2) CLEO PRIVACY POLICY
Last updated: May 27, 2026
At Cleo, we value your privacy and take the protection of your personal information seriously. This Privacy Policy explains what data we may collect, how we use it, with whom it may be shared, and what rights you may have when using Cleo and related services.
1. Data controller
Cleo is operated by Sergitanza in the Netherlands. If you have privacy questions, you can contact us at soporte@cleoia.ai.
2. Data we may process
Depending on how you use Cleo, we may process:
* account data, such as email address and user identifiers,
* subscription and plan-status information,
* messages, images, audio notes, and other content you choose to share,
* basic technical information for security, diagnostics, and service operation,
* product or analytics events where appropriate.
3. Purposes of processing
We use data to:
* create and manage your account,
* deliver Cleo's features,
* process subscriptions and related support,
* maintain security, integrity, and abuse prevention,
* improve the product and resolve incidents,
* comply with legal and contractual obligations.
4. Legal bases
Depending on the context, we process data because:
* it is necessary to provide the service you request,
* we have a legitimate interest in operating, protecting, and improving Cleo,
* we must comply with legal obligations,
* or we rely on your consent where the law requires it.
5. Service providers and third parties
We may rely on third-party providers for infrastructure, authentication, payments, storage, analytics, and technology processing. Those providers should process data only as needed to support Cleo and under their own contractual and security obligations.
6. International transfers
Some technology providers may process data outside your country of residence. Where relevant, we will use reasonable safeguards to support such transfers in line with applicable law.
7. Retention
We retain data for as long as reasonably necessary to operate Cleo, maintain accounts, resolve incidents, comply with legal obligations, and protect service security. The exact retention period may vary depending on the type of data and context.
8. Your rights
Depending on applicable law, you may have rights to request access, correction, deletion, restriction, objection, or portability for certain personal data. You may also withdraw consent where consent is the relevant legal basis, without affecting prior lawful processing.
9. Security
We apply reasonable technical and organizational measures to protect information. However, no system is completely infallible and we cannot guarantee absolute security against every possible risk.
10. Minors
Cleo is not intended for individuals under 18 and should not be used by them.
11. Changes to this policy
We may update this Privacy Policy to reflect operational, legal, or product changes. When we do, we will update the last-updated date.
12. Contact
For privacy questions or rights requests, you can contact us at: