Privacy Policy

Data controller (site & self-serve): Clio Circle — clio@cliocircle.com
Role for organizational deployments: Clio acts as data processor on behalf of the customer organization (the controller), under the DPA.

1. What Clio is — and what it is not

Clio is the Management Loop OS: it turns work signals into management actions with verified closure. Clio observes the work; it does not score the person:

• Loops are detected from signals in the connected work — never from a personal assessment.
• The individual Work Mode self-assessment is used only as context to adapt an intervention: it does not create loops, does not score performance and does not diagnose the person. Raw assessment data is never shown to managers or leadership.
• Clio does not rank employees or use Work Modes to evaluate performance or make employment decisions.
• Clio does not read private conversations or inbox content.
• Every automated proposal passes a human gate: no management intervention activates without a manager's validation.

2. Work signals Clio observes (and what it never observes)

Clio only observes sources the organization explicitly connects. This table is the same public commitment shown on cliocircle.com:

3. Account and contact data

• Account: name, work email, organization, role — from Google/Microsoft sign-in.
• Leads: name, work email, company, optional role/team size/message — when you request a demo.
• Billing: handled by Stripe; Clio does not store card numbers.
• Analytics: GA4 with Consent Mode v2 — analytics cookies only after explicit consent.

4. Gmail and Google API Services (Limited Use)

Clio's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. In Gmail, Clio only receives the active draft, when you explicitly invoke it. The draft is processed transitorily to generate the suggestion and is never stored. Clio never reads your inbox, contacts or message history.

5. AI processing

Draft-improvement uses Google Gemini; loop preparation, aggregated analysis and translations use Anthropic Claude. Both run under commercial API terms whereby the providers do not train on the data. Prompts and outputs are not persisted by Clio beyond the transaction.

6. Legal bases (GDPR)

• Contract performance: providing the service to the account holder.
• Legitimate interest of the customer organization: observing authorized work signals to manage work (assessed via the customer's own LIA; Clio provides the DPA and this table of observed data).
• Consent: analytics cookies; any optional connection.

7. Sharing

Subprocessors: Google Cloud / Firebase (hosting, data), Vercel (site hosting), Google Gemini and Anthropic (AI processing, no-training terms), Stripe (payments), Google Analytics (only with consent). No sale of personal data. No sharing with data brokers.

8. Retention and deletion

Account and workspace data: for the life of the account and up to 30 days after deletion request. Drafts and AI prompts: not stored. Leads: up to 24 months. Deletion requests: clio@cliocircle.com — processed within 30 days.

9. Your rights

GDPR: access, rectification, erasure, portability, restriction, objection — via clio@cliocircle.com. CCPA: right to know, delete, correct, and non-discrimination; Clio does not sell personal information. Organizational users should direct requests to their organization (the controller); Clio assists as processor.

10. Employees in customer organizations

If your employer deploys Clio: your organization decides which sources are connected; Clio observes only the work signals in §2; leadership sees aggregates by area, never private content and never individual scores. Clio produces no psychological evaluation of you.

11. Changes

Material changes will be announced on this page with a new effective date.