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Cookie Policy

Last Updated: 6 December 2023

We, KPTRS Investments Ltd, a company duly incorporated in Ireland under company number 496147, having its registered office at CleverCards Suite 4, The Mall, Beacon Court, Sandyford, Dublin D18 TN80 (“CleverCards/Us/We”), together with our affiliates, take privacy very seriously. This policy sets out how we, as a data controller, collect and process personal data about:

  • Visitors to our websites
  • Subscribers to or users of our online services or marketing

This Cookie Policy also sets out information about data subject rights and our obligations under data protection law and may be read in conjunction with our Privacy Policy.

WHAT IS A COOKIE?

A 'cookie' is a small data file that is placed on your computer or mobile device ("Device"). It allows a website to remember your actions or preferences until the cookie is deleted or expires. Some of the cookies CleverCards use are essential for our website to work. Our "website" includes this website, all our associated sites and our social media pages. We also use some non-essential cookies to collect information to help us improve the website.

Cookies can be stored for varying lengths of time on your browser or Device. Session cookies are generally deleted from your computer or Device when you close your browser. Persistent cookies will remain stored on your computer or Device until deleted or until they reach their expiry date as detailed in the tables below.

WHY WE USE COOKIES

We use cookies to:

  • Help improve your experience browsing our website
  • Collect information about visitors’ use of the website operations, like website navigation
  • Analyse visitor numbers and behaviours, such as what pages are frequently visited
  • Assess the success of our communications
  • Target suitable advertising messages
  • Understand which of our advertising partners has helped us reach out to new customers, or have promoted us on their websites

More details on the purpose of each cookie are set out in the tables below.

COOKIES AND YOUR PERSONAL DATA

The information we collect may include some personal data. Our use of strictly necessary cookies involves processing the following personal data:

  • Your unique user ID
  • Your IP address
  • Your approximate location based on your IP address at the time you are browsing

The lawful basis for processing of personal data relating to "strictly necessary" cookies is complying with our legal obligations and our legitimate interests to secure our website and make it available to you when processing that personal data.

Other (optional) cookies process the following personal data:

  • The date, time and duration of visits
  • The number of pages viewed
  • The amount of time spent on the website
  • Your Device information
  • Your IP address

The lawful basis for processing of personal data relating to optional cookies is our legitimate interests in maintaining, operating and improving our websites, providing our products and services to customers and managing and improving our business, provided such interests are not overridden by the rights and interests of the data subjects concerned.

Please see the section below entitled Managing and Disabling Cookies and withdrawing your consent for more information on how to provide or withdraw your consent to the placing of cookies at any time. This policy also sets out information about data subject rights and our obligations under data protection law when processing your personal data.

TYPES OF COOKIES USED AND THIRD PARTIES

The tables below explain the cookies we use, their purpose, duration and whether the cookie is placed by us or a third party. Not all of these cookies apply to all of our websites. You can check which type of cookies apply to each website using the cookie panel on the relevant website. Some cookies are referred to as 1st party cookies meaning they are set by our domain. 3rd party cookies are set by a domain other than our website. 3rd party cookies are covered by the third parties’ cookie policies.

When we send an email to you, the email includes cookies and similar technologies to help us better understand how subscribers interact with our emails, such as whether they are opened by the subscriber. If you do not consent to us setting these cookies, please unsubscribe from our email list and delete any emails that you have received.

STRICTLY NECESSARY COOKIES

These cookies are necessary for the website to function and to comply with our legal obligations and cannot be switched off in our systems. They are usually only set in response to actions made by you to request products and services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the website will not then work.

OptanonConsent This cookie is set by the cookie management tool provided by OneTrust. It stores information about the categories of cookies the website uses and whether you have given or withdrawn consent for the use of each optional category of cookie. - Expiry: 365 days - 1st Party

OptanonAlertBoxClosed This cookie is set by the cookie management tool provided by OneTrust. It is set after you have seen a cookie information notice and in some cases only when they actively close the notice down. It enables our website not to show you the message more than once. - Expiry: 365 days - 1st Party

_cfuvid This cookie is a part of the services provided by Cloudflare, including load-balancing, deliverance of website content and serving DNS connection for website operators. - Expiry: Session - 1st Party __cf_bm This cookie is a cookie necessary to support Cloudflare Bot Management. As part of our bot management service, this cookie helps manage incoming traffic that matches criteria associated with bots. This is a CloudFoundry cookie. - Expiry: Session - 1st Party

__tld_test__ Registers data on visitors’ website-behaviour. This is used for internal analysis and website optimisation. - Expiry: Session - 1st Party

PERFORMANCE COOKIES

These are optional cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our website. They help us to know which pages are the most and least popular and see how visitors move around the website. All information collected in relation to performance cookies is aggregated and is not processed by us in a way that would allow us to identify any users. If you do not allow these cookies we will not know when you have visited our website, and will not be able to monitor its performance.

amplitude_id_xxxxxx xxxxxxxxxxxxxxx These cookies are set by Amplitude Analytics, which helps to better understand how the website is used. - Expiry: 3649 days - 1st Party

amplitude_testclevercards.com Used by Amplitude for session tracking for analytics purposes. Amplitude Privacy policy. - Expiry 3649 days - 1st Party

_ga This cookie name is associated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the site’s analytics reports. - Expiry: 729 days - 1st Party

_ga_xxxxxxxxxx This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site's analytics report. The cookies store information anonymously and assigns a randomly generated number to identify unique visitors. - Expiry: 2 years - 1st Party

amplitude_cookie_test This cookie is used by Amplitude for session tracking for analytics purposes. Amplitude Privacy policy. - Expiry: Session - 1st Party

OTZ This cookie is used by Google Analytics to provide an analysis of website visitors in aggregate. - Expiry: 1 month - 1st Party

FUNCTIONAL COOKIES

These are optional cookies. These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

cwr_s Allows AWS to store session data including an anonymous session ID (uuid v4) created by the web client. This allows CloudWatch RUM to compute sessionised metrics like errors per session. - Expiry: 1 day - 1st Party

cwr_u Allows AWS to store an anonymous user ID (uuid v4) created by the web client. This allows CloudWatch RUM to count return visitors. - Expiry: 30 days - 1st Party

_gid This cookie is used for Google Analytics to store and update a unique value for each page visited. - Expiry: 1 day - 1st Party

_gcl_au This cookie is used by Google Analytics to understand user interaction with the website. - Expiry: 90 days - 1st Party

__hssrc This cookie name is associated with websites built on the HubSpot platform. It is reported by them as being used for website analytics. - Expiry: Session - 1st Party

_hjSession_3699685 A cookie that holds the current session data. This ensures that subsequent requests within the session window will be attributed to the same Hotjar session. - Expiry: Session - 1st Party

_hjAbsoluteSessionInProgress This cookie is used by HotJar to detect the first pageview session of a user. This is a True/False flag set by the cookie. - Expiry: Session - 1st Party

_hjTLDTest When the Hotjar script executes we try to determine the most generic cookie path we should use, instead of the page hostname. This is done so that cookies can be shared across subdomains (where applicable). To determine this, we try to store the _hjTLDTest cookie for different URL substring alternatives until it fails. After this check, the cookie is removed. - Expiry: Session - 1st Party

_hjFirstSeen This cookie identifies a new user's first session on a website, indicating whether or not Hotjar's seeing this user for the first time. - Expiry: Session - 1st Party

hubspotutk This cookie name is associated with websites built on the HubSpot platform. Its purpose is user authentication. - Expiry: 179 days - 1st Party

ar_debug Stores and tracks conversions. - Expiry: Session - 1st Party

test_cookie This cookie is set by DoubleClick (which is owned by Google) to determine if the website visitor's browser supports cookies. - Expiry: Session - 1st Party

_gclxxxx This is a Google conversion tracking cookie. - Expiry: 89 days - 1st Party

__Secure-ENID This cookie is used by Google to prevent fraudulent login attempts. This also contains a Google user ID which can be used for statistics and marketing purposes following a successful login. - Expiry: 13 months - 1st Party

SSID This cookie contains digitally signed and encrypted records of a user’s Google Account ID and most recent sign-in time. - Expiry: 1 year - 1st Party

SOCS This cookie is used by Google to store a user’s state regarding their cookies choices. - Expiry: 1 day - 1st Party

SIDCC This cookie is used by Google to provide the identification of trusted web traffic. - Expiry: 1 year - 1st Party

SID This cookie contains digitally signed and encrypted records of a user’s Google Account ID and most recent sign-in time. - Expiry: 1 year - 1st Party NID This cookie stores user preferences and settings, such as language preferences and customised options for Google services. This cookie helps enhance the user experience by remembering their preferences across different websites that utilise Google services. - Expiry: 6 months - 1st Party HSID This cookie contains digitally signed and encrypted records of a user’s Google Account ID and most recent sign-in time. - Expiry: 1 year - 1st Party CONSENT This cookie is used by Google to store a user’s state regarding their cookie choices. - Expiry: 2 years - 1st Party APISID This cookie is used to store and remember user preferences and settings on a website, such as language preferences, search preferences, and other customisation options. - Expiry: 1 year - 1st Party

AEC This cookie is used by Google to ensure that requests within a browsing session are made by the user, and not by other sites. - Expiry: 6 months - 1st Party

__Secure-3PSIDTS This cookie is necessary for the use of website options and services - Expiry:1 year - 1st Party

__Secure-1PSIDTS This cookie is necessary for the use of website options and services. - Expiry:1 year - 1st Party __Secure-1PSIDCC This cookie is necessary for the use of website options and services. - Expiry:1 year - 1st Party

TARGETING COOKIES

These are optional cookies. These cookies may be set through our website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. If you do not allow these cookies, you will experience less targeted advertising. _fbp Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. - Expiry: 89 days - 3rd Party IDE Used by Google DoubleClick to register and report the website user's actions after viewing or clicking one of the advertiser's ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user. - Expiry: 389 days - 3rd Party _gcl_aw This cookie is used by Google Ads to provide ad delivery or retargeting. - Expiry: 90 days - 3rd Party

__hssc This cookie name is associated with websites built on the HubSpot platform. It is reported by them as being used for website analytics. - Expiry: Session - 1st Party

__hstc This cookie name is associated with websites built on the HubSpot platform. It is reported by them as being used for website analytics. - Expiry: 179 days - 1st Party __Secure-3PSID This cookie is used for targeting purposes to build a profile of the website visitor's interests in order to show relevant and personalised Google advertising. - Expiry: 2 years - 3rd Party __Secure-3PAPISID This cookie is used for targeting purposes to build a profile of the website visitor's interests in order to show relevant and personalised Google advertising. - Expiry: 2 years - 3rd Party __Secure-3PSIDCC This cookie is used to collect information about user interactions with advertisements displayed on websites that use Google advertising services - Expiry: 1 year - 3rd Party __Secure-1PSID This cookie is used for targeting purposes to build a profile of the website visitor's interests in order to show relevant and personalised Google advertising. - Expiry: 2 years - 3rd Party __Secure-1PAPISID This cookie is used for targeting purposes to build a profile of the website visitor's interests in order to show relevant & personalised Google advertising. - Expiry: 2 years - 3rd Party SAPISID This cookie is used by Google to display personalised advertisements on Google sites, based on recent searches and previous interactions. - Expiry: 1 year - 3rd Party 1P_JAR This cookie is used by Google Analytics to provide ad delivery or retargeting. - Expiry: 30 days - 3rd Party

DSID This cookie is used to identify a signed-in user on non-Google sites and to remember whether the user has agreed to ad personalization. - Expiry: 14 days - 3rd Party

DISCLOSURE OF YOUR INFORMATION

In addition to the 3rd parties referred to in the tables above, we may disclose personal data to:

  • Third parties, including cloud service providers, who provide a service to us
  • A public authority in the event that we are required to do so by law
  • A third party where we are under a legal obligation to transfer it to that third party or where we provide it on behalf of a client who is under such legal obligation
  • A prospective seller or buyer of any of our assets or business
  • A third party where it is necessary to protect the vital interests of the data subject or another natural person

To the limited extent that it is necessary to transfer personal data outside of the EEA, we will ensure appropriate safeguards are in place to protect the privacy and integrity of such personal data, including standard contractual clauses under Article 46.2 of the GDPR. Please contact us if you wish to obtain information concerning such safeguards at help@clevercards.com.

LINKS TO OTHER SITES

Our website may, from time to time, contain links to and from other websites. If you follow a link to any of those websites, please note that those websites have their own cookie policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those websites.

DATA SUBJECT RIGHTS

To the extent that we process personal data as a result of your cookie preferences and we are a controller of that personal data, you may request access to, rectification, or erasure of your personal data, or restriction of processing or object to processing of your personal data, as well as the right to data portability. In each case, these rights are subject to restrictions as laid down by law. The following is a summary of your rights:

  • The right of access enables you to receive a copy of your personal data
  • The right to rectification enables you to correct any inaccurate or incomplete personal data we hold about you
  • The right to erasure enables you to ask us to delete your personal data in certain circumstances
  • The right to restrict processing enables you to ask us to halt the processing of your personal data in certain circumstances
  • The right to object enables you to object to us processing your personal data on the basis of our legitimate interests (or those of a third party)
  • The right to data portability enables you to request us to transmit personal data that you have provided to us, to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party, where technically feasible

You have the right to lodge a complaint with the Data Protection Authority, in particular in the Member State of your residence, place of work or place of an alleged infringement, if you consider that the processing of your personal data infringes the GDPR.

If you wish to exercise any of these rights, please contact us (help@clevercards.com). We will respond to your request within one month. That period may be extended by two further months where necessary, taking into account the complexity and number of requests. We will inform you of any such extension within one month of receipt of your request. We may request proof of identification to verify your request. We have the right to refuse your request where there is a basis to do so in law, or if your request is manifestly unfounded or excessive, or to the extent necessary for important objectives of public interest.

In limited circumstances (such as our use of social media), we may act as a joint controller with another party. In such circumstances, upon your request to exercise any of the above rights we will advise you if there is another controller who you should contact. Please note that any other joint controller will also have its own privacy policy and cookie policy.

SECURITY AND WHERE WE STORE YOUR PERSONAL DATA

We are committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorised access and use. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. We have implemented strict internal guidelines to ensure that your privacy is safeguarded at every level of our organisation. We will continue to revise policies and implement additional security features as new technologies become available. Where we have given you a password which enables you to access certain parts of our website, you are responsible for keeping that password confidential. We ask you not to share your password with anyone.

Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our website. Any transmission of personal data is at your own risk. Once we receive your personal data, we use appropriate security measures to seek to prevent unauthorised access or disclosure.

MANAGING AND DISABLING COOKIES AND WITHDRAWING YOUR CONSENT

There are two ways to manage your cookie preferences and you may need to refresh your page for the settings to take effect:

1. CONSENT MANAGEMENT TOOL (CMT)

With the exception of our social media sites, we use a CMT on our websites to assist us in managing your choices in relation to cookies and to help us to meet our obligations under ePrivacy and data protection law. This is a form of software provided by a third party (OneTrust). When you visit our website you are presented with banners, pop-ups and sliders to manage your cookie consents. The CMT can be used at any time to customise your cookie preferences in respect of our website. The CMT will record when you have consented to cookies and will ask for consent again every 6 months. It specifically controls the targeting cookies, functional cookies and performance cookies set by using our website. Strictly necessary cookies cannot be disabled, nor can the CMT be used to block 3rd party cookies on third-party websites linked from our website. These 3rd party cookies can be blocked using the method outlined below (Browser Settings).

You can update your cookie preferences by clicking on the Cookie Settings link at the bottom of the website.

2. BROWSER SETTINGS

Most web browsers give you some control over cookies through the browser settings. However, turning cookies off may interfere with your browsing experience.

For instructions on how to manage and disable cookies, visit the browser developer's website. If you use more Devices and/or browsers you will need to disable cookies on each Device and on each browser separately. Find out how to manage and disable cookies on popular browsers:

GOOGLE ANALYTICS

Some of our websites use Google Analytics. Google Analytics is a web analytics service provided by Google, Inc. If you don’t want Google Analytics to be used in your browser, you can install the Google Analytics browser add-on. Learn more about Google Analytics and privacy from Google here and here.

CHANGES TO THIS POLICY

We may change this Cookie Policy from time to time. If we make any changes, we will post those changes in this document and update the "Last Updated" date at the top of this Cookie Policy. However, if we make material changes to this Cookie Policy we will notify you by means of a prominent notice on our website prior to the change becoming effective.

CONTACT US

Questions, comments, requests and complaints regarding this Cookie Policy are welcome and should be addressed to dpo@clevercards.com or by writing to CleverCards at Suite 4, The Mall, Beacon Court, Sandyford, Dublin D18 TN80. All requests will be dealt with promptly and efficiently. You also have the right to make a complaint at any time to the Data Protection Commission, the Irish supervisory authority for data protection issues.