🔒 Privacy Policy - Cleverose

1. Data controller

• Nom / Prénom : Assane Diouf
• Statut : Micro-entrepreneur
• SIRET : 940 000 920 00014
• Email de contact : contact@cleverose.com

2. Data collected

Cleverose may collect the following data:

• Identification data: first name, email address, password.
• Connection data: IP address, browser, connection logs.
• Data related to service use: notes, tasks, uploaded files.
• Payment data: only via our Stripe provider (no banking data is stored by Cleverose).
• Usage and browsing data: audience measurement and session recordings, under the conditions described in section 8 "Cookies and trackers".

3. Processing purposes

The collected data is used to:

• Allow the creation and management of a user account.
• Provide and improve the services offered by Cleverose.
• Ensure site security and prevent fraud.
• Manage billing and subscriptions (via Stripe).
• Send service-related emails (notifications, updates).

4. Legal basis for processing

The processing carried out by Cleverose is based on:

• The execution of the contract (use of the service).
• The user's consent (e.g., newsletter subscription).
• The legal obligation (billing, accounting).

5. Data retention period

• Account-related data: retained as long as the account is active.
• Billing data: retained for 10 years (legal obligation).
• Navigation data: retained for a maximum of 13 months (cookies, analytics).
• After account deletion by the user: data is retained for a 30-day grace period (technical backups, reactivation), then permanently deleted, except billing data retained for 10 years in accordance with legal obligations.

6. Data sharing

Cleverose does not sell or rent your data.

Certain data may be transmitted to trusted providers only to ensure the service:

• Stripe (payments).
• Hostinger (data hosting).
• PostHog (product analytics and session recording within the application, hosted in the European Union).

Some of this data may be transferred outside the European Union (in particular to the United States for Stripe), under appropriate safeguards provided by the GDPR (Standard Contractual Clauses).

7. User rights

In accordance with GDPR, you have the following rights:

• Right of access, rectification, deletion of your data.
• Right to object to processing.
• Right to data portability.
• Right to lodge a complaint with the CNIL (www.cnil.fr, the French data protection authority) if you believe your rights are not being respected.

To exercise your rights, contact: contact@cleverose.com.

8. Cookies and trackers

Cleverose uses cookies strictly necessary for the operation of the site and the application (authentication, security).

• Matomo (cleverose.com website only): a self-hosted audience measurement tool, used only to count visits and page views on the marketing site. Configured in accordance with the CNIL's exemption criteria (anonymized IP address, no data shared with third parties, maximum 13-month retention), it does not require prior consent and relies on Cleverose's legitimate interest in measuring its site's audience.
• PostHog (Cleverose application only): a product analytics tool including session recording (session replay), hosted by PostHog on servers located in the European Union. It helps understand how the service is used in order to improve it. Session recordings are retained for up to 30 days. This tool sets non-essential cookies and is only activated after your consent is collected via the cookie banner displayed in the application.

You can change or withdraw your consent at any time via the cookie banner displayed in the application.

9. Data security

Cleverose implements all necessary technical and organizational measures to protect your personal data (password encryption, secure HTTPS connections, regular backups).

10. Contact

For any questions regarding this policy or your personal data, you can contact us at: contact@cleverose.com.