Privacy Policy
Last Updated: April 20, 2025
This Privacy Policy ("Privacy Policy") explains how Cluely Inc. ("Cluely," "we," "us," "our") collects, uses, shares, and protects user ("you," "your") Personal Information when you use our desktop application and related services (collectively, the "Services"). "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.
Please read this Privacy Policy carefully. By using our Services, you agree to the processing of your information in accordance with this Privacy Policy.
1. Personal Information We Collect
1.1 Types of Personal Information Collected
Depending on how you interact with our Services, we may collect the following information:
- Personal identifiers and contact information, such as your name, email address, phone number, and any other information you submit through our Services.
- Account information used to create your online account (e.g., username and password).
- Communications between you and us. When you communicate with us, we may collect and save a record of your communication and any Personal Information provided during the communication.
- Screen and audio data including visual data from your screen captures and audio inputs that you permit our application to access for the purpose of providing real-time assistance.
- Billing and financial information when you purchase our Services (e.g., billing contact name, billing address, payment details including credit card information, and your purchase history).
1.2 Sources of Personal Information
We collect Personal Information from various sources including:
- Directly from you when you register for an account, make a purchase, or use our Services
- Automatically through your use of our desktop application
- From your device when you provide screen and audio access permissions
2. How We Use Personal Information
We use the Personal Information we collect for the following purposes:
- Provide and improve our Services: To deliver the Services you request, process transactions, maintain your account, and improve our Services' functionality and user experience.
- Real-time assistance: To analyze your screen and audio inputs to provide contextual responses and support during interviews, meetings, sales calls, and other situations where you use our Services.
- Service personalization: To personalize your experience with our Services and deliver content relevant to your interests.
- Customer support: To respond to your inquiries, provide technical assistance, and resolve issues.
- Analytics and research: To understand how users interact with our Services, identify usage trends, and develop new features.
- Marketing and communications: To send you updates about our Services, provide information about products and services that may interest you, and communicate about your account or transactions.
- Security and fraud prevention: To verify accounts, prevent fraudulent transactions, monitor for and address unauthorized activities, and enforce our Terms of Service.
- Legal compliance: To comply with applicable legal requirements, industry standards, and our policies.
3. Disclosure of Personal Information
3.1 Service Providers
We may disclose Personal Information to third-party service providers who perform services for us, such as hosting providers, payment processors, customer support providers, analytics services, and other similar service providers. These service providers are contractually obligated to use your Personal Information only to provide services to us and in accordance with our instructions.
3.2 Business Transfers
If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of our business or assets, your Personal Information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your Personal Information.
3.3 Legal Requirements
We may disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency). We may also disclose your Personal Information when we believe in good faith that disclosure is necessary to:
- Comply with a legal obligation
- Protect and defend our rights or property
- Prevent or investigate possible wrongdoing in connection with the Services
- Protect the personal safety of users of the Services or the public
- Protect against legal liability
4. Cookies and Tracking Technologies
4.1 What Are Cookies
Cookies are small text files that are placed on your device by websites you visit. They are widely used to make websites work more efficiently and provide information to the website owners. We use cookies and similar technologies (such as web beacons and pixels) to collect information about your browsing activities and to distinguish you from other users of our Services.
4.2 Types of Cookies We Use
We use the following types of cookies:
- Essential cookies: Necessary for the operation of our Services. They enable core functionality such as security, account authentication, and remembering your preferences.
- Analytical/performance cookies: Allow us to recognize and count the number of visitors and see how visitors move around our Services.
- Functionality cookies: Used to recognize you when you return to our Services. This enables us to personalize our content for you and remember your preferences.
- Targeting cookies: Record your visit to our Services, the pages you have visited, and the links you have followed.
5. Security of Your Personal Information
We implement appropriate technical and organizational measures to protect your Personal Information against unauthorized or unlawful processing, accidental loss, destruction, or damage. However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
6. Your Privacy Rights
Depending on your location, you may have certain rights regarding your Personal Information:
- Access and Portability: Request access to and receive a copy of your Personal Information.
- Correction: Request correction of inaccurate or incomplete Personal Information.
- Deletion: Request deletion of your Personal Information, subject to certain exceptions.
- Restriction of Processing: Request restriction of processing under certain circumstances.
- Objection to Processing: Object to processing based on legitimate interests.
- Withdrawal of Consent: Withdraw consent where processing is based on consent.
7. Notice to California Residents
If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with specific rights regarding your Personal Information. We do not sell your Personal Information as defined under the CCPA/CPRA or share it for cross-contextual behavioral advertising purposes.
8. Notice to Users Outside the United States
Our Services are hosted in the United States. By using our Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Policy.
9. Data Retention
We retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it, including legal, accounting, or reporting requirements. When we no longer need to retain your Personal Information, we will securely delete or anonymize it.
Important Notice Regarding Audio Recording:
When Cluely captures audio during meetings, this process may be considered "recording" under various state and federal laws. Several U.S. states and other jurisdictions have enacted "two-party consent" or "all-party consent" laws that require you to obtain consent from all parties before recording conversations.
To use Cluely in compliance with these laws:
- You must inform all meeting participants that the conversation is being captured by Cluely
- You must obtain consent from all participants before enabling Cluely's audio features
- If any participant does not consent, you must disable Cluely's audio capture functionality
10. Children's Privacy
Our Services are not directed to children under the age of 13, and we do not knowingly collect Personal Information from children under 13. If we learn that we have collected Personal Information of a child under 13, we will take steps to delete such information from our files as soon as possible.
11. Links to Other Websites and Services
Our Services may contain links to other websites and services that are not operated by us. This Privacy Policy does not apply to third-party websites or services. We recommend that you review the privacy policies of any third-party websites or services that you visit or use.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. The date at the top of this Privacy Policy indicates when it was last updated. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting your Personal Information.
13. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:
Cluely Inc.
Email: [email protected]