CLIQUE PRIVACY POLICY
Last Updated February 7, 2025
This is the Privacy Policy for the Clique mobile application (“App”) provided by Clique LLC (“Company,” “us” or “we”). This Privacy Policy explains how we collect and use information when you use the App. Your privacy is important. Please read this Privacy Policy carefully.
PRIVACY SNAPSHOT
Here is a quick summary of our privacy practices. Please read this Privacy Policy in its entirety.
Personal Information: This Privacy Policy applies to processing your Personal Information by the Company when you use the App or communicate with us. “Personal Information” means information about you like your identifiers (e.g., name, username), image or voice, legally protected information, or internet activity, among others. See the full definition below. Details of how we use this information is in Section 3.
Minimum Age: You must be at least 16 years old to create a profile and use the App. DO NOT DOWNLOAD THE APP OR SUBMIT ANY PERSONAL INFORMATION TO US IF YOU ARE UNDER AGE 16. If you are a legal minor, we require consent from your parent or guardian for certain features and agreements.
Photos: The App lets you post photos and connect with your friends. You decide who can see and interact with your photos. Your photos belong to you, and you are responsible for them. Please check with others shown in a photo before posting it to the App. If you don’t like a photo of yourself posted by another user, please ask them to remove it from the App.
Cliques: You can connect with your friends and post and share photos within a group of friends (a “Clique”). Everyone in the Clique will see your photos, posts, messages, and other data that you make available within the Clique.
Your Options: You can control your Personal Information through your account or by following the instructions in Section 8.
Your Privacy Rights are described in Section 9.
Questions: Please send any questions, concerns, or privacy requests to privacy@cliqueapp.org.
You consent to this Privacy Policy by downloading the App, indicating your acceptance when prompted on the App, or by simply using our Services. We may provide additional notices about our privacy practices, each of which will be considered to form part of this Privacy Policy. If you have questions about our privacy practices or would like to make a complaint, please contact us at privacy@cliqueapp.org.
WHAT IS PERSONAL INFORMATION?
As used in this Privacy Policy, “Personal Information” means information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual consumer or household. Examples of categories of Personal Information include:
Identifiers (e.g., name, email, telephone number, address, username);
Sensitive Personal Information (e.g., government identification number; precise geolocation; racial or ethnic origin; religious beliefs; health information; contents of messages when we are not the recipient; in some cases, information about a known child);
Legally protected information (e.g., race, citizenship, marital status, sex);
Employment-related information (e.g., current or past employment);
Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);
Biometrics (e.g., DNA, face/voice prints, health data) and audio, electronic, visual, thermal, or olfactory information;
Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
Internet or other similar activity (e.g., browsing history; content interactions); and
Inferences drawn from Personal Information to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, and aptitudes.
Note that information we process may not be protected by privacy laws if it is: (i) publicly available; (ii) aggregated, meaning data about a group or category of services or users from which individual identities and other Personal Information has been removed; or (iii) deidentified so that it cannot be easily linked back to the individual.
MINIMUM AGE
The App is available to users ages 16 or older. Users under age 18 need the consent of their parent or legal guardian (in each case, a “Guardian”) to download the App and register an account. CHILDREN UNDER AGE 16 ARE STRICTLY PROHIBITED FROM USING THE APP. We reserve the right to further restrict access to certain content or features based on user age or the laws applicable to the user’s jurisdiction.
COLLECTION AND USE OF PERSONAL INFORMATION
We only collect Personal Information through the App as adequate and relevant to the specific, express purposes described below or as reasonably necessary and proportionate to provide you with the App. We process Personal Information with consent, to fulfill our obligations to you as described in the Terms of Use, or to achieve one or more legitimate interest. We may also be required to process Personal Information to fulfill certain legal obligations like responding to court orders or cooperating with law enforcement.
We collect identifiers, photos, internet activity, message contents, and any Personal Information a user includes in their Posts, as detailed below:
Your Profile. To use the App, you will need to verify your age and create your profile. To verify your age, we will ask for your date of birth, which we delete immediately after verifying that you meet the minimum age requirement to use the App. For your profile, we will collect your name and username or handle, plus a short bio if you choose to include it in your profile. We will also collect your phone number, used only for verification and authentication purposes and not visible by other users. We collect this information with consent and use it to provide the user account and facilitate use of the Services. Additionally, we may request your Guardian’s email address if we determine that your Guardian’s consent is necessary to permit you to use the App, engage with certain content, permit certain settings, or to communicate about your use of the App.
Cliques. The App allows users to invite their friends to interact on the App as part of a Clique. When you add other users to your Clique, we will collect the Personal Information from each user in the Clique to send invites and confirm the users to be included in the Clique. Members of a Clique can post and share photos and interact with one another through the App. We collect this information with each user’s consent or for our legitimate interest of understanding how users use and enjoy the App. We use this data to facilitate your use of the App and to develop and improve its features.
Your Posts. The App allows you to post photos and other content, collaborate with your friend group, and interact with other users (collectively, your “Posts”). We will collect any Personal Information you choose to include in your Posts. You are in control of the Personal Information you include in your Posts and how you allow other users to interact with your content on the App. All Posts must comply with the Acceptable Use Policy in our Terms of Use. We process the information in your Posts with your consent and use it to facilitate use of the App and for our internal business purposes.
Photo Permissions: When you Post a photo, the photo setting will be “private” by default, so only you can see the photo. You can change the photo’s privacy setting so that it is viewable by your Clique, followers of Clique members, or public. Please check with others shown in a photo before posting it to the App. If you don’t like a photo of yourself posted by another user, please ask the other user to remove it from the App or email us at privacy@cliqueapp.org to have it reviewed under our Acceptable Use Policy. By Posting a photo, you consent to our collection and use of your image and other Personal Information in the photo, and you confirm that you have the permission of others in the photo to post it to the App.
Your Activity. We automatically collect technical data from your use of the App, such as:
Device information (e.g., IP address, operating system, browser type, device ID, language, mobile network information)
Usage details (e.g., content engagement, transactions, traffic data, and the features or resources you access and use)
Stored information (e.g., metadata).
We use this information to understand how users interact with the App, to detect security incidents, and to develop and improve the App. The App does not use cookies or related technologies.
Your Communications with Us. If you contact us to request support or for any other reason, we will collect your username, email, and other information you voluntarily provide. We collect this information with your consent and for our legitimate interest of providing customer support for the App. We will use this information to help provide support to you in relation to your support request. Additionally, if you submit a Privacy Request, we must collect your email address, transaction history, login history, proof of user's identity to verify your identity and process your request.
We use the Personal Information we collect to achieve the purposes stated at the time of collection or as described in this Privacy Policy. We may also use your Personal Information to (i) monitor your compliance with any of your contracts with us; (ii) protect your or others’ privacy and enforce this Privacy Policy; (iii) if we believe it is necessary, identify, contact, or bring legal action against persons or entities who may be causing injury to you, to us, or to others; (iv) comply with a law, regulation, legal process, or court order; or (v) fulfill any other purpose to which you consent.
DISCLOSURES TO THIRD PARTIES
We only disclose Personal Information as described in this section, with your permission, or as required by law. Over the last 12 months, we have disclosed Personal Information from all categories of collection to one or more of the following recipients:
Other Users. Other users of the App can view the information you make public on your account profile. When you post Photos or other content to the App, other users will be able to view your post according to the audience settings you select and your privacy settings. Additionally, members of a Clique can share photos and interact on the App within the Clique. This disclosure is necessary to facilitate your use of the App. By posting to the App, you consent to other users’ viewing and interacting with any Personal Information you make available through your account or posts.
Our Service Providers. We use a variety of service providers such as data storage providers, analytics, and other technology services. The type of information that we disclose to a service provider will depend on the service that they provide to us. Our service providers are subject to contractual agreements that protect your Personal Information, and we require all service providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information.
Law enforcement or other government agencies, as permitted or required by law.
Other Third Parties, as permitted by applicable law, for example: if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); to comply with a legal requirement or a court order; when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.
Aggregated and Deidentified Information. We reserve the right to disclose aggregated, anonymized, or deidentified information about any individuals with nonaffiliated entities for marketing, advertising, research, or other purposes, without restriction.
DATA PROCESSING IN THE UNITED STATES
The App is owned and operated in the United States and marketed to users in the United States only. If you access the App or contact us from outside the United States, the Personal Information we collect about you may be transferred outside of your country of origin to our servers in the United States or other countries. Some countries’ laws are more restrictive than in the United States, or result in governments, courts, law enforcement, or regulatory agencies having access to or obtaining disclosure of your Personal Information pursuant to the laws of the applicable foreign jurisdiction. We are committed to transferring Personal Information via an adequacy decision, standard contractual clauses, or other lawful data transfer mechanism. By allowing us to collect Personal Information about you, you consent to the transfer and processing of your Personal Information as described in this paragraph.
DATA SECURITY
Safeguards. We implement and maintain technical, organizational, and physical measures in place to help protect your information from unauthorized access, processing, or disclosure. We maintain internal policies to govern the collection, processing, access, and handling of data. We use technical safeguards to protect information online and stored on our systems. Please note, however, that no transmission of data over the Internet is 100% secure, and we cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Information for improper purposes.
Your Account. We encourage you to take steps to protect against unauthorized access to your account and device, for example by signing off after using a shared device and keeping your login private. You are responsible for all activity on your account regardless of how the account was accessed.
Third-Party Platforms. We do not provide a feature to cross-post on third-party social media or other platforms. However, you may choose to post photos or other Posts on your page or channel. We have no control or responsibility for any user or other person’s activities on any third-party platform. Your use of third-party platforms in relation to the App is entirely optional and subject to the privacy policy and terms of use of the third-party platform you choose to use.
DATA RETENTION
We retain the Personal Information we collect about you only as long as needed to fulfill the purpose for which it was collected. For example:
Data associated with your profile on the App is retained until you delete it. If you don’t delete it, it is retained as long as your account is active.
If you contact us for customer service or with questions, we will delete your Personal Information after responding to your inquiry.
Personal Information associated with your account is deleted within one year of closing your account.
Technical device data, user ID, commercial history data, and other cookie data are retained for up to 26 months.
Privacy Request information is retained for two years or as otherwise required by law.
When we no longer have a business need for your Personal Information, we will either delete, de-identify or anonymize it whenever feasible. Where not feasible (such as data in our backup archives) we will securely store it and keep it isolated from further processing until it can be permanently deleted.
YOUR PRIVACY OPTIONS
You can use the methods described below to control how we collect and use your Personal Information:
Your Profile. You can access, update, and correct the Personal Information associated with your profile, change your settings, or delete your account within the App.
Our Emails. If you provide us with your email, we may send you informational or marketing emails according to your communication preferences. You can unsubscribe from receiving emails from us by clicking the Unsubscribe link found in any of the emails we send you, or by contacting us at privacy@cliqueapp.org to request to be removed from the mailing list.
Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests. If this changes in the future, we will update this Privacy Policy.
Block Location Tracking. You can stop all collection of precise location data through an application by uninstalling the application or withdrawing your consent through your device settings. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you.
Exercising Your Privacy Rights. If you wish to exercise your rights under applicable privacy laws (see Section 9 Notice of Privacy Rights) or if you want to express concerns, lodge a complaint or request information, please submit a Privacy Request to us at privacy@cliqueapp.org. We endeavor to respond to a verifiable Privacy Request within the period required by applicable law. If we require more time, we will notify you in writing of the reason and extension period. We will deliver our written response by mail or electronically, at your option. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so, such as requests that are excessive, repetitive, or unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
WHAT ARE MY PRIVACY RIGHTS?
The App is currently only made available to users in the United States. This section provides notices under U.S. consumer privacy laws. Some of the laws referred to below may not apply to you, or we may be exempt from certain legal obligations, in which case the information is offered as a courtesy. If you decide to use the App from outside the U.S., you agree that the App is provided in accordance with U.S. law and our Terms of Use.
United States law governs consumer privacy by federal privacy laws covering specific industries or data uses and state privacy laws providing general consumer privacy rights. California, Colorado, Connecticut, Iowa, Nevada, Oregon, Tennessee, Tennessee, Texas, Utah, Virginia, and a growing list of additional states require companies to inform consumers about their privacy rights and provide a method to exercise those rights. Depending on where you live, some or all of the following rights may be available to you:
Right to know. We provide the required information for a consumer’s right to know in this Privacy Policy. We may provide you with additional notices about other ways we process your Personal Information, such as by sending you a notice in the App.
Right to reasonable expectations. You can expect us to collect, use, or disclose your Personal Information responsibly and not for any other purpose other than as stated at the time of collection or described in this Privacy Policy. If we collect or use your Personal Information based on your consent, we will also notify you of any changes and will request your further consent as required by law. You may withdraw your consent at any time with reasonable notice by contacting privacy@cliqueapp.org.
Right to deletion. Upon your request and when required by law, we will delete your Personal Information from our systems. This right is not absolute, and we may be entitled to retain and process your Personal Information despite your request. If you make this request, we balance certain legal, contractual, and business interests against your right to request the deletion of your Personal Information.
No selling Personal Information. Some jurisdictions entitle consumers to opt out of the sale of their Personal Information. We do not sell your Personal Information. If this changes in the future, we will provide you with a method to opt out.
No sharing Personal Information. Some jurisdictions allow you to opt-out of sharing your Personal Information with third parties for cross-contextual behavioral advertising purposes. We do not share Personal Information for this purpose. If this changes in the future, we will provide you with a method to opt out.
Limited use and disclosure of sensitive Personal Information. We do not collect sensitive Personal Information, and in no case will we use or disclose sensitive Personal Information for the purpose of inferring characteristics about a consumer.
Right to accuracy, and the right to correct your Personal Information. You can correct or update your Personal Information held by us by contacting privacy@cliqueapp.org. We will update our records to reflect your accurate information.
Right to access your Personal Information. We will provide you with a copy of your Personal Information held by us upon your request and where required by law, along with details about the types of Personal Information we process, why we process it, and any third parties we work with to collect Personal Information on our behalf. Certain laws may limit the scope or frequency of requests we must fulfill.
Right to data portability. In some cases, we are required to provide your Personal Information to another organization at your request and in a structured, commonly used machine-readable format, so that the other organization can read and use it.
Right to non-discrimination. If you reside in a jurisdiction that extends a right to non-discrimination related to the exercise of privacy rights, we will not (i) deny you goods or services, (ii) charge you different prices or rates for goods or services, (iii) provide you a different level or quality of goods or services, (iv) retaliate against you as an employee, applicant for employment, or independent contractor; or (v) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised your statutory right unless permitted by law.
Right to disclosure. You may have a right to request information about how we collect and use your Personal Information, such as (i) the categories of Personal Information we have collected about you; (ii) the categories of sources for the Personal Information we have collected about you; (iii) our business purpose for collecting, using, disclosing, or selling that Personal Information, as applicable; and (iv) the categories of third parties with whom we disclose that Personal Information. We do not sell or share your Personal Information, but if we did you could request two separate lists stating: (a) sales, identifying the Personal Information categories that each category of recipient purchased; and (b) sharing for a business purpose, identifying the Personal Information categories that each category of recipient obtained. Certain laws may limit the number or frequency of requests we must fulfill.
Right to not be subject to automated decision-making and the right to opt out of profiling. We do not use automated decision-making or any form of automated processing of Personal Information to evaluate, analyze, or predict your performance, preferences, choices, or behavior.
Right to restrict processing. You may have the right to request that we restrict the processing of your Personal Information if (i) the data is inaccurate, (ii) the processing is unlawful, (iii) we no longer need the Personal Information, or (iv) you exercise your right to object. Your right to restrict may be limited to Personal Information that is sensitive in nature, or that is sold or shared for certain purposes.
Right to object. You may have the right to request, under certain circumstances and where we are required to do so by law, that we limit our processing of your Personal Information as you request.
California Shine the Light Act. If you are a resident of the State of California, you can request certain disclosures regarding Personal Information sharing with affiliates and/or third parties for marketing purposes.
Health Data Rights. We do not collect any health data. Some laws entitle consumers to certain details about health data collected about them, including (i) confirmation of whether the entity collects, shares, or sells the consumer’s health data and access that data, including a list of all third parties and affiliates with whom the entity has shared or sold the health data and a method to contact those third parties, (ii) a method to withdraw consent related to use of health data, and (iii) the right to have their health data be deleted.
THIRD-PARTY SERVICES
This Privacy Policy applies only to Personal Information processed by us. We may provide links to third-party websites or platforms for your convenience, but we have no ability to control, and we are not responsible for, the privacy and data collection, use, and disclosure practices of third-party websites. Any access to and use of linked websites is not governed by this Privacy Policy, but instead is governed by the privacy policies of those websites. We encourage you to review and understand the privacy policies of third-party websites before providing them with any information.
UPDATES AND CHANGES
We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy to our Site or through other communication. Your continued use of the App after we post an updated Privacy Policy constitutes your acceptance to all such updates. If you do not agree with the updates, do not use the App.
CONTACT US
We welcome your questions and comments about privacy. Please feel free to contact us via email at privacy@cliqueapp.org with any questions, comments, or complaints.