App and Website Privacy Policy

Effective Date: July 12, 2022

1. Acceptance We have created this Privacy Policy (the “Policy”) because we value users’ privacy. The Policy describes the types of information we may collect from you or that you may provide when you access CLEAN (the “App”). Your use of this App constitutes your acceptance of this Privacy Policy. You may not use our App if you do not agree with this Privacy Policy. This Policy may change from time to time, and the last update date is indicated at the top of this page. Your continued use of this App after we revise this Policy is deemed to be acceptance of the revisions, so please check this page from time to time for updates.

2. What information do we collect?
We may collect several types of information from and about users of our App, including the following:
  • a. Personal Information: First Name, Last Name, Email, Phone Number, City, and Country of residence.
  • b. Analytics: We use Google Analytics, Sentry, or other tracking software to measure usage, error rates, and additional information that is useful to provide a better customer experience. We will store device information, IP addresses, time and location of water tests, GPS information, etc., in a non-identifiable fashion. We may run reports against this data to output aggregate reports, patterns, and insights.
  • c. Voluntary Data: Information you voluntarily provide when you contact us for any reason.
We collect this information:
  • d. Directly from you when you provide it to us.
  • e. Automatically as you navigate through the App.

3. How we use your information We use information that we collect about you or that you provide to us, including any personal information:
  • a. To provide the services you requested.
  • b. To notify you about changes to our App or any services we offer or provide through it.
  • c. To carry out our obligations and enforce our rights.
  • d. In any other way, we may describe when you provide the information.
Data is stored with user and organization info when identifiable. We will retain water testing information in the App for logging and analytics purposes.

4. Disclosure of your information We do not sell any of your personal information to 3rd parties. We may disclose personal information that we collect, or you provide as described in this Policy:
  • a. To fulfill the purpose for which you provide it.
  • b. We use contractors, service providers, and other third parties to support our business.
  • c. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the App’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information about our App users is among the assets transferred.
  • d. We may, without restriction, disclose aggregated information about our users and information that does not identify any individual.
  • e. For any other purpose disclosed by us when you provide the information.
We may also disclose your personal information:
  • f. To comply with any court order, law, or legal process, including responding to any government or regulatory request.
  • g. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the App, our customers, or others.

5. Cookie Policy Cookies are small data files that a website or mobile application transfers to your hard drive or mobile device to store and sometimes track information about you. Although cookies identify a user’s device, cookies do not personally identify users. Our App uses cookies to distinguish you from other users, which helps us improve our App and provide you with a good experience when you browse our website or use our App. We may use cookies for the following reasons and purposes:
  • a. To provide the service you have asked for. Some cookies are essential, so you can navigate the App and use its features. Without these cookies, we would not be able to provide the services you’ve requested. For example, some cookies allow us to identify subscribers and ensure they can access the subscription-only pages. Essential cookies keep you logged in during your visit.
  • b. To improve your browsing experience. These cookies allow the App to remember your choices, such as your language or region, and they provide improved features. These cookies will help you remember your preferences and settings, including marketing preferences, remembering if you’ve filled in certain forms, so you’re not asked to do it again, remembering if you’ve been to the App before, and restricting the number of times you’re shown a particular advertisement. We might also use these cookies to highlight App services that we think will be of interest to you based on your usage of the App.
  • c. Analytics. To improve your experience on our App, we like to keep track of what pages and links are popular and which ones don’t get used so much to help us keep our App relevant and up to date. It’s also advantageous to identify trends of how people navigate (find their way through) our App and if they get error messages from web pages. This group of cookies, often called “analytics cookies,” are used to gather this information. These cookies don’t collect information that identifies you, and the information collected is anonymous and is grouped with the data from everyone else’s cookies. We can then see the overall patterns of usage rather than any one person’s activity.
Most browsers allow you to turn off cookies. To do this, look at the “help” menu on your browser. Switching off cookies may restrict your use of the App and/or delay or affect the way in which it operates.

6. Data security
The personal information you provide is stored on a password-protected server accessible only by the administrator. We use SSL. User data is secured and protected by our cloud provider (Microsoft Azure). We use Microsoft Azure B2C active directory services to store information, it is designed to be GDPR compliant, and data is stored using the highest security standards. Some more details on how Azure is GDPR compliant: https://azure.microsoft.com/en-ca/blog/new-capabilities-to-enable-robust-gdpr-compliance/ App users can only access their information, or, if the user is an admin, information about all the devices and users in their organization. Any information stored about water test results on local machines will be saved to our cloud in a non-personally identifiable structure when you click the button to sync the data to the cloud. However, we cannot guarantee the security of your personal information because any transmission of information over the Internet has inherent risks. Any transmission of personal information is at your own risk. We are not responsible for circumventing any privacy settings or security measures on the App. You are responsible for keeping your login credentials, if any, confidential.

7. Children’s privacy
Our App is not directed to children under 18, and we do not knowingly collect any personal information about children under 18. If we obtain actual knowledge that we have collected personal information about a child under 18, that information will be immediately deleted from our database. If a parent believes that their child has submitted personal information to us, they can contact us via email. We will promptly delete the information upon learning that it relates to a child under 18. Please note that some of this information may remain archived in web logs and backup archives after we delete the information from our active database.

8. International transfer
Your information, including Personal Information, may be transferred to — and maintained on — computers outside your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.

9. EU users’ rights.
This section of our Privacy Policy applies to the users of our App in the EU. We want to inform you about your GDPR rights and how we safeguard them.
  • a. Your GDPR rights to be informed, to access, rectify, erase or restrict the processing of your personal information. You have the right to obtain free information about what personal data we have obtained about you, where it is stored, for how long, for what purposes it is used, and to whom it was disclosed. You have the right to have us, without undue delay, rectify inaccurate personal data concerning you. That means you can request we change your data in our records or have your incomplete personal data completed. You have the “right to be forgotten,” i.e., to have us delete your personal information, without undue delay, if the data is no longer necessary for the purposes for which it was collected. However, GDPR gives us the right to refuse erasure if we can demonstrate compelling legitimate grounds for keeping your information.
  • b.GDPR gives you the right to restrict the processing if any of the following applies:
    • i. If you contest the accuracy of your personal data, we will restrict processing it for a period enabling us to verify its accuracy.
    • ii. The processing is unlawful, and you oppose its erasure and request the restriction of its use instead.
    • iii. We no longer need your personal data for the purposes of the processing, but you require us to restrict processing for the establishment, exercise, or defense of legal claims.
    • iv. You have objected to processing according to Article 21(1) of the GDPR pending the verification of whether our legitimate grounds override yours.
  • c. Right to data portability. Upon request, we will provide your personal data in our possession in a structured, commonly used, and machine-readable format. You have the right to transmit that data to another controller if doing so does not adversely affect the rights and freedoms of others.
  • d. Right to object. You can object, on grounds relating to your particular situation, at any time, to the processing of your personal information if based on point (e) or (f) of Article 6(1) of the GDPR. We will then have to stop processing unless we can demonstrate compelling legitimate grounds for the processing. We will have to stop processing for these purposes if you object to the processing for direct marketing purposes.
  • e. Right to withdraw consent. GDPR grants you the right to withdraw your earlier given consent to process your personal data at any time.
  • f. Rights related to automated decision making. As responsible businesses, we do not rely on automated decision-making, such as profiling.

10. Accessing and correcting your personal information
Please send a message using the contact form on this website for access to, correct, or delete any personal information you have provided to us or to ask questions about this Privacy Policy. You can also edit or delete your information in your account settings.
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