Cleero™ – Privacy & Data Protection Policy

Last Updated: November 12, 2025

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Who We Are

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This Privacy and Data Protection Policy explains how ValsyDev LLC (“ValsyDev”, “the Company”, “we”, “us”, or “our”) collects, processes, stores, and protects personal information when you use Cleero™, our intelligent productivity platform designed to unify data, tools, and workflows through AI-powered automation and integrations.

Cleero™ is a product owned and operated by ValsyDev LLC, a company registered in the State of Delaware, United States (EIN: 30-1452842). The Company acts as the primary Data Controller for data it collects directly from users and as a Data Processor where users collect or process personal information of third parties through the Cleero platform.

Our mission is to simplify digital complexity, allowing users and teams to manage tasks, data, and decisions through a single intelligent interface. We process personal information responsibly and transparently in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), LGPD (Brazil), UK Data Protection Act 2018, and similar international standards.

If you have any questions about this Policy or about how we process personal data, please contact us at:

Email: accounts@valsydev.com
Tel: +380 93 935 05 35
Address: 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex, USA

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Types and Sources of Personal Data

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We collect and process different categories of personal data depending on how you use Cleero™. “Personal data” means any information that can identify an individual directly or indirectly.

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Categories of Personal Data We Collect

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• Identity Data: Name, username, title, company name, and professional role.
• Contact Data: Email address, phone number, postal address, or work contact information.
• Account Data: Login credentials, password hashes, user IDs, and authentication tokens.
• Technical Data: Device identifiers, IP address, browser type and version, operating system, and location metadata derived from network information.
• Usage Data: Data about how you interact with Cleero™, including clicks, actions, features used, session logs, and error reports.
• Integration Data: Information retrieved or synchronized from third-party platforms that you connect to Cleero™ (such as Upwork, Telegram, n8n, or other APIs).
• Communication Data: Records of communications with our support team or feedback submissions.
• Marketing Data: Preferences related to receiving communications, promotions, and notifications.

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Information Collected from Third Parties

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Cleero™ enables integrations with external services. When users connect third-party platforms to Cleero™, we may process data on their behalf. This can include data retrieved from:

• Upwork or freelance platforms: profile information, activity, ratings, or team data
• Telegram or communication tools: chat messages, group metadata, or contact lists
• n8n or automation services: workflow triggers, execution logs, or contextual data
• Other connected apps or APIs authorized by the user

We process this data solely to deliver requested functionality and only to the extent authorized by the user or required by the connected platform’s API permissions.

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User-Collected Third-Party Data

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Cleero™ provides tools that allow users to collect, process, and organize data belonging to other individuals or organizations (for example, importing client contact lists, project data, or communication threads).

In such cases:

• Users act as Data Controllers with respect to that information.
• ValsyDev LLC acts as a Data Processor, providing the platform and ensuring technical and organizational safeguards.
• Users are responsible for ensuring that any personal data they upload, share, or process through Cleero™ is collected and used lawfully, with appropriate consent or legal basis.

ValsyDev LLC does not monitor or control the nature of third-party data collected by users and assumes no liability for user-collected information beyond maintaining secure storage, access controls, and compliance with applicable laws as a processor.

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Lawful Bases for Processing

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We process personal data under one or more of the following lawful bases:

• Performance of a Contract: To provide, maintain, and support Cleero™ and its features.
• Legitimate Interests: To operate, improve, and secure our platform, communicate with users, and prevent fraud.
• Consent: Where you explicitly agree (e.g., to receive marketing or connect integrations).
• Legal Obligations: To comply with tax, accounting, or legal requirements.

When acting as a data processor, we process data on the user’s lawful basis as specified in their instructions or agreements.

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Purposes of Processing

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We use personal data for the following purposes:

1. To provide and operate Cleero™, including account creation, login, and feature access
2. To process data shared through integrations and automation workflows
3. To personalize and optimize your experience with the platform
4. To maintain system integrity and detect unauthorized activity
5. To communicate with you about support, product updates, or security notices
6. To comply with legal and regulatory obligations
7. To analyze usage and improve product performance
8. To send marketing and promotional messages (where permitted by law)

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Data Retention

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We retain data for as long as necessary to fulfill the purposes set out in this Policy, unless a longer retention period is required by law or contract.

User-generated data may be deleted upon account closure or at the user’s request. Data processed on behalf of users will be retained only as long as their subscription or service engagement remains active.

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Data Sharing and Disclosure

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We share data only when necessary, including with:

• Service Providers: Cloud hosting, analytics, and IT providers under strict confidentiality and data processing agreements.
• Legal Authorities: If required by applicable law, subpoena, or government request.
• Third-Party Integrations: When explicitly authorized by the user.

We do not sell personal data.

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International Data Transfers

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As a Delaware-based company with global infrastructure, your data may be transferred and stored outside your country of residence. We ensure compliance with GDPR and equivalent frameworks through Standard Contractual Clauses (SCCs) and other legally recognized safeguards.

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Your Rights

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Depending on your jurisdiction, you may have the following rights:

• Access, rectify, or erase your personal data
• Restrict or object to processing
• Port your data to another service
• Withdraw consent at any time

To exercise your rights, contact us at accounts@valsydev.com.

We respond to valid requests within one month, as required by law.

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Security

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We implement technical and organizational measures to secure your data against loss, unauthorized access, or disclosure.

This includes encryption, access controls, pseudonymization, and regular audits.

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Cookies and Tracking Technologies

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Cleero™ uses cookies and similar technologies to ensure proper functionality, improve performance, and analyze usage. For details on cookie categories and consent management, please refer to our separate Cookie Policy.

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Children’s Data

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Cleero™ is not directed toward children under the age of 16, and we do not knowingly collect their data.

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Changes to This Policy

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We may update this Policy periodically. Updates will be published on this page with the revised “Last Updated” date. Continued use of Cleero™ after such updates constitutes acceptance of the new terms.

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Contact

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ValsyDev LLC
EIN: 30-1452842
16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex, USA
Tel: +380 93 935 05 35
Email: accounts@valsydev.com

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