PRIVACY POLICY of Clever Girls Collective
Last updated May 12, 2020
Welcome to Clever Girls Collective, Inc (“CLEVER”). We offer a network of bloggers and other influencers (collectively, “Influencers”) that help our clients (“Clients”) reach potential customers through social media. This Privacy Policy describes our privacy and data practices for our products and services.
This privacy policy describes the information we collect, how use it, how it may be shared, and what choices you have. This privacy policy is designed to cover all of our products and services, specifically including:
- our website;
- our application process to be Influencers; and
- the CLEVER Pixel — a tool that is placed on blogs or websites of Influencers who are bloggers.
This privacy policy is deemed incorporated by reference into our Terms of Service and our CLEVER Membership Agreement.
OUR WEBSITE
WHAT WE COLLECT FROM VISITORS AND HOW WE USE IT
Our company website (“CLEVER Site” or “Site”) is www.realclever.com. We collect personally identifiable information of Site visitors only from individuals who provide it to us knowingly and directly, such as when you apply to be an Influencer.
We log our visitor’s IP addresses to measure Site traffic, namely, how many unique visitors come to our CLEVER Site. If we did not store the IP address, our Site audience count (number of visitors) would be inflated, because we would count each page load as one visit. By using the IP address, we can recognize duplicate visits from the same IP address, and derive the number of unique visits.
Additionally, we use third party website analytics services and tools to learn the URL of the site that our visitors came from and where they go next. This enables us to understand who is referring traffic to us and where traffic goes from our Site. We also may use analytics services to understand how visitors are using our Site.
HOW WE SHARE THAT INFORMATION
We do not share information about our CLEVER Site visitors with our Clients or third parties, except in the aggregate and except as provided for below with regard to Influencer Applicants.
YOUR CHOICES
Our Site does not allow you to opt out from our logging of your IP address. You can opt out of third party services that analyze your use of our Site as described in the section below titled “Managing your Choices – Including Third-Party Tracking or Advertising Activities.”
INFLUENCER APPLICATION PROCESS
INFORMATION COLLECTED AND USED ABOUT APPLICANTS
Influencer applicants (“Applicants”) submit their applications through our Site. We collect the information that Applicants provide in the online application. This information may include personally and non-personally identifiable information.
The personally identifiable information may include your name and contact information, including email address and phone number. We use this information so that we can follow up with you.
Non-personally identifiable information may include demographic information, such as your age, gender, ethnicity, geographic location, interests, family, and education. We use this information to evaluate your likely match with Clients.
We assume that the readers of each Applicant’s blog or other social media are very similar in demographics and interests to those of the Applicant. Therefore, we evaluate whether potential Influencers will likely reach a Client’s target customers.
SHARING OF APPLICANT INFORMATION
We may share aggregate or non-personally identifiable information about Applicants with our Clients or third parties. For example, we might share that 35 Applicants from Texas applied last year or that we have a network of 1,000 Influencers who have young children.
Once an Applicant becomes an Influencer, we may share some of their information with Clients. We do this in order to help match Influencers with particular Clients. For the matching process, we typically share non-personally identifiable data like interests and demographics. We may also share some personally-identifiable information, like Influencer’s name. We do not share personal contact information of Applicants, such as their email or phone number, with Clients, except with the Applicant’s express permission. We do not share personal contact information of Influencers with Clients, except with the Influencer’s express permission.
YOUR CHOICES
The data practices described above are needed for us to assess applications and manage the Influencer network. Accordingly, we do not offer opt-out mechanisms to Applicants in connection with the application process and network membership.
CLEVER PIXEL
Influencers who are bloggers (“Bloggers”) are required to use a CLEVER pixel (“CLEVER Pixel”) on their own websites or blogs (“Blogger Sites”). We use the CLEVER Pixel as a tool to gather anonymous data about visitors to the Blogger Sites (“Followers”) so that we can understand how well our Bloggers are reaching our Clients’ target audiences.
HOW THE CLEVER PIXEL COLLECTS INFORMATION
The CLEVER Pixel (a short string of software code) collects the IP address of each visitor to each web page that it lives on, along with a record or “time stamp” of when the visit took place. This information reveals the size of the audience reached by the Blogger Site, which is a metric our Clients rely on to measure the effectiveness of Blogger campaigns. From the IP address, we can also infer the general geographic location of the computer the Follower used to access the Blogger Site.
The CLEVER Pixel collects only non-personally identifiable information, including the Follower’s IP address, the Uniform Resource Locator (“URL”) of the website visited before coming to the Blogger Site, and the type of browser used by the Follower.
Sometimes we allow a Client or a third party to “piggyback” on our pixel so that they can gather anonymous information about the Blogger’s audience using their own or third party browser cookies or web beacons. They may then use the information about Followers’ browsing behavior to learn what the Followers are interested in, and, in some cases, to subsequently show them ads that might be of interest to them, which is called targeted advertising.
We may use cookies and beacons for our own purposes, such as learning more about our Bloggers’ audiences, including their behavior after they leave Blogger Sites. The purpose of this would be to provide better services to our Clients and to measure the influence of the Bloggers.
HOW FOLLOWER INFORMATION IS USED AND SHARED
We use Followers’ non-personally identifiable information to measure the audience of our Blogger Sites and to build an understanding of that audience. We assume that each Follower is like the Blogger in many ways. We gather demographic information about each of our Bloggers during the Influencer application process in an effort to learn, indirectly, about their audience. But we prefer to have actual data.
We buy demographic data and may combine it with the data we collect ourselves through the CLEVER Pixel to build profiles of Followers or learn more about them. This may help us better determine if Followers fit into our Client’s target geographic area or demographic or interest profile.
We provide Blogger audience data to our Clients, and may share with Clients Followers’ information in the aggregate, including non-personally identifiable information about Followers’ activities after they leave Blogger Sites to show the influence of the Blogger.
YOUR CHOICES
The CLEVER Pixel does not enable Followers to opt out from its logging of their IP address and collection of non-personally identifiable information. However, a Follower may exercise certain choices over third party activities, including their use of cookies to show the Follower targeted advertising on other websites. These choices are described in the section below titled “Managing your Choices – Including Third-Party Tracking or Advertising Activities.”
CHILDREN’S PRIVACY
We do not knowingly collect any personal information from children under the age of thirteen (13) without parental consent, unless permitted by law. If we learn that a child under the age of thirteen (13) has provided us with personal information, we will delete it according to applicable law.
CHANGES TO OUR PRIVACY POLICY
We may update this privacy policy from time to time. We will notify you of any changes by posting the new policy online. If we make a material change in how we treat your personal information, we will take reasonable steps to notify you in advance of the planned change.
BUSINESS TRANSITIONS
Upon the sale or transfer of Clever Girls Collective, Inc., and/or all or part of its assets, your data or information may be among the items sold or transferred. We will request that the purchaser treat your data according to the privacy notice in place at the time it was collected.
SECURITY MEASURES
CLEVER has put in place reasonable physical and technical measures to safeguard the information collected about you. However, please note that although we take reasonable steps to protect your information, no website or computer system or wireless connection is completely secure.
YOUR CALIFORNIA PRIVACY RIGHTS
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to privacy@realclever.com.
PRACTICES OF OTHER PARTIES AND THIRD-PARTY SITES
This Privacy Policy does not apply to the privacy practices of our Clients, or the privacy practices of Blogger Sites. For that information, you should read their privacy policies when you visit their sites.
Please see Google Privacy Policy here.
MANAGING YOUR CHOICES – INCLUDING THIRD-PARTY TRACKING OR ADVERTISING ACTIVITIES
To help provide you with choices about the information collected by third parties for their purposes, we provide you the following information about choices you have:
- Opting Out of Google Analytics. We use Google Analytics to help us analyze how people are using our Site. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking https://tools.google.com/dlpage/gaoptout/
- Opting Out of ScoreCard Research. We use ScoreCard Research to help us analyze how people are using our Site. To prevent ScoreCard Research from using your information for analytics, go to https://www.scorecardresearch.com/preferences.aspx
- Opting out of MixPanel. We use MixPanel to help us analyze how people are using our Site. To prevent MixPanel from using your information for analytics, go to https://mixpanel.com/optout/
- Opting Out of Google Advertising. We may allow Google to use a cookie to inform Google that you visited our Site, and Google may later serve ads to you on other websites. To opt out of Google interest-based advertising, click https://www.google.com/settings/u/0/ads/authenticated
- Opting Out of Targeted Advertising Generally. The Self-Regulatory Program for Online Behavioral Advertising program provides consumers with the ability to opt-out of having their online behavior recorded and used for advertising purposes by member companies. To opt-out of having your online behavior collected for advertising purposes, click http://www.aboutads.info/choices/ for instructions. Choices you make are both browser- and device-specific. This means that if you opt out when using Safari on your phone, you will not be opted out on Firefox or on your laptop.
- Do Not Track. Some browsers have a ‘do not track’ feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, so we are not currently set up to respond to those signals.
- Deleting cookies. To manage or delete browser cookies, please see your browser’s privacy settings.
- Flash Cookies. We currently do not use flash cookies, but we may in the future. To control flash cookies, click http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html Flash cookies do not reside in your browser, so your browser settings will not affect them.
INTERNATIONAL USERS
If you are located outside of the United States, please note that this site is hosted on our computer servers in the United States. Therefore, your information may be processed and stored in the United States. As a result, United States federal and state governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through laws applicable in the United States. Your use of our products or services or your submission of any personal information to us will constitute your consent to the transfer of your personal information outside of your home country, including the United States, which may provide for different data protection rules than in your country.
CONTACT US
This Privacy Policy is brought to you by CLEVER. We are located at:
2415 San Ramon Valley Boulevard, Suite 4368, San Ramon, CA 94583
