1.1 We are committed to safeguarding the privacy of our website visitors.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications. You will only receive marketing email if you check the box and request to be included in our mailing list.
1.5 In this policy, "we", "us" and "our" refer to Cleo Ltd. For more information about us, see Section 14.
2.1 This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).
3. The personal data that we collect
3.1 In this Section 3 we have set out the general categories of personal data that we process.
3.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The primary source of the account data is you and/or your employer. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.
3.3 We may process your website user account data ("account data"). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by our website. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.
3.4 We may process information relating to transactions, including purchases of goods, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
3.5 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
3.6 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
4. Purposes of processing and legal bases
4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.
4.2 Operations - We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract
4.3 Relationships and communications - We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business
4.4 Direct marketing - We may process contact data and/or account data for the purposes of creating, targeting and sending direct marketing communications by email. The legal basis for this processing is consent OR our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
4.5 Research and analysis - We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services,, as well as researching and analysing other interactions with our business.. The legal basis for this processing is consent OR our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
4.6 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
4.7 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
4.8 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
4.9 Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
4.10 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
5. Providing your personal data to others
5.1 We may disclose your personal data to our professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice.
5.2 Your personal data held in our website database OR will be stored on the servers of our hosting services providers identified at .
5.3 We may disclose personal information to our suppliers insofar as reasonably necessary for the performance of a contract between you and us, (for example if a supplier needs to send a product directly to you)
5.4 Financial transactions relating to our website are handled by our payment services providers, [Paypal, Stripe]. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refund. You can find information about the payment services providers' privacy policies and practices at https://www.paypal.com/ie/webapps/mpp/ua/privacy-full https://stripe.com/en-ie/privacy .
5.5 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6. International transfers of your personal data
6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA)
6.2 Wix can store your site-visitors' data in a number of locations. Your site-visitors ́ personal information may be stored in data centers located in the United States of America, Ireland, South Korea, Taiwan and Israel. We may use other jurisdictions as necessary for the proper delivery of our services and/or as may be required by law.
Wix is a global company that respects the laws of the jurisdictions it operates within. The processing of the User Customer Data may take place within the territory of the European Union, Israel or a third country, territory, or one or more specified sectors within that third country, of which, the European Commission has decided that it ensures an adequate level of protection (transfer on the basis of an adequacy decision). Any transfer to a third country, outside the European Union, that does not ensure an adequate level of protection according to the European Commission, will be undertaken in accordance with the Standard Contractual Clauses (2010/87/EU) set out in Appendix 1 of the Wix Data Processing Agreement (DPA)
7. Retaining and deleting personal data
7.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8. Your rights
8.1 Your rights under data protection law
8.2 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies that we use You can find information about the cookies used in our website here: https://support.wix.com/en/article/cookies-and-your-wix-site
11. Cookies used by our service providers
12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(d) (Internet Explorer);
(e) (Safari); and
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
13.1 We may update this policy from time to time by publishing a new version on our website.
13.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
14. Our details
14.1 This website is owned and operated by Cleo Ltd.
14.3 Our principal place of business is at 18 Kildare Street, Dublin 2.
14.4 You can contact us:
(a) by post, to the address given above
(b) using our website contact form
(c) by telephone, on the contact number published on our website
(d) by email, using the email address published on our website
15. Data protection officer
15.1 For more information see the link to the Data Protection Commision of Ireland https://www.dataprotection.ie