Privacy Policy

Last updated: Sep 1, 2026
  • Cliarly ApS
  • Vestergade 12, 3. sal
  • 1456 København K
  • CVR: 44537249

If you have questions regarding the processing of Personal Data, you can contact us via e-mail: support@cliarly.com.

This Privacy Policy describes how Cliarly collects, processes, discloses, and protects the Personal Data that can directly or indirectly identify you as a user (hereinafter "Personal Data").

1. Data Controller vs. Data Processor

When you, as a private individual, create an account and purchase a subscription with Cliarly, Cliarly is the Data Controller for the processing of your Personal Data in accordance with this Privacy Policy.

If you access Cliarly through your school, educational institution, or workplace (B2B/Organization), your institution is the Data Controller. In these cases, Cliarly acts solely as a Data Processor on behalf of the institution, and our processing may be regulated by a separate Data Processing Agreement (DPA) entered into between Cliarly and the institution.

2. What Personal Data do we process?

Cliarly processes both information you provide us and information we collect automatically:

  • Account data: Name, email address, and payment status.
  • Technical data: Information about your device, IP address, browser data, page view statistics, and your use of our services (collected, among other things, via GA4 and Google reCAPTCHA).

2.1 Specifically regarding the processing of your content (text and audio):

For Cliarly to provide the reading and writing tool, the content you process (text, audio recordings by dictation, or screen excerpts by OCR) is transferred encrypted to our secure servers in the EU/EEA.

All processing of this content occurs solely within the session to perform the function. We do not store your content after processing, nor is your content ever used to train our own or others' models.

3. Purpose and legal basis for processing

To comply with applicable data protection legislation (GDPR), your Personal Data is only processed on a lawful basis for the following purposes:

  • Delivery of our services (GDPR Art. 6, para. 1, litra b - fulfillment of contract): To give you access to the website, create your profile, and provide our software functions.
  • Security and optimization (GDPR Art. 6, para. 1, litra f - Legitimate interest): To administer, secure, and develop our platform, e.g., by preventing misuse, troubleshooting the system, and tracking statistics on the use of our services.
  • Marketing and newsletters (GDPR Art. 6, para. 1, litra a) - Consent): To send you emails with offers, news, and updates if you have actively consented to this.
    • If you are already a paying customer, we may send you relevant information about similar products based on our legitimate interest and applicable marketing legislation. You can always unsubscribe.
  • Legal requirements (GDPR Art. 6, para. 1, litra c) - Legal obligation): To store billing data in accordance with the Danish Bookkeeping Act or to comply with requests from public authorities.

4. Disclosure of Personal Data and recipients

Cliarly neither sells nor rents your Personal Data to third parties. To operate our business and deliver our services, we only share necessary data with the following categories of recipients (sub-processors):

  • Cloud and hosting providers: For secure storage of data and operation of our platform.
  • IT and analytics systems: Tools for customer support, email sending, payment processing, and statistics (e.g., Google Analytics and reCAPTCHA).
  • Payments are processed by our secure payment provider Stripe, and Cliarly therefore does not store your full credit card information.

All our sub-processors are subject to strict data processing agreements and confidentiality requirements. If data is transferred outside the EU/EEA, we always ensure that it occurs on a lawful transfer basis (e.g., EU-U.S. Data Privacy Framework).

A complete and updated list of our sub-processors can be requested at any time by contacting us, and it is also included in our Data Processing Agreement (DPA) for organizations.

5. Security and Confidentiality

Your security is of paramount priority to us. Everything you write, read, dictate, or upload (e.g., images and PDF files) to Cliarly is considered strictly confidential and is processed exclusively on servers within the EU/EEA.

To provide a secure and stable login system that allows login via, for example, Google and Microsoft, we use a recognized Google-based login infrastructure. This means that only your basic profile information (your email address and your name) may be processed on servers in the USA. This specific processing is legally secured through the EU-US Data Privacy Framework.

Our systems ensure full encryption of all data traffic and encryption of data at rest to prevent unauthorized access or misuse of your personal data. We also use secure open-source frameworks with security controls. In addition, our cloud providers use recognized physical, technical, and organizational security measures, such as security guards, fencing, and access control systems. These measures are supplemented by advanced intrusion detection technology and continuous security monitoring to maintain a secure infrastructure.

You are responsible for keeping your password secret and securing your own account against unauthorized access. It is also not permitted to share your password with others, as the account is private and may only be used by the individual user and not shared with others.

6. Storage and Deletion

We only store your Personal Data for as long as necessary to fulfill the purposes for which it was collected. When you delete your account, your data will be deleted or anonymized as soon as possible, and no later than within 30 days.

However, information related to payment and invoicing will be stored for up to 5 years from the end of the financial year to which it relates, in compliance with the Danish Bookkeeping Act.

9. Your Rights

In accordance with the General Data Protection Regulation (GDPR), you have a number of rights in relation to our processing of your data:

  • Right to access: You have the right to be informed about what data we process about you.
  • Right to rectification: You have the right to have incorrect information corrected.
  • Right to erasure: In certain cases, you have the right to have your information deleted before our normal deletion period.
  • Right to restriction: In certain cases, you have the right to have the processing of your information restricted.
  • Right to data portability: You have the right to receive your data in a structured, machine-readable format.
  • Right to object: You can object to our processing of your data for direct marketing at any time.
  • Right to withdraw consent: If our processing is based on your consent, you can withdraw it at any time.

Please note that we do not make automatic decisions or profiling that have legal or similar significance for you.

If you wish to exercise your rights, please contact us at support@cliarly.com.

8. Cookies

We use cookies on the website to ensure functionality, collect statistics, and target our communication. You can read more about our use of cookies and change your consent in our Cookie Policy.

9. Contact

In accordance with GDPR, we have assessed the requirement to have a DPO. Since our core activity is solely to provide a reading and writing tool, and we do not carry out systematic monitoring or large-scale processing of sensitive personal data, we are not legally obliged to have a DPO.

If you, as a user, IT administrator, or partner, have questions about our processing of Personal Data, you are always welcome to contact us at:

Email: support@cliarly.com

10. Complaint to the Danish Data Protection Agency

If you are dissatisfied with the way we process your Personal Data, you have the right to file a complaint with the Danish Data Protection Agency. You can find the Danish Data Protection Agency's contact information at www.datatilsynet.dk.

We reserve the right to update this privacy policy continuously. Significant changes to the policy will be communicated directly to our users.