We care about your privacy.

1. CLUES cares deeply about the privacy of its visitors and users. To that end, this Privacy Policy (“Privacy Policy”) describes how CLUES, collect, use, and share your Personal Information, as well as an explanation of the data rights you may have in that Personal Information. This Privacy Policy applies to all CLUES users, including unregistered visitors, registered users, and premium users (collectively, “Users”, “you”, or “your”), and to all CLUES services, including our websites (including www.wix.com and any of its subdomains, the “Website”), web applications (“CLUES Apps”), mobile applications (“Mobile Apps”), and related services (collectively, the “Services”). This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you may have under other applicable data privacy laws.

Prior to accessing or using our Services, please read this policy and make sure you fully understand our practices in relation to your Personal Information.  If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately leave and discontinue all use of any of our Services.  If you have any questions or concerns regarding this policy, please contact us.

 

2. What Personal Information do we collect

 

2.1. User Information:

To provide you the Services, we must collect Personal Information relating to an identified or identifiable natural person (“Personal Information”). We collect Personal Information you provide us, from your use of the Services, and from other sources. Here are the types of Personal Information we collect about you:

  1. Information you provide us. When you register for our Services, purchase and/or register domain names, use any of our Services; and/or when you contact us directly by any communication channel (e.g., CLUES’s support tickets, emails), you may provide us Personal Information, such as name, email address, phone number, payment information (for Users with Paid Services), information you include in your communications with us, and Personal Information contained in scanned identification documents (such as an ID card, driver’s license, passport, or official company registration documents).    

  2. Information we collect when you use the Services. When you visit, download, and/or use any of our Services, we may collect aggregated usage Personal Information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc

  3. Information we collect from other sources. We may receive Personal Information about you from third-party sources, such as i) security providers , fraud detection and prevention providers for example to help us screen out users associated with fraud, ii) social media platforms, when you log-in or sign-up using your social media account, we may receive Personal Information from that service (e.g., your username, basic profile Personal Information) and in some cases, we may collect Personal Information from lead enhancement companies which help us to improve our service offering; iii) advertising and marketing partners in order to monitor, manage and measure our ad campaigns.

 

 

Quick summary#

To provide our Services, we collect Personal Information about our Users.

The Personal Information comes from you when you visit or use our services, Personal Information we collect automatically, and Personal Information we collect from other sources.

 

2.2. Users of Users Personal Information

We may also collect Personal Information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf (as further described in Section ‎6 below).

 

 

3. How we share your Personal Information

We do not share your Personal Information with service providers or others.

 

4. Where do we store your Personal Information?

Users’ and Users-of-Users’ Personal Information may be stored in our CRM held by Pukka Films Ltd

​CLUES affiliates and Third-Party Service Providers that store or process your Personal Information on CLUES’s behalf are contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.

 

5. Use of cookies and other third-party technologies

We and our Third Party Service Providers use cookies and other similar technologies (“Cookies”) in  order for us to provide our Service and ensure that it performs properly, to analyse our performance and marketing activities, and to personalize your experience.

You can learn more about how we use cookies and similar technologies and how you can exercise control over them in our Cookie Policy.

Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

Quick summary#

We and certain third party services may use cookies and similar tracking technologies throughout our services.

These technologies are used mostly for stability, security, functionality, performance and advertising purposes.

 

6. Communications from CLUES

 

6.1. Promotional Messages

We may use your Personal Information to send you promotional content and messages by e-mail, text messages, notifications within our platform, marketing calls and similar forms of communication from CLUES or our partners (acting on CLUES’s behalf) through such means.

​If you do not wish to receive such promotional messages or calls, you may notify CLUES at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.

 

Quick summary# 

We may send you promotional messages and content.
You can easily opt-out of receiving promotional messages by contacting us or unsubscribing.

 

6.2. Service and Billing Messages

CLUES may also contact you with important information regarding our Services, or your use thereof. For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your User Website; or notify you of material changes in our Services.

It is important that you are always able to receive such messages. For this reason, you are not be able to opt-out of receiving such Service and Billing Messages unless you are no longer a CLUES User (which can be done by deactivating your account).

We may also contact you with service and billing-related messages and content. You will not be able to opt-out of receiving such messages.

 

 

7. Your rights in relation to your Personal Information

CLUES agrees that it is imperative that you have control over your Personal Information. Pursuant to privacy regulations worldwide, CLUES is taking steps to enable you to request access to, receive a copy of, update, amend, delete, or limit the use of your Personal Information.

Before fulfilling your request, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g. if your request is unfounded or excessive).

You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).

If you are a CLUES User, and you wish to receive a copy, access and/or request us to make corrections to the Personal Information that you have stored with us (either yours or your Users-of-Users’), or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes.

Quick summary#

You may request to access, receive a copy of, update, amend, delete, or limit the use of your Personal Information you have stored with us. Just send us an e-mail  ​

 

8.  Data Retention

We may continue to retain your Personal Information after you have attended a training course, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding delivery of service, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.

We maintain a data retention policy which we apply to Personal Information in our care.

 

Quick summary#

We may keep your Personal Information for 12 months or longer as needed (for example, if we are legally obligated to keep it longer, or need it to protect our interests).

 

9. Security

CLUES has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and we regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.

Regardless of the measures and efforts taken by CLUES, we cannot and do not guarantee the absolute protection and security of your Personal Information, your Users-of-Users’ Personal Information or any other information you upload, publish or otherwise share with CLUES or anyone else.

If you have any questions regarding the security of our Services, you are welcome to contact us at cluestrainuing.biz

 

Quick summary#

CLUES values the security of our customers' Personal Information and we do everything in our power to protect it. 

However, as we can’t guarantee absolute protection – we encourage you to be careful, set a strong password for your accounts, and avoid submitting any sensitive information which, if exposed, could cause you major harm.

 

10. Updates and interpretation

We may update this Privacy Policy as required by applicable law, and to reflect changes to our Personal Information collection, usage and storage practices. If we make any changes that we deem as “material” (in our sole good faith discretion), we will notify you prior to the change becoming effective. In relation to any updated Privacy Policy, we will, as required by applicable law, notify you, seek your consent and/or take any other measures. We encourage you to periodically review this page for the latest Information on our privacy practices. Unless stated otherwise, our most current Privacy Policy applies to all information that we have about you and your Users-of-Users, with respect to our Website, CLUES Apps, Mobile Apps and other Services. 

Any heading, caption or section title contained herein, and any explanation or summary under the right “#ItsThatEasy” column, is provided only for convenience, and in no way defines or explains any section or provision hereof, or legally binds any of us in any way.

This Privacy Policy was written in English, and may be translated into other languages for your convenience. You may access and view other language versions by changing your CLUES Website language settings. If a translated (non-English) version of this Privacy Policy conflicts in any way with its English version, the provisions of the English version shall prevail.

 

Quick summary#

We may change this policy at any time. We will notify you of changes as required by applicable law.

11. Contacting us

If you have any questions about this Privacy Policy or wish to exercise any of your rights, please refer to those sections or contact us at cluestraining.biz. We will attempt to resolve any complaints regarding the use of your Personal Information in accordance with this Privacy Policy.