Privacy Policy

This English version is a convenience translation. The German original, available at cluency.ai/datenschutz (viewed with German selected as your language), is the legally binding version in case of any discrepancy.

1. Data Controller

The controller within the meaning of the GDPR is:

GRVITY GmbH
Schauenburgerstr. 116
24118 Kiel
Germany

Email: emilia@cluency.ai
Phone: +49 176 676 431 41

For questions about data protection, you can reach us at: datenschutz@cluency.ai

2. Legal Basis for Processing

We process personal data on the basis of the following legal grounds under the GDPR:

3. Data Collected When Visiting the Website

Server logs

When you visit our website, the following data is automatically stored in server log files: IP address, date and time of access, URL requested, referrer URL, browser, and operating system. This data is stored for a maximum of 30 days and is used exclusively to ensure the security and stability of operations (Art. 6(1)(f) GDPR).

Cookies

We use technically necessary cookies for session management, authentication, and consent status. These cookies are required for the operation of the website and cannot be disabled. In addition, we use analytics cookies for audience measurement (see section 11, Google Tag Manager / Google Analytics). We do not use marketing or retargeting cookies.

4. Registration and User Account

Using Cluency requires creating a user account. In doing so, we collect: email address, name (optional), password (encrypted). This data is processed on the basis of Art. 6(1)(b) GDPR for the performance of the contract and is stored for the duration of the contractual relationship as well as any statutory retention periods.

5. Use of the Cluency Service

Cluency analyzes content you submit (links, videos, documents, voice messages) using AI models and generates summaries and Cheat Sheets from it. In doing so:

6. Third-Party AI Services

To analyze content, anonymized data or data you submit is transmitted to the following AI providers. These providers do not use the data to train their models:

7. Telegram Bot

Cluency offers a Telegram bot. If you use it, your Telegram user ID as well as the content you send are processed. Communication takes place via Telegram's servers (Telegram Messenger Inc., Dubai / Telegram FZ-LLC). Please see Telegram's privacy notice: telegram.org/privacy.

8. Payment Processing

Payments are processed via Stripe (Stripe Inc., USA / Stripe Payments Europe Ltd., Ireland). Stripe is PCI DSS Level 1 certified. We do not store full payment data; only a customer number and subscription ID are stored in our database. Stripe's privacy policy is available at: stripe.com/de/privacy.

9. Hosting

Our website and service are hosted by Vercel Inc. (440 N Barranca Ave #4133, Covina, CA 91723, USA). Vercel is certified under the EU-US Data Privacy Framework. Server locations are in the EU (Frankfurt). More information: vercel.com/legal/privacy-policy.

10. Database Services

User data is stored in a Supabase database (Supabase Inc., USA; server location EU – Frankfurt). Transmission is encrypted via TLS 1.3.

11. Google Tag Manager & Google Analytics

We use Google Tag Manager (Google LLC, USA), through which we embed Google Analytics 4 to statistically evaluate the use of our website (e.g. pages viewed, time spent, visitor origin). This stores cookies on your device and transmits pseudonymized usage data to Google LLC (USA). The legal basis is your consent (Art. 6(1)(a) GDPR), which you may withdraw at any time with future effect. Google Tag Manager and Google Analytics are subject to the EU-US Data Privacy Framework.

12. Newsletter

If you subscribe to our newsletter, we store your email address and your consent (Art. 6(1)(a) GDPR). You can unsubscribe from the newsletter at any time via the unsubscribe link in every email. Delivery is handled via SMTP2GO (EU servers).

13. Data Security

We employ the following technical and organizational measures:

14. Your Rights

Under the GDPR, you have the following rights:

To exercise your rights, please contact: datenschutz@cluency.ai

You also have the right to lodge a complaint with a supervisory authority. The competent authority is the Independent Centre for Data Protection Schleswig-Holstein (ULD), Holstenstraße 98, 24103 Kiel, Germany.

Last updated: May 2025 · Version 1.0