Privacy Policy — Clerkly AI

Privacy Policy

This privacy policy is applicable to the Clerkly AI: Shop Assistant app for mobile devices, together with any related services operated by Arai Tech L.L.C-FZ (collectively, the "Application"). Arai Tech L.L.C-FZ is hereinafter referred to as the "Service Provider".

Data Controller Information

Arai Tech L.L.C-FZ acts as the Data Controller responsible for the processing of your personal data.

Name: Arai Tech L.L.C-FZ
Address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.
Email: admin@arai-tech.com

For data protection inquiries and to exercise your GDPR rights, please contact the Data Controller using the contact information above.

EU Representative: Oaca Stefanita Cornel, oacastefanita@gmail.com

What information does the Application obtain and how is it used?

The Application and related services acquire the information you supply when you download, access, or register for the service. Registration with the Service Provider is not mandatory. However, you might not be able to use some of the features offered by the service unless you register.

The Service Provider may also use the information you provide to send important information, required notices, and, where permitted by law, marketing communications.

Legal basis for processing your personal data

Where the GDPR applies, the Service Provider relies on one or more lawful bases to process your personal data, including:

Contract performance: processing necessary to provide the Application or fulfil a contract with you.
Consent: where you have given explicit consent to processing, including for marketing, analytics, or optional features. You may withdraw consent at any time without affecting processing that occurred before withdrawal.
Legitimate interests: where processing is necessary for the Service Provider's specific legitimate interests, such as maintaining network and information security, preventing fraud and abuse, or improving the Application's core functionality through analytics, provided those interests are not overridden by your data protection rights or fundamental freedoms.
Legal obligation: to comply with laws or government requests.

Cookies and similar technologies

The Application or its third-party SDKs may use cookies, SDKs, pixels, and similar technologies to support functionality, analytics, and service delivery. Where required by law, the Service Provider will obtain your consent before using non-essential tracking technologies.

Automated decision-making and profiling

If the Application uses automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you, you have the right to request human review, express your point of view, and contest the decision. Information about the logic involved and the likely consequences of that processing will be provided where required by law.

What information does the Application collect automatically?

In addition, the Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device's unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the Application. The information collected about the way you use the Application is described in more detail in the "Usage analytics" section below.

Usage analytics — how does the Application track the way you interact with it?

The Application uses Google Analytics for Firebase ("Firebase Analytics"), an analytics service provided by Google, to understand how users interact with the Application and to improve it. Firebase Analytics records:

Usage events describing your interactions with the Application, for example: which setup (onboarding) steps you complete, the business category you select during setup, which screens and features you open, changes to settings such as the assistant and employee languages, your responses on the in-app AI consent screen (accepted, dismissed, or later disabled), whether the microphone or speech-recognition permission was declined, when the subscription paywall is shown, and subscription purchase activity (selected plan, product identifier, price, and currency).
Diagnostic events, for example whether importing a linked website or attached document succeeded, failed (including the technical reason for the failure and the kind of file involved), or was truncated because of size limits.
Usage statistics associated with your app instance, for example counts of linked webpages, attached files, answered, unanswered, deleted, and skipped questions, the number of customers the assistant has helped, and whether automatic customer detection is enabled.
Technical information collected automatically by the Firebase Analytics SDK, such as device model, operating system version, app version, language and region settings, coarse location derived from your IP address (country or city level), session information (such as first opens, session duration, and app updates), and in-app purchase information.

Analytics data is associated with randomly generated identifiers (a Firebase app-instance identifier and Apple's identifier for vendor), not with your name or email address. Analytics events do not include the content of your business knowledge (owner notes, linked website contents, or attached document contents), the text of your customers' questions, or the assistant's replies.

The Application does not display third-party advertising, does not use analytics data for advertising purposes, and does not request permission under Apple's App Tracking Transparency framework to track you across apps and websites owned by other companies.

This processing is based on the Service Provider's legitimate interest in understanding and improving how the Application is used. Google processes analytics data on the Service Provider's behalf and may do so on servers located outside the EEA, including in the United States (see "International Data Transfers" below). You can learn more in Google's privacy policy at https://policies.google.com/privacy and Firebase's privacy documentation at https://firebase.google.com/support/privacy. To object to this processing or to request deletion of the analytics data associated with your app instance, contact the Service Provider at admin@arai-tech.com.

Does the Application collect precise real time location information of the device?

This Application does not gather precise information about the location of your mobile device.

Does the Application use Artificial Intelligence (AI) technologies?

Yes. The Application uses DeepSeek, a third-party AI service provider, in two ways: during initial setup, to suggest questions you may want to answer and to translate your greeting into the languages the assistant speaks; and in Employee Mode, to generate spoken replies to your customers' questions.

The following information is sent to DeepSeek:

During setup: the business information you have saved — your business name and category, owner notes, linked website contents, and attached document contents — together with your greeting, so that DeepSeek can suggest relevant questions and translate the greeting.
In Employee Mode: the text of the questions your customers ask (spoken questions are transcribed on your device where supported, so audio is not transmitted to DeepSeek), the business information you have saved, and recent conversation turns from the same interaction.

These transfers occur only after you provide explicit consent on the in-app AI consent screen, which is presented before any information is sent to DeepSeek. You can withdraw your consent at any time in Settings › Privacy, after which the Application will request consent again before sending any further information to DeepSeek.

DeepSeek processes this data on its own servers and, under DeepSeek's own privacy policy and terms, may retain it and use it to operate and improve its AI models, including model training. DeepSeek's servers are located outside the European Economic Area (in the People's Republic of China), a country that does not benefit from a European Commission adequacy decision; the Service Provider relies on your explicit consent and appropriate safeguards for this transfer under Chapter V of the GDPR. The Service Provider does not sell your personal data or use it for advertising or profiling. You can review DeepSeek's privacy policy at https://cdn.deepseek.com/policies/en-US/deepseek-privacy-policy.html.

Because your customers' questions may contain their personal data, you, as the operator of your business, are responsible for having a lawful basis to process that data and for informing your customers as required by your local law. Please avoid recording, or inviting customers to share, sensitive personal information such as payment, health, or identity details.

Do third parties see and/or have access to information obtained by the Application?

When you enable Employee Mode, the information described in the "Artificial Intelligence" section above is transmitted to DeepSeek, our third-party AI provider, in order to generate replies. Separately, the usage-analytics information described in the "Usage analytics" section above is transmitted to Google (Firebase Analytics), which processes it on the Service Provider's behalf to help the Service Provider understand and improve how the Application is used. Aside from this, the Service Provider does not sell your personal data or share it for advertising, and shares information with third parties only in the ways described in this privacy statement.

International Data Transfers

The Service Provider or its third-party service providers may transfer personal data outside the European Economic Area (EEA). For example, Google (Firebase Analytics) may process usage-analytics data in the United States. Where such transfers occur, the Service Provider will use an appropriate transfer mechanism required by GDPR Chapter V.

Adequacy decisions by the European Commission
Standard Contractual Clauses (SCCs) approved by the European Commission
Other safeguards or derogations recognized under GDPR Chapter V, including consent where legally permitted

Countries outside the EEA may not provide the same level of data protection as the EEA. Where required by law, the Service Provider will apply appropriate safeguards and obtain any consent required for the transfer.

The Service Provider may disclose User Provided and Automatically Collected Information:

as required by law, such as to comply with a subpoena, or similar legal process;
when they believe in good faith that disclosure is necessary to protect their rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
with their service providers who work on their behalf under contractual data-protection obligations and have agreed to adhere to the rules set forth in this privacy statement, except as otherwise described in this policy, including the Artificial Intelligence section above (for example, DeepSeek, which may use the data it receives for its own model training as described above).

Where the GDPR applies, the Service Provider enters into Data Processing Agreements (DPAs) with third-party service providers that process personal data on its behalf, as required by Article 28 of the GDPR. These DPAs impose the same data protection obligations on those service providers as described in this Privacy Policy.

What are my opt-out rights?

You can stop further collection of information from your mobile device by uninstalling the Application. Uninstalling will stop the Application from collecting data from your device, but it does not automatically delete information that has already been transmitted to the Service Provider or to third parties.

To request deletion of your personal data, withdraw consent, or exercise any of your rights, contact the Service Provider at admin@arai-tech.com.

What is the data retention policy and how can you manage your information?

The Service Provider retains personal data based on its necessity for the stated purposes:

User Provided Data: Retained for the duration of your use of the Application plus 12 months thereafter, unless longer retention is required by law
Automatically Collected Data: Retained for up to 24 months from collection, unless longer retention is required for legal compliance or security purposes
Aggregated and Anonymized Data: Retained indefinitely as it no longer identifies you
Data required for legal compliance: Retained as long as required by applicable law

You have the right to request deletion of your personal data at any time, except where retention is required by law. If you'd like the Service Provider to delete User Provided Data that you have provided via the Application, please contact them at admin@arai-tech.com and they will respond within the time required by applicable law. Please note that some User Provided Data may be required in order for the Application to function properly.

How does the Application address children's privacy?

The Application is not intended for children under 16 years of age, or where a higher age of digital consent is established under applicable law. The Service Provider does not knowingly solicit data from children or market the Application to them.

The Service Provider does not knowingly collect personally identifiable information from children. The Service Provider encourages all children to never submit any personally identifiable information through the Application and/or Services. The Service Provider encourages parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide personally identifiable information through the Application and/or Services without their permission. If you have reason to believe that a child has provided personally identifiable information to the Service Provider through the Application and/or Services, please contact the Service Provider (admin@arai-tech.com) so that they will be able to take the necessary actions. If you are under 16 years of age, or where a higher age of digital consent is established by applicable law, your parent or guardian must provide consent on your behalf where permitted by law.

How is your information kept secure?

The Service Provider is committed to safeguarding the confidentiality of your information. The Service Provider implements physical, electronic, and procedural safeguards to protect information it processes and maintains. For example, access is limited to authorized employees and contractors who need to know that information to operate, develop, or improve the Application. However, no security system can prevent all potential security breaches.

Data Breach Notification

In the event of a personal data breach that poses a risk to your rights and freedoms, the Service Provider will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by applicable law. Where the breach is likely to result in a high risk to your rights and freedoms, the Service Provider will also notify you without undue delay, providing information about the nature of the breach, the categories of data affected, and the measures taken or proposed to address the breach.

How will you be informed of changes to this Privacy Policy?

The Service Provider may update this Privacy Policy from time to time. The Service Provider will notify you of material changes by posting the updated Privacy Policy with an effective date. Where required by law, the Service Provider will seek your consent to material changes before they take effect.

Previous versions of this Privacy Policy will be maintained and made available upon request by contacting the Service Provider at admin@arai-tech.com.

This privacy policy is effective as of 2026-07-22

What are your GDPR data protection rights?

Under the GDPR, you have the following rights:

Right of Access: You can request access to your personal data.
Right to Rectification: You can request correction of inaccurate data.
Right to Erasure: You can request deletion of your personal data (the "right to be forgotten").
Right to Restrict Processing: You can request that the Data Controller limits how they use your data.
Right to Data Portability: You can request a copy of your data in a structured, commonly used, machine-readable format.
Right to Object: You can object to processing based on legitimate interests. You have an absolute right to object to processing for direct marketing purposes at any time.
Right to Withdraw Consent: Where processing is based on your consent, you can withdraw it at any time. Withdrawal is as simple as toggling preferences in the Application's settings or contacting the Data Controller.
Rights Regarding Automated Decision-Making: You have rights related to automated decisions that affect you.

If you believe your data protection rights have been violated, you have the right to lodge a complaint with your local Data Protection Authority. Contact details for each country's Data Protection Authority can be found at: https://edpb.ec.europa.eu/about-edpb/members_en

If you are located in the United Kingdom, you may contact the Information Commissioner's Office at https://ico.org.uk

What are your California privacy rights (CCPA/CPRA)?

If you are a resident of California, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) provide you with additional rights regarding your personal information:

Right to Know: You can request disclosure of the categories and specific pieces of personal information the Service Provider has collected about you.
Right to Delete: You can request deletion of personal information the Service Provider has collected from you, subject to certain exceptions.
Right to Correct: You can request correction of inaccurate personal information.
Right to Opt-Out: You can opt out of the sale or sharing of your personal information for cross-context behavioral advertising.
Right to Limit Use of Sensitive Personal Information: You can limit the use of your sensitive personal information to essential purposes.
Right to Non-Discrimination: The Service Provider will not discriminate against you for exercising any of your CCPA/CPRA rights.

To exercise any of these rights, please contact the Service Provider at admin@arai-tech.com. The Service Provider will verify your request using the information you provide and respond within the timeframes required by law. You may designate an authorized agent to make a request on your behalf.

How do you give your consent?

Where processing is based on consent, you provide that consent by affirmatively opting in to the relevant feature or action. You may withdraw consent at any time without affecting processing carried out before withdrawal. Processing based on other lawful bases, including contract performance, legitimate interests, or legal obligations, is carried out as described above.

How can you contact the Data Controller?

If you have any questions regarding privacy while using the Application, or have questions about the practices, please contact the Service Provider via email at admin@arai-tech.com.

To request deletion of your personal data or to exercise any of your rights, contact the Service Provider using the details provided above. The Service Provider will respond within one month of receiving your request, extendable by up to two months where necessary due to the complexity or volume of requests, as permitted by applicable law.

This privacy policy page was generated by App Privacy Policy Generator