Clove Fintech Inc. (“Clove”, “we”, “us”) has developed this Privacy Policy (“Privacy Policy”) to outline how we gather, utilize, and share Personal Information through our financial services software platform (the “Platform”), our website at https://helloclove.com (the “Website”), and our mobile application (the “App”) (collectively, the “Services”).
In this Policy, we use the word “Customer” to refer to anyone who has subscribed to or paid for use of our Services. We use the term “End User” to refer to any other individual user of our Services, such as an employee or service provider of a Customer, or an individual browsing or using our Website and web-based resources.
Please review this privacy policy carefully. By submitting your personal information to us, by using our Website, or by otherwise accessing or using the Services, you consent to our collecting, using and disclosing your personal information as set out in this privacy policy.
This Privacy Policy does not extend to the practices of companies that we do not own or control. The Platform and Services are designed for business use. If you are an End User of one of our Customers, the Customer controls your information processed within the Services, including your contact information and other records. Please contact the relevant Customer for any questions about your personal information.
We collect personal information that is necessary to provide our services, comply with legal obligations, and enhance the user experience.
The primary basis on which we collect, use and disclose your personal information is with your consent, unless otherwise permitted or required by law. How we obtain your consent will depend on the circumstances, as well as the sensitivity of the information collected. Subject to applicable laws, your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question. If you choose to provide personal information to us, we assume that you consent to the collection, use and disclosure of your personal information as outlined in this privacy policy.
Typically, we will seek your consent at the time your personal information is collected. Where we want to use your personal information for a purpose not previously identified to you at the time of collection, we will seek your consent prior to our use of such information for this new purpose.
You may withdraw your consent to our collection, use or disclosure of your personal information at any time by contacting us using the contact information within our Website. However, before we implement the withdrawal of consent, we may require proof of your identity. In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain products or services. Please also note that certain data will remain within the Services for us to fulfill our contractual obligations, even after you withdraw your consent.
If you provide personal information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect such information from you, and to use and disclose his or her information as described in this privacy policy.
We generallycollect the following types of personal information for the following purposes. The Personal Information that Clove collects about individuals varies based on their relationship with our Us and our Customers.
In addition to the primary uses outlined above, Clove utilizes personal information for the following purposes:
Clove uses cookies in the Services to authenticate and authorize access for End Users. A cookie is a small data file, often with a unique identifier, sent to your browser and stored on your device. Each device accessing our Website receives a unique cookie.
Cookies help recognize devices and personalize the Platform experience. Clove uses session cookies with encrypted data to uniquely identify you while logged in, enabling transaction processing and request handling. These cookies verify your identity after login and are essential for using the Services.
You can configure your browser to notify you when a cookie is sent, allowing you to accept or decline it. However, disabling cookies may limit access to certain Clove Website and Services features. We do not link cookie data to personally identifiable information submitted on the Website. Clove combines cookie-derived data with Account Information of registered users for the purposes outlined in Section 3.1.
Clove processes and stores data, including Personal Information, on servers in Canada and the United States. By submitting Personal Information or using the Services, you consent to its transfer, storage, and processing in these countries. You acknowledge that your Personal Information may be accessible to law enforcement and government agencies in Canada and the United States under legal access regimes or court orders. For more information about our policies and practices regarding transfers to other countries, contact us using the contact information in the “Contact Information” section below.
Clove engages third-party Sub-Processors (“Sub-Processors”) to perform tasks on our behalf, requiring the sharing of personal information with such Sub-Processors to deliver certain services. Clove uses Sub-Processors to collect, store, and process Customers’ and End Users’ Personal Information. Unless stated otherwise, these Sub-Processors may only use the shared Personal Information as necessary to perform their assigned tasks.
Currently, our Sub-Processors include third-party companies and individuals assisting with maintenance, database management, web analytics, and platform improvements. For an updated list, visit https://helloclove.com/sub-processors.
We may also disclose your personal information to third parties regarding your account or transactions in the following cases:
If Clove is acquired, ceases operations, enters bankruptcy, or undergoes a change of control, Personal Information may be transferred to the new controlling entity, as permitted by law.
If we intend to use or disclose Personal Information beyond what is outlined in this Privacy Policy, we will notify you and obtain consent as required by applicable privacy laws.
We may disclose Personal Information without consent if necessary to identify, contact, or take legal action against individuals causing harm or interference—whether intentional or not—to our rights, property, End Users, or others who may be affected.Additionally, we may disclose Personal Information in good faith to comply with legal requirements. We reserve the right to access, read, preserve, and disclose information as needed to:
This may involve sharing information with companies and organizations for fraud prevention and malware protection. While this policy outlines general practices, personal information may be collected, used, or disclosed beyond these terms if permitted by applicable laws, regulations, or court orders.
We have implemented commercially reasonable physical, organizational, contractual and technologicalsecurity measures with a view to protecting your personal information from accidental or unlawful destruction, loss or theft, unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that the only personnel who are granted access to your personal information are those with a business ‘need-to-know’ or whose duties reasonably require such information.
Despite the measures outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. In the case of a breach of security safeguards, we will act promptly to mitigate the risks and to inform you where there is a real risk of significant harm, or as otherwise required by law.
You are responsible for maintaining the secrecy of your identification, passwords and/or any personal information in your possession for the use of our website and/or the Services. Always be careful and responsible regarding your personal information. We are not responsible for, and cannot control, the use by others of any information which you provide to them and you should use caution in selecting the personal information you provide to others through our website or the Services. Similarly, we cannot assume any responsibility for the content of any personal information or other information which you receive from other users through our website or the Services. We cannot guarantee, or assume any responsibility for verifying, the accuracy of the personal information or other information provided by any third party.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information on our website.
We retain your Personal Information as long as needed to fulfill the identified purposes or as required by law, even after our relationship ends. Certain data may be kept to prevent fraud, support legitimate business needs (e.g., analyzing aggregated, non-personally identifiable data, account recovery), or meet legal obligations. All retained Personal Information remains subject to this Privacy Policy.
Individuals have a number of rights concerning their personal information under global privacy laws. You may make a written request to access, correct or delete any personal information about you that we have collected, used or disclosed, and we will provide you with any such personal information to the extent required by law. You may also challenge the accuracy or completeness of your personal information in our records. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend the personal information as required. If you provided personal information to a Customer and believe it is being processed by us on behalf of that Customer, please make any requests or queries regarding that personal information to the Customer directly.
Where applicable, you may be entitled to additional rights, including: (i) the right to withdraw consent to processing; (ii) the right to object to unlawful data processing, under certain conditions; (iii) the right to erasure of personal information about you, under certain conditions; (iv) the right to demand that we restrict processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, or believe your personal information is inaccurate; (v) the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, under certain conditions; (vi) the right to object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions.
Please note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
When you exercise your right to deletion of your personal information, we will delete your personal information, subject to some instances where your personal information will be maintained for us to fulfill our obligations under contract to our Customers. This information includes content contained within Customer Data.
You also have the right to lodge a complaint with the relevant data protection or privacy authority, such as the Office of the Privacy Commissioner.
We may require that you provide sufficient identification to fulfill your request to access or correct your personal information. Any such identifying information will be used only for this purpose. We will not charge you any fees to access your personal information in our records without first providing you with an estimate of the approximate fees, if any.
This Privacy Policy is current as of the “updated” date which appears at the top of this page. We may modify this privacy policy from time to time. When changes are made to this Privacy Policy they will become immediately effective when published in a revised privacy policy posted on our website, unless otherwise noted. We may also communicate the changes through our Website, by email, through platform notifications, or by other means. By submitting your personal information to us, by registering for or using any of the Services we offer, by using our Website, or by voluntarily interacting with us after we publish or communicate a notice about the changes to this privacy policy, you consent to our collecting, using and disclosing your personal information as set out in the revised privacy policy.
If you have questions or concerns about this Privacy Policy, contact our Privacy Officer at:Clove Fintech Inc.
Attn: Privacy Officer16-1720
11 Street SW, Calgary, AB, T2T 3L6
Email: [email protected]