Privacy Notice

 

Last updated: 11/12/2025

 

I. Introduction

This Privacy Notice details the methodologies by which our company (collectively referred to as "we," "us," "our," or ClikFlick) gathers, processes, and discloses data concerning individuals who engage with us or reach out via the Website or alternative communication channels. We commit substantial resources to ensuring the robust security of your personally identifiable information and its appropriate utilization. This Notice also sets forth the general procedure for how we obtain your Personal Information and the subsequent actions we undertake with that data once it is in our possession.

 

This Privacy Notice exclusively governs the processing of Personal Data of customers and visitors collected by ClikFlick through the Website and other channels expressly stated herein. It does not govern or extend to the collection, usage, or transmission of data that may occur directly between your browser and external service providers, such as Cloudflare. Data collected by Cloudflare is governed by their own privacy policies. Please visit https://www.cloudflare.com/en-gb/privacypolicy/

 

Before using the Website, please read this Privacy Notice (“Notice”) completely. Your provision of data signifies your agreement; if you do not assent to the terms outlined here, please refrain from sharing your information with us.

 

ІІ. Operations Governed by this Privacy Notice

 

This Privacy Notice governs data processing associated with the following core operations conducted by ClickFlick:

 

Operation of Digital Infrastructure: Administration, maintenance, and security of the ClickFlick online domain clickflicktech.com (the "Website"), which includes managing traffic, ensuring stability, and deploying core services facilitated by our primary infrastructure provider, Cloudflare.

 

Marketing and Customer Acquisition: Handling inquiries and data submissions received via the designated contact forms available on the Website, as well as the distribution of the ClickFlick electronic newsletter and other data-driven marketing communications aimed at increasing brand visibility.

 

Client and Partnership Management: Communication, service delivery, and strategic business dealings with ClickFlick's customers, vendors, and other collaborative associates.

 

Talent Acquisition and Internal Operations: Procedures related to the hiring and employment of staff, human resources management, and compliance with all applicable legal and regulatory obligations.

III. Defining “Personal Data” and the Scope of “Processing”

 

For our purposes, “Personal Data” or “Personal Information” refers to any data point concerning an individual who is:

 

 

“Processing” is an umbrella term covering every operation performed on personal data, such as: gathering, documenting, organization, storage, adapting, retrieving, reviewing, utilizing, sharing (through transmission, making available, or other disclosure), combining, restricting, erasing, or destroying data.

 

How We Acquire Your Personal Data

We employ various techniques to gather personal data related to our users and site visitors. Typically, you voluntarily share your data with us through direct interactions when you:

 

IV. Our Function and Identity

 

Throughout this Privacy Notice, the terms "ClikFlick", "we," "us," and "our" exclusively denote: ClikFlick Limitada, a limited liability entity formally established under the laws of Costa Rica. Should you have any inquiries concerning this Notice, please use the contact information provided above to reach us.

 

Registration number: 3-102-948845.

Address: 101 Province 06, Puntarenas, Canton 11 Garabito, Jaco, on the eastern side of the Garabito municipality, Costa Rica

Email: info@clickflicktech.com

 

If you have any questions about this Privacy Notice, please contact us via the above-mentioned contact details.

 

Depending on the context outlined below, when you interact with our Website or communicate via Social Media platforms (such as Twitter, LinkedIn, or Facebook), we may function as a data controller, a joint data controller, or a data processor concerning the collected personal data.

 

Data controller is defined as the party (entity or individual) that determines the objectives and methodologies for processing personal data. Essentially, the Data Controller bears the responsibility for deciding why and how personal data is gathered, retained, utilized, and shared. This party is also mandated to ensure that all data processing adheres to the principles and obligations of the relevant legislation, including securing necessary consent from data subjects and upholding their rights related to their data.

 

Joint data controller involves two or more entities or organizations that collaboratively decide on the purpose and means of processing personal data. In such instances, they share the accountability for compliance with data protection laws and must collectively guarantee the protection of the rights of the individuals whose data is being processed. Under the applicable data protection regulations, including the General Data Protection Regulation (referred to herein as the "Applicable Legislation"), we might be considered a joint controller—for instance, regarding your Social Media Data (defined later). When you contact us via Social Media, we are considered a data controller solely for (i) the information you submit to us and (ii) the statistical data provided by the specific Social Media channel. However, for all other handling of your data, the respective Social Media platform operates as an independent data controller.

 

Data processor is an organization or entity that handles personal data strictly on behalf of and according to the instructions of a Data Controller. The Data Processor's mandate is to execute processing tasks as directed by the Controller. These duties can encompass various operations, such as the collection, secure storage, organization, analysis, and eventual deletion of Personal Data.

 

V. Guiding Principles

 

Principles

Description

Lawfulness, Equity, and Clarity

We handle your Personal Data in a legal manner, grounded in a clear and valid objective. We guarantee that you are kept fully aware of our processing activities via this Privacy Notice and other pertinent communications.

Goal Restriction

Your Personal Data is acquired for defined, unambiguous, and rightful goals and will not be subjected to any further processing that deviates from those initial purposes. We avoid using your information for aims disconnected from the original reason for its collection without securing your explicit consent, unless mandated or authorized by law.

Data Efficiency

We only gather and process Personal Data that is appropriate, pertinent, and strictly proportional to the necessities of the intended processing goals. We do not store your data for any period exceeding the requirements for fulfilling those specific purposes, unless required for adherence to legal or regulatory obligations.

Data Integrity

We make every effort to ensure your Personal Data remains precise, comprehensive, and current. You maintain the right to seek correction for any information that is inaccurate or incomplete.

Integrity and Security

We employ suitable technical and organizational measures designed to guarantee the security and confidentiality of your Personal Data, thereby shielding it from unauthorized access, accidental disclosure, modification, or eradication.

Accountability

We assume full responsibility for our data processing procedures and ensure strict adherence to all relevant data protection laws and regulations. We meticulously document our processing activities and conduct regular reviews to verify ongoing compliance.

Legal Grounds for Handling

The processing of your personal data is always justified by one or more lawful criteria, such as your explicit consent, the necessity of fulfilling a contract, meeting legal duties, our defined legitimate interests, or other lawful grounds stipulated by the Applicable Legislation.

Exercising Data Rights

We fully respect the rights you possess as a data subject and have established mechanisms that allow you to effectively exercise those rights.

 Safeguards for International Data Transfers

In the event that we transfer your Personal Data to jurisdictions located outside the European Economic Area (EEA), we commit to implementing sufficient protective measures to secure your data, as mandated by the applicable data protection legislation.

 

Our commitment is to uphold the most rigorous standards of data protection and privacy whenever we process your Personal Data. All of our data handling activities are fundamentally shaped by the following core principle

VI. Categories and Intentions of Personal Data Processing

 

We will only handle your personal data for the express goal of delivering the services you request from us, meeting the legal duties arising from providing those services, and fulfilling our legitimate business interests (as defined in Article 6 of the GDPR for individuals in the European Economic Area).

Your personal data will be utilized for the following core objectives:

Risk Management & Compliance: To mitigate risk and deter criminal activity, which involves conducting anti-money laundering (AML), counter-terrorism, sanction checks, fraud prevention, and other necessary background screenings; detecting, investigating, documenting, and stopping financial crimes broadly defined; adhering to all applicable legal and regulatory requirements; and managing and resolving user complaints.

Service Delivery: To successfully process and provide our services to you, including activities like registering your new account and contacting you as needed via phone or email.

Financial Administration: To oversee, execute, collect, and transfer payments, fees, and related charges, ensuring the efficient financial management of these transactions.

Internal Oversight & Analysis: To maintain current and accurate internal records and to analyze how our clientele interacts with and utilizes our products and services.

Market Insight & Growth: To compile market data for studying customer behavior, including preferences, interests, and usage patterns, which informs our marketing strategies and supports business expansion.

Security & Administration: To manage and protect our website(s) and services, guaranteeing network security and effective fraud prevention measures.

Marketing & Content Delivery: To present you with relevant content and targeted advertisements on the website.

Service Enhancement: To continually improve the quality and functionality of our website(s) and services.

Consent-Based Use: For any additional purpose for which you grant us explicit consent.

Your information, irrespective of its public or private nature, will under no circumstances be sold, traded, conveyed, or otherwise transferred to any external entity for any reason without your permission, except for the specific aim of fulfilling requested services and enhancing those services. However, choosing to restrict how your personal information is used may result in certain features or services becoming unavailable to you.

 

Category of Data

Examples

Description or Comments

Analytical and Usage Data

Your Internet Protocol (IP) address.

Details related to your interactions with the Website (e.g., button clicks or data input).

Automated Collection Tools

Certain data may be gathered automatically as you browse the Website using integrated tools like Google Analytics. Further information about Google Analytics is available here. Once collected, Google compiles comprehensive reports on platform usage. These reports contain aggregated statistics that prevent us from identifying any single individual. In other words, you remain anonymous among other users.

Role of Cookies

Furthermore, we accumulate information through the use of cookies. Cookies are a standard software function that enables web servers to recognize the specific device used to access the Website. A cookie is a tiny text file that the Website stores on your device during a visit. They are essential for enabling the Website to retain your activities and preferences over a sustained period.

 

The kind of device you are using.

The web browser you access the site with.

The operating system installed on your device.

information regarding your use of the Website, for instance, when you clicked a certain button or made some input.

Contact Information Collected

name/nickname

This information is typically gathered via the dedicated contact form available on the Website. The decision regarding which data to disclose to us rests entirely with you.

email address

phone number

Any additional information requested by us or voluntarily supplied by you.

Subscription Data

email address

If you contact us via contact form on the website, we may use indicated email for our marketing and newsletter purposes.

Social Media Data

nicknames, names, and/or photos

You may contact us via Social Media as Twitter, LinkedIn or Facebook.

In general, Social Media makes available the respective statistical information to us in an anonymized form. It is impossible for us to make any conclusions about individual users and access to individual user profiles relying solely on such information.

Certain categories of personal data and processing details vary depending on the Social Media, therefore, please refer to the Privacy policies of the respective Social Media as  listed below.

messages, comments, and other communications

information provided to us by the respective Social Media as outlined below

other data that you choose to provide us with

Contract Data

full name

If you want us to enter into a contract to provide you with services, you will need to provide some Personal data about yourself. If you are acting independently, this includes, at least, your full name, passport details, and channels of communication. If you are acting on behalf of a company, you will also need to indicate your position in such a company (as example, managing director etc.).

Please note that the email as info@company.net is not personal data.

contact details

position in company

passport data

other data that required by applicable legislation for establishment of contractual relationship or agreement between us

Recruitment Data

full name

We need this information in order to understand whether you meet the requirements of our vacancy.

 

In the case of employment, the provision of certain information is required by law. We use such data only to the extent and for the purposes necessary to fulfill our legal obligations.

email address

phone number

professional experience

previous position

other information that you provide when applying and/or resume and/or during interviews: photos, skills, educational level, languages spoken, expected salary level, home address, hobby, etc.

in case of employment:

  • Passport Data
  • TIN

Feedback Data

name

If you are satisfied with the services, or for other reasons decide to tell others your impression of us, you can send us feedback and we will publish it on our Website.

position

photo

 

 

VII. Cookie Policy

“Cookies” are small text files that are downloaded on your device  (e.g. a computer or smartphone) when you access the Website. Cookies support the operation of our Website as well as allow the Website to recognize your device and store some information about your preferences or past actions.

 

Cookies aim to make a Website more efficient for users. They allow personalized settings and web pages to be offered to provide a more convenient and faster visit experience tailored to your needs. These files store information about your Website navigation. When you use the Website again, your devices will remember your data thanks to the information kept in the file.

 

Use of Cookies

The cookies that we use are as follows:

 

Strictly necessary cookies

These cookies are essential to enable you to move around our Website and use its features, such as accessing secure areas of the Website.

 

Functionality cookies

These are cookies that allow our Website to remember choices you make (such as your username in Account, or the region you are in) and to provide enhanced, more personal features. These cookies can remember changes you have made to text size, fonts, and other parts of web pages you can customize. They may also be used to provide services you have asked for.

 

Performance cookies

These cookies collect information about how you use our Website, for example, which pages you go to most often and if you get an error message. These cookies are used to improve how our Website works.

 

Some cookies are placed by third-party services that appear on our pages.

 

Google Analytics

 

We use Google Analytics for analytical purposes using cookies stored on your equipment. Google stores and uses acquired information.

For more detailed information on Google`s Privacy Policy, please visit https://policies.google.com/privacy?hl=en-US .

If you want to opt-out of being tracked by Google Analytics, please visit https://developers.google.com/analytics

 

You can change your cookie settings at any time by using the Cookie Settings button on the Website. You can then adjust the available sliders to ‘On’ or ‘Off’, then click ‘Save and close’. You may need to refresh your page for your settings to take effect.

Alternatively, most web browsers allow some control of most cookies through the browser settings. You can manage cookie settings in this way at any time.

Please keep in mind that simply disabling all cookies or all of our cookies in your browser settings may lead to certain sections or features of our Website not working. Therefore, we recommend using the Cookie Settings button on our Website instead of disabling all cookies in your web browser.

 

For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050

 

For the Internet Explorer web browser, please visit this page from Microsoft: https://support.microsoft.com/search/results?query=cookies+&isEnrichedQuery=false

 

For the Firefox web browser, please visit this page from Mozilla: https://www.firefox.com/en-US/privacy/websites/cookie-settings/

 

For the Safari web browser, please visit this page from Apple: https://support.apple.com/kb/index?page=search&src=support_serp&locale=en_US&currentPage=1&product=&doctype=&includeArchived=false&query=cookies+

 

For any other web browser, please visit your web browser’s official web pages.

 

Consequences of disabling cookies

 

 

If you clear your cookies on our Website, you will need to opt-out again.

 

To find more information about cookies please visit:https://allaboutcookies.org./

 

VIII. Retention Period for Personal Data

We retain your Personal Data only for the duration that is absolutely necessary to fulfill the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider several factors, including:

 

 

Category of Data

Period of retention

Explanation

Analytical and Statistical Data

Up to two (2) years.

Specific retention timelines are determined by Google based on its settings.

Contact Data

Two years after the most recent communication

Unless otherwise mandated by relevant legislation, this data is kept for two years following the last contact.

Subscription Data

As long as you maintain your subscriber status.

We process such data only until you opt out from receiving our marketing and newsletter emails.

Social Media Data

No specific retention period for statistical and analytical information.

 

Personal data submitted by you is retained until you or the relevant Social Media platform initiates its deletion.

 

Information on our communication will be deleted by us after 2 years from the last communication.

We do not set a retention period for this type of data, as it is aggregated and cannot identify a particular individual.

Specifically, any information relating to our direct communications will be removed from our systems exactly two (2) years following the final date of contact. Please be aware that we may lack the technical ability to fully erase the personal data you shared within those communication channels; consequently, this specific data remains processed until its removal is executed by either you or the respective Social Media service.

 

Contract Data

In case of contractual relationship between you and us, 2 years after its termination.

This term is related to our fulfillment of our obligations under the law, such as accounting, auditing, taxation, etc.

Recruitment Data

In case of employment: for the period of work in Goten and after dismissal within 1 year. In case of refusal: within 6 months after it, if you do not object to processing.

-

Feedback Data

As long as your feedback remains on our Website.

We process such data only until you opt out by informing us via contact details stipulated in the "Contact Us" section.

 

IX. Your Rights Regarding Personal Data

 

Pursuant to the Applicable Legislation, you possess specific entitlements concerning the personal information we maintain about you, as detailed below. To ensure the secure exercise of your rights as a data subject, we may need to request supplementary information from you to confirm your identity.

 

 

 

 

Rights

Description

The Right to Review Data

You hold the authority to request a copy of the personal data that is currently stored by us concerning you. Upon receiving a valid request, we will furnish you with complete details, including the justification for processing, the specific types of personal data involved, any parties that receive this data, and the duration for which the data is retained.

Right to Correction

Should you determine that the personal data we possess regarding you is either incorrect or missing necessary details, you hold the right to demand that we promptly correct or refresh the information.

Right to Deletion (Known as the Right to be Forgotten)

You may ask for your personal data to be permanently erased under specific conditions. These circumstances arise, for example, when the data is no longer necessary for the initial collection purposes, or if you withdraw your permission and no other legitimate grounds exist to continue the processing.

Right to Limit Processing

You possess the right to demand that the processing of your personal data be temporarily restricted under defined situations. This applies, for example, if you challenge the data's accuracy, or if the data handling is deemed unlawful but you oppose its complete deletion.

Right to data portability

You may request to receive the personal data you initially supplied to us in a standardized, widely used, and machine-readable format. Additionally, you are entitled to transfer this data to a different data controller, provided this is technically feasible.

 Right to Challenge Processing (Object)

You have the authority to object to the processing of your personal data when it is based on our asserted legitimate interests. We are obligated to stop processing your data unless we can establish compelling and overriding legitimate grounds for the processing that supersede your interests, rights, and fundamental freedoms.

Right to withdraw consent

If you have previously granted consent for the handling of your personal data, you have the option to withdraw this consent at any point in time. Note that retracting your consent will not invalidate the legality of any processing that occurred before the withdrawal took effect.

Right to file a complaint

If you suspect that your rights under the Applicable Legislation have been infringed, or if you feel we have failed to adequately address your concerns regarding data processing, you have the right to submit a complaint to the appropriate supervisory authority.

 

The supervisory authority is the designated data protection body in your specific country or region responsible for monitoring compliance with data protection laws. You can locate the contact information for your supervisory body on their official website or through other authoritative sources.

 

The supervisory authority in Costa Rica:

 

Agencia de Protección de Datos de los Habitantes (PRODHAB)

Website:https://www.prodhab.go.cr/

Address: KSan Pedro de Montes de Oca, Mall San Pedro, Ofimall Executive Center, 6th floor.

FAX: (506) 2234 2510

Phones: (506) 2234 0189

E-mail:info@prodhab.go.cr

To activate any of the rights listed above, or if you have questions or concerns regarding our handling of your personal data, please reach out to us using the contact details supplied in Section IV of this Privacy Notice. We commit to responding to all your requests and inquiries promptly (without undue delay) and in full compliance with the mandates of the Applicable Legislation. Be aware that, in certain situations, we may be unable to satisfy your request due to specific legal requirements or exemptions established within the Applicable Legislation.

 

X. Data Retention Policy

We will maintain your personal data only for the period during which it is necessary to fulfill the stated purpose or as legally required, which may surpass the conclusion of our formal relationship with you. We reserve the right to preserve certain records where essential for preventing fraud or future misuse, or to meet valid business objectives, such as analyzing anonymized aggregated data, facilitating account recovery, or when mandated by law.

For the purpose of meeting our legal or regulatory duties and adhering to global industry standards for data preservation, you hereby grant us permission and consent to retain records of such information throughout the duration of our Business Relationship with you, and for an additional period of five (5) years after that Business Relationship is terminated.

 

XI. Modifications to Our Privacy Notice

This Privacy Policy may be updated or amended by us occasionally, a change that will be reflected by adjusting the revision date found at the top of this page. We will notify you of any material changes by sending an email notification to the address registered in your profile. Your failure to accept a newly published edition of the Privacy Policy obligates you to immediately discontinue the use of both the website and our services.

 

XII. Contact Us

As a friendly reminder, if you have any questions or concerns regarding the provisions of this Privacy Notice, kindly contact us using the following details:

Address: 101 Province 06, Puntarenas, Canton 11 Garabito, Jaco, on the eastern side of the Garabito municipality, Costa Rica

Email: info@clickflicktech.com