Clear Ideas Privacy Policy

Last Updated: October 21, 2025

1. Introduction

Clear Ideas Incorporated and our affiliates and subsidiaries ("Company," "we," "us," or "our") respect your privacy and are committed to protecting your personal information and your right to privacy by complying with this policy. This policy describes:

• types of information we may collect or that application users (”you”) may provide when you access, or use website and application (the "Services"); and
• our practices for collecting, using, maintaining, protecting, and disclosing that information. how we collect, use, disclose, and safeguard your information when you use the Services;

We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

Our websites and apps, and these third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

By accessing or using our Services, you acknowledge that you have read, understood, accept, and consent to the practices described in this privacy policy. If you do not agree with the terms of this Privacy Policy, please do not access the Services. Your continued use of the Services after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.

2. Information We Collect

a. Personal Information

We may collect personal information that you voluntarily provide to us through direct interactions such as when you register for an account, upload content, or communicate with us.

The types of information that we collect include:

• Personal information that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, email address, telephone number, internet protocol (IP) address, user name or other similar identifier, billing and account information, and any other identifier we may use to contact you (”personal information”). This information may include:

  • Name
  • Email Address
  • Physical Address
  • Phone Number
  • Location Data

• We provide an opportunity for any user to unsubscribe from our marketing communications on an ongoing basis by using the unsubscribe mechanism at the bottom of our emails. We also provide an opportunity for any user to unsubscribe from transactional communications (such as application notifications) by accessing notification preferences in our Services.

b. Uploaded Content

Our Services allow you to upload, share, interact or display file and other content within the Services (collectively, “User Contributions”). You post and transmit User Contributions to our Services at your own risk. The Services allow you to select privacy and security settings for such User Contributions. Please be aware that no security measures are perfect. We cannot control the actions of third parties with whom you may choose to share your User Contributions. We do not guarantee that unauthorized persons will not view your User Contributions.

User Contributions may contain personal or sensitive information. You are responsible for ensuring that you have the legal right to upload and share any information contained within the User Contributions you provide.

c. Usage Data

We automatically collect certain information when you use the Services, including:

• Device Information: IP address, browser type, operating system.
• Usage Information: Pages viewed, features used, time and date of access.
• Interaction Data: Search terms and Artificial Intelligence ("AI") chat queries.
• Analytics Data: Metrics on views, downloads, and interactions.

d. Cookies and Similar Technologies

We use cookies and local storage to enhance your experience. These technologies are essential for the functioning of the Services. For more details, see Section 7 on Cookies and Similar Technologies.

3. How We Use Your Information

We use your information for various purposes, including:

• Providing the Services: To operate, maintain, and provide you with the features and functionality of the Services.
• User Authentication: To verify your identity when you access the Services.
• Analytics and Improvements: To monitor and analyze usage and trends, to provide usage analytics to users of the Services who share User Content with you, and to improve user experience.
• Communications: To send administrative information, updates, and technical notices.
• Legal Obligations: To comply with legal requirements and enforce our policies.

Lawful Bases for Processing

Depending on your location and the specific activity, we rely on one or more of the following bases:

• Consent: Where required, we obtain your consent and you may withdraw it at any time (see Section 11).
• Contract: Processing necessary to provide the Services and perform our agreement with you.
• Legitimate Interests: Service delivery, security, fraud prevention, analytics, and permitted marketing, balanced against your rights.
• Legal Obligations: Compliance with applicable laws and regulatory requirements.
• Vital Interests/Public Interest: Protecting individuals’ vital interests or, where applicable, acting in the public interest.

4. Disclosure of Your Information

We may disclose your information in the following circumstances:

a. With Other Users

When you share User Content through the Services, the recipients will have access to the User Content you have chosen to share, which may include personal information.

b. Service Providers

We engage third-party service providers to perform functions on our behalf (e.g., hosting, data storage, AI analysis). These providers have access to personal information only as necessary to perform their functions and are obligated to maintain the confidentiality and security of your information in accordance with their respective policies.

We take reasonable steps to assess and oversee these providers, including entering into data protection terms, limiting their use to our instructions, requiring appropriate security and confidentiality, and managing any subcontractors (subprocessors) with suitable safeguards.

c. Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., court orders, subpoenas).

d. Business Transfers

In the event of a merger, acquisition, or asset sale, your personal information may be transferred. We will provide notice before your personal information is transferred and becomes subject to a different Privacy Policy.

5. International Data Transfers

Your information may be transferred to, stored, and processed in countries other than your own, including the United States and Canada. These countries may have data protection laws that are different from those of your country. We take appropriate measures to ensure that your personal information remains protected in accordance with this Privacy Policy.

Where required, we use legally recognized transfer mechanisms to protect your personal information, which may include:

• Adequacy determinations for recipient countries, where applicable.
• Standard Contractual Clauses or comparable contractual safeguards for cross-border transfers.
• Binding Corporate Rules or certification schemes, where available.
• Technical measures such as encryption in transit and at rest, access controls, and minimization.

6. Data Security

We implement commercially reasonable administrative, technical, and physical security measures to protect your personal information. We are working towards compliance with industry standards such as SOC 2 and ISO 27001. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee its absolute security.

7. Cookies and Similar Technologies

a. Essential Cookies

We use cookies that are essential for the operation of the Services. These cookies enable core functionalities such as security, network management, and accessibility.

b. Analytics

We use privacy-focused analytics tools. This helps us understand how our Services are used without compromising your privacy.

c. Managing Cookies

Most web browsers allow you to control cookies through their settings preferences. Please note that disabling cookies may affect the functionality of the Services.

8. Your Rights and Choices

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

a. Access and Correction

You have the right to request access to the personal information we hold about you and to request corrections of any inaccuracies.

b. Deletion

You may request that we delete your personal information. Please note that we may need to retain certain information for legal or administrative purposes.

c. Data Portability

You have the right to request a copy of your personal information in a structured, commonly used, and machine-readable format.

d. Opt-Out of Communications

You may opt out of receiving promotional communications from us by following the unsubscribe instructions in those communications.

e. Withdraw Consent

If we process your personal information based on your consent, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us using the information provided in Section 14.

9. Children's Privacy

Our Services are not intended for individuals under the age of 13. We do not knowingly collect personal information from children under 13. If you become aware that a child has provided us with personal information, please contact us, and we will take steps to delete such information.

10. Accessing and Correcting Your Personal Information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. You have the right to request access to and to correct the personal information that we hold about you.

You can review and change your personal information by accessing the Services and visiting your account profile page.

If you delete your User Contributions from the Services, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other users of the Services. Proper access and use of information provided on the Services, including User Contributions, is governed by our terms of service.

Data Quality

We use reasonable measures to help keep personal information accurate, complete, and up to date, and we correct inaccuracies when identified. You are responsible for ensuring the information you provide is accurate and for updating it as needed through your account or by contacting us.

11. Withdrawing Your Consent

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at privacy@clearideas.com. Please note that if you withdraw your consent, we may not be able to provide you with the Services. We will explain the impact to you at the time to help you make your decision.

12. Third-Party Links and Services

Our Services may contain links to third-party websites or services that are not owned or controlled by us. We are not responsible for the privacy practices of such third parties. We encourage you to review the privacy policies of every website you visit.

13. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Any changes will be effective immediately upon posting the updated policy on the Services. Your continued use of the Services after the posting of the revised Privacy Policy constitutes your acceptance of the changes.

14. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

Email: privacy@clearideas.com

15. Governing Law

We are based in Toronto, Ontario, Canada, and we comply with all applicable Canadian laws and regulations, including the Personal Information Protection and Electronic Documents Act ("PIPEDA") and Canada’s Anti-Spam Legislation ("CASL"). We also strive to comply with relevant international laws and regulations, including but not limited to the California Consumer Privacy Act ("CCPA"), and the European Union’s General Data Protection Regulation ("GDPR"), where applicable.

This Privacy Policy and any disputes related thereto shall be governed by and construed in accordance with the laws of the Province of Ontario and the federal laws of Canada applicable therein.

16. Consent to Electronic Communications

By using our Services, you consent to receive electronic communications from us. These communications may include notices about your account and information concerning or related to the Services.

17. Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize or aggregate your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Data Disposal

When personal information is no longer needed for the purposes for which it was collected, or upon a valid deletion request (subject to legal requirements), we delete or de-identify it using reasonable and appropriate measures. These measures may include secure deletion of digital records, purging from active systems and backups according to lifecycle schedules, and destruction of physical records where applicable.

18. Monitoring and Enforcement

We maintain a privacy program designed to help ensure ongoing compliance with this Privacy Policy and applicable laws. Measures include role-based access controls, staff training, periodic reviews of privacy practices, audit and activity logging, incident response procedures, and oversight of service providers. Alleged violations are investigated and addressed as appropriate.

19. Compliance with Regulatory Standards

We are committed to complying with applicable regulatory standards and may pursue certifications such as SOC 2, ISO 27001, and others relevant to our operations. Our compliance efforts are ongoing, and we will update our practices as necessary to meet regulatory requirements.

20. Language

This Privacy Policy is provided in English. If there is a translation of this Privacy Policy, the English version shall prevail in the event of any inconsistencies.