1. Introduction

KLEAR CRM, Inc. ("KLEAR CRM," "we," "our," or "us") is committed to protecting your privacy and the privacy of your customers. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our customer relationship management platform, websites, mobile applications, and related services (collectively, the "Service").

By using our Service, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our policies and practices, do not use our Service.

2. Information We Collect

2.1 Information You Provide Directly

Account Information: Name, email address, phone number, company name, job title, billing address, and payment information when you create an account or subscribe to our Service.
Customer Data: Information about your customers and contacts that you upload, enter, or create within the platform, including names, phone numbers, email addresses, addresses, notes, tags, and any custom fields you define.
Communication Content: The content of messages (SMS, MMS, Instagram DMs), call recordings, voicemails, and any other communications sent or received through our platform.
User Content: Files, documents, images, and other content you upload to the Service.
Support Communications: Information you provide when contacting our support team, including support tickets, emails, and chat conversations.

2.2 Information Collected Automatically

Usage Data: Information about how you use our Service, including features accessed, pages viewed, actions taken, time spent, and interaction patterns.
Device Information: Device type, operating system, browser type, unique device identifiers, IP address, and mobile network information.
Log Data: Server logs that record requests made to our servers, including timestamps, referring URLs, and system activity.
Location Information: General location information derived from IP address. We do not collect precise geolocation without your consent.
Cookies and Tracking: We use cookies, pixels, and similar technologies to collect information about your browsing activities. See Section 9 for more details.

2.3 Information from Third Parties

Integration Data: When you connect third-party services (Instagram, phone carriers, email providers), we receive data from those services as authorized by you.
Payment Processors: Our payment processors provide us with transaction information and fraud prevention data.
Analytics Providers: We receive aggregated analytics data from third-party analytics services.

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Providing and Improving the Service

Operate, maintain, and provide the features and functionality of the Service
Process and deliver your communications (SMS, calls, Instagram messages)
Store and manage your customer data and contacts
Provide customer support and respond to inquiries
Process payments and manage subscriptions
Analyze usage patterns to improve and optimize the Service
Develop new features and services

3.2 Communications

Send transactional emails (receipts, notifications, security alerts)
Send service-related announcements and updates
Send marketing communications (with your consent, where required)
Respond to your comments, questions, and support requests

3.3 Security and Compliance

Detect, prevent, and address fraud, abuse, and security issues
Verify identity and prevent unauthorized access
Comply with legal obligations and enforce our terms
Protect the rights, property, and safety of KLEAR CRM, our users, and others

4. Customer Data and Your Customers' Privacy

You are the data controller for the customer data you upload to our Service. We act as a data processor on your behalf. This means:

You are responsible for ensuring you have the legal right to collect, store, and process your customers' personal information
You are responsible for providing appropriate privacy notices to your customers
You must obtain any necessary consents from your customers before collecting their data
We will only process customer data according to your instructions and the terms of our agreement
We will not sell, rent, or share your customer data with third parties for their marketing purposes
We will not use your customer data to contact your customers directly, except as necessary to provide the Service

We recommend that you maintain your own privacy policy that explains to your customers how you collect and use their information, including your use of KLEAR CRM.

5. How We Share Your Information

We do not sell your personal information or your customer data. We may share information in the following circumstances:

5.1 Service Providers

We share information with third-party vendors who provide services on our behalf, including:

Telecommunications providers (e.g., Twilio) for SMS, MMS, and voice services
Cloud infrastructure providers (e.g., Google Cloud, Firebase) for hosting and data storage
Payment processors (e.g., Stripe) for billing and payments
Analytics providers for usage analytics
Customer support tools for help desk and support services

These providers are contractually obligated to protect your information and may only use it to provide services to us.

5.2 Third-Party Integrations

When you connect third-party services (Instagram, etc.), we share data with those services as necessary to provide the integration. Your use of third-party services is governed by their privacy policies.

5.3 Legal Requirements

We may disclose information if required to do so by law or in response to:

Subpoenas, court orders, or other legal process
Requests from law enforcement or government agencies
To protect our rights, privacy, safety, or property
To enforce our terms of service
In connection with an investigation of suspected illegal activity

5.4 Business Transfers

If KLEAR CRM is involved in a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control.

5.5 With Your Consent

We may share information with third parties when you give us explicit consent to do so.

6. Instagram and Social Media Integration

When you connect your Instagram account to KLEAR CRM, we access and process data from Instagram to enable messaging functionality:

instagram_business_basic: Access your Instagram business account profile information
instagram_business_manage_messages: Read, send, and manage Instagram Direct Messages on your behalf

We store Instagram messages and conversation data to display them in your KLEAR CRM inbox and enable you to respond. We do not:

Sell or share your Instagram data with third parties for advertising
Use your Instagram data for purposes other than providing our Service
Access Instagram data beyond what is necessary for the integration

You can disconnect Instagram at any time from your KLEAR CRM settings. Upon disconnection, we will stop receiving new data from Instagram, though previously stored messages will remain in your account unless you request deletion.

7. Data Security

We implement comprehensive security measures to protect your information:

Encryption: Data is encrypted in transit (TLS 1.2+) and at rest (AES-256)
Access Controls: Role-based access controls and authentication requirements
Infrastructure Security: Hosted on SOC 2 compliant cloud infrastructure
Monitoring: Continuous security monitoring and logging
Employee Training: Regular security awareness training for all employees
Incident Response: Documented incident response procedures
Vendor Security: Security assessments of third-party vendors

While we strive to protect your information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

8. Data Retention

We retain your information for as long as necessary to:

Provide our Service and maintain your account
Comply with legal obligations (e.g., tax, accounting, regulatory requirements)
Resolve disputes and enforce our agreements
Maintain security and prevent fraud

Account Data: Retained while your account is active and for up to 90 days after account deletion for backup and recovery purposes.

Customer Data: Retained according to your instructions. You may delete customer data at any time through the Service. Upon account termination, we will delete or anonymize your customer data within 90 days, unless retention is required by law.

Communication Records: Call recordings and message logs are retained according to your account settings. You may configure retention periods or delete records at any time.

Backup Data: Backup copies may be retained for up to 90 days after deletion from production systems.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to:

Essential Cookies: Required for the Service to function (authentication, security)
Analytics Cookies: Help us understand how visitors use our website
Preference Cookies: Remember your settings and preferences

You can control cookies through your browser settings. Disabling certain cookies may affect the functionality of our Service.

10. Your Rights and Choices

Depending on your location, you may have the following rights:

10.1 Access and Portability

You can access and export your data through your account settings or by contacting us.

10.2 Correction

You can update your account information and customer data directly in the Service.

10.3 Deletion

You can delete your account and request deletion of your personal information. Some information may be retained as required by law or for legitimate business purposes.

10.4 Objection and Restriction

You may object to or request restriction of certain processing activities.

10.5 Marketing Opt-Out

You can opt out of marketing communications by clicking "unsubscribe" in emails or contacting us.

10.6 Integration Disconnection

You can disconnect third-party integrations at any time from your account settings.

To exercise any of these rights, contact us at privacy@klearcrm.com. We will respond within 30 days.

11. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

Right to know what personal information we collect, use, and disclose
Right to delete your personal information
Right to opt-out of the sale of personal information (we do not sell personal information)
Right to non-discrimination for exercising your privacy rights

To exercise these rights, contact us at privacy@klearcrm.com or call us at the number provided on our website.

12. International Data Transfers

Our Service is operated in the United States. If you are located outside the United States, your information will be transferred to and processed in the United States, where data protection laws may differ from those in your country.

By using our Service, you consent to the transfer of your information to the United States. We take appropriate safeguards to ensure your information remains protected in accordance with this Privacy Policy.

13. Children's Privacy

Our Service is not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If we learn that we have collected personal information from a child under 16, we will delete that information promptly. If you believe we have collected information from a child under 16, please contact us.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

Posting the updated policy on our website with a new "Last updated" date
Sending an email notification for significant changes
Displaying a notice in the Service

Your continued use of the Service after changes become effective constitutes acceptance of the revised Privacy Policy.

15. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us:

KLEAR CRM, Inc.

Email: privacy@klearcrm.com

General Inquiries: hello@klearcrm.com

Website: https://klearcrm.com

16. Data Protection Officer

For data protection inquiries or to exercise your privacy rights, you may also contact our Data Protection Officer at dpo@klearcrm.com.