Privacy Policy

1. Introduction and Scope

1.1 Privacy Commitment: ClueSales is a proprietary software platform owned and operated by Cluesales Labs LLP("ClueSales", "we", "us", or "our"). This Privacy Policy explains how we collect, use, disclose, retain, and protect information in connection with the ClueSales website, application, and related services (collectively, the "Service").

1.2 Customer Data: ClueSales provides software for receiving, processing, screening, scoring, routing, and transmitting information relating to inbound leads and inquiries. Information submitted to or processed through a customer's ClueSales account may include personal information belonging to that customer's customers, prospects, leads, employees, sales representatives, or other individuals ("Customer Data").

1.3 Our Role: When we process Customer Data on behalf of a customer and according to that customer's instructions, we generally act as a processor or service provider, while the customer remains responsible for determining the purposes and means of processing that Customer Data. Depending on the circumstances and applicable law, ClueSales may act as a controller or equivalent entity for information relating directly to our own customers, users, website visitors, billing administration, and business operations.

2. Information We Collect

2.1 Account and Business Information: When you create or administer a ClueSales account, we may collect information such as your name, business or organization name, business email address, telephone number, country or region, account credentials, subscription information, and other information you provide during onboarding or account administration.

2.2 Customer-Configured Contact Information: Customers may provide names, email addresses, telephone numbers, and other contact details for sales representatives, employees, administrators, or other recipients to whom lead notifications may be routed.

2.3 Inbound Lead and Inquiry Information: Depending on how the Service is configured, ClueSales may receive and process information contained in inbound lead submissions, web forms, webhooks, email notifications, or other supported sources. This may include names, email addresses, telephone numbers, company information, inquiry details, messages, source information, form fields, timestamps, and other information included in the inbound submission.

2.4 Technical and Usage Information: We may collect technical information necessary to operate, secure, troubleshoot, and improve the Service, including IP address, browser and device information, authentication events, timestamps, system logs, application events, and information about interactions with the Service.

2.5 Billing Information: Subscription purchases and payment processing are handled through our Merchant of Record, Paddle.com. ClueSales does not intentionally collect or store full payment card numbers or other sensitive payment credentials on its own infrastructure.

3. How We Use Information

3.1 Providing the Service: We use information to provide, operate, maintain, secure, and support ClueSales, including receiving and processing inbound inquiries, applying configured screening and routing workflows, generating operational lead scores or classifications, sending notifications to customer-configured recipients, and transmitting information to customer-configured integrations.

3.2 Artificial Intelligence and Automated Processing: ClueSales may use third-party artificial intelligence, machine-learning, and large language model services to perform certain functions of the Service, including extracting, structuring, screening, classifying, enriching, and scoring inbound lead information. Where these services are used, relevant Customer Data or portions of inbound lead information may be transmitted to and processed by the applicable third-party provider solely for the purpose of providing and operating the relevant ClueSales functionality. ClueSales does not use Customer Data submitted through the Service to independently market to the individuals identified in that data or to sell Customer Data as a data-broker or advertising product.

3.3 Account Administration: We use account and business information to create and manage accounts, authenticate users, administer subscriptions, communicate about the Service, provide customer support, and enforce applicable account and service requirements.

3.4 Security and Reliability: We may process information to detect and prevent fraud, abuse, unauthorized access, security threats, service misuse, and technical problems, and to maintain the reliability and integrity of our systems.

3.5 Service Improvement: We may use appropriate technical and operational information to understand service performance, diagnose errors, improve reliability, and develop or improve features. We do not sell Customer Data to third-party data brokers or advertising platforms.

3.6 Legal and Business Purposes: We may process information where reasonably necessary to comply with applicable law, respond to lawful requests, protect our rights and property, enforce our agreements, resolve disputes, or support legitimate business operations.

4. Customer Data and Processing

4.1 Customer Instructions: We process Customer Data primarily to provide the Service and according to the configuration and instructions of the applicable customer, subject to applicable law and the terms governing the customer's use of ClueSales.

4.2 Customer Responsibility: Customers are responsible for ensuring that their collection, use, disclosure, and submission of Customer Data to ClueSales is lawful and that they have the necessary rights, permissions, notices, and lawful basis required to process such information.

4.3 Configured Recipients: Customers are responsible for the accuracy and authorization of recipient information configured within their accounts. ClueSales may transmit Customer Data and lead information to those configured recipients as necessary to provide the requested routing and notification functionality.

4.4 No Sale of Customer Data: We do not sell, rent, trade, or otherwise commercially exploit Customer Data as a data-broker or advertising product.

4.5 No Direct Lead Marketing: ClueSales does not, merely by receiving or routing an inbound inquiry, use the submitted lead information to independently market or sell products or services to the individual who submitted the inquiry. Communications initiated independently by a customer or its personnel are the responsibility of that customer.

5. Service Providers and Data Sharing

5.1 Service Providers: We may use third-party infrastructure and service providers to host, operate, secure, and deliver components of the Service. These providers may include hosting, database, email, telecommunications, security, analytics, payment, and artificial intelligence or large language model providers. Such providers may process information on our behalf, including relevant Customer Data, only as necessary to provide their services to us, perform the applicable ClueSales functionality, or as otherwise permitted by applicable law.

5.2 Customer-Directed Integrations: Where a customer configures an integration, webhook, email destination, CRM, or other downstream service, ClueSales may transmit applicable information to that destination according to the customer's configuration.

5.3 Legal and Protective Disclosures: We may disclose information where reasonably necessary to comply with applicable law, legal process, court orders, regulatory requirements, or legitimate requests from authorities, or where necessary to protect the rights, safety, security, or property of ClueSales, our customers, users, or others.

5.4 Business Transfers: If ClueSales is involved in a merger, acquisition, financing, restructuring, sale of assets, or similar business transaction, information may be transferred as part of that transaction, subject to applicable law and appropriate confidentiality and data protection requirements.

6. Data Retention

6.1 Retention Principles: We retain information for as long as reasonably necessary to provide the Service, maintain appropriate operational and security records, comply with legal and contractual obligations, resolve disputes, enforce agreements, and protect our legitimate business interests.

6.2 Customer Data: Retention of Customer Data may depend on the customer's account configuration, the functionality being used, operational requirements, and applicable legal obligations. Certain lead information may be retained in operational systems, databases, logs, backups, or other systems for limited periods necessary to provide, secure, troubleshoot, or verify the Service.

6.3 Deletion: When information is no longer required for legitimate operational, legal, security, or contractual purposes, we may delete, anonymize, or otherwise securely dispose of it in accordance with our applicable retention practices.

7. Data Security

7.1 Security Measures: We maintain reasonable technical and organizational measures designed to protect information against unauthorized access, disclosure, alteration, loss, misuse, or destruction.

7.2 Access Controls: Access to production systems and information is restricted according to operational requirements and appropriate access controls. We use security measures appropriate to the nature of the information and the risks associated with its processing.

7.3 No Absolute Security Guarantee: No internet-based service, storage system, transmission method, or security measure can be guaranteed to be completely secure. Accordingly, while we take reasonable measures to protect information, we cannot guarantee absolute security.

8. Cookies and Tracking Technologies

8.1 Essential Technologies: We may use cookies, session tokens, local storage, and similar technologies that are necessary to authenticate users, maintain sessions, protect accounts, operate the Service, and maintain security.

8.2 Analytics: We may use analytics and diagnostic technologies to understand website and application usage, monitor performance, identify errors, and improve the Service. The specific technologies used may change as the Service evolves.

8.3 Browser Controls: Depending on your browser and device settings, you may be able to restrict or disable certain cookies or similar technologies. Doing so may affect the functionality of portions of the Service.

9. International Data Processing

9.1 Cross-Border Processing: Because ClueSales and certain service providers may operate in different countries, information may be processed or stored outside the country in which you or your customers are located.

9.2 Appropriate Safeguards: Where applicable law requires safeguards for international transfers of personal information, we will seek to implement appropriate mechanisms or contractual safeguards for those transfers.

10. Privacy Rights and Requests

10.1 Individual Rights: Depending on your location and applicable law, you may have rights relating to your personal information, which may include rights to access, correction, deletion, restriction, objection, portability, or withdrawal of consent where applicable.

10.2 Customer-Controlled Data: If your personal information was submitted to ClueSales by one of our customers, you should generally direct privacy requests concerning that information to the relevant customer first, because that customer may determine the purposes for which the information is processed.

Where appropriate, we will assist our customers with privacy requests relating to Customer Data in accordance with applicable law and our contractual obligations.

11. Children's Privacy

ClueSales is a business software service and is not directed toward children. We do not knowingly seek to collect personal information directly from children through the Service. If you believe that a child has provided personal information to us in circumstances where it should not have been collected, please contact us so that we can review the matter.

12. Changes to This Privacy Policy

12.1 Updates: We may update this Privacy Policy from time to time to reflect changes to the Service, our practices, applicable law, or other operational requirements.

12.2 Notice of Material Changes: Where required by applicable law, we will provide appropriate notice of material changes. The updated policy will be posted with a revised "Last Updated" date.

13. Contact Us

If you have questions about this Privacy Policy, our privacy practices, or a privacy request, please contact:

Cluesales Labs LLP
Privacy & Data Protection: support@cluesales.com