Privacy Policy

Clew AI LTD is the controller of personal information that Clew decides how and why to use through this website and its enquiry process.

We have not appointed a Data Protection Officer. Privacy and data protection queries are handled through the contact details above.

Information you provide through Talk to Clew

When you submit the Talk to Clew form, we collect:

• first and last name;
• email address;
• phone number, if you choose to provide it;
• organisation or company name; and
• the content of your enquiry.

Information you provide through Find Your Route

When you submit Find Your Route, we collect:

• first and last name;
• email address;
• phone number, if you choose to provide it;
• organisation or company name; and
• your answers to the six Find Your Route questions.

The website requires certain fields to be completed before a form can be submitted. Phone number is optional. If you do not provide the required information, the website may not be able to submit your enquiry or assessment.

Information about other people and sensitive information

The website does not ask you to provide special category or other sensitive personal information. Please do not include health information, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, information about sex life or sexual orientation, criminal-offence information, or confidential client information in the website forms unless we have specifically asked you to do so.

Because the Talk to Clew form contains a free-text field, it is possible for a visitor to provide this type of information voluntarily. If we receive sensitive information that we did not request, we will handle it only where permitted by law and will generally delete it where it is not needed for the enquiry.

If you provide personal information about another person, you should make sure that you are entitled to provide it to us and, where appropriate, make this Privacy Policy available to that person.

Technical and operational information

When you access the website, our hosting and infrastructure provider, Lovable, may process operational telemetry and log data associated with end users of published Lovable websites. Depending on the service and configuration, this can include IP address, approximate location derived from IP address, browser type and version, pages or features accessed, timestamps, session or device identifiers, and error or diagnostic information.

Clew has not added Google Analytics, Meta Pixel or another separate advertising analytics service to the website code. We do not use submitted enquiry information for behavioural advertising or visitor profiling.

Where we rely on legitimate interests, those interests include running Clew AI efficiently, responding to relevant business enquiries, maintaining a secure and reliable website, and keeping proportionate records. We consider the necessity of the processing and the impact on the people whose information is involved.

We do not currently use personal information submitted through the website to send marketing communications.

Browser session storage

Clew uses your browser’s sessionStorage to temporarily retain information entered into Find Your Route and Talk to Clew so that you can move between those parts of the website without losing your progress.

This information remains in your browser and is not submitted to Clew until you submit the relevant form. Clew’s website code removes the saved Find Your Route answers and enquiry draft from session storage following a successful submission. We do not use this storage for advertising, analytics or behavioural tracking.

Clew has not intentionally implemented advertising or analytics cookies in the website code. Our hosting provider may use technical or operational mechanisms needed to deliver and secure its service. If Clew enables additional analytics, advertising or non-essential tracking in future, we will update this Privacy Policy and any consent mechanism before or when that processing begins.

Google Fonts

The current website loads typefaces through Google Fonts. When your browser requests the Google Fonts stylesheet and font files, it connects to Google-operated servers. As part of that connection, Google may receive technical information such as your IP address and browser or user-agent information. Clew does not send the contents of your enquiry or Find Your Route answers to Google Fonts.

We disclose personal information only where reasonably necessary for the purposes described in this Privacy Policy, where required by law, or in connection with a genuine corporate transaction. Our principal service providers for the website enquiry flow are:

Our service providers may use their own authorised subprocessors. Where they process personal information on our behalf, we use contractual arrangements designed to require appropriate data protection and security measures. Some providers may also process limited information for their own purposes where they act as an independent controller.

We may also disclose personal information if Clew AI is involved in a merger, acquisition, financing, reorganisation, sale of assets or similar transaction, but only to the extent reasonably necessary and subject to appropriate confidentiality and data-protection safeguards.

We do not sell personal information, and we do not share website enquiry data for cross-context behavioural advertising or targeted advertising.

Some of the providers used to operate the website and handle enquiries operate internationally. Personal information may therefore be processed in the United Kingdom, the European Economic Area, the United States and other countries in which those providers or their authorised subprocessors operate.

Where a transfer from the United Kingdom is a restricted transfer under the UK GDPR, we take steps to ensure that an appropriate transfer mechanism is available. Depending on the recipient and circumstances, this may include UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the European Commission’s Standard Contractual Clauses, or another mechanism permitted by applicable data-protection law.

Where EU GDPR applies to a transfer from the EEA, appropriate safeguards may include an adequacy decision, the European Commission’s Standard Contractual Clauses, or another lawful transfer mechanism.

Lovable’s DPA incorporates the EU Standard Contractual Clauses for relevant EEA transfers and the UK Addendum for relevant UK transfers. Brevo states that its databases are hosted in the European Union, although it and its subprocessors may operate internationally. Microsoft and Google also operate globally.

You can contact us at sobia@clewai.io if you would like more information about the safeguards relevant to a particular transfer.

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, taking account of the nature of the information, the status of the enquiry, applicable legal requirements, and the need to establish, exercise or defend legal claims.

As a working retention rule, an enquiry that does not progress into a client engagement will normally be kept for no longer than 12 months after the last meaningful contact, unless there is a specific legal, regulatory, security or dispute-related reason to keep it for longer. If an enquiry becomes a client engagement, relevant information may become part of the client record and be retained under the arrangements that apply to that engagement.

Browser session data used by Find Your Route and Talk to Clew is removed by Clew’s website code after a successful submission. Technical and security logs held by infrastructure providers may be retained according to their own operational and legal retention schedules.

Clew uses proportionate technical and organisational measures designed to protect personal information. For the current website enquiry flow these include encrypted HTTPS connections, server-side submission handling, server-side input validation, anti-bot controls, protected connector credentials, access-controlled business email, and no separate public-facing database of enquiry submissions.

No internet transmission or information-storage system can be guaranteed to be completely secure. If you believe that personal information you have provided to Clew has been compromised, please contact us promptly.

Depending on the law that applies and the circumstances, you may have rights to:

• ask whether we process your personal information and obtain a copy of it;
• ask us to correct inaccurate or incomplete information;
• ask us to erase information in certain circumstances;
• ask us to restrict processing in certain circumstances;
• receive certain information in a portable format where the right to data portability applies;
• object to certain processing; and
• withdraw consent at any time where we rely on consent for a particular activity.

Your right to object

You have the right to object to processing that we carry out on the basis of legitimate interests. If you object, we will stop that processing unless we can demonstrate compelling legitimate grounds to continue or the processing is needed for the establishment, exercise or defence of legal claims.

You may object at any time to the use of your personal information for direct marketing. Clew does not currently use information submitted through the website forms for direct marketing.

Rights are not absolute and can be subject to legal exceptions. To make a request, email sobia@clewai.io or use Talk to Clew and state that your message concerns a privacy or data-protection request. We may need to verify your identity before acting on a request. We will respond within the timescales required by applicable law.

Find Your Route is a structured questionnaire. Clew does not use an AI model to score, diagnose or profile visitors from their answers, and the responses are reviewed by a person for the purpose of informing an initial conversation.

Clew does not use personal information submitted through this website to make solely automated decisions that produce legal or similarly significant effects.

If you are concerned about how Clew has handled your personal information, you can make a data-protection complaint by emailing sobia@clewai.io or by using Talk to Clew and clearly stating that your message is a data-protection complaint.

We will acknowledge a data-protection complaint within 30 days of receiving it. We will take appropriate steps to investigate the complaint without undue delay, keep you informed where appropriate, and communicate the outcome without undue delay.

If you are in the United Kingdom and remain dissatisfied, you also have the right to complain to the Information Commissioner’s Office (ICO), the UK’s data-protection supervisory authority. You can find current complaint routes and contact details on the ICO website.

This website and Clew’s services are intended for business and professional users and are not directed at children under 18. We do not knowingly seek to collect personal information from children through the website. If we learn that we have received personal information from a child in circumstances where it should not have been collected, we will take appropriate steps to delete it.

Privacy and data-protection rights can vary by location. Where the EU GDPR, Swiss data protection law, Canadian privacy law, or a US state privacy law applies to Clew’s processing of your personal information, we will provide the rights and protections required by that law.

Depending on the applicable law, those rights can include access, correction, deletion, portability, information about disclosures, and rights relating to certain sales, sharing, targeted advertising or profiling. Clew does not sell personal information, does not share website enquiry data for cross-context behavioural advertising, and does not use website enquiry data for targeted advertising or significant profiling.

Where applicable law allows you to use an authorised agent, we may ask for evidence of that authority and may take reasonable steps to verify the request.

We may update this Privacy Policy when our services, website technology, providers or legal obligations change. The date at the top of the policy will show when it was last updated.

Where a change materially affects how we use personal information, we will take appropriate steps to bring the change to the attention of affected individuals before or when the new processing begins, where required.

For privacy questions, rights requests or data-protection complaints: