Privacy | Cleo

Last Updated: March 22, 2025

1. Introduction

At Cleo, we are committed to protecting your privacy. This Privacy Policy explains how we collect, use, and secure your personal information. By using our Website and app (referred to collectively as the "Platform"), you agree to the terms outlined in this policy.

2. Collection of Personal Information

We collect personal information through various methods: directly from you, from third parties, and automatically as you interact with our Platform.

(a) Information You Provide

Contact and Identifiers: You may provide contact information such as your name and email address. If you use social media to access our services, we may also collect your social media IDs.
Account Information: When creating an account, we may request details such as your name, email, phone number, address, company name, job title, student ID, emergency contact, and authentication data. For specific subscriptions or group plans, additional information like home addresses and household member details may be collected.
Health Information: We collect data related to your emotional and mental well-being through your interactions with our services, including survey responses about your emotional states, wellness goals, and related inputs. This information is used solely for research, program improvement, and personal experience enhancement and is not intended for medical or clinical use.
Profile and Demographics: Your profile may include personal details such as age, ethnicity, gender identity, sexual orientation, and marital status.
Payment Information: For purchases, you will provide payment details. We use third-party processors for transactions, sharing only the necessary payment information with them.
Survey Responses: We may invite you to participate in surveys to evaluate product functionality, gather feedback, and collect research data.
Communication Details: We collect information from your communications with us, including emails and chat messages.
Support Information: When seeking support, we collect the information you provide through interactions with our customer service, including live chat or chatbots.

(b) Information from Third Parties

Benefit Sponsor Data: If your access is sponsored by an organization, we collect information from them to facilitate your enrollment.
Referral Data: We may receive names, email addresses, and engagement details of individuals referred by our users for content sharing and referrals.
Verification Data: For verifying subscription eligibility, we may allow third-party platforms to access your information for this purpose.

Device and Browser Data: We collect data such as IP addresses, device identifiers, browser types, and screen resolutions during your use.
Usage Data: We track your interactions with our Platform, including visited pages, clicked links, and general usage patterns.

(d) Aggregated and De-Identified Data We may create or collect aggregated, anonymous, or de-identified data by removing or altering personal identifiers. This type of data is not covered by this Privacy Policy.

3. Use of Personal Information

We may use your personal information for various purposes:

Platform Services: To operate and enhance our Platform and its features.
Communication: To inform you of updates or changes to our services.
Support: To provide assistance, address inquiries, and handle complaints.
Transaction Processing: To manage payments, orders, and billing.
Benefit Sponsor Notification: To update your Benefit Sponsor on your registration details if applicable.
Contractual Obligations: To fulfill agreements with you.
Quality Improvement: To improve the Platform through research, development, and evaluating marketing effectiveness.
Marketing: To provide information about new products, services, and promotions, and personalize these offers.
Advertising: To tailor advertisements you see on third-party platforms.
Security: To protect against fraud and unauthorized activities.
Legal Compliance: To meet legal and regulatory requirements and to defend or assert legal claims.

4. Data Security and Retention

We prioritize the protection of your personal information and follow widely accepted standards to secure your data during transmission and after receipt. We implement appropriate technical, administrative, and physical measures to safeguard your information from unauthorized access, destruction, loss, alteration, disclosure, or misuse.

While we strive to provide robust security, no system can be entirely secure. If you suspect unauthorized use of your account or credentials, please contact us immediately at contact@cleoarts.com.

We retain your personal information only as long as necessary to meet our obligations or as permitted by law. Our retention criteria include: (i) the duration of our relationship with you; (ii) any applicable legal requirements; and (iii) the need to retain the data based on our legal standing (e.g., statutes of limitations, ongoing litigation, or regulatory inquiries). For example, we retain your account details as long as your account is active.

5. Data Collection for Assessment Surveys

Cleo collects responses and data through assessment surveys solely for the purpose of improving our programs, enhancing user experiences, and conducting research. Any data collected will not be used for diagnosis, treatment, or medical advice, as our programs and boosts are non-clinical and non-medical in nature. We do not collect personal health information for marketing purposes, and your responses will remain confidential.

By participating in our assessment surveys, you consent to the collection of your responses and data as outlined above. You may opt out at any time or choose not to respond to specific questions without any impact on your participation in our programs.

6. Your Privacy Rights

We believe in empowering you with control over your personal data. You can exercise the following rights by reaching out to us at contact@cleoarts.com, or in some cases, through features available on the Platform:

Access: You can request information about the personal data we collect, how it is used, and if we have it, request a copy.
Correction: You have the right to request that we correct any inaccuracies in your personal data.
Portability: You can ask for an export of your personal information in a structured, machine-readable format, such as .csv or .pdf. We can also, where feasible, transfer this data to a third party you specify.
Deletion: You may request the deletion of your personal data under specific conditions.
Restriction: You can request limitations on how your data is used in particular scenarios. Keep in mind, however, that such restrictions may affect the functionality of our services.
Non-Retaliation: Rest assured that you will not face discrimination or retaliation for making a privacy-related request.

When we receive your request, we may need additional details to confirm your identity or clarify your inquiry. We aim to respond to verified requests promptly, and if more time is necessary, we will notify you via the email linked to your account or the one used in your request.

Typically, we do not charge for processing verified requests unless they are excessive, repetitive, or clearly unfounded. If a fee is applicable, we will inform you of the reason and provide an estimate before proceeding.

There may be instances where we are unable to fulfill certain requests due to legal obligations, the rights of others, safety concerns, or our ability to address or defend legal claims. Additionally, we will not process requests without adequate information to verify your identity, or if the request is made by an unauthorized third party.

Residents of specific U.S. jurisdictions may have additional rights regarding their personal information based on local laws.

7. Cookies

When you visit our websites, we may automatically gather information through the use of cookies, including third-party cookies. These cookies assist us with multiple functions such as improving site functionality, analyzing performance, maintaining security, tailoring content, and serving targeted advertisements. In compliance with legal requirements, we will request your consent before using these tracking technologies or provide an option to decline them. You can also use opt-out preference tools, like the Global Privacy Control (GPC), to prevent the sale or sharing of your personal information. For further details on the cookies we employ and your available options, please refer to our Cookie Policy.

8. Children’s Privacy

Our Platform is intended for individuals who are 18 years or older. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have inadvertently collected data from a minor, we will take steps to delete that information as soon as possible.

9. Updates

This Privacy Policy is effective as of the date listed at the top. We may update this policy occasionally to reflect changes to our Platform, correct errors, improve clarity, adjust our privacy practices, or comply with new legal requirements. For significant changes, such as alterations to how we use your personal information or your rights, we will notify you through the Platform or other methods, such as the email you provided during account registration, and update the policy on our Website. We encourage you to review this Privacy Policy regularly to stay informed about how we manage your personal information.

10. Get in Touch For any questions, concerns, or requests regarding this Privacy Policy, please contact us via email at info@cleoarts.com.