Privacy Policy

1. Scope

This Privacy Policy applies to personal information collected through Cluvay, including through our website, assessment flow, email collection forms, deep-opt-in forms, contact forms, analytics tools, cookies, referral tracking, agent and partner accounts, and communications related to your use of the service.

By using Cluvay, you acknowledge the practices described in this Privacy Policy.

2. Information We Collect

We may collect the following categories of information:

• Contact information, such as your name, email address, phone number, and any information you provide through a form.
• Assessment information, such as your quiz responses, property-related inputs, timing, goals, concerns, location information, and other details you choose to provide.
• Generated outputs and inferences, such as your score, profile, position range, summaries, friction signals, readiness indicators, and deeper analysis derived from the information you submit.
• Professional account information, if you are a real estate professional, brokerage, partner, or organization using Cluvay: account and contact details, license and brokerage information, team or organization details, subscription and billing information (payment card details are processed by our payment provider, not stored by us), and account activity. This can also include optional business figures you choose to enter — such as an average commission, a close rate, or time baselines like the minutes you typically spend qualifying a new lead — which power private, account-level features.
• Usage and device information, such as browser type, device type, pages viewed, timestamps, clicks, referral or source information, session activity, and approximate technical identifiers collected through cookies or analytics technologies.
• Communications information, such as messages you send to us, responses you provide in follow-up communications, and records of the emails we send you (for example, whether a results email was delivered).

3. Sources of Information

We collect information:

• directly from you when you complete the assessment, submit your email, request a deeper breakdown, opt into sharing, create or use an account, or contact us;
• automatically from your device or browser through cookies, analytics tools, event tracking, or similar technologies;
• from referral links, QR codes, or tracking links used to understand how users arrive at Cluvay; and
• from service providers who help us operate the website, host forms, send emails, store data, or measure performance.

4. How We Use Information

We may use personal information to:

• provide your assessment results, score, summaries, structured outputs, and deeper analysis;
• email your results to you and provide follow-up communications related to your use of Cluvay;
• process deep-opt-in submissions and deliver deeper breakdowns when requested;
• operate, maintain, improve, and troubleshoot the website and assessment experience;
• administer agent and partner accounts, subscriptions, sponsored seats, lead notifications, attribution, and any partner payouts;
• measure traffic, usage, conversions, source attribution, referral performance, and campaign performance, including in aggregated or de-identified form;
• power private, account-level features for professionals from optional business figures they choose to enter (such as commission, close rate, or time baselines), and evaluate in aggregated or de-identified form whether the platform improves outcomes — for example, how quickly first conversations happen after an opt-in — without presenting any professional’s individual figures to other users or organizations;
• detect, prevent, and respond to fraud, abuse, misuse, or security issues;
• comply with legal obligations and enforce our terms; and
• where applicable, facilitate limited communications related to a connected real estate professional only in the circumstances described in this policy and in the relevant notice shown to you at the time of collection.

5. Cookies, Analytics, and Similar Technologies

We use cookies, analytics tools, and similar technologies to understand how visitors use the site, improve performance, remember preferences, maintain session activity, and measure the effectiveness of pages, traffic sources, referrals, and campaigns.

We use Google Analytics to help us understand traffic patterns, visitor behavior, and general site usage. Google Analytics sets its own cookies and collects information such as device and browser details, pages viewed, and interaction events. We use it for our own analytics only; we do not use it for advertising personalization. You can learn how Google handles this data at policies.google.com/technologies/partner-sites and opt out of Google Analytics using Google’s browser add-on.

We also store a small number of first-party values directly in your browser (localStorage) rather than as traditional cookies:

• An active referral record — the referral code (and any related campaign identifiers) from the link or QR code that brought you to Cluvay, kept for up to 14 days so the referring professional or partner can be credited, then removed automatically.
• A visitor key — a random identifier used only to avoid double-counting visits in our own analytics. It is not used to identify you, to build a profile of you, or to track you on other websites.
• A landing flag — a value that remembers a referral visit was already counted, so it is not counted twice.
• A session identifier — created when you begin an assessment, used to connect your steps and results together.

These values are set and read only by Cluvay, are not shared with advertising networks, and are not used to track you across other websites. You can remove them at any time by clearing your browser’s site data, although doing so may affect site functionality, such as referral credit or resuming an assessment.

6. Referral Codes and Source Tracking

Cluvay may use referral codes, tracked links, QR codes, or similar source identifiers to understand how a user arrived at an assessment experience. These tools help us determine whether an experience is part of the general Cluvay platform or connected to a specific professional or referral source.

When you arrive through a referral link, the referral code is saved in your browser for up to 14 days and the tracking parameters are removed from the page address. If you return within that window and choose to move forward, the referring professional or partner can still receive credit for the introduction. After 14 days, the record expires and is removed.

Source tracking is used for analytics, attribution, platform operations, and determining whether certain disclosure language or optional sharing options should appear. It does not change your assessment results and is not shared with advertising networks.

7. How We Share Information

We may share personal information with:

• service providers that help us host the website, process forms, send emails, store data, process payments, analyze traffic, or support site operations;
• professional advisors or legal authorities when necessary to comply with law, enforce rights, or protect users and the business;
• successors or counterparties in the event of a merger, acquisition, restructuring, or sale of assets;
• for professional accounts, the teams, brokerages, enterprises, sponsors, and authorized partners connected to that account, in the circumstances described in Section 9; and
• if and only if you expressly opt in, the licensed real estate professional or brokerage connected to the site experience, and only for the limited information described in the sharing notice shown to you at that time.

We do not sell personal information, and we do not share personal information with third parties for cross-context behavioral advertising. If that ever changes, we will update this policy and provide any opt-out mechanism required by law before doing so.

8. Optional Sharing With a Connected Professional

In some cases, Cluvay may be offered through or associated with a licensed real estate professional or brokerage. If you choose to opt in, Cluvay may share a limited position snapshot with that connected professional.

The information shared may include your name, email, phone number if provided, city/state or location if provided, and a brief snapshot of your current position and key areas of uncertainty.

We do not share your full assessment responses, detailed analysis, raw answers, extended notes, or full internal scoring logic with a connected professional unless we clearly tell you otherwise at the time of collection.

If the connected professional’s account is part of a team, brokerage, or other organization, or is administered with their permission by a partner, the snapshot you share may also be visible to the people who help manage that account. The professional and their organization are responsible for how information you share is used once they receive it.

Choosing to share information with a connected professional does not create an obligation to contact or work with that professional and does not by itself create an agency, brokerage, fiduciary, advisory, client, or representation relationship.

9. Professional and Partner Accounts

If you are a real estate professional, brokerage, partner, or organization using Cluvay, we collect and use your account information to operate your account, manage subscriptions, sponsored seats, and any partner payouts, deliver lead notifications you have requested, and provide dashboards, campaign tools, and insights.

We also collect information about how professional accounts use the platform — such as campaign activity, referral and QR funnel performance, assessments generated, and feature usage — and use it to calculate attribution, measure what is working, maintain security and audit logs, and improve the service. Aggregate platform statistics derived from this activity do not identify individual assessment takers.

Professional accounts often exist inside a structure. If a seat belongs to or is sponsored by a team, brokerage, enterprise, or other organization, that organization’s administrators can see and manage information for the seats they oversee according to their role — for example, account and seat status, campaign activity and performance, aggregate funnel results, and billing or sponsorship details. Joining an organization or accepting a sponsored seat is how a professional authorizes this oversight, and an organization keeps records generated while a seat was part of it.

Professionals can also grant defined access to third parties they work with — for example, allowing a partner platform to install and manage their Cluvay embed, letting a coach review their performance, or authorizing a partner to administer referral commissions. Access granted this way is limited to the purpose presented when it is granted and can be revoked from the account. Partners who introduce professionals to Cluvay may also receive the information needed to administer that relationship, such as attribution records and commission or payout status.

10. Aggregated and De-Identified Information

We may create and use aggregated or de-identified information — for example, overall completion rates, score distributions, or campaign performance trends — to analyze, operate, and improve Cluvay. Aggregated and de-identified information does not identify you, and we maintain it in de-identified form and do not attempt to re-identify it, except as permitted by law to test whether de-identification is effective.

11. Service Providers

We use third-party service providers to support the operation of Cluvay, including hosting, database storage, email delivery, payment processing, analytics, security, performance monitoring, and form processing.

These providers may process personal information only as needed to provide services to Cluvay or as otherwise permitted by law.

12. Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the service, maintain records, improve the experience, comply with law, resolve disputes, prevent abuse, and enforce agreements.

Retention periods may vary depending on the type of information, the purpose for which it was collected, the user’s interactions with Cluvay, and legal or operational requirements. The browser-based referral record described in Sections 5 and 6 expires automatically after 14 days.

13. Security

We use reasonable administrative, technical, and organizational measures designed to protect personal information, including access controls that limit internal access to information needed to operate the service. However, no method of transmission over the internet or method of storage is completely secure, and we cannot guarantee absolute security.

Please avoid submitting sensitive personal information unless specifically requested and necessary.

14. California and Other State Privacy Rights

Depending on where you live, you may have rights under applicable privacy laws, including the right to know and access the personal information we hold about you, the right to correct inaccurate information, the right to delete certain information, the right to opt out of the sale or sharing of personal information, the right to limit certain uses of sensitive personal information, and the right not to receive discriminatory treatment for exercising privacy rights.

As described in Section 7, we do not sell personal information and do not share it for cross-context behavioral advertising, so there is currently no sale or sharing to opt out of. We also do not use or disclose sensitive personal information for purposes that would require a right to limit under California law.

To submit a privacy request, email support@cluvay.com with the subject line “Privacy Request.” We may need to verify your identity before completing certain requests, and you may use an authorized agent to submit a request on your behalf where the law allows. Residents of other states with comparable privacy laws may contact us the same way, and we will honor the rights provided by the law that applies to you.

15. Notice Regarding Children

Cluvay is intended for adults and is not directed to anyone under 18. We do not knowingly collect personal information from children under 13. If you believe a child has provided personal information through the site, contact us and we will take reasonable steps to delete it.

16. Do Not Track and Global Privacy Control

Some browsers offer “Do Not Track” or Global Privacy Control (GPC) signals. Because we do not sell personal information or share it for cross-context behavioral advertising, there is currently no sale or sharing for these signals to opt out of. If our practices ever change, we will treat a GPC signal as a valid opt-out request where the law requires it and update this policy accordingly.

17. Third-Party Sites and Tools

The site may contain links to third-party websites or rely on third-party tools. We are not responsible for the privacy, security, or content practices of those third parties. Review their privacy policies separately before providing information to them.

18. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the “Last updated” date above. Your continued use of the site after an update means the revised policy will apply to future interactions, subject to applicable law.

19. Contact Us

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

Cluvay Inc.
3905 State St, Ste 7-152
Santa Barbara, CA 93105
support@cluvay.com