CLIQUEO SAS
Proposed version: 1.0 — October 1, 2026
Contact: [email protected]
Summary of the main aspects
Cliqueo uses information to provide access to its Platform, manage accounts and subscriptions, process documents, execute Monitoring Workflows, generate Results, send configured notifications, and provide the contracted services, including Managed Launch.
The Client determines what information it provides, which sources it connects, who may access its workspace, and which recipients receive notifications. It is responsible for having the necessary rights, permissions, and authorizations for those operations.
Processing may be carried out through external technology providers, including the OpenAI and Anthropic APIs. The authorization to provide the Services includes the use of these providers for the contracted functionalities.
The authorization for processing does not include the sale of Client Data, its use for third-party advertising, or the use of its documents, integration content, or Results to train general-purpose models.
The Client may request the deletion of its account. Once validated and confirmed, account closure is immediate and irreversible for the Client. Records necessary for the purposes described in this Policy may be retained, without this keeping the account active or granting a right of recovery.
This summary facilitates reading and does not replace the full provisions that follow.
1. Identity and scope
1.1. Identity. This Privacy Policy, hereinafter the “Policy”, describes the processing of information related to the Services provided by CLIQUEO SAS, identified by registration number 901633182-7, hereinafter “Cliqueo”.
Inquiries and requests related to this Policy may be directed to [email protected].
1.2. Services covered. The Policy applies to the Cliqueo Platform, Cliqueo Signals, document analysis, monitoring, and notification functionalities, Managed Launch, and other services that refer to it.
1.3. Persons covered. The Policy covers information related to Clients, business representatives, account administrators, Authorized Users, persons who communicate with Cliqueo, and persons whose information is provided through the Services.
1.4. Business orientation. The Services are intended for businesses, organizations, and professionals who use them for their economic or professional activities.
1.5. Definitions. The expressions Client, Platform, Services, Order, Authorized User, Client Data, Results, Monitoring Workflow, and Document Analysis have the meaning established in Cliqueo’s Terms and Conditions of Use and Contracting.
For the purposes of this Policy, personal data is information relating to an identified or identifiable person.
2. Relationship with the Terms and Conditions
2.1. Complementary documents. This Policy complements the Terms and Conditions and describes how information may be processed in connection with the Services.
2.2. Commercial scope. The Policy does not expand the functionalities, capabilities, usage periods, assistance activities, or services included in the Order.
2.3. Conditions of use. The conditions regarding contracting, payments, automatic renewal, usage, cancellation, Managed Launch, intellectual property, availability, and liability are governed by the Terms and Conditions.
2.4. No transfer of ownership. The provision or processing of information does not transfer ownership of Client Data to Cliqueo. Nor does it grant the Client rights over Cliqueo’s source code, software, infrastructure, or technology.
3. Roles of Cliqueo and the Client
3.1. Management of the relationship with Cliqueo. Cliqueo determines the processing of the information necessary to manage its own commercial and operational relationships, such as account registration, invoicing, payment collection, administrative communications, support, security, abuse prevention, and defense against claims.
3.2. Processing on behalf of the Client. When processing documents, querying connected sources, executing workflows, or generating Results and notifications on behalf of the Client, Cliqueo acts in accordance with the instructions, settings, and authorizations corresponding to the Service.
3.3. Client decisions. The Client determines the business purposes of its processes, what information it provides, the sources it connects, the criteria it configures, the Authorized Users, and the recipients of its communications.
3.4. Third-party information. When the Client provides information about workers, candidates, contractors, customers, suppliers, or other persons, it is responsible for establishing the lawfulness of its collection, provision, and use for the corresponding purpose.
3.5. Services provided by the Client to other organizations. When the Client acts on behalf of another organization, it represents that it has the authority to use Cliqueo in that context and allow the processing necessary to provide the Services.
4. Categories of information
The specific categories depend on the functionalities used, the connected sources, the settings, and the information provided. Not all categories are collected in all cases.
4.1. Account and organization information. This may include name, email address, organization, position or role, account identifiers, workspace membership, permissions, and configuration preferences.
4.2. Contracting and billing information. This may include the contracted plan, data necessary for invoicing, payer information, currency, amounts, payment dates, transaction status, payment collection references, and subscription history.
Depending on the payment method used, Cliqueo may receive transaction identifiers or payment method references through the provider involved in payment collection.
4.3. Documents and content. This includes files, images, texts, records, and other content that the Client submits or allows to be accessed through its integrations.
Depending on what the Client provides, identifying data, professional information, certifications, expiration dates, document statuses, and other data related to its processes may appear.
4.4. Settings and instructions. This may include analysis criteria, monitoring conditions, execution frequencies, rules, exclusions, sources, recipients, channels, and other instructions defined for the Services.
4.5. Results and derived content. This may include extracted information, classifications, summaries, comparisons, findings, indicators, reports, statuses, and notification content.
Results may contain personal data originating from the original information or derived from its processing.
4.6. Connection information. This may include connected service identifiers, permissions, access authorizations, tokens, integration keys, and technical data necessary to maintain enabled connections.
4.7. Technical and usage information. This may include IP addresses, session identifiers, access dates and times, authentication events, browser or device characteristics, activity logs, errors, and security events.
It may also include execution and usage records, such as documents processed, number of pages, units used, and Monitoring Workflow activity.
4.8. Support and Managed Launch information. This includes communications, requests, process explanations, materials, examples, settings, and other information that the Client provides while inquiries are being handled or during the contracted assistance.
5. Origin of the information
5.1. Direct provision. Information may be provided by the Client, its representatives, administrators, or Authorized Users when registering, contracting, uploading content, configuring functionalities, or communicating with Cliqueo.
5.2. Connected sources. It may be obtained from applications, accounts, repositories, platforms, and other systems that the Client connects or authorizes.
The authorization of a connection includes the queries and operations necessary to execute the enabled functionalities within the permissions granted.
5.3. Generation during use. Some information is generated when using the Services, such as Results, activity logs, usage history, and technical events.
5.4. Providers involved. Cliqueo may receive information from providers involved in the operation, such as payment confirmations, communication delivery statuses, or relevant technical logs.
5.5. Unauthorized sources. Use of the Platform does not constitute a general authorization for Cliqueo to access all of the Client’s accounts, files, or systems. The scope depends on the enabled connections, permissions, and instructions.
6. Purposes of processing
6.1. Providing the Services. Information may be used to enable accounts, manage access, receive documents, query sources, process content, execute Monitoring Workflows, generate Results, and send configured notifications.
6.2. Managing contracting. It may be used to manage Orders, subscriptions, renewals, invoicing, payments, usage, cancellations, and the history of the commercial relationship.
6.3. Providing support and assistance. It may be used to understand requests, review settings, investigate reported errors, address inquiries, and carry out the activities included in Managed Launch.
6.4. Protecting the Platform. It may be used to authenticate access, detect irregular activity, investigate misuse, prevent fraud, protect accounts, and manage security events.
6.5. Substantiating service provision and instructions. Cliqueo may retain and use relevant records to substantiate acceptances, authorizations, settings, executions, usage, communications, and other relevant circumstances of the contracting.
6.6. Fulfilling obligations and exercising rights. Information necessary to fulfill applicable obligations, respond to valid requests, address disputes, and establish, exercise, or defend claims may be used.
6.7. Evaluating operation. Cliqueo may use technical and usage information to evaluate performance, capacity, stability, security, and use of the functionalities.
It may also use aggregated and effectively anonymized technical statistics for these purposes, in accordance with the Terms and Conditions.
7. Authorization and lawfulness of processing
7.1. Functional authorization. By providing information, connecting a source, or enabling a functionality, the Client authorizes Cliqueo to carry out the processing necessary for the purpose of the contracted Service.
This authorization includes operations involving access, receipt, storage, technical reproduction, conversion, extraction, analysis, comparison, classification, generation of Results, and transmission of configured notifications.
7.2. Automatic executions. Activation of a Monitoring Workflow includes authorization for the executions specified in its configuration. It does not require a separate manual confirmation from the Client for each scheduled execution.
7.3. Representation regarding permissions. The Client represents and warrants that it has the necessary rights, permissions, authorizations, and legal bases to provide the information and allow its processing.
Cliqueo relies on that representation to process the information and does not assume an obligation to individually review the origin and permissions of each item of data or document.
7.4. Grounds according to the activity. Depending on the nature of the processing, it may be based on the contracting and provision of the Services, the Client’s instructions, fulfillment of obligations, protection of legitimate interests where applicable, or a specific authorization when necessary.
With respect to information that the Client provides on behalf of other persons, it is the Client’s responsibility to establish the grounds that permit its processing.
7.5. Information incompatible with the conditions offered. The Client must refrain from providing information when it lacks the authority to do so or when the information is subject to special requirements that are not covered by the Service.
The mere availability of a functionality does not constitute a certification of suitability for any category of information or regulatory requirement.
8. Processing through OpenAI and Anthropic
8.1. Use of providers. Cliqueo may use the OpenAI and Anthropic APIs to analyze information, process documents, execute automation and monitoring functions, and generate Results.
8.2. Client authorization. The authorization to provide these functionalities includes transmitting to those providers and processing through their APIs the information necessary to execute the corresponding requests.
8.3. Information covered. Depending on the functionality, processing may include complete documents or fragments, images, extracted content, instructions, context, data from connected sources, and Results related to the execution.
Therefore, processing should not be understood as limited to information that does not contain personal data.
8.4. Technical selection. An execution may use one or more providers. Use of the Services does not imply that every request is processed by both or that the Client contracts for a specific model or version, unless this is an express part of the acquired functionality.
8.5. External processing. Use of these APIs means that certain information may be processed outside the infrastructure directly managed by Cliqueo.
The technical conditions depend on the services and settings used. This Policy does not constitute a promise of exclusively local processing, zero retention, or instantaneous physical deletion across all provider systems.
8.6. Purpose of the authorization. Sending information to these providers is contemplated for the execution of the contracted functionalities. It does not constitute a general authorization to use Client Data for any purpose.
8.7. Training and excluded uses. In accordance with the Terms and Conditions, the authorization granted to Cliqueo does not include using documents, integration content, or Results to train general-purpose models.
Nor does it include selling Client Data or using it for third-party advertising.
9. Automated Results and review by the Client
9.1. Automated processing. The Services may extract information, compare data, classify documents, identify conditions, and generate communications through automated processing.
9.2. Nature of the Results. Results may contain derived data or inferences that require verification. A Result should not automatically be interpreted as a complete, accurate, or definitive description of a person or situation.
9.3. Responsibility for review. It is the Client’s responsibility to review the Results before using them to make significant decisions regarding persons, rights, employment, payments, compliance, or other interests.
9.4. Business decisions. The generation of a Result or notification does not, by itself, mean that Cliqueo has made a business decision on behalf of the Client.
The Client retains control and responsibility over the subsequent use of that information.
10. Notifications and configured recipients
10.1. Authorization to send. When the Client configures a recipient or channel, it authorizes Cliqueo to transmit the information included in the corresponding notification.
10.2. Content. Notifications may include findings, statuses, excerpts, references, or links related to the Client’s documents and processes, depending on the functionality and settings used.
10.3. Responsibility regarding recipients. The Client must verify that addresses and recipients are correct and that each person or entity is authorized to receive the information.
10.4. External channels. Notifications may pass through email providers, messaging providers, or other external channels. The information transmitted is also subject to the operation of those channels and the conditions applicable to their respective accounts.
10.5. Received copies. Deleting information in Cliqueo does not erase messages, files, screenshots, downloads, or copies that are already in the recipients’ possession.
The Client is responsible for handling with its recipients any applicable requests regarding those copies.
11. Processing during Managed Launch
11.1. Purpose. Information provided during Managed Launch is used to carry out the contracted assistance and facilitate the adoption of processes using the Platform.
11.2. Information provided. This may include process descriptions, document examples, criteria, settings, sources, recipients, and materials that the Client considers necessary for the assistance.
11.3. Permissions. The Client must have the authority to share the materials and allow them to be accessed or processed during sessions, tests, and activities.
11.4. Personnel access. Authorized personnel may review the information necessary to understand the use case and provide the included activities.
11.5. Scope. Providing information in Managed Launch does not turn the assistance into custom development, permanent operation of the business, a comprehensive data audit, or individual verification of all the Client’s permissions.
12. Persons and entities that may receive information
12.1. Authorized personnel. Cliqueo personnel who need information for service provision, administration, support, Managed Launch, security, or management of the contractual relationship may access it.
12.2. Technology providers. Providers of infrastructure, hosting, storage, processing, APIs, communications, support, security, and other functions necessary for the Services may be involved.
Their involvement takes place in connection with the functions they perform and under the corresponding contractual and data protection conditions.
12.3. Payment providers. Information necessary to process transactions, confirm payment collection, address payment issues, and manage invoicing may be shared.
12.4. Client recipients. Authorized Users and third parties that the Client configures, connects, or designates as recipients may receive information.
12.5. Advisors and defense of rights. Cliqueo may provide relevant information to professional advisors and other persons involved in accounting, legal management, or the defense of its rights, when necessary for that purpose.
12.6. Authorities and requests. Cliqueo may disclose information when necessary to fulfill an applicable obligation, respond to a valid request, or carry out an action related to the prevention of, investigation of, or defense against unlawful activities.
12.7. Business transactions. Information may be accessed or transferred in connection with a reorganization, acquisition, merger, or transfer of the business or assets associated with the Services, under the relevant confidentiality and processing continuity conditions.
13. International processing
13.1. Location of processing. Information may be stored, accessed, or processed in the locations used by Cliqueo and its providers to provide the Services.
13.2. No implied exclusive residency. Contracting does not, by itself, imply that all information will remain exclusively in the Client’s country or in a specific territorial location.
13.3. Operational authorization. The Client’s authorization includes the international processing necessary for the contracted functionalities, subject to the requirements applicable to the processing.
13.4. Client restrictions. Before providing information, the Client must determine whether its obligations or commitments allow it to use services with this territorial scope.
When the Client is subject to restrictions incompatible with the conditions offered, it must refrain from providing the affected information.
14. Client responsibilities regarding privacy and access
14.1. Information provided. The Client is responsible for the data it submits, connects, or makes available to Cliqueo, directly or through its Authorized Users.
14.2. Third-party privacy. It is the Client’s responsibility to fulfill the obligations related to obtaining the information, disclosing it to Cliqueo, the configured purpose, and the selection of recipients.
14.3. Business access. The Client may directly manage its account and designate other persons. It must assign appropriate permissions, review who retains access, and withdraw authorizations that are no longer applicable.
14.4. Credentials and devices. The Client is responsible for protecting its credentials, devices, sessions, and connections, as well as preventing the use of shared or compromised access.
14.5. Data subject to special protection. The Client must evaluate applicable restrictions before uploading health, biometric, genetic, or minors’ information, or other categories subject to particular requirements.
It must not interpret this Policy as an unrestricted authorization to provide any type of information.
14.6. Unnecessary information. The Client must avoid providing data that is not necessary for the configured purpose, as well as passwords, secrets, or other access information that the functionality does not require.
14.7. Reports. The Client must report without undue delay any suspicious access, unauthorized disclosure, or privacy issue it identifies in connection with its account.
15. Confidentiality and security
15.1. Confidential information. Client Data is not considered public because it is hosted or processed on the Platform.
15.2. Internal access. Access to information is limited to the persons and providers who need it for the relevant purposes, subject to the corresponding confidentiality duties.
15.3. Security measures. Cliqueo applies technical and organizational measures related to the security of its Services. These measures may be updated as technology, risks, and the characteristics of the Platform change.
15.4. No absolute guarantee. No security mechanism is presented in this Policy as a guarantee of invulnerability, absence of incidents, impossibility of improper access, or uninterrupted operation.
15.5. Account responsibility. The measures applied by Cliqueo do not replace the protection of credentials, devices, permissions, and external services that depend on the Client.
15.6. Security information. This Policy does not constitute a statement of specific certifications, audits, or technical characteristics that have not been expressly confirmed by Cliqueo.
Cliqueo may withhold technical information whose disclosure would compromise the security of the Platform, its providers, or other clients.
15.7. No continuous human supervision. The possibility of access by authorized personnel for support or security does not mean that Cliqueo manually reviews all documents, provides human supervision of each workflow, or continuously monitors the Client’s operation.
16. Cookies and similar technologies
16.1. Technologies used. The Platform may use cookies, local storage, session identifiers, and similar technologies for functions such as authentication, session maintenance, preferences, security, and operation of the interface.
16.2. Scope. The information associated with these technologies depends on the functions used and the technical configuration of the Platform.
16.3. Browser controls. The user may manage certain technologies through their browser or device. Blocking or deleting them may prevent access, end sessions, or affect functionalities.
16.4. Non-essential technologies. When non-essential technologies subject to specific information or authorization requirements are incorporated, their use must comply with the corresponding mechanisms.
The use of technologies necessary to operate the Platform does not, by itself, constitute a general authorization for advertising tracking.
17. Cliqueo communications
17.1. Operational communications. Cliqueo may use contact details to send account confirmations, access notices, security communications, billing information, renewals, support, and other messages necessary for the contractual relationship.
17.2. Service notifications. Communications generated by Monitoring Workflows are sent in accordance with the Client’s settings and are distinct from Cliqueo’s administrative communications.
17.3. Updated contact details. The Client must keep its contact details correct and operational.
17.4. Cliqueo launches, functionalities, and promotions. Cliqueo may use the contact email address provided to inform about new launches, functionalities, and Cliqueo’s own promotions.
17.5. Commercial communications. Any commercial communication unrelated to the necessary operation of the Service must have the corresponding authorization. Commercial preferences do not prevent the sending of necessary messages regarding an active account or contract.
17.6. Data for third-party advertising. The authorization described in this Policy does not permit the use of Client Data for third-party advertising.
18. Retention of information
18.1. Retention criteria. The duration of processing depends on the purpose, the type of information, the period during which the account remains active, the functionalities used, and the retention needs related to the contracting.
18.2. Operational information. Documents, settings, and Results may be retained for the time necessary for the functionalities used and in accordance with the deletion actions performed.
18.3. Administrative and evidentiary records. Cliqueo may retain the records necessary for invoicing, payments, acceptances, authorizations, usage, security, fraud prevention, and defense against claims.
18.4. Obligations and disputes. Relevant information may be retained for the periods necessary to fulfill applicable obligations or address existing or reasonably foreseeable disputes.
The duration is determined according to the specific purpose and not solely by the cancellation date of a subscription.
18.5. Residual technical copies. Where residual technical copies exist, their purging depends on the deletion or replacement cycles of the corresponding systems. Their existence does not keep a deleted account active or create a right of restoration for the Client.
18.6. No permanent archive. Cliqueo does not constitute an indefinite document retention service or replace the archives, repositories, or backup mechanisms that the Client needs for its own operation.
The Client must retain by its own means the information it needs to keep.
19. Account deletion and effects on information
19.1. Request. The Client may request deletion through the options available on the Platform or by writing to [email protected].
Cliqueo may verify the identity and authority of the person making the request.
19.2. Immediate and irreversible deletion. Once the request has been validated and confirmed, closure of the account or workspace takes effect immediately and is irreversible for the Client.
There is no grace period or right of restoration, recovery, or reactivation.
19.3. Scope of immediacy. Immediate deletion describes the permanent closure of the account and the removal of operational access to it. It does not constitute a statement of simultaneous physical erasure of all technical copies or records existing in each system.
Information that must be retained in accordance with the preceding section does not keep the deleted workspace available or authorize the Client to recover it.
19.4. Individual user and business workspace. Deleting a person’s access does not automatically imply deletion of their organization’s workspace.
Deletion of the business workspace must be requested by the Client or by a person with sufficient authority.
19.5. Disconnection of sources. Disconnecting an integration does not necessarily mean deleting documents, Results, or records obtained previously.
Nor does it delete information that remains in the source system.
19.6. Information in the systems of the Client or its recipients. The Client is responsible for handling with its own providers and recipients requests related to original documents, messages, downloaded files, and other copies existing outside Cliqueo.
This distinction refers to the external systems chosen by the Client and does not make the Client the administrator of the technology providers contracted by Cliqueo.
19.7. Commercial effects. Account deletion does not, by itself, create a right to a refund. Its effects on subscriptions, renewals, unused units, and other Services are governed by the Terms and Conditions.
20. Privacy within organizations
20.1. Business administration. Workspace administrators may have access to information, settings, or activity of other Authorized Users according to the available permissions.
20.2. Access expectations. Anyone using a business account must bear in mind that their access is part of a workspace managed by the corresponding organization and not necessarily an independent personal environment.
20.3. Internal instructions. The Client is responsible for informing its Authorized Users about internal rules of use, permissions, and the persons authorized to administer the workspace.
20.4. Authority over the workspace. A request related to personal data does not make the requester an administrator of the organization or grant them authority to delete other persons’ information or close a business workspace without authorization.
21. Minors
21.1. Use of the Services. The Services are not directed at minors or designed for them to enter into contracts or administer accounts.
21.2. Information provided by the Client. If the Client includes information about minors in its documents or sources, it is responsible for determining that it may do so and for complying with the corresponding specific requirements.
21.3. Absence of general authorization. Acceptance of this Policy does not constitute a general authorization to process information about minors or replace the permissions required of the Client.
21.4. Incompatible use. Cliqueo may restrict access or processing when it identifies use that is incompatible with the orientation and conditions of the Services.
22. External services and their policies
22.1. Services connected by the Client. Applications, repositories, email systems, and other services that the Client uses directly may have their own privacy policies and conditions.
22.2. Scope of this Policy. This Policy describes processing related to Cliqueo. It does not replace the policies of external services or govern all operations they carry out independently.
22.3. External configuration. The Client must review the permissions, recipients, retention rules, and conditions of the external accounts it connects or uses.
22.4. Difference between providers. The providers that Cliqueo uses to provide its Services are distinct from the providers with which the Client maintains its own relationship.
The Client’s obligations regarding its external accounts do not mean that it must manage the contracts or internal settings of Cliqueo’s providers.
23. Changes to this Policy
23.1. Updates. Cliqueo may update this Policy to reflect changes in its Services, functionalities, processes, providers, or applicable requirements.
23.2. Version identification. The published version will indicate its date. The Client must consult the Policy associated with the Services it uses.
23.3. Communications. Cliqueo may communicate updates through the Platform or the registered contact details.
23.4. Processing that requires additional actions. When a change requires additional information or a specific authorization, the corresponding mechanisms will be used. Publication of an update is not presented as an unlimited authorization to use information for any purpose.
24. Contact
Inquiries, requests, and communications related to this Policy or the processing of information may be directed to:
CLIQUEO SAS
To facilitate handling, the communication must describe the request and identify, where applicable, the related account, organization, document, or processing. Passwords or additional information that is not necessary to address the request must not be sent.