This privacy policy ("Policy") describes how eLearning Company, Inc. ("eLearning Company", "CLUELABS by eLearning Company", "Cluelabs", "we", "us" or "our") collects, protects and uses the personally identifiable information ("Personal Information") you ("User", "you" or "your") may provide on the cluelabs.com website and any of its products or services (collectively, "Website" or "Services"). It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

GDPR Compliance Statement

We are committed to ensuring the protection of personal data and the rights of our users by complying with the General Data Protection Regulation (GDPR). We are dedicated to safeguarding the personal data of our clients, partners, and users accessing our services from the European Union.

Under the General Data Protection Regulation (GDPR), residents of the EU may exercise certain rights regarding their personal data. If you would like to make a data subject access request, please contact us to submit your request.

We have appointed a Data Protection Officer (DPO) and they can be reached by submitting a contact us form.

Subprocesors

Below is the list of our current subprocessors.

Google Cloud Platform: We use Google Cloud Platform to host the website, provide computing services, and store and process data related to your use of the Website. Applies to all users of the website.

Amazon Web Services: Applies to you only if the widget/service you are using is sending or receiving email or text messages. Such sending and receiving occurs through Amazon Web Services. If your widget/service does not use email or text messaging, this subprocessor does not apply to you.

OpenAI: Applies to some widgets/services that use AI features. If your service/widget does not use AI, this subprocessor does not apply to you.

Zendesk: Applies to those users who submit a support ticket or Cluelabs custom development ticket. Zendesk is our support platform. If you do not contact support, this does not apply to you.

Stripe: Stripe is our payment processor. If you make payments on the website (e.g. when signing up for paid service), this processor applies to you.

Mailchimp: Mailchimp is our marketing platform. If you opt-in to receive newsletters and service alerts, this applies to you. Note that by registering on the website you consent to receiving important service alerts.

The Platform and Infrastructure

This website, its services, and its functions (e.g. data storage, data processing, networking, etc.) are built on Google Cloud Platform infrastructure. When you access our Website - you connect to a server on Google Cloud, when you create an account on the website - you save your data on Google Cloud. Google Cloud Platform is a cloud computing suite of products that provides a series of modular cloud services including computing, networking, data storage, data analytics, machine learning, and other services. Use the links below to learn more about the Google Cloud Platform.
Data Security: https://cloud.google.com/blog/topics/developers-practitioners/data-security-google-cloud
Data Center Security: https://www.google.com/about/datacenters/data-security/
Certifications and Compliance: https://cloud.google.com/security/compliance/offerings#/regions=USA

Our Guiding Principles

Lawful Processing: We process personal data lawfully, fairly, and transparently. We only collect personal data with the explicit consent of the users or under another lawful basis.

Purpose Limitation: We collect data for specified, explicit, and legitimate purposes, and we ensure that the data is not processed further in a manner that is incompatible with those purposes.

Data Minimization: We ensure that the personal data we collect is adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.

Accuracy and Storage Limitation: We keep personal data accurate and up-to-date, removing or correcting any inaccurate data without delay. We retain personal data in a form that permits the identification of data subjects for no longer than necessary.

Security and Confidentiality: We implement appropriate technical and organizational measures to ensure the security of personal data, including protection against unauthorized or unlawful processing, accidental loss, destruction, or damage.

Data Storage Location Options

When you use this Website to procure services and resources that involve storing end-user data and/or transactional data, you are given the option to select the country (and, sometimes, region) where such data will be stored. This applies to the following offerings: AI Storyboarding, Translation, User Flow Analytics, Data Cloud, PDF Maker (if storing a .docx template). Currently, the list of available options includes 40+ data centers on 6 continents.

Some offerings do not involve storing end-user data and/or transactional data. These offerings include: Closed Captioning, Google Sheets, PDF Maker, Timer, Progress Bar, and others. Such resources pass the data directly to the destination without saving a copy or logging it.

Collection of Personal Information

We receive information that you knowingly or unknowingly provide to us when you create an account, publish content, make a purchase, fill any online forms on the Website. This information may include your email address, IP address, location, or other Personal Information. You can choose not to provide us with certain information by closing your Account and terminating the use of our Services. Users who are uncertain about what information is mandatory are welcome to contact us.

Collection of Non-personal Information

When you visit the Website, some information about you is received automatically. This data may include information such as your device's IP address, browser type and version, operating system type and version, language preferences or the webpage you were visiting before you came to our Website, etc.

Sale of Data

None of the data or information you provide in the course of using the Website is ever sold to third parties for any purpose. This includes but is not limited to: your email address, your name, your location, widget metadata you save, the data your end-users process through our Services, etc.

Advertisement

This website does not provide advertisements and does not use personally identifiable information about individual customers to deliver tailored advertisements to the intended audience.

Managing Personal Information

You are able to access, add to, update and delete certain Personal Information about you. The information you can view, update, and delete may change as the Website or Services change. When you update information, however, we may maintain a copy of the unrevised information in our records. Some information may remain in our private records after your deletion of such information from your account. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

Use and Processing of Collected Information

Any of the information we collect from you may be used to personalize your experience, process transactions, run and operate our Website and Services, research, develop new Products and Services.

We may process Personal Information related to you if one of the following applies: (i) You have given your explicit or implicit consent (for example, by agreeding to our Terms of Use). Note that under some legislations we may be allowed to process information until you object to such processing (by opting out); (ii) Provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) Processing is necessary for compliance with a legal obligation to which you are subject; (iv) Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Content You Create and Share through This Website

When you enable third-parties to access, view, interact with, distribute or modify the content you obtain from this website, it is your responsibility to obtain their consent to our policies (including privacy, data collection, data storage, data sharing policy, etc). No third-party is allowed to use the content obtained from this website without explicitly agreeing to these policies. If you are enabling a third-party to access the website content, it is your responsibility to ensure that they agree to our policies. It is also your responsibility to notify them which of their personal information may be collected, stored, used, and shared. You will be solely responsible for any consequences and events that arise from a third-party’s usage of the website and its content if such usage was enabled by you.

The Rights of Users

You may exercise certain rights regarding your information processed by us. In particular, you have the right to do the following: (i) you have the right to withdraw consent where you have previously given your consent to the processing of your information; (ii) you have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent; (iii) you have the right to learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing; (iv) you have the right to verify the accuracy of your information and ask for it to be updated or corrected; (v) you have the right, under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it; (vi) you have the right, under certain circumstances, to request the erasure of your Personal Information from us; (vii) you have the right to receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.

The Right to Object to Processing

Where Personal Information is processed for a public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection. You must know that, however, should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn, whether we are processing Personal Information for direct marketing purposes, you may refer to the relevant sections of this document.

How to Exercise These Rights

Any requests to exercise User rights can be directed to the us through the contact form on the website. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Billing and Payments

We use third-party payment processors to assist us in processing your payment information securely. Such third-party processors' use of your Personal Information is governed by their respective privacy policies which may or may not contain privacy protections as protective as this Privacy Policy. We suggest that you review their respective privacy policies.

Privacy of Children

We do not knowingly collect any Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through our Website or Service. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through our Website or Service without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through our Website or Service, please contact us.

Newsletters

We offer electronic newsletters to which you may be subscribed at the time of registration on the website. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.

Cookies

The Website uses "cookies" to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. We may use cookies to collect, store, and track information for statistical purposes to operate our Website and Services. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you will not be able to use and experience the features of the Website and Services.

Do Not Track Signals

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, this Website is not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your personal information.

Links to Other Websites

Our Website contains links to other websites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other websites or third-parties. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every website that may collect Personal Information.

Information Security

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our Website cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite best efforts.

Data Breach

In the event we become aware that the security of the Website has been compromised or users Personal Information has been disclosed to unrelated third-parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website.

Legal Disclosure

We will disclose any information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account and personal data will likely be among the assets transferred.

Changes and Amendments

We reserve the right to modify this Policy relating to the Website or Services at any time, effective upon posting of an updated version of this Policy on the Website. When we do, we will revise the updated date at the top of this page. Continued use of the Website after any such changes shall constitute your consent to such changes.

Acceptance of This Policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By using the Website or its Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to use or access the Website and its Services.

Contacting Us

If you have any questions about this Policy, please contact us using the contact form on the website.