Privacy Policy

0. Scope

Clonify processes personal data in two distinct roles. As a data controller, we process the personal data of creators using Clonify in a trial, on a paid plan or through Clonify Studio. As a data processor, we process the personal data of visitors interacting with a creator's published clone on behalf of that creator.

A. Creator data (Clonify customer)

In this section, Clonify acts as data controller.

A.1 Controller

• Entity: Marea Kiss LLC
• Address: 30 N Gould St, Ste R, Sheridan, WY 82801, USA
• Email: privacy@clonify.com

A.2 Data we collect

• Account: email, name, profile photo, subdomain, language preference.
• Billing: fiscal data, country, subscription plan, payment history. Card data is processed by our payment provider; Clonify does not store card numbers.
• Uploaded content: audios, videos, documents, URLs and derived artifacts (transcripts, embeddings, knowledge graph, voice profile). To import public content you point us to (websites, YouTube or Instagram videos) we use Firecrawl, Supadata and Webshare, which only receive those public addresses.
• Voice clone (optional): if you enable voice, the audio samples you upload are sent to ElevenLabs to create the clone's voice. Only upload your own voice or one you have permission to use.
• Affiliate programme (optional): if you refer customers to Clonify, your referral code, the customers attributed to you, the commissions earned and the PayPal account where we pay you. PayPal processes the payment under its own terms.
• Technical: IP address, user agent, session cookies, error logs.
• Usage: pages viewed, actions in admin panel, quota consumption and, only with consent, a protected navigation replay with interface text and personal fields masked.
• Optional advertising measurement: only with consent, Meta click and browser identifiers, pages viewed and registration, trial, subscription and first-purchase events. Email and local user identifiers included in server events are normalised and securely hashed before transmission.

A.3 Purposes and legal basis

• Service provision, authentication, billing, support — contractual necessity (art. 6.1.b GDPR).
• Tax and accounting obligations — legal obligation (art. 6.1.c).
• Product analytics, fraud prevention, service improvement — legitimate interest (art. 6.1.f).
• Optional protected session replay to identify usability blocks — consent (art. 6.1.a GDPR). It can be rejected without affecting the service.
• Optional Meta advertising measurement, attribution and audience improvement — consent (art. 6.1.a GDPR). It remains off until accepted and can be rejected without affecting the service.
• Commercial communications about features and similar services — legitimate interest based on existing contractual relationship (LSSI-CE art. 21.2), with opt-out in every email.

A.4 Google Calendar connection (Google user data)

Connecting your Google account is optional and only relevant if you use the Meetings module. When you connect it, Clonify requests two Google Calendar permissions through Google's OAuth flow, and reads the email address of the connected account to display which calendar is linked:

• See your availability (calendar.freebusy): we read only the busy/free time ranges of your primary calendar, to hide already-busy slots on your public booking page.
• See and edit events (calendar.events): we create, update, and delete on your calendar only the events that correspond to bookings managed by Clonify, so each meeting appears on your agenda and you are never double-booked.

What we do NOT do: we do not read, modify, or store any of your other calendar events, nor do we use Google Calendar data for advertising, profiling, or any purpose beyond the booking sync described above. We only manage the events Clonify itself generates from your bookings.

Storage and revocation: we store the Google access and refresh tokens encrypted at rest and use them solely for the operations above. You can revoke access at any time from Clonify (Meetings → Integrations) or from your Google account's permissions page; once revoked, we stop accessing your calendar.

Clonify's use and transfer of information received from Google APIs, including the YouTube API Services, to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

A.5 Google Drive connection (Google user data)

Connecting Google Drive is optional and only relevant if you use the "Google Drive folder" connector to feed your Knowledge in Clonify. When you connect it, Clonify requests one permission through Google's OAuth flow:

• See and download your Drive files (drive.readonly): we read the files in the folder you choose, and its subfolders, so their content can feed your clone. We need read access rather than a one-off file picker because the point of the connector is that files you add to that folder LATER are brought in automatically, and those files do not exist yet when you grant consent.

What we do with it: we download the files of that folder, transcribe videos and audio, extract the text of PDFs, text files and Google Docs, Sheets and Slides, split it into passages and index it, so your clone can answer using that content. The subfolder structure is mirrored inside Clonify. Once a day we check the folder and bring in whatever is new or changed.

What we do NOT do: we never write, modify or delete anything in your Drive — access is read-only. We do not access files outside the folder you selected. We do not use Google Drive data for advertising, profiling, or any purpose beyond feeding the clone you configured. Deleting a file in Drive does not delete it from your Knowledge: we tell you and you decide.

Storage and revocation: we store the Google access and refresh tokens encrypted at rest and use them solely for the operations above. You can disconnect the folder at any time from Clonify (in Knowledge) or revoke access from your Google account's permissions page; once revoked, we stop accessing your Drive. Content already ingested stays in your Knowledge until you delete it.

A.6 Who we share Google user data with

We do not sell Google user data and we do not transfer it to third parties for advertising. We share, transfer or disclose it only with the following service providers, who act as our processors under a data processing agreement and only to the extent needed to provide the features described above:

• Cloudflare R2 — temporary storage: only the videos and audio of that folder pass through it, so they can be sent for transcription, and the file is deleted as soon as the transcription finishes. PDFs, text files and Google Docs, Sheets and Slides are processed in memory and never stored there.
• AssemblyAI Inc. — transcribes the videos and audio of that folder into text.
• OpenAI L.L.C. — turns the extracted text into the numeric vectors used to search it, and generates clone replies.
• Anthropic PBC — language models that generate clone replies from that content.
• Cohere Inc. — reorders the retrieved passages by relevance before they reach the model.
• Neon Inc. — the PostgreSQL database where the extracted text and its vectors are stored.
• Vercel Inc. — hosts and runs the application that performs the operations above.

The list above describes the Google Drive connection (A.5). The Google Calendar connection (A.4) involves fewer providers: calendar data is only handled by Neon, as the database, and Vercel, as the hosting that runs the sync — it never goes to the transcription or language-model providers. The YouTube connection has its own explanation in section A.9.

Each of these providers is listed in section C with its location and its data processing agreement. Beyond them, we disclose Google user data only where legally required. We do not use Google user data to develop, improve or train generalised or non-personalised artificial intelligence or machine learning models, and our providers process it under contract without using it to train theirs.

A.7 Facebook and Instagram Lead Ads connection

Connecting a Meta account is optional. When a creator enables it, Clonify reads the Meta user's identifier and display name, the identifiers and names of the Pages they administer, the identifier and username of any linked Instagram professional account, and the identifiers and names of Lead Ads forms. Access and Page tokens are encrypted at rest.

The permissions pages_show_list, pages_read_engagement, pages_manage_ads and leads_retrieval are used only to list the creator's authorised Pages and forms and retrieve the leads generated by those forms. pages_manage_metadata is used only to subscribe or unsubscribe the selected Pages from real-time lead notifications. With this connection, Clonify does not create or modify campaigns or ads, and does not read or manage messages, comments or reviews.

The creator can disconnect Meta at any time under Settings → Facebook and Instagram leads. This revokes Clonify's Page subscriptions and deletes the stored Meta tokens and connection metadata; contacts already imported remain in the creator's CRM until the creator deletes them. A Meta data-deletion request also deletes the connection associated with that Meta user.

A.8 Connecting your own AI (Claude, ChatGPT, Cursor and others)

Connecting an external AI app to your account is optional. When you do, you authorise that app (for example Anthropic's Claude, OpenAI's ChatGPT or Cursor) on a Clonify screen to use your account with your own permissions: it can read the information you have access to (your clone's conversations, contacts, sales, courses, emails and your clone's knowledge) and create, change or delete content when you ask it to.

Clonify only gives that app the data each action it runs asks for, at the moment it runs it. What the app does with that data afterwards is governed by its own terms and privacy policy, which you accept with it. If the information includes data about your contacts or students, you, as controller of that data, decide to share it with the AI you connect.

To keep the connection we only store an identifier of the app, the address it returns to and access codes that we never keep in readable form (only their fingerprint). The access code expires after one hour and is renewed while you keep using the connection; if it goes unused for 60 days, it stops working. You can disconnect it at any time under Settings → Connect your AI: every code stops working immediately.

A.9 Social publishing

Connecting a social account is optional. You do it yourself from Marketing → Social media, signed in to your Clonify account. You can connect a Facebook Page, an Instagram professional account, a Threads profile, a YouTube channel, a TikTok account, and a LinkedIn profile or the LinkedIn company pages you administer. Networks open in phases, and that screen shows which ones are available on your account. Each one has its own section below. Pinterest, Bluesky and Google Business are not available.

When you connect a network, Clonify stores the identifier and name of the account or Page, the public username and an access token encrypted at rest. We do not store your password for that network. With that permission we publish only what you schedule (text, a link and the image or video whose address you give us) and we read aggregate figures for that post and the account: impressions, reach, reactions, comments, shares, saves, clicks and followers, as each network provides them. This connection does not read direct messages or reply to comments. The clone's Instagram messages remain a separate connection, under each clone's Channels.

Clonify's desktop app schedules posts on the same connected accounts. It does not open a connection of its own. You can disconnect an account at any time: we delete the token and cancel anything not yet published. What is already published stays on the network until you delete it there. If you ask Meta to delete your data, we disconnect the social accounts linked to that Meta user and give you a confirmation code on the instructions page.

How to ask for deletion of social data

YouTube connection (Google user data)

Connecting your YouTube channel is optional and only relevant if you publish videos from Clonify. Networks open in phases: under Marketing → Social media you can see whether it is available on your account and connect it yourself. For this connection, Clonify uses the YouTube API Services. By connecting you agree to the YouTube Terms of Service, and the Google Privacy Policy applies. Clonify requests two permissions through Google's OAuth flow:

• youtube.upload: upload to your channel the video or Short you schedule, with the title, description, privacy setting and thumbnail you choose.
• youtube.readonly: know which channel you connected (identifier, name, handle, picture and subscribers) and read the views, likes and comment counts of the videos Clonify uploaded for you.

What we store. The channel data listed above; Google's access and refresh tokens, encrypted; and for each post, the title, description, video and thumbnail addresses, the options you chose, its status, the video's YouTube identifier and its figures. We do not store your Google password. The video file is not kept: it passes through memory while it uploads to YouTube.

What we use it for. Only to publish what you schedule and show you how it did. We do not edit or delete videos on your channel, read your other videos or the text of comments, or write comments. We do not sell this data or use it for advertising or to train AI models. It only goes to Google and to the providers that host the service (Neon and Vercel, in section C). If you ask your Clonify assistant about it, it passes through the language models in section C only to answer you; if you ask for it from an external AI you connected, section A.8 applies.

Clonify's use and transfer of information received from Google APIs, including the YouTube API Services, to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

How long. Tokens, for as long as the channel stays connected: we delete them when you disconnect it or as soon as we see you have withdrawn the permission. While the channel is connected, its data and figures are updated every few hours; anything YouTube has not confirmed for 30 days is deleted. Seven days after you disconnect or we detect that you have withdrawn the permission, we delete the channel data, the figures and each video's identifier. What you wrote yourself (title, description, addresses and options) stays in your history until you ask us to delete it or the periods in section D apply when you close your Clonify account.

How to revoke and delete. Disconnect the channel under Marketing → Social media: we delete the tokens straight away, ask Google to withdraw the permission and cancel anything not yet published. You can also remove Clonify at https://myaccount.google.com/permissions: Google does not tell us, but we see it the next time we use the connection, usually within a few hours. We then delete the tokens and the same 7-day period applies. To delete the data sooner, or what you wrote, write to privacy@clonify.com. What is already published stays on YouTube until you delete it there.

TikTok connection

Connecting TikTok is optional and only relevant if you post videos from Clonify. You authorise it yourself on TikTok's screen (Login Kit), which shows these permissions:

• user.info.basic: know which account you connected (identifier, name and picture), to show it to you in Marketing → Social media and before posting.
• video.publish: post to your account the video you confirm in Clonify, with the caption, cover, privacy level, interaction settings and commercial content disclosure you choose.
• video.list: read the views, likes, comments and shares of the videos Clonify posted for you. It is optional: without it you can still post, but there are no figures.

What we store. The account identifier, its name, username and picture; TikTok's access and renewal tokens, encrypted; and for each post, the text, the video address, the options you chose, its status and its figures. We do not store your TikTok password. The video file is not kept: if Clonify has to upload it, it passes through memory and goes to TikTok.

What we use it for. Only to post what you confirm and show you how it did. We do not read your other videos, your messages or your followers. We do not sell this data or use it for advertising or to train AI models, and it only goes to TikTok and to the providers that host the service (Neon and Vercel, in section C). If you ask your Clonify assistant about it, it passes through the language models in section C only to answer you; if you ask for it from an external AI you connected, section A.8 applies.

How long. Tokens, for as long as the account stays connected: we delete them when you disconnect it. A video's figures are updated while it is connected. The account name and the post history stay in your panel after you disconnect, until you ask us to delete them or the periods in section D apply when you close your Clonify account.

How to revoke and delete. Disconnect the account under Marketing → Social media: we delete the tokens straight away and cancel anything not yet published. You can also remove Clonify in TikTok (Settings and privacy → Security → Apps with permission): we lose access, but TikTok does not tell us, so disconnect it in Clonify too to delete the tokens. To delete the rest of the data, write to privacy@clonify.com. What is already published stays on TikTok until you delete it there.

LinkedIn connection

Connecting LinkedIn is optional and only relevant if you post from Clonify. Your personal profile and your company pages are two independent connections: you authorise each one separately on LinkedIn's screen and you can have just one of them. These are the permissions.

Personal profile:

• openid, profile: know which member is connecting their account and show you their name and picture in Marketing → Social media and when posting.
• w_member_social: post to your profile the text, image or video you schedule in Clonify.
• r_member_social: read how many reactions and comments what Clonify posted to your profile has received. It is only requested if LinkedIn grants this permission to Clonify; without it you can still post from your profile, but there are no figures.

Company pages:

• rw_organization_admin: see which pages you administer, so you can choose where to post, and read the page's followers and the impressions, reach and clicks of what Clonify posted. We do not change the page's settings, roles or admins.
• w_organization_social: post to the page you choose the text, image or video you schedule in Clonify.
• r_organization_social: read how many reactions and comments what Clonify posted to the page has received.

What we store. From the profile, your member identifier, your name and the address of your picture. From each page, its identifier, its name and its public LinkedIn address, and your member identifier. From both connections, the permissions granted and the access tokens and, if LinkedIn grants one, renewal tokens, always encrypted. From each post, the text, the link, the file address, the time, the status and the aggregate figures. We do not store your LinkedIn password or ask for your email. The file is not kept: Clonify downloads it from the address you give us, sends it to LinkedIn and does not keep a copy.

What we use it for. Only to post what you schedule and show you how it did. We do not comment, react or send messages, and we do not read your connections, your messages or other posts. We do not sell this data or use it for advertising or to train AI models, and it only goes to LinkedIn and to the providers that host the service (Neon and Vercel, in section C). If you ask your Clonify assistant about it, it passes through the language models in section C only to answer you; if you ask for it from an external AI you connected, section A.8 applies.

How long. Tokens, for as long as the account stays connected: we delete them when you disconnect it. LinkedIn access expires after 60 days and is only renewed automatically if LinkedIn provides a renewal token; otherwise you will need to connect again. Figures are updated while the account is connected. The account name and the post history stay in your panel after you disconnect, until you ask us to delete them or the periods in section D apply when you close your Clonify account.

How to revoke and delete. Disconnect your profile and each page under Marketing → Social media: we delete the tokens straight away and cancel anything not yet published. You can also remove Clonify in LinkedIn (Settings & Privacy → Data privacy → Permitted services): we lose access, but LinkedIn does not tell us, so disconnect it in Clonify too to delete the tokens. To delete the rest of the data, write to privacy@clonify.com. What is already published stays on LinkedIn until you delete it there.

Facebook, Instagram and Threads connection

Connecting these networks to publish is optional. You authorise it yourself on the Meta, Instagram or Threads screen. It is a separate connection from the Lead Ads one (A.7) and from the clone's Instagram messages. These are the permissions.

• pages_show_list, pages_manage_posts, pages_read_engagement, read_insights, pages_read_user_content: on Facebook, see the Pages you manage, post what you schedule to the one you connect and read aggregate figures for the Page and those posts, including their views, clicks, reactions, comments and shares. We also show you the latest comments on those posts (author, text and date), for you to read only. We do not read your ads figures.
• instagram_business_basic, instagram_business_content_publish, instagram_business_manage_insights: on Instagram, if you sign in with Instagram, identify your professional account, post what you schedule and read its aggregate figures.
• instagram_basic, instagram_content_publish, instagram_manage_insights, pages_show_list, pages_read_engagement: the same if you connect the Instagram account linked to a Facebook Page.
• threads_basic, threads_content_publish, threads_manage_insights: on Threads, identify your profile, post what you schedule and read its aggregate figures.

What we store. Your Meta user identifier and, for each Page or account, its identifier, name, public username and, on Instagram and Threads, the address of its picture; the permissions granted; the access tokens and, when the connection goes through Facebook, your user token to renew them, always encrypted; follower counts; and for each post, the text, the link, the file addresses, the time, the status, its identifier on the network and its figures. We do not store your password. Facebook comments are read when you open the post and are not stored. Files are not kept: the network collects them from the address you give us.

What we use it for. Only to post what you schedule and show you how it did. We do not read direct messages or reply to comments with this connection. We do not sell this data or use it for advertising or to train AI models. It only goes to Meta and to the providers that host the service (Neon and Vercel, in section C). If you ask your Clonify assistant about it, it passes through the language models in section C only to answer you; if you ask for it from an external AI you connected, section A.8 applies.

How long. Tokens, for as long as the account stays connected: we delete them when you disconnect it or when we receive a deletion request from Meta. Figures are updated every few hours while it is connected. The account data and the post history stay in your panel after you disconnect, until you ask us to delete them or the periods in section D apply when you close your Clonify account.

How to revoke and delete. Disconnect the account under Marketing → Social media: we delete the tokens straight away and cancel anything not yet published. You can also remove Clonify from Meta (Settings → Apps and websites): we lose access, but to delete the tokens also disconnect it in Clonify or ask for deletion as explained below. To delete the rest of the data, write to privacy@clonify.com. What is already published stays on the network until you delete it there.

A.10 Clonify Studio (desktop app)

Clonify Studio is a free app you install on your computer. It works with the AI you connect yourself. To use it you need a Clonify account, and the rest of this policy applies to that account. This section explains what stays on your computer, what goes to that AI and what Clonify receives.

On your computer. Your videos, whiteboards and creations are stored on your computer, and videos and audio are transcribed there with Whisper. Any API keys you add are stored on your computer, encrypted by the system where it allows this. Studio updates itself and downloads the programs it needs from GitHub and other public repositories, which receive your IP address as with any download.

Permissions. By default, your AI only reads each creation's folder and what you put on the whiteboard, and only writes to that creation. You can give it full access to your computer on a specific whiteboard. That option is off by default. The app also reads your skills and your creations' sessions in your computer's Claude Code folder, without sending them to Clonify. When it opens, Studio also adds itself to your Claude Code and Codex, if you have them, using their official commands, so you can launch your templates from them. That connection only works within your computer and with a key, and you can remove it under Connections.

Your AI. Studio launches the official Claude Code and Codex programs. You sign in to your Anthropic or OpenAI account on each company's own screen, and Studio does not read or store those credentials. What your AI needs in order to work, such as your instructions, texts, transcripts, images or video frames, goes to Anthropic or OpenAI under your account and is governed by their terms and privacy policy. If you connect a key for another service, what you ask of it goes directly to that service. From Studio, your AI can look up your Clonify account as explained in A.8 and create drafts, but it cannot send, publish or delete. While it works under those default limits, it cannot reach your contacts, purchases, conversations, students, bookings or answers either.

What Clonify receives.

• Your account and your seat: your email, your name if you sign in with Google, the invitation link you came through and your answers to the opening questions.
• Usage signals: when the app asks Clonify for permission or uses credits, and its version. The first time you use it, it also sends PostHog an anonymous event for each opening screen, so we can see where people stop, with the version and operating system. The app does not tell us what you create, unless you accept the recording explained below.
• Credits: purchases, balance and transactions, with the tool, model and cost of each use. Payment is processed by Stripe.
• What you send through Feedback, with its screenshots.
• What you publish in the Community: templates, covers, ratings and comments. An Anthropic AI reads each template's text and the team reviews it before publishing.
• What you or your AI upload to your Clonify account, such as drafts and photos.

Your answers and what you have done in Studio are kept as tags on your contact in Clonify's own account, so we know what to show you and write to you about Studio and Clonify. Every commercial email includes an opt-out, as set out in A.3.

Tools paid with credits. They are optional. What you request passes through Clonify to its provider: images to Google (Gemini), voice to ElevenLabs, video and audio clean-up to fal.ai, and Claude by credits to Anthropic. Clonify does not keep the content of those requests, only what it needs to charge for and track them, such as the model, duration and cost. If you clone your voice, your recording goes to ElevenLabs with your consent, and we keep when you gave it, its text and a fingerprint of the audio. You can remove it, and it is then deleted from ElevenLabs as well.

Optional recording. At the end of the opening tour, Studio offers to record your first 10 minutes of use so we can see how it is used. It is off by default, and the legal basis is your consent. If you accept, the recording of that window goes to PostHog along with your email and account number. It shows what appears in the window, including the whiteboard, except what you type in fields, your keys and your file paths. A notice at the top shows while it records, and you can stop it at any time.

You control what is on your computer. To delete your account or exercise your rights over what Clonify receives, write to privacy@clonify.com.

B. Contact and visitor data processed for a creator

When a visitor interacts with a creator's clone, the creator is the data controller and Clonify is the data processor, bound by the Data Processing Addendum.

B.1 Data processed

• Identifiers: email and optional name when the visitor logs in via OTP; anonymous cookie ID when anonymous.
• Conversations: full transcripts of messages with the clone.
• Memory profile: AI-generated summary plus five neutral fields (context, goal, problem, constraints, next step) derived from the conversation, to personalise future replies.
• Technical: IP address, user agent, language, originating page.
• Meta Lead Ads: When the creator enables the connection, we process the name, email, phone number and answers to questions in the selected forms. We retain the questions and options needed to interpret those answers, the submission date and the source information Meta provides about the Page, form, campaign, ad set, ad and platform. These data appear in the contact record. The creator is the controller of these data and determines the content, legal basis and retention of their ad form.
• Connected channels: if the creator connects WhatsApp, Instagram or Discord, we process the messages exchanged there with the clone. Those platforms also process them under their own terms with the visitor.
• Meetings: bookings and, when the creator records a meeting, the recording and its automatic transcript. Participants are told before joining that the session may be recorded.
• Exams: answers, grade and, if the creator turns on supervision, the browser incidents (leaving full screen, switching tabs, copying or pasting). Open answers can be graded by AI. If the creator makes the AI grade final, the student may ask the creator to review it.
• Identity check in exams: if an exam requires it, Stripe compares a photo of the student's ID document with a selfie. This is biometric data, so it only happens after the student gives explicit consent on screen (art. 9.2.a GDPR). Clonify only keeps the result and the verified name, not the images, which stay with Stripe.
• Cookies: see the Cookie Policy.

B.2 OTP clickwrap

When a visitor enters the one-time code received by email, they accept the visitor terms and this privacy policy. The acceptance is timestamped and linked to the email address.

B.3 Profiling (art. 22 GDPR)

The memory profile is automated processing designed to personalise the clone's behaviour. It does not produce legal effects or decisions significantly affecting the visitor. Visitors may reset or delete their memory profile by writing to privacy@clonify.com, or continue anonymously to avoid building one.

B.4 Artificial intelligence

The clone always introduces itself as an AI: a label in the chat window, a first message on WhatsApp, Instagram and Discord, and the greeting in voice calls. If someone sincerely asks whether they are talking to a person, it says it is an AI clone. Clonify does not use creators' or visitors' data to train AI models, its own or anyone else's, nor to improve another creator's clone. The language models that generate replies (OpenAI and Anthropic) are used through their API, under terms in which they do not use that data to train their models.

C. Subprocessors

We rely on the following subprocessors, each bound by a DPA with appropriate safeguards (Standard Contractual Clauses for US-based vendors). The ones that process creators' audience data are also listed in the DPA.

PostHog analytics and protected replays on public marketing pages or during a new account's first 14 days only activate after analytics consent. Technical error logging (what broke, on which page and in which browser, without identifying you or storing anything on your device) is sent to PostHog without consent, on the basis of our legitimate interest in keeping the service working. Meta and Google Ads measurement, including YouTube campaigns, only activates after advertising consent and when those tools are configured.

D. Retention

Clonify applies a Shopify-style soft-delete retention schedule:

• Active tenant: creator data retained indefinitely while the subscription is active. Visitor data retained for 3 years from last interaction.
• Tenant cancelled: workspace enters "suspended" state, visitor data retained for 90-day grace period.
• After 90 days: visitor data purged. Minimal tenant skeleton (billing/tax records) kept 4 years for Spanish fiscal obligations, then deleted.
• Visitor deletion request: processed immediately, regardless of tenant status.

E. Your rights

Under GDPR and Spanish data protection law you have the rights of access, rectification, erasure, opposition, restriction, portability, and not to be subject to solely automated decisions (ARSULIPO).

To exercise any of these, write to privacy@clonify.com including proof of identity. We respond within 30 days. If you are a visitor of a clone, we will forward the request to the corresponding creator (controller) when applicable.

You may also lodge a complaint with the Spanish AEPD (www.aepd.es) or your local supervisory authority.

F. Security

We apply technical and organisational measures: multi-tenant isolation enforced by code review and lint, TLS in transit, encryption at rest by Neon, rate limiting on sensitive endpoints, OTP for sensitive flows, role-based access control, and CORS pinning.

G. International transfers

Marea Kiss LLC is established in the United States, and the main database and application hosting are located in the US (Virginia). Several subprocessors are also based in the United States. Transfers are covered by Standard Contractual Clauses (Commission Decision 2021/914) and, where applicable, by the EU-US Data Privacy Framework.

H. Minors

Clonify is intended for users over 16. We do not knowingly collect data from minors below this age.

I. Changes

We may amend this policy to reflect legal or service changes. Material changes will be notified by email or by a prominent notice on the platform.