What is 'Cloaking'?
'Cloaking' (including grammatically inflected forms) is the practice of creating proxy-based identifiers corresponding to personally identifiable information.
What information does Cloaked collect?
Summary: We collect the categories of information listed below. We do not have access to passwords, which are salted and hashed, or encrypted.
Depending on your use of the Service, we may collect information about you, the Service may generate cloaked identifiers to mask categories of information listed below. We will have access to those cloaked data elements.
• Account and contact information, including your name, username, passwords (name, username, password, as stored: salted + hashed, or encrypted), contact information, and other specifics based on product type.
• Billing and tokenized credit card information.
• For Cloaked Pay, Certain know-your-customer information, including date of birth, gender, and financial account data.
Cloaked Pay GLBA Notice
• Device information, We store requested and referring URL, browser/IP information, and analytical data on use of the service.
How is information collected with Cloaked?
Summary: We collect information as part of payment authorization and fraud screening. Cookies provide Service functionality. Information in log files provide and improve our Service.
We collect information directly from you as well as from third parties, like those providing payment processing and fraud prevention services.
Registering to Use and While Using the Service
You may create an account to use features of the Service. You may provide information to us and directly to our service providers, like our payment services provider.
In addition to cookie data, we collect Device Information via log files to administer and monitor the Service.
Financial Institutions and Data Aggregators
Does Cloaked collect information from children under 13 years of age?
No: The Service is not permitted, designed for, or directed to children under the age of 13. We do not collect information from any person we actually know is under the age of 13. If you believe your child has provided us with personal information, please alert us at firstname.lastname@example.org. If we learn that we have collected personal information from a minor, we will promptly take steps to delete such information. Cloaked Card is not permitted for persons under the age of 18.
What does Cloaked do with the information it collects?
European Data Protection Laws require us to explain the legal bases for our processing of your information. We process your information:
(a) where you have given consent to the processing, which consent may be withdrawn at any time without affecting the lawfulness of processing based on consent prior to withdrawal;
(b) where it is necessary to perform the contract we have entered into or are about to enter into with you (whether in relation to the provision of the Service or otherwise);
(c) where it is necessary for us to comply with a legal obligation to which we are subject; and/or
(d) where it is necessary for the purposes of our legitimate interests (or those of a third party) in providing or marketing the Service and your interests or fundamental rights and freedoms do not override those legitimate interests.
To provide some more detail, we use the information collected to:
• Provide the Service;
• Process your application and transactions;
• Determine your eligibility for the Service;
• Verify your identity;
• Prevent fraud;
• Manage and service your account;
• Operate and improve the Service; and
• Contact you for customer service and billing purposes.
Unless you request otherwise (where permitted by law), we and third parties acting on our behalf may subsequently send you electronic newsletters or contact you about the Service. If you no longer desire to receive these communications, we will provide you with the option to change your preferences in each communication we send to you. You may also inform us by email: email@example.com.
If you identify yourself to us by e-mail with questions, we will use your information to respond to your questions or comments, and file your questions or comments (with your information) for future reference.
We also use information collected to send announcements regarding the Service or your billing account status. You cannot unsubscribe from Service or transactional announcements as they contain important information relevant to your use of the Service.
When does Cloaked disclose information to third parties?
Summary: We may disclose contact information, and device data, to third-parties to comply with relevant law, or for legal reasons. This information may also be disclosed to Professional Advisors to provide us with business services. In the event of an investment in Cloaked or a sale of our business, we may share limited, required information with an investor or purchaser.
We disclose information we gather through the Service to the following third parties, as set forth by our Terms of Service, or as separately authorized by you:
Laws and Legal Rights
We may disclose your information as required by law, to enforce law or contract, or to protect the safety and/or security of our users or the Service.
We may provide information to our Professional Advisors in the course of professional services rendered to provide us with business services like accounting or legal services.
We may employ independent contractors, third party service providers, vendors, and suppliers to provide us with business services related to the Service. These Outside Contractors may have access to information collected through the Service. We use reasonable efforts to ensure that these Outside Contractors (a) limit their use of your information only to the extent necessary to provide services, and (b) are capable of protecting the security of your information.
Sale of Business
We may transfer information to a third party in connection with a sale, merger, transfer of all or substantially all of the assets of Cloaked.
Is the information collected through the service secure?
Summary: Your information is stored using commercially reasonable security techniques.
We want your information to remain secure. We strive to provide transmission of your information from your device to our servers that align with commercially reasonable standards and to employ administrative, physical, and electronic measures to protect your information from unauthorized access.
Our Data Protection Officer (DPO) acts as an administrative control to ensure commercially reasonable privacy controls are employed and working, both for Cloaked and third parties utilized by Cloaked. Our DPO can be reached at firstname.lastname@example.org.
There is always risk involved in transmitting information over the Internet. As a result, although we strive to protect your information, we cannot ensure or warrant the security or privacy of information you transmit to us, and you do so at your own risk.
Could my information be transferred to other countries?
Summary: Your information may be transferred to the United States. If you are located in the European Economic Area or the United Kingdom, although the United States has less stringent privacy laws than your home country, where required, we ensure the same degree of protection that is required under European Economic Area and United Kingdom regulations.
For how long will my information be kept?
We will only retain your information for as long as necessary to fulfill the purposes for which we collected it or as otherwise permitted by applicable law.
To determine the appropriate retention period for information, we consider the amount, nature, and sensitivity of that information, regulatory requirements, the potential risk of harm, and the purposes for which we process your information and achieving those purposes through.
What choices do I have regarding my information?
Summary: You can opt out of marketing communications by contacting us. As outlined below, users in the European Economic Area, Canada, and the United Kingdom may have additional rights which can be exercised by contacting us.
If you have questions, requests, or would like to update information, please contact us at email@example.com.
Residents of Europe
Under certain circumstances and in compliance with the European Data Protection Laws, you may have the right to:
Request access to your information (commonly known as ‘data subject access request’).
Request correction of the information that we hold about you.
Request erasure of your information.
Object to processing of your information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground;
Request the restriction of processing of your information.
Request the transfer of your information to another party; and
Lodge a complaint with the relevant supervisory authority (as defined in the European Data Protection Laws).
If you are covered by the European Data Protection Laws and want to review, verify, correct or request erasure of your information, object to the processing of your information, or request that we transfer a copy of your information to another party, please contact firstname.lastname@example.org.
Residents of Canada
You acknowledge that your personal information may be processed and stored in foreign jurisdictions as described above. In these cases, we will comply with applicable local law requirements relating to the conditions for disclosure or release of personal information.
If you are a Canadian resident, you have certain rights regarding your personal information as described below:
• Access: You have a right to access your personal information held by us. Upon written request and authentication of identity, we will provide you with your personal information under our control. We will also give you information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We may charge you a reasonable fee for doing so.
In some situations, we may not be able to provide access to certain personal information (e.g. legal bases). We may also be prevented by law from providing access to certain personal information. If we must refuse an access request, we will notify you in writing.
• Accuracy and Correction: If you demonstrate the inaccuracy or incompleteness of your personal information, we will amend the information as required.
• Withdraw Consent: You have the right to withdraw your consent to use or communication of your personal information at any time by communicating with us at email@example.com. We may however be unable to offer you certain services if you withdraw your consent. This will not affect the lawfulness of any use or communication of your information that happened before such withdrawal, nor does it oblige us to delete personal information that we are otherwise allowed or required to retain under applicable law;
• Complaints: If you request, we will provide our complaint procedure, absent legal circumstances that prevent us from doing so.
• Supervisory Authorities: If you have unresolved concerns, you have the right to complain to a data protection authority where you reside, where you work, or where you believe there has been non-compliance with data protection or privacy laws.
If you are a resident of the province of Québec, the following additional rights are available to you:
• Portability of Your Personal information: You have the right to receive your personal data in a structured, commonly-used and machine-readable format. You also have the right to request that we transmit your personal information to another organization.
• De-indexation: You have the right to request, in certain circumstances, that we cease disseminating your personal information or to de-index any hyperlink that allows access to that personal information by technological means, if such dissemination contravenes applicable law or a court order.
These rights may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information that we are required by law or have compelling legitimate interests to keep.
All users have the right to "opt out" of receiving marketing communications by following directions provided in the communication or by contacting firstname.lastname@example.org.
DO NOT TRACK
We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request.
Who do I contact if I have any privacy questions.
Contact us at: email@example.com
Policy last updated on: August 15, 2023