Privacy Policy
Effective: 2026-05-12 · Version v13-2026-05-11
Effective Date: 2026-05-12 · Last Updated: 2026-05-12 · Version: v13-2026-05-11
This Privacy Policy describes how Surface Owl Inc., a California corporation ("Clarifi," "we," "us," or "our"), collects, uses, shares, and protects personal information in connection with Clarifidata.app — the website, application, and related services we operate (collectively, the "Service"). Clarifidata.app is a product name and trademark of Surface Owl Inc.; it is not a separate legal entity.
This Privacy Policy is incorporated into and forms part of our Terms of Service.
1. Scope and Notice at Collection
1.1 Scope
This Policy applies to personal information we collect from and about:
- Visitors to clarifidata.app and related domains
- Registered account holders (Free, Watch, Pro, and Board tiers)
- Authorized seat invitees on paid accounts
- Recipients of our marketing or transactional emails
This Policy does not apply to information about nonprofit organizations and their officers contained in publicly available IRS Form 990 filings, which we obtain from the U.S. Internal Revenue Service, ProPublica's Nonprofit Explorer, the National Center for Charitable Statistics, and similar public sources. That information is publicly disclosed by the IRS and is not personal information about you. If you happen to also be a nonprofit officer named in a public filing, your inclusion in such filings is governed by federal nonprofit-disclosure law and is not within our control.
1.2 Notice at Collection (CCPA §1798.100(b); 11 CCR §7012)
At each point where we collect personal information from you (signup, billing checkout, support contact), we present a short, in-context Notice at Collection identifying:
- The categories of personal information we are collecting at that moment;
- The business or commercial purposes for which we are collecting it; and
- A link to this complete Policy.
We do not collect personal information for purposes that are not described in this Policy or in the corresponding Notice at Collection.
2. Information We Collect
2.1 Information You Provide Directly
| Category | Examples | When collected |
|---|---|---|
| Account information | Name, email address | Account registration |
| Account credentials | Password (handled by Auth0; we never see, store, or have access to your password in any form) | Account registration |
| Organization affiliation | EIN of primary nonprofit, school name, role/title (optional) | Account setup |
| Domain verification data | Email domain you administer; verification challenge responses | Paid-tier signup |
| Billing information | Payment card details, billing address (collected by Stripe; we receive only tokenized references and last-4 digits) | Subscription purchase |
| User-generated content | Chat queries, custom peer lists, comments, support tickets | Use of the Service |
| Communications | Messages you send to our support email address | Voluntary contact |
| Survey or interview responses | If you participate in customer discovery | Voluntary participation |
| Inbound form submissions | Name, email, role, message, organization name, EIN, IP address; optional marketing-email opt-in | Submission of a public-facing contact, demo, sample, or sign-up form on our website (may occur before you create an account) |
2.2 Information Collected Automatically
| Category | Examples | Source |
|---|---|---|
| Usage data | Pages viewed, features used, time spent, click paths | Application logs |
| Device and connection data | IP address (used for approximate geolocation only), browser type, operating system, referrer URL, language preference | Web requests |
| Authentication metadata | Login timestamps, session duration, MFA events | Auth0 |
| Performance data | Page load times, error events, debug traces | Application monitoring |
| Cookies and similar technologies | Session cookies, preference cookies, analytics cookies | See Section 5 |
2.3 Information from Third Parties
| Source | Information |
|---|---|
| Stripe | Subscription status, billing period, payment method type (last-4 digits), invoice history |
| Auth0 | Authentication state, email verification status, role assignments |
| Public IRS filings (about your designated organization, where the EIN you choose corresponds to your real organization) | Officer names, compensation, financial filings |
We do not purchase personal information from data brokers.
We are not a "data broker" as defined in California Civil Code §1798.99.80, because the only personal information we collect about identified individuals is collected directly from those individuals through our Service. Public information we collect about nonprofit organizations and their officers from IRS Form 990 filings is publicly disclosed by the IRS as a matter of federal nonprofit-disclosure law and is not collected for sale to third parties.
2.4 CCPA Categories of Personal Information (Civ. Code §1798.140(v))
The following table maps the personal information described above to the enumerated CCPA statutory categories, with sources, purposes, and retention by category. The categories of third parties to whom we disclose each category of personal information are described comprehensively in §4.1 (Service Providers).
| CCPA Category | Collected? | Examples | Sources | Purposes | Retention |
|---|---|---|---|---|---|
| (A) Identifiers | Yes | Name, email, IP address, account ID, EIN | You, Auth0, web requests, inbound form submissions | Provide Service, authenticate, communicate, prevent fraud, respond to inbound inquiries | Account lifetime; see §6 |
| (B) Customer records (Civ. Code §1798.80(e)) | Yes | Name, billing address, payment-method last-4 digits | You, Stripe, inbound form submissions | Process subscriptions, billing, tax, respond to inbound inquiries | Account lifetime; billing record retained seven (7) years with PII deidentified after closure (see §6) |
| (C) Protected classification characteristics | No | — | — | — | — |
| (D) Commercial information | Yes | Subscription tier, transaction history, feature usage | You, Stripe, application logs | Provide Service, billing, product analytics | Account lifetime; billing 7 years |
| (E) Biometric information | No | — | — | — | — |
| (F) Internet/network activity | Yes | Pages viewed, click paths, session data, performance data | Application logs | Provide Service, security, debugging, analytics | 12 months |
| (G) Geolocation | Limited | Approximate location inferred from IP only (city/region level); no precise geolocation collected | Web requests | Security (anomalous-login detection), analytics | 12 months |
| (H) Sensory information (audio/visual) | No | — | — | — | — |
| (I) Professional/employment information | Optional | Role/title (only if you provide it) | You | Personalize onboarding | Account lifetime |
| (J) Education information (FERPA-covered) | No | — | — | — | — |
| (K) Inferences | Limited | Inferred feature interest from usage patterns | Application logs | Improve Service | 12 months |
2.5 Sensitive Personal Information (Civ. Code §1798.140(ae))
We collect a limited subset of sensitive personal information — specifically, account login credentials (email address used as username, and password) — solely to authenticate you and secure your account. Processing of these credentials is limited to purposes specified in 11 CCR §7027(m) (authenticating users and securing the Service), and falls within the safe harbor described in Cal. Civ. Code §1798.121(a). We do not use these credentials for any other purpose, including analytics, marketing, profiling, or training of machine-learning models.
Under California Civil Code §1798.121(a), processing of sensitive personal information for these limited authentication and security purposes does not give rise to a right to limit. We do not use this sensitive personal information for any other purpose, do not infer characteristics from it, and do not disclose it for any purpose other than to provide and secure the Service. The right to limit therefore does not apply to our processing.
We do not collect or process any other category of sensitive personal information (such as government identifiers, account log-in for non-Service accounts, financial account access codes, precise geolocation (we collect only approximate IP-based geolocation as disclosed in §2.4(G), which is not "precise" for purposes of §1798.140(ae)), racial or ethnic origin, religious beliefs, union membership, mail/email/text-message contents not directed to us, genetic data, biometric data for identification purposes, or sex-life or sexual-orientation data).
3. How We Use Information
We collect, use, and retain personal information only to the extent reasonably necessary and proportionate to achieve the purposes described in this Section, consistent with our obligations under California Civil Code §1798.100(c). Specifically, we use personal information to:
- Provide, operate, and maintain the Service
- Process subscriptions, payments, and renewals
- Authenticate users and prevent unauthorized access
- Send transactional communications (account confirmations, password resets, renewal reminders, security alerts)
- Send marketing communications about new features or pricing — only if you opt in (see Section 11)
- Respond to your inquiries and provide support
- Monitor and improve the Service, including diagnosing technical issues, measuring feature usage, and conducting product research
- Detect, prevent, and respond to fraud, abuse, security threats, and violations of our Terms
- Comply with legal obligations and respond to lawful requests from public authorities
- Enforce our Terms of Service and protect our rights
3.1 No Use for Training Machine-Learning Models
We do not use customer inputs (including Chat queries, custom peer lists, comments, or any other Customer Data you submit) to train, fine-tune, evaluate, or benchmark any machine-learning model — neither models we operate ourselves nor any third-party model. Anthropic processes Chat queries solely to generate a response to you and is contractually prohibited from training on customer inputs.
We log Chat queries internally to detect abuse, debug issues, and measure feature usage. Aggregated, deidentified usage statistics may be used for product research, but identifying inputs are never used to train any model.
3.2 No Automated Decision-Making
We do not use automated processes to make decisions producing legal or similarly significant effects about any individual. The Service produces analytical Outputs about public nonprofit organizations; all decisions made in reliance on Outputs are made by the user, not by us.
4. How We Share Information
We share personal information only as described below.
We do not sell personal information for monetary or other valuable consideration, and we do not share personal information for cross-context behavioral advertising, as those terms are defined in the California Consumer Privacy Act. Our disclosures to vendors listed in Section 4.1 are made under written contracts that meet the CCPA's service-provider/contractor requirements (Civ. Code §1798.140(ag), (j)) and are not "sales" or "sharing" under California law.
4.1 Service Providers (Subprocessors)
We share personal information with vendors who help us provide the Service. Each is contractually obligated to protect personal information and to use it only for the purposes we direct.
| Subprocessor | Function | Data shared |
|---|---|---|
| Auth0 (Okta, Inc.) | Authentication and identity management | Email address, password (hashed), authentication metadata |
| Stripe, Inc. | Payment processing, subscription management, billing portal | Name, email, billing address, payment details, subscription status |
| SparkPost (MessageBird) | Email delivery (transactional and marketing) | Email address, name, message content |
| Modal (Modal Labs, Inc.) | Optional cloud GPU compute for data processing | Usage data only; no personal identifiers processed |
| Anthropic, PBC | Large-language-model API for the Chat feature | Chat queries (text content); no account identifiers |
| Fly.io | Application hosting and database hosting | All application data (encrypted at rest) |
| Cloudflare | Network protection and DDoS mitigation | IP address, request metadata |
Public subprocessor list and change notice. We maintain a current public list of subprocessors at clarifidata.app/subprocessors. We will provide at least thirty (30) calendar days' notice of any new subprocessor that materially affects the processing of your personal information by posting an update to that page and, for paid-tier customers, by email. You may object to a new subprocessor by contacting our support email address within that period; if we cannot reasonably accommodate your objection, your sole remedy is to cancel the affected subscription with a prorated refund of the unused portion of the current term. See Terms §5.2 for the prorated subprocessor-objection refund and Terms §5.2 and §14.5 for other refund circumstances.
4.2 Legal and Safety Disclosures
We may disclose personal information if we believe in good faith that disclosure is necessary to: (a) comply with applicable law, regulation, legal process, or governmental request; (b) protect the rights, property, or safety of Clarifi, our users, or others; (c) detect, prevent, or respond to fraud, abuse, security threats, or technical issues; or (d) enforce our Terms of Service.
4.3 Business Transfers
If Clarifi is involved in a merger, acquisition, financing, asset sale, or bankruptcy, personal information may be transferred as part of that transaction. We will provide notice before personal information is transferred and becomes subject to a different privacy policy.
4.4 With Your Consent
We may share personal information for any other purpose with your express consent.
4.5 Organization-Linked Accounts
If an organization that administers your email domain links your account under Terms §3.4, the organization's administrator may access your account information, the Customer Data you submit (such as Chat queries, custom peer lists, and comments), and Outputs you generate. We provide advance notice by email before linking takes effect, and you may opt out by deleting your account before linking, per Terms §3.4.
5. Cookies and Similar Technologies
We use a small number of cookies and similar technologies to operate the Service and, with your consent, to measure aggregate usage. Cookie categories:
| Category | Purpose | Consent | Duration |
|---|---|---|---|
| Strictly necessary | Authentication and session management | Required for the Service to function — no separate consent collected | Session, up to thirty (30) calendar days |
| Analytics | Aggregate first-party usage measurement via Google Analytics (page views, sessions, feature use) — used solely to understand and improve the Service | Opt-in via cookie banner; off by default | Up to two (2) years |
Cookie banner and consent. Before any non-strictly-necessary cookie is set on your browser, we present a cookie banner allowing you to grant or decline consent for the Analytics category. You may change your choice at any time via the cookie preferences link in our website footer.
Google Analytics configuration. We configure Google Analytics to maximize first-party-only use and to avoid any flow of data to Google for advertising purposes: Google Signals is OFF, IP addresses are anonymized before storage, no Google Ads or audience integrations are enabled, and analytics data retention is set to the minimum supported retention window. We do not use cookies for cross-site behavioral advertising and do not engage in selling or sharing of personal information for cross-context behavioral advertising as those terms are defined under the California Consumer Privacy Act (see §4).
Global Privacy Control (GPC). We honor the Global Privacy Control browser signal as a CCPA opt-out request to the extent the right to opt out under California law applies to our processing. Because we do not engage in "selling" or "sharing" as defined by CCPA, our processing already complies with that opt-out posture by default; GPC has no functional effect on cookie behavior beyond our recording of the signal.
"Your Privacy Choices" / "Do Not Sell or Share My Personal Information" link. California Civil Code §1798.135 requires a "Do Not Sell or Share My Personal Information" or "Your Privacy Choices" link only from businesses that engage in "selling" or "sharing" personal information as those terms are defined in the CCPA. Because we do not sell or share personal information for cross-context behavioral advertising or any other purpose (as stated in §4), we are not required to provide such a link, and none is provided. If our practices change, we will update this Policy and provide the required link before any such sale or sharing begins.
Browser-level blocking. Most browsers let you block or delete cookies through settings. Blocking strictly necessary cookies will prevent the Service from functioning correctly.
6. Data Retention
We retain personal information only as long as necessary to provide the Service or comply with legal obligations. The retention periods below reflect what is reasonably necessary and proportionate to achieve the stated purposes for each category of personal information, consistent with our data-minimization commitment in §3 and Cal. Civ. Code §1798.100(a)(3) and (c). The following table is the canonical retention schedule (referenced from Terms of Service §14):
| Data category | Retention period |
|---|---|
| Active account data | Duration of your account |
| Free-tier data not accessed for 12 months | Existing data preserved; new filing ingestion frozen after 24 months |
| Free-tier accounts not re-confirmed within thirty (30) calendar days of annual re-engagement email | Suspended; data preserved for ninety (90) calendar days, then deidentified |
| Cancelled paid accounts | Account data retained ninety (90) calendar days after cancellation, recoverable via reactivation. Reactivation more than thirty (30) calendar days after cancellation is treated as a new subscription per Terms §5.4 (chat trial resets, retention timers reset). After ninety (90) calendar days, account data is deidentified unless you have requested deletion under §10. Customer Data export is available for thirty (30) calendar days following termination per Terms §14.4. |
| Failed-payment dunning | Stripe runs dunning approximately 21 days; account data preserved through dunning, then downgraded to Free tier with retention per the Free-tier rows above |
| Billing records | Retained for seven (7) years (tax and audit requirements), with personally identifying information deidentified after account closure |
| Consent records (clickwrap, auto-renewal, marketing opt-in/opt-out) | All consent and consent-withdrawal events are stored together in our consent_records system. Auto-renewal consent records are retained for at least three (3) years from the date of consent, or one (1) year after termination of the related subscription, whichever is longer, as required by Cal. Bus. & Prof. Code §17602(a)(6), and are exempt from user-initiated deletion under CCPA §1798.105(d)(8) (compliance with legal obligation). ToS and Privacy Policy clickwrap acceptance records are retained for the duration of your account and for one (1) year after account termination. Marketing opt-in and opt-out records are retained for at least three (3) years from the event date to demonstrate compliance with CAN-SPAM and state-law opt-out obligations |
| Chat query logs | Retained 90 days for abuse detection and debugging; aggregated metrics retained longer |
| Authentication logs | Retained 12 months |
| Backups | Retained no more than thirty (30) calendar days; backups are overwritten on standard rotation cycles managed by our hosting provider |
Upon a verified deletion request (Section 10), we accelerate deletion of personal information from active systems while retaining the minimum data necessary to satisfy legal obligations (in deidentified form where possible).
6.1 Deidentification Commitments (Civ. Code §1798.140(m))
Where we deidentify personal information in lieu of deletion, we:
(a) Take reasonable measures to ensure the data cannot be re-associated with you; (b) Publicly commit (here, in this Policy) to maintain and use the data only in deidentified form; (c) Contractually obligate any downstream recipient to do the same; (d) Make no attempt to re-identify you; and (e) Implement technical safeguards (such as removal or hashing of direct identifiers, aggregation, and access controls) designed to prohibit re-identification of the data.
7. Data Security and Breach Notification
7.1 Security Safeguards
We implement reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, alteration, disclosure, or destruction. These include:
- TLS encryption for all data in transit
- Encryption at rest for sensitive data fields and database backups
- Authentication via Auth0 (industry-standard identity provider)
- Payment data isolation via Stripe (we never store full card numbers)
- Access controls limiting employee access to personal information on a need-to-know basis
- Audit logging of administrative actions
- Regular security review of dependencies and infrastructure
7.2 Breach Notification
If we determine that a breach of the security of our system has occurred and that personal information of California residents was, or is reasonably believed to have been, acquired by an unauthorized person, we will notify affected users in the most expedient time possible and without unreasonable delay, consistent with California Civil Code §1798.82, by email to the address on file and by posting on our website. The notice will include the information required by §1798.82(d).
Where direct individual notice is not feasible — because the cost would exceed the statutory threshold, the number of affected residents exceeds the statutory threshold, or we lack sufficient contact information — we will provide substitute notice as authorized by Cal. Civ. Code §1798.82(d)(2), which may consist of email notice when available, conspicuous posting on our website for at least thirty (30) calendar days, and notification to major statewide media. Where a single breach affects more than five hundred (500) California residents, we will electronically submit a single sample copy of the security breach notification to the California Attorney General as required by Cal. Civ. Code §1798.82(f).
For users in other states, we will provide notification consistent with the applicable state breach-notification law.
No security measure is perfect. We do not warrant against unauthorized access to your data; please use a strong, unique password and notify us immediately of any suspected compromise.
8. Children's Privacy, FERPA, and Health Data
The Service is designed for adult school administrators, board members, and advisors. We do not collect, host, or process student personal information, FERPA-covered education records, or any data about persons under 18 years of age.
The Service is not directed at children under 18, and we do not knowingly collect personal information from children. If we learn we have collected information from a child under 18, we will delete it promptly. If you believe a child has provided us with personal information, contact us at our support email address.
The Service is not designed to accept Protected Health Information (PHI) as defined under the Health Insurance Portability and Accountability Act (HIPAA), and we are not a Covered Entity or Business Associate. See Terms §9.3 for restrictions on submitting PHI.
9. International Users
The Service is operated from the United States and intended for U.S. residents only. We do not target or knowingly market the Service to residents of the European Union, the United Kingdom, the European Economic Area, Switzerland, or other jurisdictions with comprehensive privacy laws (such as the GDPR or UK GDPR).
By creating an account, you represent that you are a U.S. resident. If you nonetheless access the Service from outside the United States, you do so at your own initiative, you consent to the transfer of your information to and processing in the United States, and you agree that the laws of the United States and the State of California, without regard to conflict-of-laws principles, govern your use, to the maximum extent permitted by your local law.
Use of the Service is also restricted by U.S. sanctions, as described in Terms of Service §1.
10. Your Privacy Rights
10.1 California Residents (CCPA / CPRA)
If you are a California resident, you have the following rights regarding your personal information:
- Right to know (Civ. Code §1798.110) — request information about the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collection, and the categories of third parties with whom we share it
- Right to delete (Civ. Code §1798.105) — request that we delete personal information we have collected from you, subject to legal exceptions
- Right to correct (Civ. Code §1798.106) — request correction of inaccurate personal information
- Right to data portability (Civ. Code §1798.130(a)(3)) — receive the personal information we have collected about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another entity without hindrance
- Right to opt out of sale or sharing (Civ. Code §1798.120) — we do not sell or share personal information for cross-context behavioral advertising; this right is reaffirmed but moot for our practices
- Right to limit use of sensitive personal information (Civ. Code §1798.121) — we collect sensitive PI only for the authentication and security purposes described in §2.5, which fall within the §1798.121(a) safe harbor; this right is therefore moot for our processing
- Right to non-discrimination (Civ. Code §1798.125) — we will not deny, charge differently for, or provide a different level of Service in retaliation for your exercise of these rights
How to Exercise These Rights
Submit your request through one of these methods:
(a) Email: our support email address with the subject line "California Privacy Request." Include your account email address and a description of the request.
(b) Account settings: Logged-in users may submit a request directly from the account settings page.
We will:
- Acknowledge receipt within ten (10) business days
- Verify your identity (typically by confirming the request from your account email and validating recent account activity per 11 CCR §7060)
- Respond substantively within 45 days (extendable by an additional 45 days with notice if reasonably necessary), per Civ. Code §1798.130(a)(2). For account-deletion requests specifically, you may also use the self-serve flow described in §10.3, which typically completes within seven (7) business days.
Authorized Agents
You may designate an authorized agent to make a request on your behalf. To verify an authorized agent's authority, we may require:
(a) A copy of a written, signed permission from you authorizing the agent to act on your behalf; (b) Verification of the agent's identity; and (c) Direct confirmation from you (e.g., a reply from your account email) that you have authorized the request.
Requests submitted without these verifications may be denied or delayed.
"Shine the Light" Disclosure (Civ. Code §1798.83)
We do not share personal information with third parties for their direct marketing purposes; therefore, no California "Shine the Light" disclosure is required, and the right described in §1798.83 is moot for our practices.
10.2 Residents of Other States
Residents of certain other U.S. states have similar rights to know, delete, correct, port, and opt out of certain processing under their state laws. To exercise these rights, follow the procedure in §10.1; we apply substantially the same process for all U.S. state privacy requests.
State-Specific Disclosures
Residents of states with comprehensive consumer privacy laws — including Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), Montana (MTCDPA), Delaware (DPDPA), New Hampshire (NHPA), New Jersey (NJDPA), Maryland (MODPA), Minnesota (MNCDPA), Iowa (ICDPA), Tennessee (TIPA), and any other state whose comprehensive privacy law applies to our processing of your personal information — have rights that are substantially similar to those described in §10.1, including the rights to access, delete, correct, port, and opt out of targeted advertising, sale, and profiling that produces legal or similarly significant effects. We extend these rights to all U.S. residents regardless of whether your state's law technically applies to our processing. To exercise any of these rights, follow the procedure in §10.1, replacing "California Privacy Request" with the name of your state in the email subject line (e.g., "Virginia Privacy Request"). We apply the same identity verification, response-time, and authorized-agent procedures described in §10.1 to all such requests.
For all of the above states: we do not engage in "targeted advertising" or "sale" of personal information, so those opt-outs are reaffirmed but moot for our practices.
No profiling for significant decisions. We do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects about any individual. The Service produces analytical Outputs about public nonprofit organizations; any decisions made in reliance on Outputs are made by the user. Accordingly, the right to opt out of profiling under state privacy laws does not apply to our processing.
Appeals (VA, CO, CT, TX, OR, MT, DE, NH, NJ, MD, MN, and other states requiring an appeals process)
If we deny your privacy request in whole or in part, you may appeal that decision within a reasonable period after receiving our response. To appeal, email our support email address with the subject line "[State] Privacy Appeal" (e.g., "Virginia Privacy Appeal"), referencing the original request and explaining why you believe the denial was incorrect.
We will respond to your appeal within sixty (60) calendar days of receipt, in writing, with our decision and a plain-language explanation of the reasoning. If we deny the appeal, we will provide you with the contact information for your state's Attorney General or other regulator with jurisdiction over consumer privacy complaints, so that you may submit a complaint if you wish. We extend this appeals process to all U.S. residents on the same terms, regardless of whether your state's law technically requires it.
10.3 Account Deletion via Self-Serve
In addition to the formal request processes above, you may delete your account at any time through the account settings. Self-serve account deletion executes hard-deletion of personal information from active systems within seven (7) business days, with corresponding updates to backups occurring through normal backup-rotation within thirty (30) calendar days. This is faster than the statutory forty-five (45) calendar day CCPA response window and is offered as a convenience.
Note: Consent records relating to auto-renewing subscriptions (under Cal. Bus. & Prof. Code §17602) are retained for the statutory period described in §6 and are exempt from user-initiated deletion under CCPA §1798.105(d)(8) (compliance with legal obligation). All other personal information is deleted on request as described above.
For users who cannot log in (lost credentials, account suspended), email our support email address with the subject line "Delete account" — we will verify your identity and process the request within fourteen (14) business days (still well within the forty-five (45) calendar day legal SLA).
10.4 Annual Privacy Policy Review
We commit to reviewing this Privacy Policy at least annually for completeness and accuracy. Any material changes are subject to the notification process in §13.
10.5 Accessibility
This Privacy Policy is designed to be readable on common screen readers and assistive technologies, and the page that renders this Policy on our website conforms substantially with the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. If you need this Privacy Policy in an alternative accessible format, contact us at our support email address (subject line: "Accessibility") and we will provide a copy in a reasonable alternative format at no charge.
11. Marketing Communications
11.1 Opt-In Capture
We will not send you marketing communications (such as feature announcements, drip campaigns, or newsletters) unless you opt in. You may grant or withdraw consent at any of the following points:
- At account signup — by checking the "Email me about Clarifi product updates and pricing" checkbox during Auth0 signup.
- At any time after signup — by toggling marketing preferences in your account settings (see §11.3).
- On a public-facing form — if you submit a contact, demo, sample, or sign-up form on our website before creating an account, you may opt in via the checkbox on that form. If you later create an account using the same email address, your opt-in carries forward.
- By emailing our support address — see §11.3.
We record each opt-in and opt-out event (including timestamp, source, and IP address) in our consent_records system as the canonical record of your marketing preferences. Retention of those records is described in §6.
11.2 Transactional Communications
You will continue to receive transactional emails (renewal reminders, password resets, billing receipts, security alerts) regardless of your marketing preferences, as these are required to operate your account.
11.3 Unsubscribe (CAN-SPAM)
You may opt out of marketing emails at any time by:
- Clicking the "unsubscribe" link in the footer of any marketing email (unsubscribe is honored within 10 days, as required by the CAN-SPAM Act)
- Updating your communication preferences in your account settings
- Emailing our support email address with the subject "Unsubscribe"
12. Do Not Track and Global Privacy Control
Our Service does not respond to "Do Not Track" browser signals because no consistent industry standard for honoring DNT exists for first-party services. We do not use cross-site tracking or sell personal information regardless of DNT signals.
We honor the Global Privacy Control (GPC) browser signal as a CCPA opt-out request to the extent the right to opt out under California law applies to our processing. As described in §5, our processing already complies with this posture by default.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Material changes (such as new categories of personal information collected, new sharing relationships, or changes to your rights) will be communicated by email at least thirty (30) calendar days before they take effect. The "Last Updated" and "Effective Date" fields at the top of this Policy reflect the latest version. A version history is maintained internally and available on request. We also commit to an annual review of this Policy as described in §10.4.
Continued use of the Service after the effective date of an update constitutes acceptance of the updated Policy.
14. Contact
Privacy questions, requests, or complaints? Use the routing tags below to ensure timely response:
Email: clarifi-support@clarifidata.app
| Subject Line | For |
|---|---|
| California Privacy Request | CCPA / CPRA rights request (§10.1) |
| [State] Privacy Request | Other state privacy rights requests (§10.2) |
| [State] Privacy Appeal | Appeal of denied state privacy request (§10.2) |
| Privacy Inquiry | General privacy questions |
| Delete account | Self-serve account deletion (§10.3) |
| Security | Suspected security incident or breach |
| Unsubscribe | Marketing opt-out |
Mailing Address:
Surface Owl Inc. (operator of the Clarifidata.app service) c/o Republic Registered Agent Inc. 3400 Cottage Way, Ste G2 Sacramento, CA 95825
If we do not respond to your concern to your satisfaction, you may contact the California Attorney General's office (https://oag.ca.gov/privacy) or the regulator in your state of residence.