Last updated on May 31 2021

Clearbox AI Privacy Policy

Owner and data controller

Clearbox AI Solutions S.r.l. Corso Castelfidardo 30/a - 10129 Turin (Italy) VAT ID: (IT)12161430017 email: info@clearbox.ai Henceforth referred to as Clearbox AI.

Scope of this policy

This policy covers the personal data that users provide to or collected by Clearbox AI to allow Users to access their website and services, and any of its sub domains of clearbox.ai that include its services and products.

The purposes of processing

When you use the website and services of Clearbox AI your data is processed for the following purposes:

  • Provide, maintain and improve our Services, including, for example, to register you as a new customer, to process and deliver your order including managing payments, fees and charges;
  • Provide and deliver the products and services you request, process transactions and send you related information like email confirmations;
  • Send you technical notices, updates, security alerts and support and administrative messages;
  • Communicate with you about products, services, offers, promotions, rewards and events offered by Clearbox AI, and provide news and information we think will be of interest to you;
  • Monitor and analyse trends, usage and activities in connection with our Services;
  • Personalise and improve our Services and provide content or features that match user profiles or interests;
  • Deliver relevant website content and/or advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
  • Administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting data)

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Types of data collected

Among the types of Personal Data that our Website collects, by itself or through third parties:

  • Identity data: includes first name, maiden name, last name, username or similar identifier, social media and community profile username, github profile for example, in addition to email address.
  • Profile data: includes your username and profile information, biographical information, your preferences, feedback, and responses.
  • Contact data: includes address, email address and telephone number.
  • Participation data: includes information received through participation in any interactive features of our Services, surveys, promotions,, source code, requests for customer support or information you choose to otherwise communicate with us.
  • Usage data: includes information on how the website, products and services are used.
  • Marketing and communication data: includes preferences in receiving marketing communications.
  • Aggregated data: Information related to use and performance of its platform by the users to improve our services and user experience. This aggregated data is collected and combined from different users, and it is completely anonymous and the users cannot be identified through this data. For example, aggregated data can help us identify the most used features or the types of Machine Learning Models ("ML Models") that are uploaded most on the platform to optimise our services.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.

Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party's consent to provide the Data to Clearbox AI.

All cookies on this site

Below is a survey of the cookies we use at clearbox.ai. Please keep in mind that this information may change from time to time, for instance because we may abjust our website or because cookie regulations may change. We take every effort to keep this information as accurate as possible and we therefore recomment visitors to check this page on a regular basis.

Necessary cookies

Cookie Name Purpose Duration
optional-cookies-accepted This cookie is used to store whether cookies can be used in the user’s browser 30 days
shown-newsletter-popup This cookie is used to stop the newsletter popup from showing if the user already interacted with it 15 minutes

Analytical cookies

Cookie Name Purpose Duration
ajs_user_id This cookie helps track visitor usage, events, target marketing, and can also measure application performance and stability. 365 days
ajs_anonymous_id This cookie helps track visitor usage, events, target marketing, and can also measure application performance and stability. 365 days
_gid This cookie is used by Google Analytics to store and count pageviews. 1 day
_gcl_au This cookie is used by Google Adsense to store and track conversions. 90 days
_gat This cookie is used by Google Analytics to read and filter requests from bots. 1 minute
_ga This cookie is used by Google Analytics to store and count pageviews. 2 years
_ga_* This cookie is used by Google Analytics to store and count pageviews. 1 year
_drip_client_* This cookie is used by Drip for marketing purposes and to handle newsletter subscriptions. 2 years

Third-party cookies

Some of our pages display content from external providers, e.g. YouTube, Facebook and Twitter.

To view this third-party content, you first have to accept their specific terms and conditions. This includes their cookie policies, which we have no control over.

But if you do not view this content, no third-party cookies are installed on your device.

Third-party providers on our website:

  • YouTube

Children under the age of 13

Our Website and Services are not intended for children under 13 years of age. No one under age 13 may provide any personal information to Clearbox AI. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@clearbox.ai

Mode and place of processing the data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • Processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Managing contacts and sending messages, Analytics, Contacting the User, Content commenting, Handling payments and Remarketing and behavioral targeting.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Detailed information on the processing of personal data

Personal Data is collected for the following purposes and using the following services:

Analytics

The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

Google Analytics with anonymised IP (Google Ireland Limited)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilises the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualise and personalise the ads of its own advertising network.

This integration of Google Analytics anonymises your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.

Personal Data collected: Cookies; Usage Data.

Place of processing: Ireland – Privacy Policy.

Information required for sign up

Users may have to sign up to use some of our products and services on our website or one of its sub domains. In that case they have to provide us with their first and last name, and email address and can log in with third party credentials such as a github account. We will collect this information to provide optimal services to the users.

Contacting the user

Contact form (this Website)

By filling in the contact form with their Data, the User authorises this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data collected: email address; name, company, phone number

Managing contacts and use information

We use G Suite tools as a content management system to manage contacts and store linked user information.

G Suite is a paid offering of Google, it offers solutions for email, word processing, spreadsheets, presentation decks, shared calendars, cloud storage. According to Google’s website , there are no ads in G Suite Services or Google Cloud Platform. Google does not scan for advertising purposes in Gmail or other G Suite services. Google does not collect or use data in G Suite services for advertising purposes. For more information on their privacy policy please follow this link.

The rights of users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Website does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilised by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using this Website who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.

This Website (or this Application and related tools and products)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Website including products offered by Clearbox AI through this website as described in relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies

Small piece of data stored in the User's device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

Last updated: 29/07/2022