Cleva North America, Inc. (“Cleva”) (meaning Cleva and its parents, subsidiaries and affiliates) takes its customers and website users (“User”) on-line security and privacy seriously, so Cleva will make reasonable efforts as described below to ensure its Users confidence and protect their on-line security and privacy. This Privacy Policy covers some of the information that Cleva may choose to collect from its Users when they visit the website or receive and respond to Cleva communications, how Cleva uses such information, and under what circumstances Cleva will disclose it. By using the website or responding to Cleva’s communications, the User agrees to the terms and conditions of this Privacy Policy.

1. Types of Information Collected.

a. Traffic Data Collected. Cleva automatically tracks and collects the certain information when the User visits Cleva’s website, including the User’s: (i) IP address; (ii) domain server; (iii) type of computer; and (iv) type of web browser (collectively “Traffic Data”). Traffic Data is anonymous information that does not personally identify the User but is helpful in Cleva’s efforts to improve the User’s experience on the website. Cleva also uses “cookies,” which are small data files that may be stored on the User’s computer by the website (and may use other automated information gathering devices).

b. Personal Information Collected. In order for the User to access certain services and to purchase products that Cleva may offer via the website, Cleva requires the User to provide information that personally identifies the User (“Personal Information”). Personal Information may include: (i) “Contact Data” (such as name, mailing and e-mail addresses); and (ii) “Financial Data” (such as account or credit card number). If the User communicates with Cleva by e-mail or completes online registration forms, surveys or other forms, any information provided in such communication may be collected as Personal Information.

2. Uses of Personal Information Collected. Cleva will use Contact Data to respond to the User’s requests and inquiries. Cleva uses the User’s Financial Data to verify the User’s qualifications for certain products or services and to bill for products and services. As appropriate Cleva will provide User’s Personal Information to Cleva’s licensee and franchisees. Cleva may use the User’s Contact Data to send the User information about Cleva, its products or services. If the User does not wish to receive such information, the User may, at any time, use the Contact Us link on the website to advise Cleva accordingly, or the User may, upon receipt of such information, follow the instructions enclosed in such communication to remove the User’s name from the website mailing list.

3. User Choice Regarding Collection, Use and Distribution of Traffic Data and Personal Information. The User may choose not to allow the use of the cookies mentioned under the Traffic Data Collection section above. The User’s system settings control the use of cookies (not Cleva).The User should check whether the User’s browser settings allow the User to refuse cookies. If the User does not accept cookies, the User will still have access to some of the functions of the website, but the use of the website may be affected (for example, some functions may not be available or may be slowed down).

The User may choose not to provide Cleva with any Personal Information. In such an event, the User can still access and use much of the website; however, the User will not be able to access and use those portions of the website that require the User’s Personal Information. Some pages on the website may give the User the option of revealing certain Personal Information about the User on the website.

Cleva will not, without asking for the User’s prior permission, use Personal Information it collects from the User for purposes other than those for which the Personal Information was collected.
If the User desires to review or change any Personal Information that Cleva may have about the User, the User can send its request with clear instructions to Cleva at the Contact Us link on the website.

4. Confidentiality of Personal Information. Cleva will not disclose to unrelated third parties (but may disclose to its parents, subsidiaries, affiliates, licensees, franchisees, subcontractors, credit card processors and other related parties) any Personal Information about User, without User’s prior consent unless Cleva has a good faith belief that such action is necessary to: (a) comply with legal process or other legal requirements of any governmental authority; (b) protect and defend the rights or property of Cleva; (c) enforce this Agreement; or (d) operate or conduct maintenance and repair of Cleva’s services or equipment, including the services provided by the website as authorized by law. In the latter case, any disclosure of User’s personal information will be governed by a confidentiality obligation.

5. Lost or Stolen Information. The User must promptly notify Cleva if the User’s credit card, user name or password is lost, stolen or used without permission. In such an event, Cleva will cancel that credit card number, user name or password and update its records accordingly.

6. Links and User Privacy. The website may contain links to other website. Cleva is not responsible for the privacy practices or the content of such websites and in providing the link Cleva does not imply any endorsement, recommendation or approval of such sites. The User accessing any such site is entirely at the User’s own risk. 

7. General Internet Security Issues. User is aware of the general security and on-line privacy risks pertaining to the Internet (for which Cleva is not in any way responsible).

8. Underage Users.  Individuals under the age of eighteen are not allowed to use the website without the consent/supervision of their parent or legal guardian. Individuals under the age of thirteen are not allowed to post any contact information for display on the website.

9. Updates and Changes to the Privacy Policy. Cleva reserves the right, at any time, to change this Privacy Policy, simply by posting a changed Privacy Policy on this website. The date of the most recent revision is provided below. The User is responsible to check this Privacy Policy periodically and when it uses the website for any such changes to the Privacy Policy.