Privacy Policy

Last updated: December 11, 2025

Clearly B.V. ("Clearly," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Services.

1. Information We Collect

1.1 Information You Provide

We collect information you provide directly to us, including:

• Account Information: Name, email address, company name, and password when you register for an account
• Payment Information: Billing address and payment method details (processed securely through our payment provider)
• Communications: Information you provide when you contact us for support or other inquiries
• User Content: Any content, data, or code you upload or process through our Services

1.2 Information Collected Automatically

When you use our Services, we automatically collect:

• Usage Data: Information about how you use our Services, including job submissions, API calls, and feature usage
• Log Data: IP address, browser type, operating system, referral URLs, and timestamps
• Device Information: Device type, unique device identifiers, and mobile network information
• Cookies and Similar Technologies: We use cookies and similar technologies to collect information about your browsing activities

1.3 Information from Third Parties

We may receive information from third parties, including:

• OAuth providers (GitHub, Google, Microsoft) when you choose to authenticate using these services
• Our GPU cloud provider partners regarding your compute usage
• Analytics providers and advertising partners

2. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our Services
• Process transactions and send related information
• Send you technical notices, updates, security alerts, and administrative messages
• Respond to your comments, questions, and support requests
• Monitor and analyze trends, usage, and activities
• Detect, investigate, and prevent fraudulent transactions and other illegal activities
• Personalize and improve your experience
• Send promotional communications (with your consent)

3. Legal Basis for Processing (GDPR)

If you are in the European Economic Area (EEA), our legal bases for processing your personal data include:

• Contract: Processing necessary to perform our contract with you (providing the Services)
• Legitimate Interests: Processing necessary for our legitimate interests, such as improving our Services, preventing fraud, and marketing (where not overridden by your rights)
• Consent: Processing based on your consent, which you can withdraw at any time
• Legal Obligation: Processing necessary to comply with legal obligations

4. Information Sharing

We may share your information in the following circumstances:

• With GPU Cloud Providers: We share necessary information with third-party providers to provision and manage compute resources on your behalf
• With Service Providers: We share information with vendors who perform services on our behalf (payment processing, analytics, customer support)
• For Legal Reasons: We may disclose information if required by law or to protect our rights, privacy, safety, or property
• Business Transfers: In connection with a merger, acquisition, or sale of assets
• With Your Consent: We may share information with your consent or at your direction

We do not sell your personal information to third parties.

5. Data Retention

We retain your personal information for as long as necessary to:

• Provide our Services to you
• Comply with legal obligations
• Resolve disputes and enforce our agreements

Account information is retained for the duration of your account plus 2 years. Usage logs are retained for 12 months. You may request deletion of your data at any time, subject to legal retention requirements.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit (TLS) and at rest
• Regular security assessments and penetration testing
• Access controls and authentication requirements
• Employee training on data protection

However, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

7. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. When we transfer data outside the EEA, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions by the European Commission
• Other legally approved transfer mechanisms

8. Your Rights (GDPR)

If you are in the EEA, you have the right to:

• Access: Request access to your personal data
• Rectification: Request correction of inaccurate data
• Erasure: Request deletion of your data ("right to be forgotten")
• Restriction: Request restriction of processing
• Portability: Request transfer of your data to another service
• Objection: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent at any time where processing is based on consent

To exercise these rights, contact us at privacy@clearly.eu. We will respond within 30 days.

9. Cookies and Tracking

We use cookies and similar technologies to:

• Keep you logged in
• Remember your preferences
• Analyze how our Services are used
• Provide personalized content

You can control cookies through your browser settings. Note that disabling certain cookies may affect the functionality of our Services.

Types of Cookies We Use:

• Essential Cookies: Required for basic functionality (authentication, security)
• Analytics Cookies: Help us understand how users interact with our Services
• Preference Cookies: Remember your settings and preferences

10. Children's Privacy

Our Services are not intended for individuals under 16 years of age. We do not knowingly collect personal information from children. If we learn we have collected personal information from a child, we will delete it.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or through our Services. Your continued use of our Services after such notification constitutes acceptance of the updated policy.

12. Data Protection Officer

We have appointed a Data Protection Officer. You can contact our DPO at:

Email: dpo@clearly.eu

13. Supervisory Authority

If you are in the EEA and believe we have not adequately addressed your concerns, you have the right to lodge a complaint with your local data protection authority. In the Netherlands, this is the Autoriteit Persoonsgegevens (AP).

14. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us:

Clearly B.V.
Keizersgracht 520
1017 EK Amsterdam
Netherlands
Email: privacy@clearly.eu