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, 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.
• 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 or responses you provide in follow-up communications.

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, 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;
• measure traffic, usage, conversions, source attribution, referral performance, and campaign performance;
• 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 may use cookies, pixels, 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.

Depending on how the site is configured, these tools may collect identifiers, browser details, device details, page activity, referral data, event data, and interaction data. You can often manage cookies through your browser settings, although disabling them may affect site functionality.

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.

Source tracking may be used for analytics, attribution, platform operations, and determining whether certain disclosure language or optional sharing options should appear.

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, 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; 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 for money. We also do not share personal information for cross-context behavioral advertising unless specifically stated in a notice at collection or consent experience.

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.

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. Service Providers

We may use third-party service providers to support the operation of Cluvay, including hosting, database storage, email delivery, 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.

10. 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.

11. Security

We use reasonable administrative, technical, and organizational measures designed to protect personal information. 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.

12. California Privacy Rights

California residents may have rights under applicable privacy laws, including the right to know, access, correct, and delete certain personal information, as well as the right to opt out of certain data-sharing practices where applicable and the right not to receive discriminatory treatment for exercising privacy rights.

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.

13. Notice Regarding Children

Cluvay is not directed to children under 13, and 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.

14. Do Not Track

Some browsers offer a “Do Not Track” setting. Because there is no universally accepted standard for how to interpret that signal, we do not currently respond differently to browser-based Do Not Track signals unless and until a recognized standard is adopted.

15. 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.

16. 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.

17. Contact Us

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

Cluvay
support@cluvay.com