PRIVACY POLICY

Effective Date: January 15, 2026
Scope: Claruma Platform (Global)

1. INTRODUCTION AND DEFINITION OF ROLES

Claruma ("We", "Us") takes your privacy seriously. To understand how we handle data, you must distinguish between our two legal roles under international data protection standards:

• Claruma as CONTROLLER: We act as the Data Controller for your account information (email, password hash, billing details) and technical security logs required to maintain the platform's integrity.
• Claruma as PROCESSOR: We act strictly as a Data Processor regarding the content of your presentations and the data of your audience. We do not own, scrape, or independently monetize the audience data generated within your sessions.

2. DATA WE COLLECT

2.1 Account Data (Controller)

When you register, we collect your email address, name, and encrypted password. If you upgrade to a paid tier, our third-party Merchant of Record (MoR) collects billing information. Claruma does not store raw credit card numbers.

2.2 Usage and Security Data (Controller)

We collect technical metadata such as IP addresses, User Agent strings, and interaction logs. This data is strictly used for security purposes (e.g., preventing voting fraud, DDoS protection) and platform optimization.

2.3 Presentation Data (Processor)

Content you upload (slides, images, text) remains your property. We store it solely to deliver the Service.

3. NO DATA BROKERAGE & MARKETING POLICY

We do not sell data to third parties.

Claruma does NOT sell, rent, or lease user lists, audience voting habits, or device fingerprints to data brokers. We do not build "shadow profiles" for third-party profit.

Internal Retargeting: Claruma reserves the right to use tracking technologies (such as pixels) to build profiles for our own marketing purposes. This means if you interact with Claruma, you may subsequently see advertisements promoting Claruma services on other platforms. This data is siloed and used solely to market Claruma to you, not to sell your profile to others.

4. INTERNATIONAL DATA TRANSFERS

Claruma operates primarily from servers located in the Americas. By using the Service, you acknowledge and consent that your data may be transferred to, stored, and processed in jurisdictions that may not have data privacy laws equivalent to those in your home country (e.g., GDPR in Europe). We implement technical safeguards to protect your data during transit and rest.

5. DATA RETENTION & "RIGHT TO BE FORGOTTEN"

We implement a strict deletion policy upon account termination:

• Active Accounts: We retain your data for as long as your account is active to provide the Service.
• Deleted Accounts (Technical Erasure): Upon your request for deletion, a specialized process runs to ensure the "Right to be Forgotten".
  • Analytics Data: All behavioral and analytics data is permanently deleted.
  • Presentation Content: Your slides and user-generated content are cryptographically hashed or securely destroyed, rendering them technically unrecoverable and useless.
  • Personal Identifiers: Your email and profile data are anonymized in our operational databases.
• Legal Exception (Billing): We are legally required to retain billing and transaction records for a minimum of 7 years by tax authorities. These records remain in our isolated financial systems strictly for compliance and are not used for platform operations or marketing.

6. YOUR RIGHTS

Depending on your jurisdiction, you may have the right to access, correct, or delete your personal data. To exercise these rights, please contact our Legal Team at [email protected].