The protection of personal data and the confidentiality of information processed by our customers are of great importance to CleverApprove, operated by Zitouni GmbH.
This Privacy Policy explains the nature, scope and purposes of the processing of personal data in connection with the use of CleverApprove and the associated website.
CleverApprove is a web-based software solution for creating, managing and conducting digital approval and review processes. Among other things, users can use the platform to provide documents, files and content for review, grant approvals, exchange feedback and document processes in a traceable manner.
This Privacy Policy applies to:
We process personal data exclusively in accordance with applicable data protection laws, in particular the General Data Protection Regulation (GDPR) and applicable national data protection provisions.
When using CleverApprove, our customers may process their own personal data and personal data of third parties within the platform, for example in documents, files, comments or approval processes. With regard to such data, we generally act as a processor within the meaning of Art. 28 GDPR. Responsibility for the lawfulness of the processing and compliance with information obligations towards data subjects remains with the respective customer as the controller.
Further information on processing on behalf of customers can be found in the section "Processing on Behalf of Customers pursuant to Art. 28 GDPR" of this Privacy Policy.
The controller responsible for the processing of personal data within the meaning of the General Data Protection Regulation (GDPR) is:
Zitouni GmbH
Managing Director: Nabil Zitouni
Hauptstr. 43
69190 Walldorf
Germany
Email: support@cleverapprove.com
Website: www.cleverapprove.com
If you have any questions regarding data protection or wish to exercise your rights as a data subject, you may contact us at the address above at any time.
A Data Protection Officer has not currently been appointed, as the statutory requirements for mandatory appointment under Art. 37 GDPR are currently not met. If a Data Protection Officer is appointed in the future, their contact details will be published here.
This Privacy Policy uses the terms defined in the General Data Protection Regulation (GDPR). Unless otherwise stated below, the definitions of Art. 4 GDPR apply.
The most important terms in connection with CleverApprove are:
Personal data means any information relating to an identified or identifiable natural person.
This includes, for example, names, email addresses, contact details, user information or information that can be attributed to a specific person.
Processing means any operation performed on personal data, whether or not by automated means. This includes, in particular, collecting, recording, storing, organizing, retrieving, using, transmitting, restricting or deleting data.
A data subject is any natural person to whom personal data relates.
The controller is the natural or legal person that determines the purposes and means of processing personal data.
Zitouni GmbH is the controller for personal data that we process ourselves. This includes, in particular, data relating to:
With regard to personal data that our customers enter into CleverApprove or process as part of their own processes, our customers generally determine the purposes and scope of processing. Our customers therefore remain the controllers within the meaning of the GDPR.
This applies in particular to personal data contained in documents, files, comments, approval processes or other content.
A processor processes personal data on behalf of a controller and exclusively in accordance with the controller's documented instructions.
Where our customers use CleverApprove to process their own content and personal data, Zitouni GmbH generally processes such data as a processor in accordance with Art. 28 GDPR.
Processing is carried out exclusively for the purpose of providing the CleverApprove platform, conducting approval processes and technically enabling the functions requested by the customer.
A sub-processor is a service provider engaged by a processor that processes personal data in order to provide specific services.
Technical service providers may be used for the technical provision and operation of CleverApprove. These include, in particular:
The service providers used are carefully selected and involved only to the extent necessary. Processing is carried out on the basis of appropriate contractual agreements and in compliance with data protection requirements.
The technical infrastructure of CleverApprove is operated exclusively on servers located in Germany.
Content data means all information and files that customers or users upload, store or process within CleverApprove as part of approval processes.
This may include, in particular:
Such content may contain personal data, confidential information or, depending on the particular use case, special categories of personal data within the meaning of Art. 9 GDPR.
Zitouni GmbH processes this content exclusively for the technical provision of CleverApprove and for conducting the approval processes initiated by the customer.
Approval recipients or reviewers are persons invited by a customer to view, comment on or approve specific content within an approval process.
These persons may work within or outside the customer's organization.
The respective customer is responsible for ensuring that inviting approval recipients and disclosing content to them is lawful under applicable data protection law.
We process personal data exclusively for the purposes for which it was collected and only to the extent necessary to provide, administer and improve our services.
The purposes of processing depend on whether we process personal data as controller or as processor.
As the operator of CleverApprove, we process personal data of our customers, users and prospective customers in particular for the following purposes:
Provision and operation of CleverApprove
We process data to provide access to the platform, user accounts and the technical functions of CleverApprove.
Registration and management of user accounts
We process data to create and manage user accounts, including the administration of organizations, roles and permissions.
Contract performance and customer management
We process data to perform and manage our contractual relationships, including communication, plan management, billing and invoicing.
Payment processing
Required data is transmitted to payment service providers used by us for processing payments and subscriptions.
Communication and support
We process contact details and communication content in order to respond to inquiries, provide technical support and inform users about important information concerning their account or the platform.
Security and stability of the platform
We process technical information and log data to ensure the security, availability and functionality of CleverApprove and to detect and prevent unauthorized access, misuse and security incidents.
Further development and improvement of our services
We may use technical information and anonymized or aggregated data to further develop the functionality, security and usability of CleverApprove.
Compliance with legal obligations
We process data where necessary to comply with legal obligations, such as statutory commercial and tax retention requirements.
CleverApprove enables our customers to process their own content and personal data within the platform and to conduct approval processes with internal and external participants.
Within a process, customers may add additional persons and assign different roles to them depending on the permissions granted. These may include, in particular:
Personal data processed in the course of such collaboration may include, in particular:
In addition, customers may upload and process files and documents through CleverApprove. These may include, for example:
Depending on the customer's use of the platform, the content processed in CleverApprove may contain personal data, confidential information or special categories of personal data pursuant to Art. 9 GDPR.
Zitouni GmbH processes this data exclusively to provide the functions of CleverApprove, including:
No substantive analysis of files and information uploaded by customers is carried out. In particular, such data is not used for our own advertising purposes and is not used to train AI systems.
The processing of this data is carried out as processing on behalf of the respective customer pursuant to Art. 28 GDPR. The customer remains responsible for the lawfulness of the processing, the selection of participating persons and the assignment of access rights.
Personal data is processed exclusively on the basis of applicable data protection laws, in particular the General Data Protection Regulation (GDPR).
Depending on the nature and purpose of the processing, processing is based on the following legal grounds:
Personal data is processed pursuant to Art. 6(1)(b) GDPR insofar as this is necessary for the performance of a contractual relationship with our customers.
This includes, in particular:
This also applies to pre-contractual measures, for example inquiries about our services or preparations for entering into a contract.
Personal data is processed pursuant to Art. 6(1)(c) GDPR where we are legally obliged to do so.
This includes, in particular:
Where necessary, we process personal data pursuant to Art. 6(1)(f) GDPR to protect our legitimate interests or the legitimate interests of third parties.
Our legitimate interests include, in particular:
We always take into account the rights and interests of data subjects and carry out processing only where no overriding interests oppose it.
Where the processing of personal data is based on consent, it is carried out pursuant to Art. 6(1)(a) GDPR.
Consent may be withdrawn at any time with effect for the future. The lawfulness of processing carried out before consent was withdrawn remains unaffected.
This may be relevant in particular if optional services or functions requiring consent are introduced in the future.
Personal data that our customers enter into CleverApprove or process as part of their own approval processes is generally processed by Zitouni GmbH as a processor pursuant to Art. 28 GDPR.
The respective customer, as controller, determines the purpose and legal basis of this processing.
In particular, the customer is responsible for ensuring that:
Different categories of personal data may be processed as part of providing and using CleverApprove. The specific data processed depends on which functions are used and which content our customers enter into the platform.
When using our website, registering and managing customer accounts, the following personal data may be processed:
Master Data and Contact Data
This includes, in particular:
Account and Access Data
This includes, in particular:
Contract and Payment Data
This includes, in particular:
Payment data is processed through the payment service providers used for payment processing.
When using CleverApprove, technical information required for operation, security and further development of the platform may be processed.
This includes, in particular:
Activities within the platform may also be documented, for example:
This data serves, in particular, to ensure security, traceability and the proper functioning of the platform.
CleverApprove enables customers to conduct digital review and approval processes with internal and external participants.
Customers may process, in particular, the following personal data within the platform:
Our customers can provide files and content within CleverApprove for review, coordination and approval.
This may include, in particular:
The content may contain personal data, such as names, contact details or other information relating to natural persons.
Depending on the customer's area of use, uploaded content may also contain special categories of personal data pursuant to Art. 9 GDPR or other confidential information.
Zitouni GmbH does not select or determine the content uploaded by customers. The respective customer decides which data is processed within CleverApprove.
When customers or prospective customers contact us, for example by email or through support channels, the following data may be processed:
This data is used exclusively to process the relevant inquiry and communicate with the user.
When visiting our website at www.cleverapprove.com, the web server automatically processes information transmitted by your browser to our server.
This data is technically necessary to provide the website, ensure system stability and security, and detect potential errors or attacks.
The data processed may include, in particular:
This data is generally not combined with data from other sources.
Server log data is processed in particular for the following purposes:
Processing is based on Art. 6(1)(f) GDPR. Our legitimate interest is to provide a secure, stable and functional website and reliable services.
The technical infrastructure of CleverApprove is operated exclusively on servers in Germany. Accordingly, technical data generated when visiting our website is processed within Germany, unless expressly stated otherwise for specific external services.
Server log data is stored only for as long as necessary for the purposes stated above and is subsequently deleted or anonymized, unless statutory obligations or legitimate interests require longer retention.
Our website and the CleverApprove platform use only technically necessary cookies and similar technologies that are required for secure and proper operation.
Cookies are small text files stored on your device that may contain certain technical information. They enable, among other things, the recognition of a session and the provision of specific functions.
We use cookies in particular for the following purposes:
The cookies used do not contain information that is evaluated for advertising purposes. We do not analyze user behavior for marketing or tracking purposes.
As these cookies are technically necessary to provide the services and functions expressly requested by you, consent is not required for their use.
The legal basis for the use of technically necessary cookies is § 25(2) no. 2 of the German Telecommunications-Telemedia Data Protection Act (TDDDG) and Art. 6(1)(f) GDPR. Our legitimate interest is the secure and functional provision of our website and the CleverApprove platform.
We currently do not use analytics, statistics, marketing or tracking services.
Use of CleverApprove by customers and their internal users requires the creation of a user account. During registration and management of a user account, we process personal data required to provide and use the platform.
During registration, the following data may be processed:
This data is processed to:
Processing is carried out for the performance of the contract pursuant to Art. 6(1)(b) GDPR.
CleverApprove enables customers to manage internal users within their organization and organize collaboration within the platform.
Different roles and permissions may be assigned, including:
The following data may be processed for the management of these users:
Roles and permissions are assigned by the respective customer. The customer is responsible for determining which persons receive access to its content and processes.
CleverApprove enables customers to invite external persons to review or approve processes without requiring them to create their own CleverApprove user account.
Customers may, for example, add customers, business partners, clients or other external participants as reviewers or recipients.
The following data of an invited person may be processed for sending an approval request:
This data is processed to send the approval request, address the invited person and enable access to the relevant process.
The invited person receives an individual link by email through which they can access the associated process and, depending on the permissions defined by the customer, for example:
No separate user account is created for external reviewers. Access is limited to the specific process that has been shared with them.
The respective customer is responsible for:
To ensure secure operation of the platform, technical information relating to user accounts may be processed, including:
Passwords are stored only in a technically appropriate form and are not stored in plain text.
Processing of this data is carried out to ensure the security and stability of CleverApprove on the basis of Art. 6(1)(f) GDPR.
User accounts are deleted when they are no longer required or the contractual relationship has ended, unless statutory retention obligations or legitimate interests prevent deletion.
Data relating to external recipients and reviewers is processed and deleted in accordance with the use of the relevant process and the settings and instructions of the customer.
The deletion of content and processes is governed by the contractual agreements and settings of the respective customer.
CleverApprove is a SaaS platform for the digital creation, management and execution of review and approval processes.
Customers can create processes within the platform, provide files, involve internal and external persons, and document reviews and approvals in a traceable manner.
The content and personal data processed in this context are used exclusively to provide the functions offered by CleverApprove.
Customers can create approval requests within CleverApprove and involve participating persons.
The following information may be processed, in particular:
This data serves to conduct, manage and document review and approval processes in a traceable manner.
Customers can upload files and documents to CleverApprove for review and approval.
These may include, for example:
Uploaded content may contain personal data, such as names, contact details or other information relating to natural persons.
Depending on the customer's particular use case, files may also contain confidential information or special categories of personal data pursuant to Art. 9 GDPR.
Zitouni GmbH does not select or substantively evaluate files uploaded by customers. The customer decides which content is processed.
CleverApprove enables different participants to collaborate within an approval process.
Depending on their requirements, customers can involve internal users and external recipients.
Internal users may, for example, act as creators, editors or other participants within the customer's organization.
External reviewers or recipients do not receive their own CleverApprove user account. When invited, they receive an email containing an individual link through which they can access only the specific process shared with them.
The following data may be processed:
The customer is responsible for ensuring that invited persons are authorized to view or process the relevant content.
As part of an approval process, participants may leave comments, annotations or other feedback.
Approval decisions and processing steps may also be documented, including:
This information is used exclusively for collaboration, documentation and traceability within the respective process.
CleverApprove may store information relating to different versions and processing steps within a process.
This may include, in particular:
The storage of this information enables traceable documentation of review and approval processes.
CleverApprove provides an archiving function for completed or no longer actively processed processes.
Customers can determine when processes are archived. Archiving can be:
Unless the customer chooses different settings, the standard archiving period is 90 days.
During the archiving period, the associated data remains stored and available in accordance with the customer's permissions.
After the specified archiving period has expired, archived data is automatically deleted unless statutory obligations or other legitimate reasons prevent deletion.
The customer remains responsible for establishing appropriate retention and deletion periods for its own processes.
Zitouni GmbH processes customer content exclusively for the technical provision of CleverApprove and for carrying out the approval processes requested by the customer.
Customer content is not used for our own purposes. In particular, customer content is not:
Processing is carried out as processing on behalf of the respective customer pursuant to Art. 28 GDPR.
The customer remains responsible for the lawfulness of the processing, the selection of content and the authorization of participating persons.
As part of the use of the platform, CleverApprove sends various automated emails required to provide and use its functions.
These include, in particular:
When a customer sends an approval request to an internal or external person, CleverApprove processes the recipient data required for this purpose.
This may include, in particular:
The data is used exclusively to send the approval request and enable access to the intended process.
The customer is responsible for ensuring that the disclosure and processing of recipient data is lawful.
Additional emails may be sent for user account management and the technical provision of CleverApprove, including:
These messages serve exclusively to perform the contract, maintain security and ensure proper use of the platform.
We use a technical service provider to send automated emails.
Transactional emails are sent via:
Mailjet GmbH
Alt-Moabit 2
10557 Berlin
Germany
Mailjet is a provider for sending electronic messages and supports us in the technical delivery of system and notification emails.
Processing is carried out exclusively for the purpose of email delivery and on the basis of a data processing agreement pursuant to Art. 28 GDPR.
The technical service provider receives only the data necessary to deliver the respective message.
System and notification emails sent through CleverApprove are used exclusively to provide platform functions.
Email addresses used for such communications are not used for our own advertising purposes unless separate consent has been obtained.
We use technical service providers to provide the server and system infrastructure required for the technical operation and provision of CleverApprove.
Personal data is processed exclusively in connection with the provision, maintenance and security of the CleverApprove platform.
The technical operation of CleverApprove is provided through our technical service provider:
ServiceSystems, Christian van de Velde
Auf der Wurth 3
26969 Butjadingen
Germany
This provider supplies the technical infrastructure and server systems required to operate the platform.
The servers used for this purpose, provided by Hetzner Online GmbH, are located exclusively in Germany.
The technical infrastructure is used in particular for:
Technical service providers receive access to personal data only to the extent necessary to provide their services.
Access may be required in particular for:
Processing is carried out on the basis of appropriate contractual agreements pursuant to Art. 28 GDPR.
Technical service providers are required to process personal data exclusively in accordance with documented instructions and to implement appropriate technical and organizational measures to protect the data.
Data within the CleverApprove infrastructure is stored and processed exclusively on servers located in Germany.
CleverApprove's infrastructure does not store customer data or uploaded files on servers outside Germany.
Please note, however, that customers may send approval requests to external recipients. If such recipients access the provided content using their own systems or devices, further processing may take place outside Germany or outside the European Union, for example through the recipient's own email or IT systems.
Zitouni GmbH has no control over such processing by recipients or their service providers.
In addition to the hosting infrastructure, other technical service providers may be used where necessary for the operation of CleverApprove.
These include, in particular:
An overview of the service providers used and their processing activities may form part of the information on our sub-processors.
We use an external payment service provider to process paid subscriptions and payments.
Payment processing for CleverApprove is carried out via:
Stripe Payments Europe Limited
Stripe processes payment data in connection with payment processing, subscription management and payment transactions.
The data processed by Stripe may include, in particular:
Credit card and other payment details are not stored or fully processed by Zitouni GmbH. Such payment data is processed directly by Stripe as part of the payment process.
Processing is carried out in particular for the following purposes:
Following successful payment, invoices are automatically sent to the email address provided by the customer.
Processing is carried out for the performance of the contractual relationship pursuant to Art. 6(1)(b) GDPR and for compliance with legal obligations, in particular commercial and tax requirements pursuant to Art. 6(1)(c) GDPR.
Stripe processes certain payment data as an independent controller in connection with payment processing. Stripe's privacy policy applies additionally to processing carried out by Stripe.
Where Stripe acts as a service provider on our behalf, processing is carried out on the basis of appropriate contractual agreements.
Customer data within the CleverApprove infrastructure is stored and processed exclusively on servers in Germany.
Customer data and uploaded files are generally not transferred by the CleverApprove infrastructure to countries outside the European Union (EU) or European Economic Area (EEA).
However, processing of personal data in third countries cannot be completely excluded in certain circumstances.
This may apply in particular to the following situations:
Customers may send approval requests to external persons who may use their own IT systems or email services whose servers are located outside the EU or EEA.
If a recipient uses a CleverApprove approval link or processes information transmitted by email, personal data may be processed by the recipient's systems or service providers outside the EU.
Zitouni GmbH has no control over such processing by the respective recipient or their service providers.
The customer is responsible for ensuring the lawfulness of transferring data to the recipients selected by the customer.
For certain service providers used by us, processing in third countries may be possible due to their corporate structure or technical infrastructure.
Where personal data is transferred to third countries, we ensure that the requirements of Art. 44 et seq. GDPR are complied with.
Appropriate safeguards may include, in particular:
Information on the service providers used and the applicable data protection safeguards can be found in the information on our technical service providers and sub-processors.
We retain personal data only for as long as necessary for the respective processing purposes or as required by statutory obligations.
The specific retention period depends on the type of data and how CleverApprove is used.
User account data is stored for as long as the user account exists and is required to provide CleverApprove.
After termination of the contractual relationship or deletion of an account, the associated data is deleted unless statutory retention obligations or legitimate reasons require continued storage.
Processes, files, comments, approvals and associated information created by customers within CleverApprove are stored for as long as necessary for use of the platform and the processes intended by the customer.
Customers can manage the archiving of their processes through the relevant CleverApprove settings.
CleverApprove provides an archiving function for completed or no longer actively processed processes.
Customers can determine when processes are archived:
Unless a different setting is selected, the standard archiving period is 90 days.
After the specified archiving period has expired, archived data is automatically deleted unless statutory obligations or other legitimate reasons prevent deletion.
Regular technical backups are created to ensure system availability and recoverability.
Backups are used exclusively for:
Data deleted from the active system may remain in existing backups for a limited period.
Deletion from backups takes place as part of the regular backup rotation and technical deletion processes.
Access to backup data is limited to cases where it is necessary for restoration purposes, technical maintenance or security measures.
Where data is subject to statutory retention obligations, in particular tax or commercial records such as invoices and payment records, it is stored for the periods required by law.
Such data is processed exclusively to comply with the respective legal obligations and is deleted after the retention periods have expired.
Customers can delete data or control its archiving using the available CleverApprove functions.
The customer remains responsible for establishing and complying with appropriate retention and deletion periods for the personal data it processes.
We implement appropriate technical and organizational measures (TOMs) pursuant to Art. 32 GDPR to protect personal data.
These measures are designed in particular to protect personal data against unauthorized access, loss, alteration or unlawful processing and to ensure an appropriate level of security corresponding to the risks associated with the processing.
The measures implemented include, in particular:
Communication between users and the CleverApprove platform takes place via encrypted connections.
This protects data during transmission against unauthorized access.
Access to data and functions within CleverApprove is controlled through a role- and permission-based access system.
This ensures that:
Appropriate security measures are used to protect user accounts.
These include, in particular:
The technical infrastructure of CleverApprove is operated on servers located in Germany.
Measures used to protect the infrastructure include, in particular:
Technical service providers receive access to personal data only to the extent necessary for operation, maintenance or technical support.
Processing is carried out on the basis of appropriate contractual agreements and in accordance with GDPR requirements.
Technical and organizational measures are regularly reviewed and developed further in accordance with technological developments and data protection requirements.
Complete security of data transmission or IT systems cannot be technically guaranteed. However, we implement appropriate measures to reduce the risk of unauthorized processing or data loss.
When using CleverApprove, our customers may process personal data relating to their own customers, employees, business partners or other participants within the platform.
This may include, in particular:
The respective CleverApprove customer is generally the controller within the meaning of the General Data Protection Regulation for this data.
Zitouni GmbH processes this data exclusively on behalf of the customer and for the provision of CleverApprove services.
Processing is carried out on the basis of a data processing agreement pursuant to Art. 28 GDPR.
The data processing agreement governs, in particular:
Zitouni GmbH processes customer personal data exclusively in accordance with documented instructions from the respective customer.
Customer content is not used for our own purposes.
In particular, customer data is not:
Technical service providers may be used to provide CleverApprove and may act as sub-processors pursuant to Art. 28 GDPR.
These include, in particular:
Sub-processors are engaged only if they provide appropriate guarantees for the protection of personal data and appropriate contractual agreements are in place.
An up-to-date list of the sub-processors used may form part of CleverApprove's contractual and data protection information.
The customer remains responsible for:
Zitouni GmbH supports the customer, within the scope of contractual agreements and available technical capabilities, in fulfilling its data protection obligations.
Under the General Data Protection Regulation, data subjects have various rights regarding the processing of their personal data.
Where Zitouni GmbH processes personal data as controller, for example in connection with the website, registration of a user's own account or contract management, data subjects may exercise their data protection rights directly against Zitouni GmbH.
These rights include, in particular:
Right of Access (Art. 15 GDPR)
Data subjects have the right to obtain information about whether and which personal data concerning them is being processed.
Right to Rectification (Art. 16 GDPR)
Data subjects may request the correction of inaccurate personal data or completion of incomplete personal data.
Right to Erasure (Art. 17 GDPR)
Data subjects may request the deletion of their personal data under the statutory conditions.
Right to Restriction of Processing (Art. 18 GDPR)
Data subjects may, under certain conditions, request restriction of the processing of their personal data.
Right to Data Portability (Art. 20 GDPR)
Under the statutory conditions, data subjects have the right to receive personal data in a structured, commonly used and machine-readable format or to request its transmission to another controller.
Right to Object (Art. 21 GDPR)
Data subjects may object to the processing of their personal data where the statutory requirements are met.
Withdrawal of Consent (Art. 7(3) GDPR)
Where processing is based on consent, consent may be withdrawn at any time with effect for the future.
Personal data processed by our customers within CleverApprove is processed by Zitouni GmbH exclusively as a processor pursuant to Art. 28 GDPR.
In these cases, the respective CleverApprove customer is the controller within the meaning of the GDPR.
Data subjects should therefore generally contact the respective customer that processes their data within CleverApprove.
Zitouni GmbH supports customers, within the scope of its statutory obligations and contractual agreements, in handling such requests where necessary and technically possible.
To exercise data protection rights, data subjects may contact us:
Zitouni GmbH
Managing Director: Nabil Zitouni
Hauptstr. 43
69190 Walldorf
Germany
Email: support@cleverapprove.com
We review each request and process it in accordance with the applicable statutory requirements.
Irrespective of any other legal remedies, data subjects have the right to lodge a complaint with a data protection supervisory authority if they believe that the processing of their personal data violates the GDPR.
A complaint may, in particular, be lodged with the supervisory authority responsible for the controller.
CleverApprove does not carry out automated decision-making within the meaning of Art. 22 GDPR.
In particular, CleverApprove does not make decisions that produce legal effects concerning data subjects or similarly significantly affect them.
The platform is used exclusively to technically support review and approval processes. Decisions concerning approvals, rejections or other assessments are made by the persons involved.
No automated evaluation, analysis or profiling takes place.
We regularly review this Privacy Policy and amend it where necessary due to technological developments, changes to our services, new CleverApprove functions or legal requirements.
The current version of this Privacy Policy is available on our website.
Where material changes significantly affect your rights or the manner in which personal data is processed, we will inform you in an appropriate manner where legally required.
The version of this Privacy Policy published at the time of use of CleverApprove shall apply.
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