Clover Privacy Policy

Last Updated: July 05, 2022

We may update this Privacy Policy from time to time, so check this page regularly for updates.

1. Introduction

This is the Privacy Policy of Clover, Inc. ("Clover", "us", "we", or "our") and is incorporated into and is subject to our Terms of Use. This Privacy Policy explains how Clover collects, uses, stores, protects, and shares your personal information through our services.

2. Who We Are

The company that is responsible for your information under this Privacy Policy is:

Clover, Inc.
1500 Don Mills Road, Suite 401
North York, Ontario, Canada
M3B 3K4

If you are located in the European Union ("EU"), European Economic Area ("EEA") or the United Kingdom ("UK"), Clover, Inc. is the "data controller" of your personal information collected through our services.

3. Where This Privacy Policy Applies

This Privacy Policy applies to websites, apps, and other services Clover operates. For simplicity, we refer to all of these as our "services" or the "Clover services" in this Privacy Policy. To make it extra clear, we’ve added links to this Privacy Policy on all applicable services.

4. Children's Privacy

IF YOU ARE UNDER 18 YEARS OF AGE, DO NOT USE OR ACCESS THE CLOVER SERVICES AT ANY TIME OR IN ANY MANNER.

Clover is restricted to individuals who are 18 years of age or older. For that reason, we do not knowingly collect or maintain personal information from individuals under the age of 18. If we learn that personal information of individuals under 18 has been collected on or through our services, we will promptly take appropriate steps to delete this information.

If you are the parent or legal guardian of an individual under the age of 18, who has become a Clover member, please contact Clover Support at [email protected] to have that individual’s account terminated and personal information deleted.

For "data subjects", as defined by the European Union General Data Protection Regulation ("EU-GDPR") and the United Kingdom General Data Protection Regulation ("UK-GDPR"), in the EU, EEA, or the UK, where the processing of personal information is based on consent, Clover will not knowingly engage in that processing for users under the age of consent established by applicable data protection law. If we learn that we are engaged in that processing with such users, we will halt such processing and promptly take appropriate steps to delete their personal information.

5. What Information We Collect

We collect certain information when you use Clover. This includes:

information you provide to us;
information we collect automatically;
information we receive from other sources;

Please note that we need certain types of information so that we can create your Clover profile and provide our services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use Clover. We outline in more detail the information we collect below.

Information you provide to us

Account information. When you create a Clover account, you are required to provide us with your name, date of birth, gender, and sexual orientation. Depending on your method of account creation you may also need to provide us with an email address and/or create a password. You will need to complete a series of questions regarding your preferences and what you are looking for on Clover. If you have given us permission to access to your device’s location we will use the GPS location of your device to automatically update your Clover profile’s location. To access certain features, you may need to verify your account or add other information to your account (like a verified phone number or a profile photo).
Content you create. This includes any content that you upload to Clover. For example, you may write chat messages to other users, create custom mixers, or upload and share multimedia files; including photos, voice messages, or videos. This also includes optional information that you provide on your Clover profile, such as, your bio, photos, interests, social media accounts, and custom profile locations.
Purchase information. If you make any in-app purchases or purchase any paid services on Clover, you will need to complete the purchase through a third party processor, such as Apple, Google, or PayPal. Depending on the third party processor, we may receive and store certain order information from them, such as, the order ID, order amount, and/or the date of expiry.
Information from actions you take. We collect information about your use of and activities on Clover. This includes the users you Fave, the Mixers you join, users you block, filter settings, Live streams you view, Gifts you send or receive, and other related actions.
Other information you provide directly to us. You may have the option to submit additional information to us as you use Clover. For example, you may submit information to our Clover Support team when requesting assistance with your account, or you may submit a Success Story for display on our website.

Information we collect automatically

We also collect information automatically from you when you use Clover. This includes:

Information about when you access Clover. We collect information on when you access Clover, including when you open the app on your device or log out of your account.
Information about your device. We collect information about the device you are using to access Clover. This includes information like your IP address, time zone, operating system, device make and model, push notification tokens, permissions you have allowed us to access or denied us from accessing, and advertising or device identifiers.
Information from third party connections. If you register or connect your Clover account to a third party, such as Facebook, we collect the authorization token provided to us from the third party, as well as, any information you have given us permission to collect from that third party. For example, usernames or photos.
Other information that we collect automatically. When you take certain actions on other sites, we may receive information about you. For example, when we advertise for Clover on third party platforms, if you click on the ad, we may receive information about which ad you saw and on which platform. Similarly, we may also receive certain information when you click on a referral link, such as which website you came from.

Information we receive from other sources

We may receive information about you from other sources, including from other users and third parties, and combine that information with the other information we have about you. For example, if you interact with our social media account on another platform, such as Instagram, we may receive certain information about you like your username on that platform. Additionally, other users may provide information about you as they use Clover, for instance as they interact with you or if they submit a report involving you.

6. How We Use Your Information

We do not sell any of the personal information that we collect.

We may use your information for the following purposes:

Identification and authentication: We use your information to verify you when you access your Clover account.
Operating our services: We use your information to provide our services, process and fulfil purchases, provide customer support, and to otherwise comply with our contractual obligations to you.
Communicating with you: We use your information when we communicate with you, e.g. when we respond to a customer support or other inquiry.
Improving our services: We use your information to understand how our services are being used and how we can improve them. In general, we analyze aggregated data, rather than specific user information. We may, however, need to analyze a specific case to address a specific problem, e.g. a bug that affects only a few accounts.
Customizing your experience: We use your information to personalize the service to you. This may include remembering your preferences or displaying users that you might enjoy, based upon your filter choices.
Marketing and advertising: We use your information to show you ads on third-party sites, and to measure the effectiveness of those ads.
Exercising our rights: Where reasonably necessary, we use your information to exercise our legal rights and prevent abuse of our service. For example, we may use your information to detect and prevent fraud, spam, or content that violates our Terms of Use.
Legal compliance: We use your information where we are legally required to do so. For example, we may need to gather your information to respond to a subpoena or court order.
Protecting your information: Where appropriate, we may anonymize, backup, and delete certain information.

We may use algorithms and other automated means to implement any of the above.

7. How We Share & Disclose Your Information

When you tell us to. When you post content to Clover or add information to your public Clover profile, you are telling us to share that content with other Clover users. We may also share your information as you otherwise instruct us or provide us your consent to do so.
With our vendors. We may share information with vendors we hire to carry out specific work for us. This includes payment processors like PayPal that process transactions on our behalf, cloud providers like Amazon that host our data and our services, and analytics providers like Appsflyer or Google that provide us with statistical analysis of our services. We may also share limited information with advertising platforms, like Facebook, to help us reach people that we think will like our product and to measure the performance of our ads shown on those platforms. We do this to help bring more users to Clover, and provide only the information required to facilitate these services. This may include information like the fact that the app was installed or that you registered for a Clover account.
To comply with the law. We may share information in response to a request for information if we believe disclosure is required by law, including meeting national security or law enforcement requirements. Where allowed and feasible, we will attempt to provide you with prior notice before disclosing your information in response to such a request.
In an emergency. We may share information if we believe in good faith that it's necessary to prevent serious harm to a person.
To enforce our policies and rights. We may share information if needed to enforce our Terms of Use or other policies, or to protect the rights, property, and safety of ourselves and others.
With our related companies. We may share information with our related companies, including parents, affiliates, subsidiaries, and other companies under common control and ownership.
Sale, Acquisition, or Transfer of Assets. We may share information if Clover is evaluating and/or engaging in a merger, acquisition, reorganization, bankruptcy, or sale, transfer, or change in ownership of Clover or any of its assets.
Aggregated or de-identified information. We may share information about you that has been aggregated or anonymized such that it cannot reasonably be used to identify you. For example, we may share aggregated user statistics in order to describe our business to partners or the public.

8. How Long We Retain Your Information

We retain your information for as long as it is necessary, for example, to comply with our contractual obligations to you or to provide you with our services. Where we do not need your information in order to provide our services to you, we retain it only for so long as we have a legitimate business purpose in keeping such information, as may be allowed by applicable laws. However, there are occasions where we are likely to keep this information for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defense of legal claims.

After your Clover account has been deleted, we store some information in an aggregated and anonymized format for statistical purposes.

9. How We Protect Your Information

Security of your information is important to us. We use a variety of managerial, technical, and physical measures to protect the integrity and security of your information. These measures are designed to protect your information from unauthorized access, theft, disclosure, modification, or loss and we regularly review our security measures to consider any new available technologies and/or methods.

No security precautions or systems can be completely secure. We cannot ensure or warrant the security of any information you transmit to Clover, and you do so at your own risk. We cannot guarantee that such information may not be accessed, stolen, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Should a breach occur we will notify affected individuals as soon as feasible, or as required under applicable laws.

10. Our Legal Bases For Processing Your Information

We rely on legal grounds to process your personal information to the extent permitted by applicable law, which may include, without limitation: your consent, to honor contractual commitments or to take steps in anticipation of entering into a contract, to fulfill legal obligations, and Clover’s legitimate interests.

For greater clarity, our Legal Bases to process your personal information is generally one of the following four:

Consent: We process your personal information on the basis of your express, clear, and freely given consent for specific purposes. You can revoke your consent through the Clover services or through your device’s permissions settings at any time.
To Honor Our Contractual Commitments: Much of our processing of your personal information is to meet our contractual obligations to you, or to take steps at your request in anticipation of entering into a contract with you. For example, to create your Clover account or provide you with customer support.
Legal Obligations: We need to use and disclose personal information in certain ways to comply with our legal obligations, e.g. we retain information where we are required by law or if we are compelled to do so by a court order or regulatory body.
Legitimate Interests: In many cases, we process your personal information on the basis that it furthers our legitimate interests in ways that are not overridden by your interests or fundamental rights and freedoms. This includes:
- To provide a safe and enjoyable user experience;
- To prevent misuse, and to enforce our Terms of Use and other policies against users who violate them;
- To provide customer support;
- To engage in Marketing or Advertising, e.g. advertising on third-party services or sending emails or other communications to let you know about new features or services;
- To track the fundamental metrics of our business, to perform financial reporting, and to respond to regulatory obligations;
- To analyze and improve our business, e.g. collecting information about how you use the Clover services to optimize the design and placement of certain features or add new features;

11. Where We Store Your Information

Information collected by the Clover may be stored and processed in your region, in the United States, in Canada, or in any other country where Clover or its affiliates, subsidiaries, partners, or service providers are located or maintain facilities. If we provide any information about you to any such entities, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Policy and applicable law. These data transfers allow us to provide the Clover services to you. By accessing or using Clover or otherwise providing information to us, you understand that your information will be processed, transferred, and stored in the United States, in Canada, and other countries, where different data protection standards may apply and/or you may not have the same rights as you do under local law.

When transferring data outside of the EU, EEA, or the UK, we use “standard contractual clauses” (standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data), and we rely on the European Commission's “adequacy decisions” (decisions regarding countries which have been deemed to offer an adequate level of data protection by the European Commission or other competent governmental body) for such data transfers.

12. Your Rights & Choices

You have choices when it comes to what personal information you share with us and what content you post on Clover. You can access and edit most of your profile information by signing into your Clover account and editing it through the “Edit Profile” option in the app. In most cases you can delete any content you have posted publicly or personal information you have entered on your profile within the app itself. We also provide a number of tools in the Privacy settings that allow you to control, among others, who can view your online status, send you messages or video chat requests, or if you want to be shown in the Discover or Dates sections. If you require help with managing your account or content please contact us at [email protected]

You may also be afforded certain rights under applicable privacy laws depending on the jurisdiction you reside in, or your geographical location.

If you are a data subject in the EU, EEA, or UK, you have the following rights with respect to your personal information:

Right of access;
Right to rectification;
Right to erasure (‘right to be forgotten’);
Right to restriction of processing;
Right to data portability;
Right to object to certain processing;
Right not to be subject to a decision based solely on automated processing;

If you wish to exercise any of these rights above please contact our Data Protection Officer at [email protected].

For your protection and the protection of other Clover users, we may ask you to provide proof of identity before we can answer your request to exercise any of the rights listed above.

Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property, or the privacy or other rights of other Clover users.

Also, we may not be able to accommodate certain requests to object to or restrict the processing of personal information where such requests would not allow us to provide our services to you anymore. For example, we cannot provide our services to you if we do not have your date of birth because we need to ensure that you are over the age of 18. If we are unable to accommodate your request to object or restrict the processing of your personal information you may still request to delete your Clover account.

Clover processes “special categories of personal data” as defined by the EU-GDPR and the UK-GDPR. For example, when you register for an account we require you to provide us with your sexual orientation in order to create your Clover profile and provide our services to you. Furthermore, you may choose to provide us with other special categories of information such as your religion, or ethnicity, to display on your Clover profile. You will be asked for your consent to process special categories of personal data from within the Clover app itself. You have the right to withdraw your consent to the processing of this type of personal information at any time. In the case where this information is located on your Clover profile, as optional information, you can remove your consent by removing the information from your profile using the “Edit Profile” option within the app itself. In the case where this information is required to create your Clover profile and provide our services to you, you may remove your consent by requesting that we delete your Clover account. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your other personal information where we rely on a legal basis other than consent to process that information.

You have a right to lodge a complaint with the data protection supervisory authority in the country where you are located if you have concerns about how we process your personal information. If you are located within the UK you may file a complaint with the Information Commissioner's Office (“ICO”).

We use automated decision making processes to show your Clover profile to other users based on your preferences and the preferences of the other users. If you wish to remove yourself from this automated decision making process you can turn off the option to be included in Discover and/or Dates under the Privacy settings within the app.

You have the right to opt-out of email marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" link in the marketing emails we send you. You can further manage your email and push notification settings from within the app.

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. With respect to California's "Shine the Light" law, Civil Code section 1798.83, we do not disclose personal information to third parties for the third parties' direct marketing purposes. For more information on your rights under the California Consumer Privacy Act (CCPA), please visit the PRIVACY NOTICE FOR CALIFORNIA RESIDENTS.

13. Third-Party Services

Clover may link to third-party websites or services. The privacy practices of those third parties are not governed by this Privacy Policy. We encourage you to review the privacy policies of those third-party websites and services to understand their privacy practices.

14. Cookies

Cookies are small bits of information that are transferred to and stored in separate files within your computer's browser. While we do not use cookies on the Clover website we do use Google Analytics. Google Analytics uses its own cookies to track website visitor interactions. You can instruct your computer's browser to stop accepting cookies through your browser's settings. If you wish to stop Google Analytics tracking on your web browser you will need to adjust your browser's cookie settings.

15. Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. However, Clover does not recognize or respond to browser-initiated DNT signals at this time. You may wish to edit your browser’s cookie settings instead.

16. Changes To This Privacy Policy

Clover will update this Privacy Policy from time to time (for example to reflect updates to the Clover services, or to reflect changes in the law). We always indicate the date the last changes were published in the “Last Updated” date at the top of the page. If changes are significant, we’ll provide a more prominent notice as required by law, such as by emailing you. Please check this Privacy Policy periodically for those changes. Your continued use of the Clover services after the posting of changes constitutes your binding acceptance of such changes.

17. How To Contact Us

For any questions, comments, inquiries, or complaints relating to your privacy, please contact us at:

Clover Inc.
Attention: Data Protection Officer
1725 Avenue Road
PO Box 70059
Toronto, Ontario, Canada
M5M 0A0

Email: [email protected]