DRAFT — Pending Attorney Review & Finalization · Not legally effective until published with an effective date
Legal · Clenta, Inc.

Privacy Policy

Version 0.1 Last updated: May 25, 2026 Effective: Pending

Contents

  1. Information We Collect
  2. How We Use Your Information
  3. How We Share Your Information
  4. Data Retention
  5. Cookies and Tracking Technologies
  6. Your Privacy Rights
  7. Security
  8. Children's Privacy
  9. Links to Other Websites
  10. Changes to This Policy
  11. Contact Us

Clenta, Inc. ("Clenta," "we," "our," or "us") operates the website at clenta.ai and the Iris mobile application (iOS and Android). This Privacy Policy explains how we collect, use, disclose, and protect personal information about you when you visit our website, join our waitlist, or use our products.

About end-client data: This policy does not cover how our business customers (retailers and operators) use Iris to manage their own client relationships. That data processing is governed by the Clenta Data Processing Agreement. Clenta processes that data as a service provider on behalf of its business customers.

Section 1 — Information We Collect

1.1 Website Visitors (clenta.ai)

When you visit clenta.ai, we may collect:

1.2 Waitlist and Access Request Submissions

When you submit your email address to join our waitlist or request early access, we collect:

This information is used solely to contact you about product updates and access. We do not sell or share it with third parties for their marketing purposes.

1.3 Account Users (Associates, Managers, Administrators)

When you create a Clenta account or are added by your employer, we collect:

1.4 Payment Information

Billing and payment are handled by Stripe. Clenta does not store credit card numbers or full payment card data. We receive transaction-level information such as invoice amounts, payment dates, and subscription status. Stripe's privacy policy is available at stripe.com/privacy.

Section 2 — How We Use Your Information

We use the information we collect to:

We do not:

Section 3 — How We Share Your Information

3.1 Within your organization

If your employer has provisioned a Clenta account, your name, role, and email may be visible to your organization's administrators. Individual Iris conversations are visible only to you and your organization's administrators on applicable plans.

3.2 Service providers

We share personal information with third-party service providers who process data on our behalf under written agreements requiring appropriate data protection. Our current service providers include:

ProviderPurposeLocation
SupabaseDatabase, authentication, and infrastructureU.S. (AWS us-east-1)
AnthropicAI model powering Iris (zero data retention per API terms)U.S.
HetznerAgent runtime infrastructureGermany (EU)
StripePayment processingU.S.
Apple / Expo Application ServicesApp distribution and build infrastructureU.S.

3.3 Legal requirements

We may disclose personal information if required by law, court order, or governmental authority, or if we believe disclosure is necessary to protect rights, safety, or security.

3.4 Business transfers

If Clenta is acquired or merged with another company, your personal information may be transferred as part of that transaction. We will notify you of any such transfer and the applicable privacy policy going forward.

Section 4 — Data Retention

Data typeRetention period
Waitlist email addressesUntil you unsubscribe or request deletion, or 24 months from collection if no account is created
Account informationFor the duration of your account, plus 30 days after account closure
Iris conversation and log dataFor the duration of the organization's subscription (per the DPA)
Server access logs90 days
Payment records7 years (legal/tax obligation)
Backup copiesDeleted within 90 days of the applicable deletion trigger

Section 5 — Cookies and Tracking Technologies

5.1 Current cookie use

Clenta currently uses only strictly necessary cookies — session tokens required to keep you authenticated in the application. These cookies are essential for the application to function.

We do not currently use:

5.2 Future cookies

If and when Clenta introduces analytics or other non-essential cookies, we will update this Privacy Policy with at least 30 days' notice, implement a cookie consent banner on clenta.ai, and provide controls to accept or reject non-essential cookies.

Section 6 — Your Privacy Rights

6.1 All users

Regardless of your location, you may request to access, correct, delete, or export the personal information we hold about you. Contact us at privacy@clenta.ai to make a request. We will respond within 30 days.

6.2 California residents (CCPA/CPRA)

If you are a California resident, you have the right to know what personal information we collect and how we use it, request deletion, opt out of the "sale" or "sharing" of your personal information (we do not sell or share), and not be discriminated against for exercising your rights.

Clenta does not sell personal information. To submit a California privacy request, contact privacy@clenta.ai.

6.3 EEA, UK, and Swiss residents (GDPR / UK GDPR)

If you are located in the European Economic Area, United Kingdom, or Switzerland, you have rights under the GDPR and UK GDPR, including the right to access, rectify, erase, restrict, and port your personal data, and to object to processing based on legitimate interests.

Legal basis for processing: We process account user data on the basis of contract performance. We process waitlist data on the basis of legitimate interests. We process server logs on the basis of legitimate interests (security and debugging).

You have the right to lodge a complaint with your local data protection authority. In the UK, that is the ICO (ico.org.uk).

Where personal data is transferred from the EEA or UK to the U.S. or other third countries, such transfers are subject to Standard Contractual Clauses or other appropriate safeguards.

To exercise your GDPR rights, contact privacy@clenta.ai.

Section 7 — Security

We implement appropriate technical and organizational measures to protect your personal information, including AES-256 encryption at rest, TLS 1.2+ in transit, row-level database security isolating each organization's data, and JWT-based authentication.

No security measure is 100% effective. If you believe your account has been compromised, contact us immediately at privacy@clenta.ai.

Section 8 — Children's Privacy

The Services are not directed to individuals under the age of 16, and we do not knowingly collect personal information from anyone under 16. If we learn that we have collected personal information from a child under 16, we will delete it promptly.

Section 9 — Links to Other Websites

clenta.ai may contain links to third-party websites. This Privacy Policy does not apply to those sites. We encourage you to review the privacy policies of any third-party sites you visit.

Section 10 — Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will post the updated policy with a new "Last Updated" date and notify account users via email or in-app notification at least 30 days before material changes take effect.

Section 11 — Contact Us

For privacy-related inquiries, data access requests, or to exercise your rights:

Email: privacy@clenta.ai
Mail: Clenta, Inc., [REGISTERED ADDRESS PENDING C CORP COMPLETION]

We aim to respond to all requests within 30 days.