Privacy Policy

Last Updated: April 4, 2024

1. Purpose

ClearPico is committed to protecting your personal data in compliance with privacy principles and applicable laws, including the Personal Data Protection Law No. 6698 ("PDP Law").

We process personal data only for specified purposes, ensuring accuracy and timeliness. Data may be recorded, stored, and organized, transferred to authorized institutions as required by law, and shared with third parties (domestically or internationally) in accordance with legal provisions.

This policy outlines how we collect, use, and store your data, protect and share it with third parties, and allow you to withdraw consent, correct, or update your information.

2. Collection and Processing of Personal Data

We process personal data only for the purposes stated in this policy.

Types of Data Collected:

• Device Information: IDFA, IDVF, IP address, device name, OS version

• Transaction Data: Order history, purchase records

• Location Data: Country, city (general location)

How We Collect Data:

1. Direct Input: Information you provide (e.g., when contacting us)

2. Third-Party Platforms: Apple App Store, Google Play, etc.

3. Automatically Generated Data: Logs, usage duration, device details

3. Data Categories and Types

1. Identity Information: Name, email, phone number

2. Device and Network Data: IDFA, IDVF, IP address, device type, OS version

3. Transaction Data: Purchase history

4. Marketing Data: Advertising-related data (e.g., IDFA, IDVF)

Note: ClearPico does not collect Google user data via Google APIs. Any interaction with Google services follows Google's User Data Policy.

4. Data Processing Principles

We adhere to the following principles:

• Legality and Fairness: Processing complies with laws and fairness

• Accuracy: Data is kept up-to-date when necessary

• Purpose Limitation: Only processed for legitimate, specified purposes

• Data Minimization: Only necessary data is collected

• Retention Period: Kept only as long as legally required or needed

5. Purposes and Legal Grounds for Processing

Why We Process Data:

1. Identity and Contact Info: For service delivery, support, and sales

2. Security Processing: To ensure compliance and business continuity

3. Marketing Data: For analytics, service improvement, and ads

Legal Bases:

• Contract Performance: Fulfilling agreements with you

• Legitimate Interest: Business needs (without overriding your rights)

• Legal Obligation: Compliance with laws

• Consent: For targeted ads (you can withdraw anytime)

6.Fees

We offer both free and paid Services. If you choose to subscribe to a paid Service, you agree to pay the fees ("Fees") as quoted to you when you purchase that Service. We may calculate taxes payable by you based on the billing information that you provide us at the time of purchase. You are responsible for all charges related to using the purchased Service (for example, data charges and currency exchange settlements). You will pay the Fees in the currency We quoted at the time of purchase. We reserve the right to change the eligible currencies at any time, except where not permitted by applicable law. We reserve the right to change its prices at any time. However, if we have offered a specific duration and Fee for your use of the Service, we agree that the Fee will remain in force for that duration.

7. Third-Party Websites and Apps

Our services may include links to external sites not controlled by ClearPico. We are not responsible for their privacy practices. Always review their policies before use.

8. Use of Cookies

We use cookies to enhance functionality, improve user experience, and personalize content.

What are cookies? Small text files stored on your device.

Manage cookies: Adjust browser settings (blocking may affect features).

9. Push Notifications

We may send app updates or service-related alerts. Control notifications by adjusting device settings anytime.

10. Data Storage and Security

We implement strict measures to protect your data, including encryption, access controls, and secure storage.

11. Sharing and Transferring Data

We may share data with third-party providers (e.g., cloud services, analytics firms) for business operations (storage, CRM, support) and legal compliance (authorities, regulations).

12. Your Rights (PDP Law and GDPR)

You have the right to:

1. Access – Know if your data is processed

2. Correct – Fix inaccurate data

3. Delete – Request removal when no longer needed

4. Withdraw Consent – Opt out anytime

5. Object – Stop processing for specific purposes

6. Data Portability – Transfer data to another provider

13. Complaints and Disputes

If you believe your rights were violated, you may file a complaint with the relevant data protection authority or contact us for resolution assistance.

14. Policy Updates

We may update this policy as needed. Changes take effect upon posting. Continued use constitutes acceptance of the revised policy.

15. Contact Us

For questions or to exercise your rights:

Email: feedback_clearpico@hotmail.com