PRIVACY POLICY 
READ CAREFULLY

This is the Privacy Statement of Cloverleaf Marketing DMCC in relation to data collected and processed by Cloverleaf Marketing DMCC on its own behalf acting as a Data Controller in the provision of its website and associated services.

This Privacy Statement applies to any information provided or collected through this Cloverleaf Marketing DMCC website and/or any Cloverleaf Marketing DMCC application, including any application on social media or other website which are provided by Cloverleaf Marketing DMCC, a company registered in UAE with company number DMCC 188223 and the extended Cloverleaf Marketing DMCC Group of Companies.
Throughout this Policy, the use of 'Cloverleaf Marketing DMCC' represents the full Cloverleaf Marketing DMCC Group of Companies.

This Privacy Statement (together with our Cookies Policy sets out the basis on which we, as a Data Controller, gather, use, process and disclose any personal data we collect from you, or that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We are committed to protecting the privacy and personal data of users.
We will use your personal data only for the purposes and in the manner set forth below which describes the steps we take to ensure our processing of your personal data is in compliance with the General Data Protection Regulation ((EU) 2016/679) (GDPR) and any implementing legislation (Data Protection Legislation).

Please read the following carefully to understand our use of your personal data.



THE TYPES OF PERSONAL DATA WE MAY COLLECT ABOUT YOU
When you visit or use our website and services in any way, we may collect and process different types of information about you.

General Principles for the Processing of Personal Data

Personal Data will be collected, stored, processed and transmitted in accordance with Cloverleaf Marketing DMCC’s established policies and applicable local and international laws, rules and regulations.

The principles of Cloverleaf Marketing DMCC with respect to the processing of Personal Data are as follows:

Personal Data will be processed fairly, lawfully and transparently,

Personal Data will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes,

Personal Data collected by Cloverleaf Marketing DMCC will be adequate, relevant, and not excessive in relation to the purposes for which it is collected,

Personal Data collected by Cloverleaf Marketing DMCC will be accurate and, where necessary, kept up to date to the best of our ability,

Personal Data will be protected against unauthorised access and processing using appropriate technical and organisational security measures and controls; and

Personal Data collected by Cloverleaf Marketing DMCC will be retained as identifiable data for no longer than necessary to serve the purposes for which the Personal Data was collected.

If Cloverleaf Marketing DMCC engages in the processing of Personal Data for purposes other than those specified in this Privacy Statement, Cloverleaf Marketing DMCC will provide notice of these changes, the purposes for which the Personal Data will be used, and the recipients of Personal Data.



COLLECTION OF INFORMATION
Cloverleaf Marketing DMCC may collect Personal Data about you from a variety of sources, including, directly from you, from other Users, from resellers and distributors, from our vendors, from our service providers, from third party information providers, from our affiliates, and through the operation of the Website.

“Personal Data” collected by Cloverleaf Marketing DMCC includes:

• your first and last name;

• billing or shipping address;

• credit card or payment information;

• email address;

• phone number;

• purchase information and history;

• your account number;

• Identification Documents for N20 purchase;
   

For employment purposes, your CV or professional information; and
a combination of your username and password used to access the Website.
Cloverleaf Marketing DMCC collects your Personal Data as follows:



INFORMATION YOU PROVIDE VOLUNTARILY
We may collect Personal Data directly from you when you voluntarily provide it to us. For example, when you communicate with us over the telephone or through the Website by way of email, online chat, web form, or online account registration.



INFORMATION THAT WE COLLECT AUTOMATICALLY
When you visit our Website, we may collect certain information automatically from your device.  In some countries, including countries in the European Economic Area, this information may be considered Personal Data under applicable data protection laws.

Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, your Media Access Control (MAC) Address, broad geographic location (e.g. country or city-level location) and other technical information.  We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked. We may collect online behavioural data linked to online identifiers through tracking technology and this may be matched to personal data to improve our offerings to you. We will never process your personal data unlawfully and we will also ensure your rights and freedoms are protected.
We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors. Some of this information may be collected using cookies and similar tracking technology.



FROM OTHER USERS
We may receive Personal Data about you from other users of the Website when they provide information to us. For example, we may receive information when they communicate with you or with us through the Website.



FROM RESELLERS AND DISTRIBUTORS
We may obtain Personal Data about you from the resellers and distributors or provide them to approved distributors for the purposes of any orders you may make.



FROM OUR VENDORS
We may obtain Personal Data about you from vendors.



FROM THIRD PARTY INFORMATION PROVIDERS
Cloverleaf Marketing DMCC may also obtain Personal Data from third parties that have obtained or collected information about you and that have the right to provide that Personal Data to us. Cloverleaf Marketing DMCC will only obtain this Personal Data where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your Personal Data to us.



HOTJAR
Some of our webpages use services provided by Hotjar Ltd. Hotjar provides services including Heatmaps, Visitor recordings, Funnels and Form Analysis, Feedback Polls, Surveys and Recruiters. The information generated by the tracking code and cookie about your use of the website will be transmitted to and stored by Hotjar on servers in Ireland. Through the Hotjar tracking code the information collected includes:
Device-specific data

The following information may be collected through your device and browser:

• your device's IP address (collected and stored in an anonymized format);

• your email address including first name and surname;

• device screen size;

• device type (unique device identifiers) and browser information;

• geographic location (country only);

• preferred language used to display the webpage.

Log data
Our servers automatically record information which is created upon using Hotjar. Data includes:

• referring domain;

• pages visited;

• geographic location (country only);

• preferred language used to display the webpage;

• date and time when website pages were accessed;
   

Hotjar will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Hotjar uses a variety of services hosted by third parties, such as Google Analytics and Optimizely. These services may collect information sent by your browser as part of a web page request, such as cookies or your IP request. For information on how Google Analytics and Optimizely collect and use your information, please refer to their privacy policies. By continuing to use this website, you consent to the processing of the above data by Hotjar and by the third parties used by Hotjar in accordance with their respective privacy policies. The cookies used by Hotjar have differing durations; some persist for the session only, others will persist for a longer period, with a maximum of 365 days.
To opt out please go to the following link:
https://www.hotjar.com/opt-out
 

USE OF INFORMATION
Cloverleaf Marketing DMCC uses Personal Data we collect to operate our business and provide you with goods and services, which includes using this data to improve our offerings and personalise your experiences. We also may use the data to communicate with you, for example, informing you about your account and product information.

Cloverleaf Marketing DMCC may use your Personal Data for a variety of purposes (the “Purposes”), including to:

Provide you with the products and services you purchase. We provide these in line with our contractual obligations to you, either directly through us or through our partners should you satisfy due diligence requirements for example for the purchase of N20 products;

Provide, maintain and improve the Website and our services, including to operate certain features and functionality of the Website;

Understand user preferences to enhance users’ experience with Cloverleaf Marketing DMCC and its Affiliates, contractors, and business partners;

Research and analyse the effectiveness of the Website and the marketing, advertising and sales efforts of Cloverleaf Marketing DMCC, its Affiliates, contractors, and business partners;

Collect account receivables owed by customers of Cloverleaf Marketing DMCC;

Process orders and payments made through the Website;

Develop additional goods and services;

Process job applications;

Comply with a legal obligation or respond to lawful requests by public authorities (including national security or law enforcement requirements);

Manage our everyday business needs;

Enforce compliance with our Terms of Use and applicable law;

Prosecute and/or defend a court, arbitration or similar legal proceedings;

Communicate directly with you by sending you newsletters, promotions and special offers or information about new products and services on an ongoing basis in accordance with your marketing preferences. You can unsubscribe from our marketing communications by clicking “Unsubscribe” at the bottom of any communication we issue, or by contacting us;

Communicate directly with you by phone to respond to customer service enquiries or comments through the Website, social media or otherwise, to discuss issues relating to your account or the Website, and to provide customer support;

Deliver advertising to you, including to help advertisers and publishers serve and manage ads on the Website or on third party sites, and to tailor ads based on your interests and browsing histories;

Compile aggregated statistics about the operation and use of our Website and to better understand the preferences of the visitors of our Website; and

We may combine and enhance the Personal Data we collect about you with other information we receive from third parties to provide you with the best service possible.

We may also use the Personal Data we collect about you through the Website to generate anonymised, aggregated data. When we do so, we ensure that the anonymised, aggregated data is no longer personally identifiable and may not later be used to identify you.

If you apply to work for Cloverleaf Marketing DMCC we may retain your details, or details of candidates who may be of interest to us on a central database, for a period of up to six months. Alternatively, if you would like to be removed from the database, you may request this.



INFORMATION SHARING
We share your Personal Data as necessary to complete any transaction or provide any goods or services that you have requested or authorised or with your consent where appropriate. We also share Personal Data with vendors, resellers and distributors, service providers, affiliates and business units when required by law and or for the fulfilment of any orders made.

We may share personal data internally with teams such as Sales, Customer Service, Finance, Marketing and Operations and Compliance to ensure your products and services are delivered in line with your purchasing agreement with us. We will only ever process this data for as intended. We may do this to respond to legal process, to protect our customers, to maintain the security of our business, and to protect the rights or property of Cloverleaf Marketing DMCC. You can contact us anytime around how we share your data internally.



WE MAY DISCLOSE YOUR PERSONAL DATA AS FOLLOWS:
Vendors
Cloverleaf Marketing DMCC may share Personal Data about you with the third party vendors that make goods and services available through us. For example, we may share your Personal Data with a third party vendor if you purchase or access a service or goods through us, or a Cloverleaf Marketing DMCC reseller or distributor, and that vendor requires verification of purchase.

Resellers and Distributors
Cloverleaf Marketing DMCC may share your Personal Data with the resellers and distributors that we supply to when you purchase through the Website. For example, we may share your Personal Data if you purchase goods which we provide through an approved reseller or distributor, and that reseller or distributor leveraged our reseller tools and services. Alternatively, we may provide your information to an external third party to facilitate a legitimate interest that we believe you may have pertaining to our Goods.



AFFILIATES AND BUSINESS UNITS
Cloverleaf Marketing DMCC may share your Personal Data with our Partners regardless of whether these entities share the Cloverleaf Marketing DMCC brand. We may also share your Personal Data with other business units that also offer products or services under the Cloverleaf Marketing DMCC brand or one of our other brands. Our affiliates and business units will use your Personal Data we share with them in a manner consistent with this Privacy Statement.



OTHER USERS
Cloverleaf Marketing DMCC may share your Personal Data with other users when you elect to interact with those users (or request that we communicate with them on your behalf) through the Website. This may include facilitating communications with other users or enabling posting of Personal Data to areas of the Website accessible by other users. You should be aware that any Personal Data (or other information) you provide in these areas may be read, collected, and used by others who access them.



LAW ENFORCEMENT AND SAFETY
Cloverleaf Marketing DMCC may share your Personal Data with any competent law enforcement, regulatory, government agency, court, other governmental officials, or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) in connection with actual or proposed litigation, (iii) to exercise, establish or defend our legal rights or interests or protect our property, security and people, or (iv) to protect your vital interests or those of any other person.



SALE OR ACQUISITION OF ASSETS
If Cloverleaf Marketing DMCC transfers ownership or control of any portion of Cloverleaf Marketing DMCC or the Website to an actual or potential buyer, whether in the context of an acquisition, merger, reorganisation, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), we may transfer your Personal Data to that actual or potential buyer, provided that the use of your Personal Data by that third party remains subject to applicable law.



OTHER
If you have asked us to share data with third party sites (such as social media sites), their servers may not be secure. Note also that, despite the measures taken by us and the third parties we engage, the internet is not secure. As a result, others may nevertheless unlawfully intercept or access private transmissions or data.



COOKIE POLICY
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
Our marketing team may use cookies to track analytics on our website traffic and visitors or for use in targeted advertising.

Within the website application, when users choose the “remember me” option during log in, we use cookies to keep them logged in. This cookie is not permanent, it will expire after a fixed period of time. Other cookies may be required for other similar functionality.
Please see our Cookie Policy for further details.



SOCIAL MEDIA
If you make use of any Cloverleaf Marketing DMCC social media features, we may access your personal data via that social media provider in accordance with their policies. When using a social media feature and if you have chosen to include it in your social media account, we may access personal data such as your name, profile picture, gender, birthday, email address, address and any other information you have chosen to make available. Depending on the privacy settings of you and your friends, we may access information that you provide to a social media provider regarding your respective locations (e.g. location data) to provide you with relevant content. We may also access information from social media providers about your use of our content that we run on their website.



WHERE WE STORE PERSONAL DATA
By submitting your personal data, you agree to the transfer, storing and processing. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Statement and the Data Protection Legislation.). We will store your personal data only for as long as necessary for the purposes of providing access to our goods and services to you; as required by law, and for the exercise or defence of any legal claims. We store data on our dedicated internal CRM system.



SAFEGUARDING PERSONAL DATA
The security and confidentiality of your personal data are extremely important to us. As no data transmission over the internet can be guaranteed as 100% secure, we cannot ensure or warrant the security of any information that you transmit to us and you transfer the personal data at your own risk. We endeavour to use and keep under review appropriate technical and organizational measures (including staff training and awareness) in order to protect against unauthorized or unlawful processing of your personal data, including unauthorized destruction, alteration or disclosure or access.



DISCLOSURE OF PERSONAL DATA
We may disclose your personal data to third parties:
Where a service provider provides a service or function on our behalf, including credit card processing, business analytics, customer service, marketing, distribution of surveys, and fraud prevention. We may also authorize third-party service providers to collect information on our behalf, including as necessary to operate features of the website or to facilitate the delivery of online advertising tailored to your interests.

International Data Transfers
Your Personal Data may be transferred to, and processed in, countries other than the country in which you are resident.  These countries may have data protection laws that are different to the laws of your country.
Specifically, our primary website servers are in Ireland and our partners operate around the world.  This means that when we collect your Personal Data we may process it in any of these countries. However, we have taken appropriate safeguards to require that your Personal Data will remain protected in accordance with this Privacy Statement.

These include implementing the European Commission’s Standard Contractual Clauses for transfers of Personal Data between our Affiliates, which require us to protect Personal Data they process from the EEA in accordance with European Union data protection law.

Retention Period
We retain Personal Data we collect from you in line with our business retention periods. For example, where we have an ongoing legitimate business need to do so (such as to provide you with a product or service, or to comply with applicable legal, tax or accounting requirements), we may retain the data for up to 7 years.

YOUR RIGHTS
You have a right to know what personal data we hold about you and to request a copy of the personal data held by us about you by contacting us (see below).

You can also contact us to express the following choices:

You can request to correct your personal data if it is inaccurate, incomplete or out of date or request the deletion of your personal data.

You also always have the option not to share any of your personal data with us or to object to the processing of your data or data portability at any time.

If you do not want to receive newsletters, announcements, or other communications and/or services from the Cloverleaf Marketing DMCC please do not opt-in for those communications or services at the time of registration. If you have opted-in and, at a later time, wish to opt-out, please click on the unsubscribe link inserted in our communications or amend your preferences by contacting us (see below).

Along with every email communication sent to you, we provide you the opportunity to discontinue receiving future communications (i.e., unsubscribe). Simply follow the unsubscribe process or directions provided in the email. We will respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than one month after receipt of your request. We may request proof of identification to verify your request. All requests should be addressed to info@cloverdmcc.com.
It is your responsibility to ensure that any information you have provided to us is accurate and up-to-date. If any of the information that you have provided to us changes, please send us an email entitled ‘CHANGE OF DETAILS’ to info@cloverdmcc.com.

 You have the right to lodge a complaint with the Data Protection Commissioner if you are unhappy with how we are processing your personal data.



CHANGES TO PRIVACY STATEMENT
We reserve the right to change this Privacy Statement from time to time at our sole discretion. If we make any changes, we will post those changes here and update the “Last Updated” date at the bottom of this Privacy Statement. Where you have previously consented to our use of your personal data, your continued use of the Digital Media after we make changes are deemed to be acceptance of those changes, so please check this Privacy Statement periodically for updates.



CONTACT US
Questions, comments, requests, and complaints regarding this Privacy Statement and the information we hold are welcome; please contact us at info@cloverdmcc.com