banner/settings to opt in/out of analytics.
- You can also install the “Google Analytics Opt-out Browser Add-on” and manage ad settings in your Google account (where applicable).
7) International Data Transfers
If Personal Data is transferred outside the EEA/UK to countries without an adequacy decision (e.g., to Google LLC in the United States), we implement appropriate safeguards such as Standard Contractual Clauses and additional measures where necessary. You may request a copy of relevant safeguards using the contact details in Section 1.
8) Data Retention
We retain Personal Data only as long as necessary for the purposes described in this Policy, including compliance and reporting. Typical retention periods:
- Contact inquiries: up to 24 months after resolution (unless law requires longer).
- Analytics (GA4): event data retained for 14 months per our current configuration; aggregated/de-identified analytics may be kept longer.
- Technical logs/security data: typically 12–24 months, unless needed longer for investigations.
When no longer needed, Personal Data is securely deleted or anonymized.
9) Your Rights
Subject to legal conditions and exemptions, you may have the right to:
- Access your Personal Data and obtain a copy.
- Rectify inaccurate or incomplete data.
- Erase data (“right to be forgotten”).
- Restrict or object to processing (including processing based on legitimate interests).
- Data portability for data you provided to us that we process by automated means and on the basis of consent or contract.
- Withdraw consent at any time (this does not affect the lawfulness of processing before withdrawal).
To exercise your rights, contact us at support@clonden.com.
10) Security
We use technical and organizational measures designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. However, no method of transmission or storage is completely secure.
11) Third-Party Websites
The Website may contain links to third-party sites. We are not responsible for the privacy practices or content of third-party sites. We encourage you to review their privacy policies.
12) Online Marketing and Affiliate Programs (General)
From time to time, we may participate in affiliate or advertising programs. If you click a monetized link and later complete a qualifying action (e.g., a purchase), we may receive a commission. Partners may use cookies or similar identifiers to attribute transactions. Where required by ePrivacy/TTDSG, we will obtain your consent before setting non-essential identifiers. We will provide a clear, visible disclosure on pages that contain affiliate links.
13) Children’s Privacy
The Website is not directed to children, and we do not knowingly collect Personal Data from children. If you believe a child has provided us Personal Data, please contact us so we can take appropriate action.
14) Changes to This Policy
We may update this Privacy Policy from time to time. We will post the updated version on this page and adjust the “Last updated” date above. Material changes may also be communicated via an on-site notice. We encourage you to review this page periodically.
15) Contact
If you have any questions about this Privacy Policy or our data practices, please contact us at:
support@clonden.com
