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Legal

Privacy Policy

Last updated: 20 January 2021

Clikk AS delivers a sharing platform and meta portal where the user are able to discover new people, connect with them, and share their socials and digital profiles in one place, called Clikk (the “Service”).

Clikk AS will process personal data through the Service. All processing of personal data is in accordance with the privacy rules in force at any given time, including the Norwegian Personal Data Act and the General Data Protection Regulation (GDPR).

You will find at the description below on the purpose and background for our processing of personal data as part of the Service, what data is processed, the purpose and the background for the processing and your rights with regard to the processing of your personal data. This policy only applies to the use of the Service.

We draw especially attention to the section below about the processing of personal data for minors/children.

If you have questions or want to know more about our processing of personal data, you can contact us – see contact information below.

Data controller and processor

If you use the Service by agreement directly with Clikk, Clikk is the data controller (i.e. the responsible for the processing of personal data) for the personal data which is collected and processed upon the use of the Service. Contact information for Clikk is:

Clikk AS
Address: Raveien 205, 3184 Borre, Norway
Tel: +47 950 23 017
Email: privacy@clikk.app
Company registration no.: 922 736 952

Purpose and personal data processed

The processing of personal data is necessary to make the Service and its functionality available to you. We only process the necessary minimum of personal data.

The following information will be collected and processed when you use the app:

  • User content: Phone numbers, email addresses, usernames, user-IDs and/or URL-links you add to the Service, social media account information, and posts and media files from social medias (Facebook, Twitter, Instagram etc.) you connect to the Service.
  • Product interaction: Operating system, device model, screen resolution, version of the app on your device, the connection to the network used (telephone network/wifi), whether the device is held horizontally or vertically, time and date of use, and IP address.
  • Diagnosis: Information and data such as technical logs, data, statistics, know-how, etc. about the use of the app and the Service and the content processed as a result of the Service.
  • Location data: We collect information about your location, including location information based on your SIM card, Cellular and/or IP address. With your permission, we may also collect Global Positioning System (GPS), and Bluetooth data if approved.
  • Phone book: We collect information from your phone book, if you grant us access to your phone book on your mobile device. 

The above is collected and processed to secure, analyse, develop, improve and support the Service, including machine learning and artificial intelligence.

We store data until it is no longer necessary to provide our Service, or until your account is deleted – whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs.

No data will be transferred from your device when the app is not in use. We are still updating data from your connected socials via tokens.

As a registered user, the following personal data is processed:

  • Contact information: Name, birthdate, gender, location (country).
  • Phone numbers, email addresses, usernames, user-IDs and/or URL-links you add to the Service, social media account information, and posts and media files from social medias (Facebook, Twitter, Instagram etc.) you connect to the Service.
  • Information provided by tokens from connected social medias that you connect to the Service.
  • Profile picture
  • Password
  • Information about your friends. You can choose whether to find other users of the Service using our “Find Friends” function and to invite your contacts to join you on the Platform. We will use the contact information you have for that person, such as from within your telephone’s contact list or Facebook friends list
  • Location: SIM card, Cellular and/or IP address. With your permission, we may also collect Global Positioning System (GPS), and Bluetooth data if approved.

The personal data is stored and processed as long as your account is active. If your account is deleted, all data will be deleted after three months. During this period, you will be able to recover your account by signing in with your credentials. If you want all your personal data deleted immediately, you can do so by sending a request to data@clikk.app.

On the computer or other device available that has given you access to the Service, an account will also be registered, and the following information will be processed:

  • Name, username, email address and/or telephone number, birthdate, gender, location (country) of the person who created the account and is logged in.
  • Social media account information.
  • Profile picture.
  • Posts and media files from social medias (Facebook, Twitter, Instagram etc.) you connect to the Service
  • Usernames, User-IDs and/or URL-links you added to the Service.
  • Location: SIM card, Cellular and/or IP address. With your permission, we may also collect Global Positioning System (GPS), and Bluetooth data if approved.
  • Your phone contacts if approved.

Other personal data may also be processed and in other ways, but then you will be informed.

Clikk is the data controller, processing will be based on Clikk having to fulfil an agreement with where the data subject is a party (GDPR Article 6 (1) b). If Clikk is a data processor, the processing will be on the basis which the data processor relies on.

Information we obtain from other sources
We may receive the information described in this Privacy Policy from other sources, such as: 

  • Social Media. If you choose to link or sign up using your social network (such as Facebook, Twitter, LinkedIn, Instagram, or Google), we may collect information and posts from these social media services, including your contact lists for these services and information relating to your use of the Platform in relation to these services. 
  • Third-Party Services. We may collect information about you from third-party services, such as advertising partners and analytics providers. 
  • Other Users of the Platform. Sometimes other users of the Platform may provide us information about you, including through customer service inquiries.
  • Other Sources. We may collect information about you from other publicly available sources. 

Especially about the processing of personal data about minors and children

The processing of personal data for minors will take place in the same way as for other users, and which is described in this policy. We minimise the personal data that is processed and secure the personal data appropriately and impose a level for the processing of personal data equivalent for minors for all users.

Both the minor and the guardian on behalf of the minor may exercise the rights of the minor below.

Disclosure and transfer of personal data

Clikk does not transfer your personal data to third parties.

Clikk uses data processors to collect, store or otherwise process personal data on our behalf. In such cases, we have entered into agreements to ensure information security in all stages of the processing.

All processing of personal data that Clikk carries out will take place within the EU / EEA area.

Security

Clikk will take all necessary technical and organisational measures to secure your personal data. All processing and transmission are encrypted by Microsoft services.

Your rights when we process personal data about you

Your rights below apply where Clikk is responsible for processing, see “Data controller and processor” above.

Right of access, correction, and deletion

You have the right to have access to, correction or deletion of your personal data. If you have registered an account, most of the data you have provided will be manageable in the app. If the data has not been deleted, see above.

In order to exercise your rights, you must contact us using the contact information included above in this policy. We will respond to your inquiry to us as soon as possible and within 30 days. If it takes more than 30 days, you will be notified.

As a registered user, you can also require that incorrect data is corrected or to delete personal data. You can also correct or delete your data through the app if you are a registered user. We will as far as possibly accommodate a request to delete personal data, as long as we do not need the data.

If necessary, we will ask you to confirm your identity or provide additional information before we allow you to exercise your rights. We are required to ensure that we only give access to your personal data to you – and not someone who pretends to be you.

Right to protest on the processing

You also have the right to have the processing restricted in certain cases, such as if:

a) You dispute the accuracy of the personal data, for a period that enables Clikk to check the accuracy of the personal data.

b) The processing is not lawful, and you oppose the deletion of the personal data and instead request that the use of the personal data be restricted.

c) Clikk no longer needs the personal data for the purpose of the processing, but you need them to determine, assert or defend legal claims.

d) You have objected to processing under GDPR Article 21 (1) pending the verification of whether Clikk’s legitimate interests take precedence over your privacy.

The right to data portability

For information that you have provided to Clikk and which is necessary to implement an agreement with Clikk, and which is processed automatically (i.e. not manually by Clikk), you can request that the personal data about you be disclosed or transferred to another supplier in a structured, commonly used and machine-readable format (data portability).

Automated decisions, including profiling

No automated decisions will be made, as mentioned in GDPR Article 22 (1) and (4) based on your personal data.

The right to complain to a supervisory authority

Clikk uses the Norwegian supervisory authority (Datatilsynet) as the leading supervisory authority for cross-border processing pursuant to GDPR Article 56.

If you believe that our processing of personal data is not in accordance with what we have described here or that we in other ways violate the privacy legislation, then you set forth a complaint to Datatilsynet.

You will find information on your rights and how to contact Datatilsynet on their website: www.datatilsynet.no.

Changes

Should there be a change in our processing of personal data or changes in the regulations on the processing of personal data, change in the information provided here may be required. If we have your contact information, we will notify you of the changes. Otherwise, updated information will always be available in the app or on our website.