Privacy Policy
Updated at May 27th, 2024
Information You Provide Directly
We collect information you voluntarily provide when you create an account, use Platform features, or communicate with us:
- Account Registration — Name, email address, password, and account preferences.
- Identity Verification (KYC) — Government-issued identification (passport, driver’s license, or national ID), proof of address documentation, and a selfie or photograph for identity matching. This information is collected to comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations.
- Creator Account Connection — When Creators connect their YouTube, TikTok, or Spotify accounts via OAuth, we access read-only revenue data, subscriber/follower counts, engagement metrics, and content metadata through official platform APIs. We do not access login credentials.
- Investment Activity — Transaction amounts, investment selections, wallet addresses, and dividend history.
- Communications — Content of emails, support requests, feedback, and any information you provide through contact forms or surveys.
- Profile Information — Any additional information you choose to add to your profile, such as a bio or profile picture.
Information Collected Automatically
When you access the Platform, we automatically collect certain technical and usage information:
- Device Information — Browser type and version, operating system, device type, screen resolution, and unique device identifiers.
- Usage Data — Pages viewed, features accessed, time spent on pages, click patterns, navigation paths, search queries, and interaction patterns.
- Log Data — Internet Protocol (IP) address, access timestamps, referring and exit URLs, and server response data.
- Cookies and Tracking Technologies — We use cookies, web beacons, and similar technologies to collect information about your browsing activity. See Section 8 for details.
- Location Data — Approximate geographic location derived from your IP address. We do not collect precise GPS location.
Information from Third Parties
We may receive information about you from third-party sources:
- Platform APIs — Creator revenue data, engagement metrics, and audience analytics from YouTube (via YouTube Data API v3), Spotify (via Spotify Web API), and TikTok (via authorized API providers), accessed with Creator authorization.
- Identity Verification Partners — Verification results and risk assessments from our KYC/AML service providers.
- Blockchain Data — Transaction confirmations, wallet balances, and distribution records from blockchain networks used for USDC settlement.
- Analytics Providers — Aggregated and anonymized usage analytics from third-party analytics services.
How We Use Your Information
We use the information we collect for the following purposes
Artificial Intelligence and Automated Processing
The Platform uses artificial intelligence systems, including Satei AI, to analyze Creator data and generate investment scores, channel valuations, risk assessments, revenue projections, and fraud detection signals.
Satei AI processes the following data: historical platform revenue, subscriber/follower counts, view and engagement metrics, upload/release frequency, audience demographics (where available), and growth trends.
AI-generated outputs are used to: (a) provide informational tools for Users making investment decisions; (b) determine Creator eligibility for Offerings; (c) detect potentially fraudulent or manipulated metrics; and (d) optimize deal terms and pricing recommendations.
AI outputs are informational tools and do not constitute investment advice, guarantees of performance, or automated decisions with legal or similarly significant effects on individuals. Human review processes are available for Creator eligibility determinations.
Creators may request a human review of their Satei AI score or eligibility determination by contacting creators@clockvest.com.
Data Retention
We retain your information for as long as necessary to fulfill the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements
When data is no longer needed for any retained purpose, we will securely delete or anonymize it in accordance with our data retention procedures.
Data Security
We implement industry-standard technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction.
Security measures include: encryption of data in transit (TLS/SSL) and at rest; access controls and authentication requirements for internal systems; regular security assessments and vulnerability testing; employee security training and access restrictions based on role; incident response procedures for security events; and secure credential storage using hashing and salting.
Despite our efforts, no method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee absolute security of your information. In the event of a data breach affecting your personal information, we will notify you and applicable regulatory authorities as required by law.
Your Rights and Choices
Depending on your jurisdiction, you may have the following rights regarding your personal information:
- Right of Access — Request a copy of the personal information we hold about you.
- Right to Correction — Request correction of inaccurate or incomplete personal information.
- Right to Deletion — Request deletion of your personal information, subject to legal retention requirements and active contractual obligations.
- Right to Data Portability — Request a copy of your data in a structured, commonly used, machine-readable format.
- Right to Restrict Processing — Request that we limit how we process your information in certain circumstances.
- Right to Object — Object to processing of your information based on legitimate interests.
- Right to Withdraw Consent — Where processing is based on your consent, withdraw that consent at any time without affecting the lawfulness of prior processing.
- Right to Opt Out of Marketing — Opt out of marketing communications at any time by clicking “unsubscribe” in any marketing email or contacting us.
To exercise any of these rights, contact us at hello@clockvest.com. We will respond to your request within thirty (30) days, or within the timeframe required by applicable law. We may need to verify your identity before processing your request.
How Do We Use The Information We Collect?
Any of the information we collect from you may be used in one of the following ways:
- To personalize your experience (your information helps us to better respond to your individual needs).
- To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you)
- To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs)
- To process transactions
- To administer a contest, promotion, survey or other site feature
- To send periodic emails
How Do We Use Your Email Address?
By submitting your email address on this website, you agree to receive emails from us. You can cancel your participation in any of these email lists at any time by clicking on the opt-out link or other unsubscribe option that is included in the respective email. We only send emails to people who have authorized us to contact them, either directly, or through a third party. We do not send unsolicited commercial emails, because we hate spam as much as you do. By submitting your email address, you also agree to allow us to use your email address for customer audience targeting on sites like Facebook, where we display custom advertising to specific people who have opted-in to receive communications from us. Email addresses submitted only through the order processing page will be used for the sole purpose of sending you information and updates pertaining to your order. If, however, you have provided the same email to us through another method, we may use it for any of the purposes stated in this Policy. Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
How Long Do We Keep Your Information?
We keep your information only so long as we need it to provide ClockPay to you and fulfill the purposes described in this policy. This is also the case for anyone that we share your information with and who carries out services on our behalf. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we’ll either remove it from our systems or depersonalize it so that we can't identify you.
How Do We Protect Your Information?
We implement a variety of security measures to maintain the safety of your personal information when you place an order or enter, submit, or access your personal information. We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. After a transaction, your private information (credit cards, social security numbers, financials, etc.) is never kept on file. We cannot, however, ensure or warrant the absolute security of any information you transmit to ClockPay or guarantee that your information on the Service may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or managerial safeguards.
Could my information be transferred to other countries?
ClockPay is incorporated in United States. Information collected via our website, through direct interactions with you, or from use of our help services may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such data. To the fullest extent allowed by applicable law, by using any of the above, you voluntarily consent to the trans-border transfer and hosting of such information.
Is the information collected through the ClockPay Service secure?
We take precautions to protect the security of your information. We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your information. However, neither people nor security systems are foolproof, including encryption systems. In addition, people can commit intentional crimes, make mistakes or fail to follow policies. Therefore, while we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If applicable law imposes any non-disclaimable duty to protect your personal information, you agree that intentional misconduct will be the standards used to measure our compliance with that duty.
Personnel
If you are a ClockPay worker or applicant, we collect information you voluntarily provide to us. We use the information collected for Human Resources purposes in order to administer benefits to workers and screen applicants.
You may contact us in order to (1) update or correct your information, (2) change your preferences with respect to communications and other information you receive from us, or (3) receive a record of the information we have relating to you. Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion.
Sale of Business
We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of ClockPay or any of its Corporate Affiliates (as defined herein), or that portion of ClockPay or any of its Corporate Affiliates to which the Service relates, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding, provided that the third party agrees to adhere to the terms of this Privacy Policy.
Affiliates
We may disclose information (including personal information) about you to our Corporate Affiliates. For purposes of this Privacy Policy, "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under common control with ClockPay, whether by ownership or otherwise. Any information relating to you that we provide to our Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.
Governing Law
This Privacy Policy is governed by the laws of United States without regard to its conflict of laws provision. You consent to the exclusive jurisdiction of the courts in connection with any action or dispute arising between the parties under or in connection with this Privacy Policy except for those individuals who may have rights to make claims under Privacy Shield, or the Swiss-US framework.
The laws of United States, excluding its conflicts of law rules, shall govern this Agreement and your use of the website. Your use of the website may also be subject to other local, state, national, or international laws.
By using ClockPay or contacting us directly, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not engage with our website, or use our services. Continued use of the website, direct engagement with us, or following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your personal information will mean that you accept those changes.
Your Consent
We've updated our Privacy Policy to provide you with complete transparency into what is being set when you visit our site and how it's being used. By using our ClockPay, registering an account, or making a purchase, you hereby consent to our Privacy Policy and agree to its terms.
Links to Other Websites
This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by ClockPay. We are not responsible for the content, accuracy or opinions expressed in such websites, and such websites are not investigated, monitored or checked for accuracy or completeness by us. Please remember that when you use a link to go from the Services to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our platform, is subject to that website’s own rules and policies. Such third parties may use their own cookies or other methods to collect information about you.
Payment Details
In respect to any credit card or other payment processing details you have provided us, we commit that this confidential information will be stored in the most secure manner possible.
Kids' Privacy
We do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
Changes To Our Privacy Policy
We may change our Service and policies, and we may need to make changes to this Privacy Policy so that they accurately reflect our Service and policies. Unless otherwise required by law, we will notify you (for example, through our Service) before we make changes to this Privacy Policy and give you an opportunity to review them before they go into effect. Then, if you continue to use the Service, you will be bound by the updated Privacy Policy. If you do not want to agree to this or any updated Privacy Policy, you can delete your account.
Third-Party Services
We may display, include or make available third-party content (including data, information, applications and other products services) or provide links to third-party websites or services ("Third- Party Services").
You acknowledge and agree that ClockPay shall not be responsible for any Third-Party Services, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect thereof. ClockPay does not assume and shall not have any liability or responsibility to you or any other person or entity for any Third-Party Services.
Third-Party Services and links thereto are provided solely as a convenience to you and you access and use them entirely at your own risk and subject to such third parties' terms and conditions.
Tracking Technologies
Cookies
We use Cookies to enhance the performance and functionality of our platform but are non-essential to their use. However, without these cookies, certain functionality like videos may become unavailable or you would be required to enter your login details every time you visit the platform as we would not be able to remember that you had logged in previously.
Local Storage
Local Storage sometimes known as DOM storage, provides web apps with methods and protocols for storing client-side data. Web storage supports persistent data storage, similar to cookies but with a greatly enhanced capacity and no information stored in the HTTP request header.
Sessions
We use "Sessions" to identify the areas of our platform that you have visited. A Session is a small piece of data stored on your computer or mobile device by your web browser
Information about General Data Protection Regulation (GDPR)
We may be collecting and using information from you if you are from the European Economic Area (EEA), and in this section of our Privacy Policy we are going to explain exactly how and why is this data collected, and how we maintain this data under protection from being replicated or used in the wrong way.
What is GDPR?
GDPR is an EU-wide privacy and data protection law that regulates how EU residents' data is protected by companies and enhances the control the EU residents have, over their personal data.
The GDPR is relevant to any globally operating company and not just the EU-based businesses and EU residents. Our customers’ data is important irrespective of where they are located, which is why we have implemented GDPR controls as our baseline standard for all our operations worldwide.
What is personal data?
Any data that relates to an identifiable or identified individual. GDPR covers a broad spectrum of information that could be used on its own, or in combination with other pieces of information, to identify a person. Personal data extends beyond a person’s name or email address. Some examples include financial information, political opinions, genetic data, biometric data, IP addresses, physical address, sexual orientation, and ethnicity.
The Data Protection Principles include requirements such as:
Personal data collected must be processed in a fair, legal, and transparent way and should only be used in a way that a person would reasonably expect.
Personal data should only be collected to fulfil a specific purpose and it should only be used for that purpose. Organizations must specify why they need the personal data when they collect it.
Personal data should be held no longer than necessary to fulfil its purpose.
People covered by the GDPR have the right to access their own personal data. They can also request a copy of their data, and that their data be updated, deleted, restricted, or moved to another organization.
Why is GDPR important?
GDPR adds some new requirements regarding how companies should protect individuals' personal data that they collect and process. It also raises the stakes for compliance by increasing enforcement and imposing greater fines for breach. Beyond these facts it's simply the right thing to do. At ClockPay we strongly believe that your data privacy is very important and we already have solid security and privacy practices in place that go beyond the requirements of this new regulation.
Individual Data Subject's Rights - Data Access, Portability and Deletion
We are committed to helping our customers meet the data subject rights requirements of GDPR. ClockPay processes or stores all personal data in fully vetted, DPA compliant vendors. We do store all conversation and personal data for up to 6 years unless your account is deleted. In which case, we dispose of all data in accordance with our Terms of Service and Privacy Policy, but we will not hold it longer than 60 days.
We are aware that if you are working with EU customers, you need to be able to provide them with the ability to access, update, retrieve and remove personal data. We got you! We've been set up as self service from the start and have always given you access to your data and your customers data. Our customer support team is here for you to answer any questions you might have about working with the API.
California Residents
The California Consumer Privacy Act (CCPA) requires us to disclose categories of Personal Information we collect and how we use it, the categories of sources from whom we collect Personal Information, and the third parties with whom we share it, which we have explained above.
We are also required to communicate information about rights California residents have under California law. You may exercise the following rights:
Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information we collect, use, or share; (2) purposes for which categories of Personal Information are collected or used by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you.
Right to Equal Service. We will not discriminate against you if you exercise your privacy rights.
Right to Delete. You may submit a verifiable request to close your account and we will delete Personal Information about you that we have collected.
Request that a business that sells a consumer's personal data, not sell the consumer's personal data.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
We do not sell the Personal Information of our users.
For more information about these rights, please contact us.
California Online Privacy Protection Act (CalOPPA)
CalOPPA requires us to disclose categories of Personal Information we collect and how we use it, the categories of sources from whom we collect Personal Information, and the third parties with whom we share it, which we have explained above.
CalOPPA users have the following rights:
Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information we collect, use, or share; (2) purposes for which categories of Personal Information are collected or used by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you.
Right to Equal Service. We will not discriminate against you if you exercise your privacy rights.
Right to Delete. You may submit a verifiable request to close your account and we will delete Personal Information about you that we have collected.
Right to request that a business that sells a consumer's personal data, not sell the consumer's personal data.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
We do not sell the Personal Information of our users.
For more information about these rights, please contact us.
Contact Us
Don't hesitate to contact us if you have any questions.
Via Email: support@theclockchain.io
Via this Link: https://www.theclockchain.io