Privacy Policy

Validity Date: September 26, 2025

At Clariteer, we take your privacy seriously and are committed to protecting your Personal Data. This Privacy Policy explains how we handle your Personal Data, outlines your privacy rights, and describes how the applicable law protects you. 

Please refer to the Glossary at the bottom of the Privacy Policy to understand the meaning of any defined terms used. 

Clariteer SA/NV, a public limited liability company having its seat at Rue de Rome 9/3-4, 1060 Saint-Gilles and registered with the Register of Legal Entities of Brussels (and VAT authorities) under the number 1026.204.174 is the Controller responsible for processing your Personal Data.

If you have any general questions or concerns about this Privacy Policy or our processing of your Personal Data, you can contact us at hello@clariteer.com.  

We may collect, use, store, and transfer one or more types of Personal Data about you, depending on the nature of your interaction with us. We do not collect any Special Categories of Personal Data about you. 

We use various methods to collect Personal Data from and about you, including through the following:

• Direct interactions - You may provide Personal Data to us by filling in forms or by corresponding with us by phone, email, or otherwise. This includes data you provide when you create an account, contact us, complete surveys, participate in events, engage with our customer service and support, or interact with us for business development purposes.
• Automated technologies or interactions - We may collect Technical Data about your browsing actions and usage patterns as you interact with our Online Services, but only where you have provided your consent. This data may be collected using cookies, pixel tags, server logs, and other similar technologies. For more details, please refer to Cookie Policy.
• Third parties or publicly available sources – We may receive Personal Data about you from external sources, such as business partners or services. This includes data obtained from publicly available and third-party databases or services, which we use to supplement the information we collect directly.

Below, we outline the ways in which we use your Personal Data, along with the legal bases we rely on to do so. Please note that we may Process your Personal Data under more than one Lawful Basis, depending on the specific purpose for which it is being used. For more details about the Lawful
Bases we rely on, please refer to the Glossary section.

When you sign in to Clariteer using your Google account, or when you grant us access to your Google data through OAuth, we may access certain information from your Google account, depending on the permissions you grant.

• Data Accessed: Basic profile information: name, email address, and profile picture (via Google Sign-In).
• Data Usage: We use the accessed Google data only to (1) authenticate your identity and allow you to log into our application and (2) display your name, email address, and profile picture within your account. We do not use Google user data for advertising or marketing purposes without your explicit consent.
• ‍Data Sharing: We do not share Google user data with third parties except as required to operate our services (for example, cloud hosting or authentication providers listed above), and only in compliance with this Privacy Policy.
• ‍Data Storage & Protection: Google user data is stored securely on our servers hosted on Microsoft Azure. Access is restricted to authorized personnel only and is protected by industry-standard encryption in transit and at rest.
• ‍Data Retention & Deletion: We retain Google user data only for as long as necessary to provide our services to you. If you choose to disconnect your Google account or request deletion, we will delete all associated Google user data from our systems. You can request deletion at any time by contacting us at hello@clariteer.com.

8. CHANGE OF PURPOSE

We will only use your Personal Data for the purposes for which it was collected, unless we reasonably determine that a different use is compatible. If we ever need to use your Personal Data for an unrelated purpose, we will notify you and explain the legal basis for doing so. 

In limited cases, we may Process your Personal Data without your knowledge or consent, but only where required or permitted by law and always in accordance with our legal obligations and data protection responsibilities.

We may transfer your Personal Data outside the European Economic Area (EEA) or the United Kingdom (UK) to third-party service providers based in other countries.

Where such transfers are to countries that do not offer an adequate level of data protection under applicable laws, we implement appropriate safeguards, such as the European Commission’s Standard Contractual Clauses or other approved mechanisms, to ensure your data remains protected.

We have implemented appropriate technical and organisational security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered, or disclosed.

In addition, we limit access to your Personal Data to those employees, agents, contractors, and other third parties who have a business need to know. They will only Process your data on our instructions and are subject to a duty of confidentiality.

We have procedures in place to deal with any suspected Personal Data breach or incident and will notify you and any applicable regulator of a breach where we are legally required to do so.

We retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, provide our Services, comply with legal obligations, resolve disputes, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

To determine the appropriate retention period, we consider the type and sensitivity of the data, the purpose for Processing, potential risks, and legal requirements.

Where Personal Data is no longer needed, we will securely delete or anonymise it. In some cases, we may retain anonymised data for analytical or statistical purposes indefinitely.

You have the following rights in relation to your Personal Data, subject to certain conditions under applicable data protection laws:

1. Access – You have the right to request information about how we Process your Personal Data and to access the Personal Data we hold about you.
2. Correction – You may request the correction of inaccurate Personal Data we hold about you.
3. Erasure – You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, or where you have withdrawn consent or successfully objected to Processing, in accordance with applicable law. This includes the right to request the deletion of any Google user data you have authorized us to access through OAuth.
4. Restriction – You may request that we suspend the Processing of your Personal Data in certain circumstances. In such cases, we will only retain the data for the exercise or defence of legal claims.
5. Portability – You may request to receive your Personal Data in a structured, commonly used, and machine-readable format, and to have that data transmitted to another party, where technically feasible.
6. Object/Withdrawal of consent - You may object to the Processing of your Personal Data where we rely on legitimate interest or withdraw your consent at any time where Processing is based on consent.

The exercise of some of these rights (in particular the rights to erasure, restriction of Processing, or objection) may prevent Clariteer from being able to provide all or part of the Services, including paid Services, where the Processing of Personal Data is strictly necessary for the performance of the contract.

Our Online Services may contain links to third-party websites or applications, and other websites or applications may link to ours. These third-party services are not under our control, and we are not responsible for their content or privacy practices. We encourage you to review the privacy policies of any third-party websites of applications you visit or interact with. 

For more information about the cookies we use, please refer to our Cookie Policy.

We may update this Privacy Policy from time to time at our sole discretion. If we make any material changes, we will notify you in accordance with applicable legal requirements. By continuing to use our Online Services after any updates take effect, you acknowledge and agree to the revised Privacy Policy.

• Data Protection Legislation means any applicable data privacy laws and regulations, including, but not limited to, the General Data Protection Regulation (EU) 2016/679 (“GDPR) and any other applicable data protection laws in the jurisdiction where the Parties operate. 
• Google User Data means any information obtained from a user’s Google account through the Google APIs (such as Google Sign-In, Gmail, Drive, or Calendar), subject to the Google API Services User Data Policy.
• Lawful Basis/Bases means the legal grounds on which we are permitted to Process your personal data under Data Protection Legislation. 
• Online Services refers to all digital services provided by us, including our private equity investment management application (the “Application”) and our website, whether accessed via desktop, mobile, or other devices.
• Personal Data - means any information about an individual from which that person can be identified. It does not include where the identity has been removed (i.e. anonymised data). 
• Process/Processing – means any operation or set of operations performed on Personal Data, whether or not by automated means. This includes collection, use, storage, disclosure, transfer, or deletion of Personal Data.