Your privacy is important to us.

Summary 

The Clever Firm, Inc and its subsidiaries (hereinafter “CLEVER FIRM“, “we“, “our“, “us“) respect the privacy rights of its online visitors (“you”, “your”, “yours”) and recognize the importance of protecting the information collected about them. CLEVER FIRM has adopted a Privacy Policy that guides how we collect, store and use the information that you provide us with. 

The following information is provided by CLEVER FIRM to enable you to be fully informed of our Privacy Policies. By visiting www.thecleverfirm.com you are accepting and consenting to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not further access and/or use the website.

This Privacy Policy does not apply to websites maintained by other companies or organisations to which we link. CLEVER FIRM is not responsible for any personal information you submit to third parties via our website. Please ensure that you read the Privacy Policy of such other companies or organisations before submitting your details. 

What information do we collect from you and how?

CLEVER FIRM collects personal information in several ways when you became a member or take part in activities in which you are requested to provide this information. When you become a member of CLEVER FIRM, we need to hold personal information including your name, company name and address, email address, and location, so that we can process and fulfill your membership. Additionally, we may also need to obtain information as a result of authentication for payment, certificates or identification. If you become a member you participate on the membership list. If you wish to be included on any of our mailing lists or within our various chat boards, you are providing us authorization to include you by electing to be included.

Similarly, when you visit our website, we will collect the data known as  “clickstreams”(server address, domain name, etc). This information, combined with the details you have provided us with enables us to customize your next visits better.

Your personal information is only retained for a period reasonably necessary to meet the purposes for which it is collected.

How this information may be used

We may use your information for organising events, drawing up statistics or other website functions as well as for providing you with the services available on the website. Where there is a legal obligation to do so, we may disclose your information to any relevant regulatory body. We may also disclose your information in response to a valid, legally compliant request by a competent authority or in response to a court order or otherwise in compliance with any applicable law, regulation, legal process or enforceable governmental request or other statutory requirement; including the investigation of potential violations thereof; to detect, prevent or otherwise address fraud, security or technical issues; or to protect against imminent harm to the rights and property of CLEVER FIRM.

We may also use your personal information to send you information and materials by e-mail or via The Clever Application, including events and special offers and newsletters that we consider may be of interest to you. This information will only be sent to you if you have given us your specific prior authorisation.

By visiting the member-only, secured part of the website  www.TheCleverFirm .com we may use your personal information for analysing the visits to the website and determining the individual and overall interests of visitors to the website. This provides us with information that enables us to improve the products, services, functions, promotions that may be of most interest to you and the design of the website to better meet our visitors’ needs.

Opt-in provision

When you register, we will provide a link to the Privacy Policy and consent button for the collection of personal data. It is important to note that if you do not consent to the collection of data, you cannot proceed into our Member-only area nor join the network as a Member.

In addition, you will be given the option to opt-in of subscribing to:

Our regular newsletter will be sent by email to you with respect to new events or any other information of interest. Such alerts may include marketing information about CLEVER FIRM, our subsidiaries or selected business partners; and/or one-off marketing promotions from us.

At all times, you can unsubscribe from any service or update to which you have subscribed. Any e-mail or newsletter which we send will contain an easy automatic unsubscribe link so that you can opt out.

Protection of information

We use our best endeavors to maintain appropriate safeguards to ensure the security, integrity and privacy of the information you have provided us with. To guarantee the security of your details we have set in place a series of security measures and safeguards. Your personal details are stored on secure networks that may only be accessed by a limited number of persons holding special access rights and who undertake to respect and maintain the confidential nature of this information. In addition, we will take reasonable steps to ensure that third-party business partners’ to whom we transfer any data will provide sufficient protection of that personal information.

Despite these measures, whenever you provide your personal details on the Internet, there is a risk that this information may be intercepted and used by third persons whom we are unable to control. Although CLEVER FIRM makes every effort to protect your personal details and privacy, we are unable to guarantee the security of the information you make available over the Internet at your own risk.

Third parties

Your details may be transferred to partners that host our websites and third parties who assist us in the design and use of the website, or provide us with services or analyse data collected. These third parties will use the data for the purposes of carrying out the tasks described above, and undertake to respect and maintain the personal details. In addition, your details may be transferred to companies that form part of our network and for the purposes described earlier in this privacy policy. Other than in these cases, we do not sell, trade or transfer your personal details in any form to third parties without informing you first and in accordance with the data protection legislation currently in effect.  

Hyperlinks

We may include hyperlinks on this website to other websites or resources operated by third parties other than CLEVER FIRM, including advertisers. While we are careful in who is selected for these services, CLEVER FIRM has not reviewed all of these websites linked to this website and is not responsible for the content or accuracy of any off-site pages nor are we responsible for the availability of such external websites or resources, and do not endorse and are not responsible or liable, directly or indirectly, for the privacy practices or the content of such websites, including (without limitation) any advertising, products or other materials or services on or available from such websites or resources, nor for any damage, loss or offence caused or alleged to be caused by, or in connection with, the use of or reliance on any such content, goods or services available on such external websites or resources.

Cookies

During your visit to this website, CLEVER FIRM may collect data of an impersonal nature, mainly through the use of cookies, such as, but not limited to click stream cookies. A cookie is a small text file which a server can place on the hard drive of a user’s computer. It contains information about the relevant visitor’s visit to the website. Cookies can be used to collect specific information during your visit to the website. This information can help CLEVER FIRM to ensure that the website and the services more closely accommodate the requirements and preferences of the users of the website. You may configure your internet browser to notify you each time a new cookie is about to be stored on your computer so that you may decide whether to accept or reject it. Please refer to your internet browser’s help section for specific instructions. Please note that some parts of the website may not function properly if you reject cookies.

Reviewing, editing and deleting your data

Under the terms of the applicable data protection rules and legislation, you are entitled to inspect, correct and/or delete any personal data concerning you, as well as to revoke your consent to receive information about promotions and other matters of interest related to CLEVER FIRM, at any time. To this end, you may address a request for such inspection, correction, deletion and/or objection to: laura@thecleverfirm.com

Changes to the Privacy policy

CLEVER FIRM reserves the right to amend, modify and/or replace all or part of this website and the information and materials contained on it, as well as this Privacy Policy. Please check this Privacy Policy periodically for changes or modifications.

If you are a registered user, we will inform you about our intended change of this Privacy Policy at least two weeks before its effectiveness by sending you the intended new version via email. In case you do not disagree with the validity of the new Privacy Policy within two weeks from receipt, the new Privacy Policy will apply for the contractual relationship between you and us. With the email containing the new Privacy Policy, we will inform you about this deadline and the meaning of your not disagreeing expressly.

CLEVER FIRM Privacy Policy

1. Introduction
This Privacy Notice sets out the data processing practices carried out by The Clever Firm, Inc.

If you have any requests concerning your personal information or any queries with regard to these practices, please contact laura@thecleverfirm.com.

2. Who We Are
The Clever Firm, Inc (CLEVER FIRM) is a Canadian company with affiliates and supporting team members located in Pune, India and La Massana, Andorra.

The CLEVER FIRM supports professionals located across the globe increase their knowledge in US and Cross-border taxation through organizing in-person and virtual networking events, hosting online and app-based collaboration tools, providing in person and online courses and maintaining an online membership directory.

CLEVER FIRM seeks to achieve its purpose through:

Maintaining a secure member area of our website.
Maintaining up to date member records
Organizing and hosting in person and virtual member events and course in Canada, Europe and India

Providing an android and IOS application that will provide all of the services that are available online in our membership area.

As the CLEVER FIRM is not a European based entity it has not formally determined its status or requirements under General Data Protection Regulation, however, we aim to achieve the same standards per below until a proper assessment is completed.

3. Information collection

3.1 Ways we collect data
We collect information in the following ways:

Information you give us. For example, when you engage with us by becoming a member, signing up for an event or webinar or otherwise provide us with personal information. When you register as a member or for an event, we’ll ask for personal information, like your name, company and email address and store this data on our Canadian based servers along with your account.
Information we get from your use of our website and services. We collect information about the services you use and how you use them, like when you visit our websites or view and interact with our content.
Information from third parties. We may also receive information about you from third parties. This can include information such as your name, postal address, email address, phone number, your geographic location (for mobile devices), credit/debit card details. We, like all companies, are able to confirm what browser you are using, IP address and computer operating systems that are being used and this information may be used to improve the services we offer.
Information from Research. We may also obtain information about you from your company website and other public sources such as LinkedIn where you have actively provided your information to the general public. Should we choose to connect with you through these publicly available databases, you will be given the opportunity to opt out of all communication with us and we will remove your data immediately.

3.2 Sensitive Personal Data
The GDPR recognises that certain categories of personal information are more sensitive. We do not believe we collect sensitive personal data beyond your name, company, email, professional designation (i.e. CPA, LLB, EA etc).

4. Use of personal information
We process personal information collected via this website for the purposes of:

Tailoring our events and resources according to our members interests
dealing with inquiries and requests
administering payments from event attendees and members;
maintaining membership details and directories;
providing members with information about additional products and services.
providing membership and Conference registration services
exchanging personal information with third parties e.g. Sponsors, Exhibitors
Maintaining information as a reference tool or general resource.
Google Analytics to measure the use of the website (see Cookies).

5. Website users
The CLEVER FIRM website uses cookies to help our websites work well and to track information about how people are using them. More information on cookies can be found in section

5.1 - see Cookies.

In addition, if you register on our website then the following will also apply:

The CLEVER FIRM website collects personal information when you register with us.
The website you sign up to will collect information such as your name, email address and location. Once you register with that website you will not be anonymous to us when you subsequently sign in.
As part of the registration process and continued use of CLEVER FIRM services, you agree that any registration information you give to CLEVER FIRM will always be accurate, correct and up to date. Should you need to amend any of your personal information, you can do so by logging into your Clever Firm Membership area or by emailing Laura@thecleverfirm.com
We collect and retain information about your interactions with us so that we can process your interactions and deal with future queries.
We use cookies to allow us to store limited information on an individual’s computer to either track them through tracking cookies or to allow people to have automatic logons as an example. We use this information to provide you with a good experience when browsing our website and to improve the functionality of our site.
Parts of the CLEVER FIRM website are restricted to CLEVER FIRM members only.

5.1 CLEVER FIRM Cookies
To provide the best experience to our users the CLEVER FIRM makes use of cookies. Our cookies do not store sensitive personal information. They only store the browser association that loads the data and provides a dynamic experience for the site user.

5.2 Inappropriate website content
If you post or send any content that we believe to be inappropriate, offensive or in breach of any laws, such as defamatory content on our forums or social media pages, we may use your personal information to inform relevant third parties such as your internet provider or law enforcement agencies.

6. Your credit card information
If you use your credit card to join us or pay for a registration online or over the phone, we will ensure that this is done securely and using a reputable payment provider. We do not store your credit card details as all payments will be made through said provider, depending on the method of payment.

If we receive an email containing any credit card details, it will be immediately deleted, no payment will be taken and you will be notified about this. All purchases should be completed through the CLEVER FIRM website or by sending payment via bank transfer.

7. Legal basis for processing personal data
In most instances, we collect and use your personal information by relying on the legitimate interest legal basis. This is because when you, for example, request to receive services or products from the CLEVER FIRM, we have a legitimate organisational interest to use your personal information to respond to you and there is no overriding prejudice to you by using your personal information for this purpose. This is also the case where we process your information for our internal administrative purposes, and where we need to take steps to protect our network security or risk of fraud.

In some instances, we will rely on obtaining your consent to our use of your personal information. This is the case, for example, where we seek to obtain your consent to receive email marketing about CLEVER FIRM conferences.

8. Promotion– It’s your choice
If you’re giving us your information, it is only to be used for the purpose of exactly what we have indicated before you provided it. We aren’t in the business of selling your information, however we are in the business of building a useful and collaborative professional network which includes maintaining a membership directory of your details available to all members behind a secure membership portal. In addition, we will use that information to notify you of various events, resources and courses that are available to you as a Clever Network member. If you choose to have this information deleted or to leave the network entirely, you may elect to do so through your member portal or by emailing laura@theclevernetwork.com.  You will always receive communication about your account and membership renewal.

If you opt out of receiving information from us, we will retain your details on a do not contact list to help ensure that we do not continue to contact you in the future.

8.1 Email Promotion 
If you actively provide your consent to us along with your email address, we will contact you for marketing purposes by email. By subscribing to CLEVER FIRM emails or opting in to email communication from CLEVER FIRM, you grant us the right to use the email for both information and email marketing purposes concerning CLEVER FIRM conferences worldwide.

8.2 CLEVER FIRM Members’ Directory
One of the benefits of membership is that you can be listed in the CLEVER FIRM Members’ Directory. If you would like to opt out of appearing, choose ‘Manage Profile’ from the My CLEVER FIRM Home menu, and select ‘Yes’ or ‘No’ under ‘Make your Profile Public’ to make your profile accessible or inaccessible through ‘Members Directory’. Note that only current individual and Corporate Members have access to the Members’ Directory.

9. Data Retention
In order to comply with Canadian tax regulations, we keep records for all individuals who have purchased goods or services from CLEVER FIRM (e.g. conference registration, CLEVER FIRM membership) for 7 years, and will continue to send you marketing information about related conferences or about CLEVER FIRM membership during that period.

If you register your interest for a conference, but have not yet attended one, we retain your contact details for up to 3 years and will send you marketing information about related conferences or about CLEVER FIRM membership.

If you applied for membership but never completed your application through lack of payment, we will leave the invoice available to you for 90 days from issuance. We would then suspend your membership and keep your record for up to 3 years after that; we will continue to send you marketing information about related conferences or about CLEVER FIRM membership.

You can opt out at any time by emailing laura@thecleverfirm.com .

10.  Your rights to your personal information

Under the GDPR, you have the following rights:

1. The right to be informed - this is fulfilled through this notice.

2. The right of access - you have the right to obtain confirmation that your data is being processed and access to your personal data. This is so that you are aware of and can verify the lawfulness of the processing. If you request the information, we will provide a copy of the information free of charge.

Should you wish to exercise these rights, we require you to prove your identity with two pieces of approved identification. Please address requests to the Laura McLeman, laura@thecleverfirm.com and we will respond within 30 days, of receipt of your written request and confirmed ID. Please provide as much information as possible about the nature of your contact with us to help us locate your records.
3. The right to rectification - to adjust your personal information login to your member portal and update your personal data accordingly. If you are unable to log in to your portal, it may mean that your membership status does not grant you access to members’ area of the website. Please contact laura@thecleverfirm.com and we will assist you.

If we have disclosed the personal data in question to third parties, we will inform them of the rectification where possible. We can also inform you about the third parties to whom the data has been disclosed where appropriate.

4. The right to erase - this is also known as ‘the right to be forgotten’. The broad principle underpinning this right is to enable you to request the deletion or removal of personal data where there is no compelling reason for its continued processing. If you would like us to erase you from our database, please email laura@thecleverfirm.com. If we have disclosed the personal data in question to third parties, we will inform them about the erasure of the personal data, unless it is impossible or involves disproportionate effort to do so.

5. The right to restrict processing - individuals have a right to ‘block’ or suppress the processing of personal data. In this case, we still may maintain some of your personal data (for legitimate business purposes such as tax or accounting purposes), but we will be restricted in what we can do with your data until 1) you verify the data, or 2) you confirm the processing purpose for the data.

If we no longer need the personal data but you require the data to establish, exercise or defend a legal claim.

If we have disclosed the personal data in question to third parties, we will inform them about the restriction on the processing of the personal data, unless it is impossible or involves disproportionate effort to do so. We will inform you if we decide to lift a restriction on processing.

6. The right to object - you have the right to object to processing based on legitimate interests (including profiling) and direct marketing (including profiling). Please note, we do NOT sell data or provide to third parties for any other purposes than as disclosed by us (for example, providing conference attendee details to sponsors and attendees). We will inform you of your right to object in the first communication you receive from us. We will stop processing personal data for direct marketing purposes as soon as we receive an objection.

7. The right to data portability - you have the right to obtain the data that the CLEVER FIRM processes on you and use it for your own purposes. This means you have the right to receive the personal data that you have provided to CLEVER FIRM in a structured machine-readable format and to transmit the data to a different data controller. This will be done after identity verification and for legitimate business purposes only.

11. Rights in relation to profiling and remarketing

11.1 Profiling
We may collect, and our third-party providers of advertisements and content may collect, information about where you are on the internet (e.g. the URL you came from, IP address, domain types like .com), your browser type, the country and telephone area code where your computer is located, purchase history, the pages of our website that were viewed during your visit, and any search terms that you entered on our website ("User Information"). We may collect this information even if you do not register with us.

You should be aware that this site is being monitored and may capture information about your visit that will help us improve the quality of our service, or be used to present you with CLEVER FIRM products and services which are relevant to your browsing history when you visit other websites.

11.2 Remarketing
CLEVER FIRM uses other websites to present services or information. Third-party vendors, including Google, Facebook, Linkedin and Twitter, may show CLEVER FIRM information on sites across the Internet.

We do have relationships with carefully-selected and monitored suppliers who may also set cookies during your visit to be used for remarketing purposes, to show you different products and services based on what you appear to be interested in. These companies also use automated technologies to collect information when you click on our ads, which helps track and manage the effectiveness of our marketing efforts.

12. Recipients – Information and Disclosure
CLEVER FIRM may disclose your personal information in the following circumstances:

To suppliers or service providers only to provide the products or services you've requested from us where, for example, we use an event provider / organizer or we deliver items to you
To third parties who provide a service to us and are data processors. We require these third parties to comply strictly with our instructions and data protection laws and we will make sure that appropriate controls are in place. We enter into contracts with all of our data processors and regularly monitor their activities to ensure they are complying with CLEVER FIRM policies and procedures.
Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example, to government bodies and law enforcement agencies), or in order to enforce or apply our rights (including in relation to our website or other applicable terms and conditions) or to protect CLEVER FIRM, for example in cases of suspected fraud or defamation.
To CLEVER FIRM employees or directors or consultants, to assist with the running of CLEVER FIRM.

13. International transfers of personal information
As CLEVER FIRM is a global network with CLEVER FIRM members and affiliated companies, your information may be processed outside of your local jurisdiction.

Specifically, your personal data will be stored on Canadian data servers. Should you choose to purchase or register for any of our online courses, Clever Fresher India will be the processor of your information however your personal data will continue to be stored on Canadian data servers.

14. Changes to this privacy policy
We may update the terms of this policy at any time, so please do check it from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address you have provided to us or by placing a prominent notice on our website(s). By continuing to use our website, you will be deemed to have accepted such changes.

15. Complaints, compliments or comments
If you are unhappy with our work or something that we have done or failed to do, we want to know about it. Your comments enable us as an organisation to learn and continuously improve our services. Email us at laura@thecleverfirm.com

 
Appendix 1: List of Information Collected

Membership database and application form
Title  
First Name(s) 
Last Name  
Position

Employer / Company Name  
Address (city, state, county, postcode, country)  
Website 
Email address 
Alternative email 
CLEVER FIRM mailings opt in 
Third party preferences

Google Analytics
IP address 
Website user behaviour (duration on site/pages visited/geographical location)

Conference registration forms
Title 
Name 
Date of birth 
Company 
Address (city, state, country, postcode) 
Dietary requirements 

Email address 
Alternative email address 
Event Notifications Opt In.