Privacy policy
Last updated:
This policy covers the Clevernibs website and early-access waitlist.
Who is responsible?
Thomas Leicht, operating Clevernibs, is responsible for your personal data (the “controller” under the GDPR).
[Street and house number, postcode, city, country]
Contact: clevernibs@gmail.com.
When you visit the website
Cloudflare Pages hosts and delivers this website. Cloudflare processes technical data such as your IP address, requested pages, request times and browser information to deliver the site and protect it against abuse.
The legal basis is our legitimate interest in running a reliable, secure website (Article 6(1)(f) GDPR).
Technical logs: [Confirm which logs are retained and their deletion periods for the Cloudflare services enabled on this site.]
When you join the waitlist
We use your email address to send early-access invitations and Clevernibs launch updates through HubSpot. Signing up is optional. Without your email address, we cannot send these messages. The legal basis is your consent (Article 6(1)(a) GDPR).
You can withdraw consent at any time using the unsubscribe link in our emails or by contacting us. This does not affect processing that was lawful before you withdrew.
We store your email address to manage the waitlist. [Confirm which signup and consent records are kept, and any additional technical data collected by the HubSpot signup flow.]
We remove entries from the active waitlist when you withdraw consent or the waitlist ends, and in any event within three years of signup, whichever comes first.
Where necessary to document consent or defend legal claims, we retain limited consent records for up to three years after your subscription ends. Our legitimate interest in demonstrating lawful communication is the legal basis (Article 6(1)(f) GDPR). We keep a minimal unsubscribe record while we continue sending launch emails, solely to prevent further messages to you.
When you contact us
We use your email address, message and any details you send to answer your request. Our legitimate interest in handling enquiries is the legal basis (Article 6(1)(f) GDPR). For requests about entering or performing a contract, Article 6(1)(b) GDPR applies instead.
We use HubSpot to receive contact form submissions and Google's Gmail service to receive notifications and answer messages. We delete routine enquiries within six months after resolving them. Where a message must be retained under a legal obligation, we retain it for the applicable statutory period.
Service providers and international transfers
Cloudflare, HubSpot and Google receive data needed to provide their services. These providers use international infrastructure, so data may be processed outside the European Economic Area, including in the United States.
Transfers to certified US recipients covered by the EU–U.S. Data Privacy Framework rely on the European Commission's adequacy decision. Where that framework does not apply, the providers use EU standard contractual clauses where required, as described in their linked terms. You can contact us for a copy of the applicable safeguards.
[Verify the recipients, transfer countries and safeguards for the actual accounts, including the consumer Gmail account, before publication.]
Provider details: Cloudflare privacy policy, Cloudflare data processing terms, HubSpot privacy policy, HubSpot data processing terms, Google privacy policy and Google data transfer frameworks.
Cookies and tracking
After a successful signup, a temporary cookie carries your email address to the confirmation message. It is removed when that message loads, or expires after one minute.
This website does not use advertising cookies or visitor analytics trackers. Fonts are served from this website, so your browser does not contact Google Fonts. We do not track email opens or link clicks.
[Confirm these settings in Cloudflare and HubSpot before publication. Describe any enabled cookies or tracking and obtain consent where required.]
Your rights
Subject to the GDPR's conditions, you can ask to access, correct or delete your data, restrict its use, or receive a portable copy. You can withdraw consent at any time. Contact us using the details above.
You can object to processing based on legitimate interests for reasons relating to your situation. You can always object to direct marketing.
You can also complain to a data protection authority, including in the country where you live or work, or where you believe an infringement occurred. We do not make automated decisions that have legal or similarly significant effects on you.