Privacy Policy

This Privacy Policy and Terms of Use (hereinafter “the Policy”) establish the rules of use of the applications “OWLY - Free AI powered chatbot”, Whazzup, Pic4me (hereinafter “the Application”) and how the User’s personal data is collected, processed, stored and transferred to third parties by Clifton Networks LP (hereinafter “Clifton”) in connection with such use. .

1  General provisions

1 This Policy applies to all users (each, a “User” or “you”) of the Application.

2 By installing the Application on a mobile device, the User agrees to the terms of this Policy. If the User disagrees with any term of the Policy, he (she) shall stop using the Application and delete it.

3 Clifton may periodically amend or update this Policy. The Policy contains a reference to a current version with recent updates or amendments. A new version of the Policy enters into force when published, unless the text of a new Policy provides differently. 

4 Clifton reserves the right, in its sole discretion, to modify, limit or discontinue any aspect of the Application, as well as any aspect relating to the use of the Application.

2  Personal data of the User.

1 Clifton collects, processes and stores the following personal data of the User:

1 Personal data that the User shall provide to register and personal data that is collected by the Application in an automatic manner: data of a public social media profile (if registration is made through a social media profile), metadata, IP address, browser settings, location, operating system language, device ID and other.

2 Personal data that is provided by the User in his (her) sole discretion: biography, social media links and other.

2 The goal of collection, processing and storing of personal data is to ensure effective operation of the Application and identification of users, to personalize user experience and enable machine learning, to develop and to test new features and functionalities, to detect technical flaws and bugs, to monitor statistical data (for example, number of users), to carry out marketing research and totailor advertising and marketing, and to offer new services. Clifton is free to use personal data of the User for any other goals related to the functionality of the Application and other applications developed or published by Clifton and its family of companies.

3 In order to optimize the Application and to assure its proper functioning, Clifton may transfer user personal data to its partners and service providers (for example, payment service providers). We may also share your information within our family of companies and with advertisers to provide you with information on products and services that may be relevant to you. In the event Clifton sells or transfers the Application to another company, collected personal information will likely be one of the assets transferred. By accepting the Policy, the User expresses his (her) consent with such transfer (including a cross-border one). Clifton is not liable for any data protection infringements committed by its partners or service providers, if applicable law does not envisage such liability.

4 Clifton is not liable for any possible infringements connected to collection, processing and storing of personal data by third parties.

5 Clifton can use, transfer, exploit and enjoy other rights in relation to copyrighted materials made available by the User through the Application. Such copyrighted materials may contain personal information (for example, facial image in a picture). By making available such copyrighted materials through the Application, the User gives a full and unconditional consent to Clifton to use such personal data, images and other personal information embedded into such copyright objects. By making available such copyrighted materials, the User also guarantees that the consent of all personal data subjects is received, if their personal data is embedded into such copyright objects. It is the User’s responsibility to seek consent of all such personal data subjects before posting or making available such copyrighted materials through the Application. Clifton cannot be liable for any non-received consent of such personal data subjects.

6 Clifton has no capacity to verify personal data provided by the User. Clifton presumes that all personal information and data provided by the User or collected by Clifton is accurate and up-to-date. Clifton cannot be held liable for provision of incorrect, inaccurate or not up-to-date personal data by the User and any possible consequences deriving therefrom.

3 Rights and obligations of the User

1 The User has a right to:

1 request from Clifton any information about what personal data is collected, processed and stored about him (her);

2 correct or amend his (her) personal data by editing his (her) User Account;

3 delete the personal data, which is provided by the User in his (her) sole discretion (see para. 2.1.2.);

4 delete the personaldata which is provided automatically (see para. 2.1.1.) by deleting the User Account. If the User Account is deleted, the Application can no longer be used.

5 ask Clifton to delete personal data that is incorrect, incomplete, unlawfully obtained or that is no longer relevant, if such deletion cannot be done independently in accordance with para. 3.1.3. and 3.1.4.

2 The User is obliged:

1 to provide only such personal data that is accurate and up-to-date;

2 not to collect and use personal data of other users for any purposes;

3 to comply with applicable law on data protection.

4 Disclosure of personal data

1 Clifton does not transfer personal data of users to third parties except in the cases envisaged by this Policy and (or) applicable law.

2 Clifton may disclose the User’s personal data when it is required to do so for national security protection reasons, by law enforcement and other legitimate demands of a competent authority in accordance with a legal procedure established under applicable law. Clifton may also restore and transfer such personal data that has been previously deleted or changed when requested by a completent authority and in accordance with a legal procedure established under applicable law (for example, pursuant to a court order).

4 Clifton may disclose the User’s personal data in order to protect its own business interests, interests of other users and public. By accepting the Policy, the User agrees to such disclosures. 

5  Retention and transfer of personal data

1 Clifton will take reasonable measures (technical, organizational and legal) to protect the User’s personal data from unauthorized access, destruction, modification, alteration, copying, distribution and other unauthorized actions of third parties.

3 Clifton may fix an exact term for retention of the User’s personal data, if such term is prescribed by applicable law or if it is required for the goals of processing specified in para. 2.2.

4 By installing and using the Application, the User expresses his (her) consent for transferring of his (her) personal data to the country where  servers of Clifton and its partners providing support for the Application are located or any other country where Clifton and/or its partners has or will have their servers and other equipment. The User also consents to transfer of his (her) personal data to countries where the data protection regime may be less stringent that in a country of his (her) domicile, residence or citizenship.

6  No Warranty; Limitation of liability

1 Clifton takes reasonable measures to maintain confidentiality of the User’s personal data in accordance with para. 5.  Nevertheless, Clifton cannot guarantee full security of any personal data that the User provides to Clifton or that is collected about the User in the course of his (her) use of the Application. Clifton is also not able to guarantee that personal data will not be disclosed, published, changed or destroyed. To the maximum extent permitted by applicable law, Clifton and its affiliates, service providers, officers, employees and agents shall not liable for any such disclosures, publications, changes and destructions.

2 You expressly acknowledge and agree that your use of the Application is at your sole risk and that, to the maximum extent permitted by applicable law, the Application and any content or information provided by the Application, are provided “as is” and “as available”, with all faults and without warranty of any kind, and Clifton hereby disclaims all warranties and conditions with respect to the Application and any content or information provided by the Application.

3 The Application is intended solely for entertainment purposes and may not be used as a substitute for professional advice and/or information. Clifton and its affiliates, service providers, officers, employees and agents shall have no liability for any actions taken or not taken by any user based on its interactions with the Application.

4 Clifton and its affiliates, service providers, officers, employees and agents shall not be liable, in contract, tort (including, without limitation, negligence), under statute or otherwise, as a result of or in connection with the Application, for any: (i) economic loss (including, without limitation, loss of revenues, profits, contracts, business or anticipated savings); or (ii) loss of goodwill or reputation; or (iii) special or indirect or consequential loss.

7  Miscellaneous

1 Clifton does not purposefully direct its activities to a territory of any country. In spite of the fact that the Application may be initially downloaded and installed only in some jurisdictions, it is expected that it will be accessible to a broader range of users from other countries. The fact that the Application can be downloaded and installed in particular jurisdiction does not mean that Clifton purposefully directs its activities to such jurisdiction.

2 If any term of this Policy is determined to be invalid by a court or other competent authority, its invalidity does not lead to invalidity of the Policy and its other terms. If any term of this Policy or the whole Policy is determined to be invalid by a court of one country, such invalidly does not lead to invalidity in other countries.

3 This Policy shall be governed by and construed in accordance with the laws of the State of New York, United States of America, without regards to its principles of conflicts of law. All disputes arising out of this Policy shall be resolved by, and the User hereby agrees to submit to the exclusive jurisdiction of, any state or federal court located in New York County.

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Privacy Policy