Privacy Policy

This Privacy Policy explains how Clearly Technologies Ltd, a company registered in England and Wales, trading as “Clearly” (“Clearly”, “we”, “us”), collects, uses, shares, and protects personal data in connection with our website at useclearly.comand the Clearly fleet-analytics platform (together, the “Services”).

Controller and processor roles. For personal data in the operational and telematics records that we process to provide analytics to a customer, Clearly acts as a processor on that customer’s behalf, under our End-User License Agreement and a Data Processing Agreement (available on request). The customer is the controller of that data, and their own privacy notice governs it.

This Policy covers the personal data for which Clearly is the controller— namely data about website visitors, prospects who contact us, and the individuals who administer or use a Clearly account.

1. Personal data we collect

• Enquiry and demo-request data. When you request a demo or contact us, we collect your name, work email, company, fleet size, current telematics provider, and any message you send.
• Account and user data. For Authorized Users of the platform, we process identity and authentication data (email addresses are stored hashed, via AWS Cognito), display and locale preferences, and the group and security scope that determines what a user may see.
• Product-usage data. We collect analytics about how the platform is used (for example features used and pages viewed) to understand and improve the Service.
• Technical and log data. IP address, device and browser information, approximate location derived from IP, cookie identifiers, and security and audit logs.
• Customer operational data.Operational and telematics data from your connected services (for example telematics providers such as Geotab, fuel-card providers, and maintenance or finance systems) is processed on the customer’s behalf as described in the callout above and in the EULA.

2. How we use personal data, and our legal bases

Where UK GDPR applies, we rely on the following legal bases:

• To provide and secure the Services— performance of a contract with your organization, and our legitimate interest in keeping the Services secure and reliable.
• To respond to enquiries and demo requests— our legitimate interest in responding to, and following up on, business enquiries.
• To improve the Services— our legitimate interest in understanding usage and developing new features (product analytics).
• For business-to-business marketing— our legitimate interest in telling business contacts about relevant Clearly products, subject to your right to opt out at any time (see Section 4).
• To comply with law— where we are under a legal obligation, and consent where we specifically ask for it.

3. Cookies and similar technologies

Our marketing website uses only strictly-necessary cookies — for example a secure, HttpOnly session cookie and cookies that support security. Within the signed-in platform we use product-analytics technologies to measure usage and improve the Service. We do not use advertising cookies or sell cookie data. You can control cookies through your browser settings; blocking strictly-necessary cookies may stop parts of the Service from working.

4. Marketing communications

We may send business-to-business marketing to business contacts on the basis of our legitimate interest. Every marketing email includes an unsubscribe link, and you can opt out at any time by using it or by emailing support@useclearly.com. Opting out of marketing does not stop service-related messages you need to receive.

5. How we share personal data

We do not sell your personal data. We share it only with service providers that process data on our behalf under contract (our sub-processors):

• Amazon Web Services (AWS)— cloud hosting, authentication, storage, and related infrastructure (scoped to your organization’s region);
• ClickHouse Cloud— the analytics database;
• Anthropic— the large-language-model provider powering the Vera assistant;
• Vercel— website and frontend hosting and content delivery;
• Railway— API hosting;
• our product-analytics provider— to measure in-app usage.

Your connected services (such as telematics providers like Geotab and fuel-card providers) are data sources you connect at your own direction, not our sub-processors. Where you enrol through Geotab’s Order Now program, Geotab also facilitates billing on our behalf. We may also disclose personal data where required by law, or to protect the rights, safety, or security of Clearly, our users, or the public. A current list of sub-processors is available on request from support@useclearly.com.

6. International transfers

Clearly operates a region-aware architecture: each organization’s data resides in the cloud region assigned to it and is not moved outside that region in the ordinary course of providing the Service. Some of our sub-processors (for example Anthropic, in the United States) may process limited personal data outside the United Kingdom. Where we transfer personal data internationally, we use appropriate safeguards, such as the UK International Data Transfer Agreement or Addendum, the European Commission’s Standard Contractual Clauses, or a jurisdiction covered by a UK adequacy decision.

7. How we protect personal data

We maintain administrative, technical, and organizational measures designed to protect personal data, including encryption in transit (TLS/HTTPS with HSTS), encryption of stored service credentials, authentication with support for multi-factor authentication and enterprise single sign-on, role-based access control, session management usingHttpOnly cookies, a content security policy, per-organization data isolation, soft-deletion so removals are recoverable and auditable, and audit logging. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

8. How long we keep personal data

We keep personal data only for as long as necessary for the purposes described in this Policy: for the duration of your organization’s relationship with us and for a reasonable period afterwards, plus any period required to meet legal, accounting, or reporting obligations. Enquiry and demo-request data is kept for a reasonable period to follow up and maintain our records. Because we apply soft-deletion, deleted records remain recoverable and auditable for a limited period before permanent removal.

9. Your rights under UK GDPR

Subject to conditions and exemptions under applicable law, you have the right to: access a copy of your personal data; have inaccurate data corrected; have your data erased; restrict or object to processing (including objecting to direct marketing); data portability; and, where we rely on consent, to withdraw it at any time. To exercise any of these rights, contact support@useclearly.com. Where Clearly processes operational data on a customer’s behalf as a processor, please direct requests to that customer. You also have the right to complain to the UK Information Commissioner’s Office (ICO) at ico.org.uk, though we’d welcome the chance to resolve any concern first.

10. Your rights under US state privacy laws

If you are a California resident (or covered by a comparable US state law), you have the right to know what personal information we collect and how we use it, to request access to and deletion or correction of that information, and to opt out of the “sale” or “sharing” of personal information. We do not sell or share personal information as those terms are defined under these laws. We will not discriminate against you for exercising your rights. To make a request, contact support@useclearly.com.

11. Children

The Services are business tools intended for organizations and their staff. They are not directed to children, and we do not knowingly collect personal data from children.

12. Changes to this Policy

We may update this Policy from time to time. When we make a material change, we will publish the updated version here with a new effective date, and, where appropriate, notify you.

13. Contact us

Questions about this Policy or your personal data can be directed to Clearly Technologies Ltd (trading as “Clearly”) at support@useclearly.com, or by post to our registered office at 25 Eccleston Place, London, England, SW1W 9NF. Clearly Technologies Ltd is registered in England and Wales under company number 12955814.