PRIVACY POLICY

Effective Date: _________

At XPN Network (‘Clearserf’, ‘we’, ‘us’, ‘our’) , we recognize that privacy is very important and value your privacy. You will find below the important information about your rights in relation to your personal data and the explanation of the choices that you have with respect to that information, so please read carefully.

When visiting our website , our application (the "App"), Clearserf may receive information that you voluntarily provide when you fill out a “sign up” form and may collect certain ‘cookie’ information from your device.

Please note that you’re not required to provide us with any personal information while using the website. Clearserf is not intended for users under 18 years of age.

This Privacy Policy applies to all information and data Clearserf could receive about users when such users visit the Website, the websites of our partners, clients, advertisers. Privacy Policy provides information about our Website which enables our partners to use our services and then describes our principles about data collection and use. It also describes the type of data Clearserf collects and utilizes when showing ads to users.

Clearserf provides its services strictly in accordance with the appropriate legislation regarding the collection and processing of data, the principles and rules of international legislation regarding the collection, processing, and protection of data.

1. GENERAL PROVISIONS

  • Clearserf collects the following types of personal data:
  • name,
  • email,
  • telephone number,
  • location,
  • age,
  • gender,
  • photo;
  • Data provided intentionally and voluntarily by the user is used exclusively for the purpose of the cooperation of the user and Clearserf to get access to our services.
  • Clearserf also collects personal information that allows us to identify the user while maintaining their privacy via cookies. Such personal information includes, but not limited to:
  • IP-address of user;
  • Geographic location of user;
  • Type of user's OS;
  • The user's browser (for ex. Google Chrome or Safari);
  • The language of user's browser;
  • Data on visited sites by the user (site addresses);
  • Data on the shows of ads to users and user's clicks on ads).
  • Clearserf uses such personal data in order to provide services, to manage and develop its services, to show ads, to determine the needs of users in one or other ads. All personal information is handled in accordance with the applicable legal obligations.
  • Clearserf may publish results and photos of users after use of Clearserf services on its website and social media as a report and advertisement of Clearserf.
  • All personal information is stored in a secure way and will be deleted irretrievably or anonymized once the request has been dealt with and within the applicable retention times.
  • Clearserf processes and stores personal information at the data center of Clearserf placed on the territory of XPN Network (68 CIRCULAR ROAD, #02-01, SINGAPORE (049422)) for the period necessary to fulfill the purpose for which it was collected or to comply with legal and regulatory requirements.

COOKIES

  • Clearserf uses cookies to collect personal information. Such data does not allow us to identify users. Such information collected through cookies are used for the following purposes:

    to determine user preferences,

    to collect the number of times a user visited the website,

    to customize website parameters for user characteristics,

    to select and display targeted ads to the user,

    to remember the number of times the same ad was delivered to a user;

  • Cookie is a small text file stored on the user's hard drive while visiting the website. Cookie is connected with a web browser and is unique for each browser.
  • When accessing the website and in order to continue, the user has to accept the use of cookies by clicking in the appropriate box indicating his clear and evident consent.
  • Cookies will be stored for a maximum of 12 months after being dropped on a device.
  • Clearserf also uses pixel tags (also known as javascript or 1×1 pixels) and tracking codes to drop cookies. A pixel tag is a tiny graphic or script placed on a website that is not visible to the user. The use of pixel tags and tracking codes allows Clearserf to count the number of visits to the website.
  • Clearserf believes that the tracking technologies used by Clearserf and described above enhance the user's web experience. However, a user can disable or delete the use of cookies at any time via settings in his browser via activation opt-out function. However, disabling Cookies can lead to the non-operability and/or limited access to some parts of this website and/or its partners' websites, and the user will be deprived of the opportunity, including receiving targeted ads from Clearserf and its partners.
  • Customers, advertisers, partners of Clearserf can use their own databases, which can contain personal data of users that were provided by users for the purposes of clients, advertisers, and partners. In such cases, advertisers, customers, and partners of Clearserf are fully responsible for the user's consent to the processing of the information provided by them and to obtaining appropriate information.
  • The user is entitled at any time to prohibit Clearserf to collect personal information by cookies via activation "Opt-Out'' function.
  • The user is entitled at any time to request Clearserf to delete any personal information regarding the user from Clearserf data services by sending an email to: info@xpn.com.
  • Clearserf notes activation of "Opt-out" is applicable only to this Website. The refusal does not apply to advertisers, partners of Clearserf, who use their own cookies to collect statistical information.

DATA CONTROLLER, DATA COLLECTED, PURPOSE

  • Besides the data collected when a cookie is dropped, Clearserf also collects the following possible personal data: the IP-address, postal code, region and country of a user, language setting, the type of browser (such as Chrome, Safari, Firefox or Internet Explorer), operating system used and connection speed, status of a user (unknown, accepting or not accepting cookies), the web page address(es) where the ad has been delivered, and administered clicks on ads. This information helps our technology to choose the most relevant service to a user.
  • The information collected (by means of cookies and/or other tracking methods) is processed for internal purposes only: i.e. to possibly build user profiles that enable Clearserf to optimize and personalize its services.

PROVISION OF DATA TO THIRD PARTIES

  • Clearserf provides access to user or customer's personal data (name, email, telephone number) in the following cases:
  • the user has been given appropriate consent to provide such data;
  • at the request of the public authorities in order to comply with the applicable legislation.
  • By giving consent to the processing of personal data, the user agrees that his data can be transferred to payment systems to the extent necessary for making payments.
  • Clearserf processes the information itself and does not transfer and provide access to user or customer's personal information to third parties without appropriate consent.

OTHER

The Privacy Policy applies solely to this Website. Clearserf does not control and is not responsible for any third party website.

GDPR CLAUSE

In operating this Website, Clearserf processes data as a controller (as such terms are defined in the GDPR). As a controller, Clearserf is committed to fulfill data subjects’ (‘users’) GDPR rights.

  • Under GDPR, if you are EU resident, you may:
  • Request information about the processing of your data, as well as the receipt of a copy of your personal data. You can request information on the purposes of the processing, the categories of personal data being processed, the recipients of the data (if they are passed on), the duration of the storage or the criteria for determining the duration.
  • Correct your data. Should your personal data be incomplete, you have the right to complete the data, taking into account the processing purposes.
  • Delete or block your data. Reasons for the existence of a cancellation/blocking right can be, among others, the revocation of the consent on which the processing is based, the data subject objects to the processing, the personal data were processed unlawfully.
  • Restrict the processing.
  • Object to the processing of your data.
  • Revoke your consent to the processing of your data in the future.
  • Complaint to the competent supervisory authority about inadmissible data processing.
  • FINAL PROVISIONS

    This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically to be aware of and review any updates.