Privacy Policy

1. Scope and Roles

This Privacy Policy applies where ClarifiVC acts as a controller or business, meaning we determine the purposes and means of processing personal information, such as when we collect information through our website, marketing activities, sales process, account administration, and general operation of our business.

In some cases, ClarifiVC may process personal information on behalf of our customers in connection with our platform services. In those cases, ClarifiVC may act as a processor or service provider and our customer’s privacy policy and instructions will govern that processing. If you have questions about personal information processed by ClarifiVC on behalf of a customer, please contact the relevant customer directly.

2. Personal Information We Collect

We may collect the following categories of personal information, depending on how you interact with us:

A. Identifiers and Contact Information

• name
• email address
• phone number
• business address
• employer, company name, job title, and professional role
• account username and similar account identifiers
• online identifiers such as IP address, device identifiers, cookie IDs, and similar identifiers

B. Commercial and Transaction Information

• information about subscriptions, purchases, inquiries, product previews, and transactions
• billing information, invoicing details, and payment-related records
• records of services purchased, obtained, or considered

C. Internet or Network Activity Information

• browsing history on our website
• interaction data regarding pages viewed, links clicked, features used, referring URLs, and session activity
• log data, device event information, crash data, and diagnostic data

D. Professional or Employment Information

• company affiliation
• business contact details
• job title, department, and role
• information provided in connection with partnership, recruiting, vendor management, or sales inquiries

E. Communications and Submission Information

• content of communications you send to us
• support requests, preview / walkthrough requests, feedback, survey responses, and meeting notes
• information contained in forms, chat submissions, emails, or other communications

F. Geolocation Information

• approximate location derived from IP address or similar technical data

G. Sensitive Personal Information

We do not seek to collect sensitive personal information except where reasonably necessary and lawful. To the extent we collect sensitive personal information, we will use and disclose it only for permitted purposes, such as providing requested services, ensuring security and integrity, preventing fraud, complying with law, or other purposes authorized by applicable law.

H. Customer Data

If you use our platform through an organization that is a ClarifiVC customer, we may process personal information contained in customer-provided data on behalf of that customer. That information is governed by our agreement with the customer and the customer’s instructions.

3. Sources of Personal Information

We collect personal information from the following sources:

• directly from you, such as when you contact us, request a walkthrough, create an account, subscribe, fill out forms, or otherwise interact with us;
• automatically from your browser, device, and use of the Services through cookies, pixels, SDKs, logs, and similar technologies;
• from your employer, colleagues, or other users within your organization;
• from service providers, business partners, analytics providers, marketing partners, and publicly available sources; and
• from our customers when they provide data to us in connection with their use of our platform.

4. How We Use Personal Information

We may use personal information for the following purposes:

• to provide, operate, maintain, secure, and improve the Services;
• to create, administer, and manage accounts;
• to process transactions, billing, payments, renewals, and related administration;
• to provide customer service, respond to inquiries, and communicate with you;
• to personalize content, measure engagement, and improve user experience;
• to monitor usage, troubleshoot issues, perform analytics, and develop new features and services;
• to send product, service, administrative, security, and transactional communications;
• to send marketing communications in accordance with applicable law and your preferences;
• to detect, prevent, investigate, and respond to fraud, abuse, security incidents, and other harmful or unlawful activity;
• to enforce our agreements, policies, and legal rights;
• to comply with legal obligations, court orders, and regulatory requirements; and
• to support business transactions such as financing, investment, merger, acquisition, reorganization, or sale of assets.

We may also deidentify or aggregate information and use it for any lawful purpose. Where we maintain deidentified information, we will take reasonable measures designed to ensure that it cannot reasonably be reidentified, except as permitted by applicable law.

5. Legal Bases for Processing Under GDPR

If the GDPR or UK GDPR applies to our processing of your personal information, we rely on one or more of the following legal bases:

• Performance of a contract: to provide the Services, manage accounts, process transactions, and perform our contractual obligations.
• Legitimate interests: to operate and improve our business and Services, secure our systems, communicate with customers and prospects, prevent fraud, and manage ordinary business operations, provided those interests are not overridden by your rights and freedoms.
• Compliance with legal obligations: to comply with applicable laws, regulations, lawful requests, court orders, and legal process.
• Consent: where required by law, such as for certain cookies or marketing communications. You may withdraw consent at any time, but withdrawal will not affect prior lawful processing.
• Vital interests or public interest: where permitted in limited circumstances under applicable law.

6. Cookies and Similar Technologies

We and our service providers may use cookies, pixels, local storage, analytics tools, and similar technologies to collect information about your use of the Services. These technologies may help us remember preferences, understand usage patterns, maintain security, measure the effectiveness of marketing, and improve functionality.

Depending on your jurisdiction, we may request consent before placing certain non-essential cookies on your device. You can manage cookies through your browser settings and, where available, our cookie consent tools. Disabling certain cookies may affect the functionality of the Services.

We may allow third parties such as analytics and advertising providers to collect information through automated technologies, subject to applicable law.

7. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients:

• Service providers and contractors that perform services on our behalf, such as hosting, cloud infrastructure, analytics, CRM, communications, customer support, security, and professional services providers;
• Affiliates and related entities for internal administrative, operational, compliance, and business purposes;
• Business partners and integrations where necessary to provide requested services or where you direct us to do so;
• Professional advisors such as lawyers, auditors, insurers, and consultants;
• Government authorities and other third parties where required to comply with law, legal process, or enforceable governmental request, or to protect rights, safety, and security;
• Relevant parties to corporate transactions such as investors, lenders, acquirers, counterparties, and their advisors in connection with due diligence or an actual or proposed financing, merger, acquisition, reorganization, or sale of assets; and
• Others with your direction or consent.

We do not sell personal information for money. We also do not knowingly share personal information for cross-context behavioral advertising in a manner that would trigger an opt-out obligation under California law, except to the extent cookies or similar technologies used on our website are later determined to constitute such a "share" or "sale" under applicable law. In that case, you may exercise your rights as described below.

8. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, satisfy legal, accounting, tax, audit, and reporting requirements, enforce our agreements, resolve disputes, and maintain security.

Retention periods vary depending on the nature of the information, the context in which it was collected, our legal obligations, and whether retention is reasonably necessary for ongoing business needs. When personal information is no longer reasonably necessary, we will delete, deidentify, or anonymize it, unless retention is required or permitted by law.

9. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, acquisition, disclosure, alteration, and destruction. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

You are responsible for maintaining the confidentiality of account credentials and for using appropriate security measures when accessing our Services.

10. International Data Transfers

ClarifiVC is based in the United States, and we may process personal information in the United States and other countries where we or our service providers operate. These countries may have data protection laws that differ from those in your jurisdiction.

Where required by applicable law, we will implement appropriate safeguards for cross-border transfers of personal information, such as the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum, or other lawful transfer mechanisms.

11. Your Privacy Rights

Depending on your location and applicable law, you may have certain rights regarding your personal information.

A. California Privacy Rights

If you are a California resident, subject to certain exceptions and verification requirements, you may have the right to:

• know the categories of personal information we collected about you;
• know the categories of sources from which personal information was collected;
• know the business or commercial purposes for collecting, selling, or sharing personal information;
• know the categories of third parties to whom we disclose personal information;
• access specific pieces of personal information we hold about you;
• request deletion of personal information we collected from you;
• request correction of inaccurate personal information;
• limit the use and disclosure of sensitive personal information, where applicable;
• opt out of the sale or sharing of personal information, where applicable; and
• not receive discriminatory treatment for exercising your privacy rights.

B. GDPR and UK GDPR Rights

If you are located in the European Economic Area, Switzerland, or the United Kingdom, and applicable law applies, you may have the right to:

• access your personal information;
• request correction of inaccurate or incomplete personal information;
• request deletion of your personal information;
• object to certain processing;
• request restriction of processing;
• request portability of your personal information;
• withdraw consent where processing is based on consent; and
• lodge a complaint with a supervisory authority.

C. Exercising Your Rights

To exercise privacy rights, please contact us using the details in the "Contact Us" section below. We may need to verify your identity before processing your request. You may also designate an authorized agent to make a request on your behalf where permitted by law.

We will respond in accordance with applicable law. If we deny a request, we will explain the basis for the denial where required. California residents may have the right to appeal certain decisions where required by law.

12. California Privacy Disclosures

This section provides supplemental disclosures for California residents.

A. Categories of Personal Information Collected

In the preceding 12 months, we may have collected the following categories of personal information under California law:

• identifiers;
• personal information described in California Civil Code Section 1798.80(e);
• commercial information;
• internet or other electronic network activity information;
• geolocation data;
• professional or employment-related information;
• education information, if provided in recruiting or partnership contexts; and
• in limited cases, sensitive personal information.

B. Categories of Personal Information Disclosed for Business Purposes

In the preceding 12 months, we may have disclosed the categories above to service providers, contractors, advisors, affiliates, and other recipients described in Section 7 for business purposes.

C. Sales and Sharing

We do not knowingly sell personal information for monetary consideration. We do not knowingly share personal information for cross-context behavioral advertising in a manner requiring an opt-out under California law, except to the extent certain cookie-based practices are later interpreted as a sale or share. If that changes, we will provide any legally required opt-out mechanisms.

D. Sensitive Personal Information

We do not use or disclose sensitive personal information for purposes other than those permitted by California law, unless we provide any required notice and rights.

13. Marketing Communications

You may opt out of receiving promotional emails from us by using the unsubscribe link in the message or by contacting us. Even if you opt out of promotional communications, we may still send you transactional or relationship messages, such as account, service, billing, security, and legal notices.

14. Children’s Privacy

Our Services are not directed to children under 16, and we do not knowingly collect personal information from children under 16 without appropriate authorization where required by law. If you believe we have collected personal information from a child in violation of applicable law, please contact us so we can take appropriate action.

15. Third-Party Websites and Services

The Services may contain links to third-party websites, plug-ins, integrations, or services. We are not responsible for the privacy, security, or content practices of third parties. We encourage you to review the privacy policies of those third parties before interacting with them.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we do, we will post the updated version and revise the Effective Date above. If required by law, we will provide additional notice or obtain consent for material changes.

17. How AI and machine learning are used

First-party systems. We do not train shared machine-learning models on your financial data. Your data is used to compute the metrics, forecasts, and insights you and your authorized stakeholders see. Nothing more.

Third-party LLM providers. Some optional features (deck analysis, the assistant chat, document extraction, retrieval-augmented answers) call external large-language-model providers when enabled. The exact set of providers and their configured retention modes may change over time; the current list of LLM providers and retention modes is available on request through our contact page. We will not enable a provider that allows the training of provider-side models on your data without an explicit, separate opt-in. If you would prefer to avoid third-party LLM use entirely, contact us and we will disable those features for your organization.

Heuristic vs. ML labeling. Some features that use the “AI” label internally are deterministic ruleset implementations (e.g., GL account normalization, deal scoring, oracle insights) rather than trained ML classifiers. Our KPI glossary documents how each metric is derived.

18. Data retention: detailed practices

Active financial periods and audit trails are retained for the lifetime of your subscription. On account deletion we remove customer-identifiable records within 30 days, except where law requires longer retention. Aggregated, de-identified usage analytics may be retained indefinitely.

19. Contact Us

If you have questions about this Privacy Policy or would like to exercise your privacy rights, please contact us at: