Privacy Policy
Effective date: July 01, 2025
Please read the following information (the “Policy”) carefully, as it contains all relevant information to be provided by us, Clearcue, located at Gotse Delchev 26E, Sofia, Bulgaria (“Clearcue” or “we”), and you as the user or data subject (“you”), regarding personal data processing through Clearcue’s website, software and services (the “Services”), including the processing of your personal data by third parties using our Services, as well as data collected through job application channels we control.
If you do not agree to the terms of treatment described in this Policy, please do not access or otherwise use the Services. If the processing refers to your personal data, please contact us to request deletion — you can do so by emailing us at hello@clearcue.ai.
1. Our use of personal data
“Personal data” refers to any information that identifies a person (a “data subject”), such as a name, identification number, location data, or other factors specific to an individual's identity.
When using our Services or applying for a position on our team, you may be asked to provide personal data. Additionally, as a processor, Clearcue may access contact information concerning employees of companies contacted via our platform.
Our services are built for business use. We do not knowingly collect personal data from children under the age of eighteen (18). If we become aware that a minor has provided us with personal data, we will delete it promptly.
2. The data we collect and why
We collect personal data from users of the Services, employees of Clearcue’s clients. Below you will find the relevant details concerning all this data.
2.1. Categories of data
Collected and processed data includes the following categories of data (examples are provided as well):
Identification: full name; residential address.
Contact details: phone and mobile number; email address.
Usage: traffic data; usage statistics.
Location: IP address.
Payment: credit card number.
Communications: e-mails.
Business: company; position; seniority.
2.2. Groups of data subjects
We process data pertaining to the following groups of subjects:
Website users – individuals who access our website.
Client users – individuals authorized by a Clearcue client to access and use our systems.
Prospects – individuals targeted by the client’s communications.
For each of these groups we process the following categories of data:
Website users – usage and location.
Client users – identification, contact details, usage, location, payment, communications, business.
Prospects – identification, contact details, business.
2.3. Details of the processing activity
Data deletion. Once the applicable retention period ends, Clearcue will either remove or irreversibly anonymize your personal data, unless there’s a legal or contractual reason for us to retain it.
Sharing data. We may disclose your personal data to trusted third-party vendors and infrastructure partners who help us operate, host, or improve our platform—for example, providers like Amazon Web Services or analytics platforms. These third parties only act under our instructions and are bound by data protection agreements.
Requests for disclosure. If we receive a legally binding request from a regulatory, judicial, or government body asking for access to your personal data, we will:
ask the authority to contact you directly where possible;
notify you promptly unless we are legally restricted from doing so;
take reasonable legal steps to object to the request where applicable, especially if it conflicts with your privacy rights.
Third-party responsibility. Please note that we are not accountable for how external services, websites, or platforms handle your data. If your personal information is processed by others outside our control, their own privacy policies apply.
3. Data protection rights
You can exercise any of the rights listed in this section by reaching out to us at hello@clearcue.ai.
3.1. Data privacy framework
Clearcue complies with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework, established by the U.S. Department of Commerce alongside relevant regulatory authorities in Europe, the UK, and Switzerland.
We uphold the principles of the Data Privacy Framework (DPF) as they relate to data received from the European Economic Area (EEA), the UK, and Switzerland. You can find more information about the DPF here and view the list of participating organizations.
Compliance with principles. Clearcue is committed to the DPF Principles and maintains the necessary certifications. In the case of any conflict between the content of this Privacy Policy and the DPF Principles, the Principles shall take precedence.
Transfers to third parties. When transferring data to third parties, we require all vendors and partners to commit to confidentiality and to provide data protection safeguards consistent with our own obligations under the DPF.
Legal oversight. The U.S. Federal Trade Commission (FTC) has jurisdiction over Clearcue’s compliance with the DPF.
Unresolved complaints. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may contact our third-party dispute resolution provider based in the United States (free of charge) via this form.
Binding arbitration. Under specific conditions, you may invoke binding arbitration as a final option to resolve complaints under the DPF. More information on this process is available on the DPF website.
Mandatory disclosures. In certain circumstances, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
3.2. Your rights under European and UK privacy laws
If you are located in the EU, UK, or Switzerland, you have the following rights under applicable data protection laws (e.g., GDPR or UK GDPR):
Right to information – You have the right to clear and transparent information about how your personal data is used.
Right of access – You may request access to the personal data we hold about you.
Right to rectification – You can ask us to correct or update inaccurate or incomplete data.
Right to erasure – In certain situations, you may request that your data be deleted (also known as “the right to be forgotten”).
Right to restrict processing – You can ask us to temporarily limit how we use your data.
Right to data portability – Where applicable, you may request to receive your personal data in a machine-readable format or ask us to transfer it to another provider.
Right to object – You can object to how we process your personal data, including for marketing purposes.
Right to withdraw consent – Where we rely on your consent for processing, you can withdraw that consent at any time.
Right to lodge a complaint – You may lodge a complaint with your local data protection authority, such as:
If you're a corporate contact, you can opt out of our direct marketing by following the unsubscribe instructions included in our emails or by contacting us at contact@Clearcue.ai.
3.3. California privacy rights
Under the California Consumer Privacy Act (CCPA), California residents may have additional rights regarding their personal data. These include:
The right to know what personal data we collect, use, or disclose.
The right to request deletion of your personal data.
The right to opt out of the sale or sharing of your data (Clearcue does not sell personal data).
The right to access your data in a portable format.
We do not discriminate against California residents who exercise their rights under the CCPA. For verification, we may ask for basic identifying information such as name and email address. Authorized agents may also submit requests on your behalf.
To make a request, contact hello@clearcue.ai.
4. Safety
We take the protection of your personal data seriously and implement appropriate security measures to reduce the risk of unauthorized access, disclosure, or misuse. While no method of data transmission over the internet or method of storage can be guaranteed to be completely secure, we follow industry best practices to safeguard your information.
Our systems use SSL (Secure Socket Layer) encryption to secure communications and data exchanged during registration, login, and other sensitive operations. Additional safeguards include encryption at rest, firewall protection, strict access controls, and regular system monitoring. Access to personal data is restricted to authorized Clearcue personnel who require it to perform their job duties and are subject to confidentiality obligations.
5. Changes to this policy
Clearcue reserves the right to update or modify this Privacy Policy at any time. Any revisions will become effective once the updated version is published on our website. If we make material changes that significantly impact how we process your personal data, we will notify you in advance—either through the Website or via email, where appropriate.
We encourage you to review this Policy periodically to stay informed of any updates. The version of the Policy available on our website at the time of your visit will be considered the official, complete, and binding version.
6. Limited use disclosure
Clearcue’s access to and use of information obtained from Google APIs complies fully with the Google API Services User Data Policy, including the Limited Use requirements. This means Clearcue does not use Google Workspace APIs to build, train, or enhance generalized AI or machine learning models. Additionally, we do not use these APIs to bypass Gmail protections, such as through email warmup or similar practices.
Any data accessed through Google APIs is used strictly for the purpose of delivering Clearcue’s services to you and may only be transferred to third-party applications as permitted under Google’s Limited Use restrictions.
7. Contacts
If you have any questions, feedback, or concerns regarding this Privacy Policy or how Clearcue handles personal data, please feel free to reach out to us at hello@clearcue.ai