Privacy Policy

This Privacy Policy explains how Happy Data GmbH ("Happy Data", "Claro", "we", "us") collects and processes personal data in connection with getclaro.ai, our business activities and the Claro platform.

Claro is a product of Happy Data GmbH.

1. Who we are

The controller responsible for the processing described in this Privacy Policy is:

Commercial Register: Amtsgericht Charlottenburg, HRB 260319 B
VAT ID: DE365722845
Email: hello@getclaro.ai

2. What this Privacy Policy covers

This Privacy Policy applies where Happy Data GmbH acts as a data controller, including when we process personal data relating to:

• visitors to our website;
• people who contact us, request a demo or submit a file for evaluation;
• prospective customers and business contacts;
• customer representatives;
• partners and suppliers;
• authorised users of the Claro platform.

Customers may also use Claro to process data under their own control.

Where we process personal data contained in customer data on behalf of a customer, we act as a processor and process that data in accordance with the applicable customer agreement and Data Processing Addendum.

This Privacy Policy does not replace those agreements.

3. Personal data we collect

Depending on your interaction with Claro, we may process:

Contact and professional information

Your name, business email address, telephone number, company, role, professional profile and other business contact information.

Communications

Information contained in emails, forms, meeting requests, support requests and other communications with us.

Account and usage information

Where you use the Claro platform, we may process account identifiers, authentication information, workspace information, access records and information about your use of the service.

Technical and website information

This may include your IP address, browser and device information, operating system, pages viewed, timestamps, referral information and similar technical information.

Information collected through cookies and similar technologies is described in our Cookie Policy.

Business information from public sources

For business development purposes, we may obtain professional contact information from publicly available sources such as company websites, professional networking platforms, business directories and event information.

We do not intentionally request special categories of personal data through our website or for ordinary business-development activities.

4. Why we process personal data

We process personal data for the following purposes.

Responding to enquiries and demo requests

To respond to your communications, arrange demonstrations, assess potential projects and provide information you request.

Legal basis: taking steps at your request before entering into a contract and/or our legitimate interest in responding to business enquiries.

Managing customer and business relationships

To negotiate agreements, manage customer and partner relationships, administer accounts, provide support, communicate about projects and manage our commercial operations.

Legal basis: performance of a contract where applicable and our legitimate interests in managing relationships with organisations and their representatives.

Operating and securing Claro

To provide access to our services, authenticate users, maintain reliability, prevent misuse, investigate incidents and protect our systems and users.

Legal basis: performance of a contract where applicable, our legitimate interests in operating and securing our services, and compliance with legal obligations where relevant.

Business development

To identify organisations and professionals for whom Claro may be relevant and communicate with them about our services where permitted by applicable law.

Legal basis: our legitimate interests in developing our B2B business. Where consent is required for a particular communication or technology, we rely on consent.

You may object to direct marketing at any time.

Website analytics and improvement

To understand how our website is used, diagnose issues and improve our content and user experience.

Where applicable, optional analytics or similar technologies are activated only in accordance with your cookie choices.

Legal basis: consent where required and, where permitted, our legitimate interests in improving our services.

Legal and regulatory obligations

To comply with accounting, tax, regulatory and other legal requirements and to establish, exercise or defend legal claims.

Legal basis: compliance with legal obligations and our legitimate interests in protecting our legal rights.

5. Files and information submitted to Claro

If you submit a supplier file, catalog extract or other material to us for a demo, audit or evaluation, we use that material to provide the evaluation you requested and to communicate with you about the result.

Please only provide information that you are authorised to share.

Where a separate confidentiality agreement, customer agreement or Data Processing Addendum applies, that agreement governs our use of the relevant customer information.

6. AI and automated processing

Claro uses internally developed software, workflow orchestration, machine-learning technologies and third-party model inference as part of its services.

AI-assisted processing may support activities such as:

• extraction;
• matching;
• classification;
• enrichment;
• data validation;
• workflow automation.

Customer workflows are designed around bounded, task-specific processing.

Depending on the workflow, controls may include:

• structured input and output schemas;
• deterministic validation;
• context separation;
• confidence assessment;
• source provenance;
• exception handling;
• human review.

Claro retains control of the workflow, validation logic and processing rules surrounding model inference.

Where third-party providers process customer data on our behalf, they are engaged subject to appropriate contractual, security and data-protection obligations.

Customer data is not used to train shared or third-party general-purpose AI models unless explicitly agreed with the customer.

Access to customer data is restricted according to operational need and least-privilege principles.

Claro does not use personal data to make solely automated decisions about individuals that produce legal or similarly significant effects.

7. Service providers and subprocessors

We may disclose personal data where necessary to providers supporting our business and services, including:

• cloud infrastructure and hosting providers;
• communication, scheduling and collaboration services;
• CRM and business operations tools;
• analytics and monitoring providers;
• AI and automation service providers;
• security providers;
• professional advisers such as lawyers, accountants and auditors;
• authorities where disclosure is required by law.

Providers processing customer data on our behalf are subject to appropriate contractual, confidentiality, security and data-protection obligations.

We assess the role, data access and processing location of material service providers used in customer-data workflows.

Material changes to subprocessors or processing locations involving customer data are managed in accordance with the applicable customer agreement and Data Processing Addendum.

We do not sell personal data.

8. International data transfers and data location

Our core platform infrastructure is hosted in the European Union.

Customer-data processing locations may depend on the services and subprocessors used for the applicable workflow and are governed by the applicable customer agreement and Data Processing Addendum.

Some service providers supporting our business may process personal data outside the European Economic Area.

Where personal data is transferred outside the EEA, we use appropriate safeguards required by applicable data-protection law, including where applicable:

• adequacy decisions;
• European Commission Standard Contractual Clauses;
• other legally recognised transfer mechanisms.

9. Data retention

We retain personal data only for as long as necessary for the purposes for which it was collected and to meet applicable legal, contractual, accounting and security requirements.

In general:

• prospect and business-contact information may be retained for up to 24 months from the last meaningful interaction;
• direct-marketing data is removed or suppressed when you object or unsubscribe;
• account and customer relationship information is retained for the duration of the relevant relationship and for any additional period required by law;
• information required for legal claims or compliance may be retained for the applicable statutory period.

Customer data processed as part of a Claro service is retained in accordance with the applicable customer agreement, Data Processing Addendum or agreed retention schedule.

Where possible, data that is no longer required is deleted or anonymised.

10. Cookies and similar technologies

We use cookies and similar technologies to operate our website and, where enabled, understand its use.

Essential technologies are always active. Functional (analytics) and marketing technologies are switched off until you enable them in the cookie card shown on your first visit, and you can change or withdraw that choice at any time through the Cookie preferences link in the footer. Cookies already present from an earlier version of this website are not treated as consent.

More information, including the technologies currently in use, is available in our Cookie Policy.

11. Your rights

Subject to applicable law, you may have the right to:

• request access to your personal data;
• request correction of inaccurate or incomplete data;
• request deletion of your personal data;
• request restriction of processing;
• receive certain data in a portable format;
• object to processing based on legitimate interests;
• object at any time to processing for direct marketing;
• withdraw consent at any time where processing is based on consent.

You also have the right to lodge a complaint with a competent data-protection supervisory authority.

To exercise your rights, contact hello@getclaro.ai.

We may request information necessary to verify your identity before completing a request.

12. Security

We use technical and organisational measures designed to protect customer and personal data against accidental or unlawful loss, alteration, disclosure or access.

Depending on the relevant service and workflow, these measures may include:

• encryption in transit and at rest;
• multi-factor authentication for administrative and cloud access;
• least-privilege access controls;
• logical separation of customer data;
• controlled access to production data;
• operational logging and monitoring.

Security controls are reviewed as our architecture, services and risk profile evolve.

Additional security information may be made available to customers and prospective customers as part of our security and procurement documentation.

13. Security incidents

We maintain processes for assessing and responding to security incidents.

Where required, affected customers and competent authorities are notified in accordance with applicable law and contractual obligations.

Specific notification timelines or incident-response commitments may be defined in the applicable customer agreement or Data Processing Addendum.

14. Children

Claro is a business-to-business service and is not directed to children.

We do not knowingly collect personal data from children through our ordinary website and business-development activities.

15. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to our services, technology, legal requirements or business practices.

The current version will always be published on this page together with its most recent update date.

16. Contact

For questions about this Privacy Policy or our processing of personal data:

hello@getclaro.ai