PRIVACY POLICY

CLEVER CRAFT, LLC (“we,” “Boswell”) and its affiliates are committed to protecting and preserving your privacy. This policy, together with our Terms of Use and Conditions, and any other underlying agreements or terms, sets out the basis on which any data we collect from you, or that you provide to us, will be processed by us. This Privacy Policy is designed to inform users of the Boswell website platform (“Platform”), mobile application (“App”) and services of how we collect, use and disclose your Personally Identifiable Information (“PII”).

PII includes any information that can individually identify you and/or your clients, and includes name, contact information, email address, telephone number or postal address. Protected Health Information (“PHI”) includes any data or information that identifies you and/or your clients as a patient, including individually identifiable health information held or transmitted by a covered entity or its business associate, in any form or medium, whether electronic, on paper, or oral and other data that you and/or your clients may share when you use the Platform or App (“Data”). PII, PHI and Data will be collectively referred to as “Personal Data” in this Privacy Policy.

Please read this privacy policy carefully as it contains important information about the following:

What information we may collect about you
How we will use information we collect about you
Whether we will disclose your details to anyone else
Your choices regarding the Personal Data you provide to us

This Privacy Policy only applies to the actions of Boswell and Users with respect to this Platform and App. It does not extend to any websites or applications that can be accessed from this Platform or App including, but not limited to, any links we may provide to social media websites or applications.

Information We May Collect About You

We may collect and process the following Personal Data about you:

Information you give us. This is information (including Personal Data) you consent to giving us about you by filling in forms on our Platform and App, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use our Platform and App, subscribe to any of our services, search for a service, and when you report a problem with our Platform or App.

The information you give us may include your name, address, email address, phone number, financial information, personal description, photographs, payment information, and details regarding your clients.

Information we automatically collect about you. With regard to each of your visits to our Platform and App we will automatically collect information including the following:

Technical information, including a truncated and anonymized version of your Internet protocol (IP) address, browser type and version, operating system and platform
Information about your visit, including what pages you visit, how long you are on the site, how you got to the site (including date and time); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

How We Use Information Collected About You

We use information about you in the following ways:

Information you give us. We will use this information to: - Provide you with information and services that you request from us - Carry out our obligations arising from any contracts entered into between you and us and to provide you with information and services that you request from us - Manage your account(s) with us - Notify you about changes to our service or the functionality of the Platform and App

Information we collect about you. We will use this information: - To administer our Platform and App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes - To improve our Platform and App to ensure that content is presented in the most effective manner for you and for your computer or device - As part of our efforts to keep our Platform and App safe and secure - To make suggestions and recommendations to you and other users of our Platform and App about goods or services that may interest you or them.

Disclosure of Your Information

We are committed to keeping your personal information private. We will not disclose your personal information to any third parties without your consent, except in limited circumstances, such as:

To fulfill a service to you, for example using a third party payment processor to bill you for our services
For data processing reasons, for example using cloud services to store your data or apps
To help us provide our services to you, for example to help handle customer service inquiries
For research purposes that have been okayed by an ethics board and uses data that does not identify you
When legally obligated to disclose it
When we find that your actions on our Platform or App violate our Terms of Use and Conditions

We will seek to obtain your consent before sharing your Personal Data with third parties for other reasons not listed above.

Your information may be shared with carefully selected third parties including:

Business partners, suppliers and sub-contractors for the performance and execution of any contract we enter into with them or you in connection with us providing our services to you
Business partners, suppliers and sub-contractors to help them or us provide and improve their or our services like customer service
Analytics and search engine providers that assist us in the improvement and optimization of our Platform (however all analytics information shared will be in non-personally identifiable, aggregate form)

We will not rent or sell your Personal Data to other entities. We may, however, share your personal information to respond to legal requirements, enforce our policies, respond to claims that a listing or other content violates the rights of others, or protect anyone’s rights, property, or safety.

We may also share Personal Data with a company that acquires our business, whether through merger, acquisition, bankruptcy, dissolution, reorganization, or other similar transaction or proceeding. If this happens, we will post a notice on our home page.

We will always endeavor to ensure that third parties keep your Personal Data secure and do not use your Personal Data for their own direct marketing purposes. Please be aware that we are not responsible for the privacy practices of such third parties.

Security Precautions in Place to Protect Against the Loss, Misuse or Alteration of Your Information

We maintain reasonable security measures to protect Personal Data from loss, destruction, interference, misuse, unauthorized access, disclosure, alteration or destruction. We have put in place physical, electronic and managerial procedures to safeguard and secure the information we collect.

However, we cannot ensure or warrant the security of any information that you transmit to us, and you transmit such information at your own risk.

Access to Your Personal Data

The rights you have to control what personal information we have about you and how we use it will depend on what laws apply.

Individuals who are residents of California, Colorado, Connecticut, Utah, and Virginia may have additional rights:

Right to Access: You have the right to know whether we have collected your personal information and to access such personal information.
Right to Delete: You have the right to request that we delete your personal information, subject to certain exceptions.
Right to Correct: You have the right to request that we correct any personal information we have collected about you.
Right to Portability: You have the right to request a copy of your personal information in a readily useable format.
Right to Opt-Out: You have the right to opt out of certain uses of your personal information including sale, targeted advertising, and profiling.

To make requests, contact us using the information at the end of this policy. You may be entitled to make requests through an authorized agent. We may need to verify your identity before fulfilling your request. We will not discriminate against you for exercising these rights.

For residents outside of the United States, you may have additional rights under the General Data Protection Regulation (GDPR) and other laws.

If you want to access your Personal Data please contact us using our contact information below.

Retention

We will retain your Personal Data only for as long as is necessary for the purposes set out in this privacy policy, for the performance of contractual obligations between you and us, or longer where required by applicable law.

International Data Transfer

Please be aware that your information may be transferred to, processed, maintained, and used on servers and databases located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your location. We will take reasonable steps to protect your privacy in accordance with applicable law and this policy.

Links to Third Party Websites

Our Platform and App may contain links to other websites outside of our control and are not covered by this Privacy Policy. If you access other sites using the links provided, the operators of these sites may collect information from you that will be used by them in accordance with their privacy policy, which may differ from ours.

Our Platform and App may use social media features, such as the Facebook “like” button (“Social Media Features”). These features may collect your IP address, which page you are visiting on our Platform, and may set a cookie to enable the feature to function properly. You may be given the option by such Social Media Features to post information about your activities on this Platform to a profile page of yours that is provided by a third party Social Media network in order to share with others within your network. Social Media Features are either hosted by a third party or hosted directly on our Platform. Your interactions with these features are governed by the privacy policy of the company providing the relevant Social Media Features.

Use by Minors

Our Platform and App are designed and intended for those who have reached the age of majority (18 years of age). By using our Platform and/or App, you affirm that you are at least 18 years of age or older. We are not liable for any damages that may result from a user’s misrepresentation of age.

No one under age 13 is authorized to submit or post any information, including personally identifying information, on our Platform or in our App. Under no circumstances may anyone under age 13 use our Platform or App. Parents or legal guardians of children under 13 cannot agree to this Privacy Policy on their behalf.

For children between the ages of 13 and 17, parental or legal guardian consent is required before any personal information is submitted to our Platform or App.

Changes to Our Privacy Policy

We may change this policy as we may deem necessary from time to time or as may be required by law. If we make material changes to this policy, we will notify you by updating the date of this policy and posting it on our Platform and App. Any changes will be effective immediately on posting. Your use of the Platform or App after revised policy has been posted will be governed by the revised policy.

Contacting Us

We welcome any queries, comments, complaints or requests you may have regarding this Privacy Policy.

165 Middlesex Ave #1222, Somerville, MA 02145

Effective Date: January 11, 2021