Privacy policy.

This Privacy Policy explains how Clearlinks, Inc. ("Clearlinks", "we", "us") collects and processes personal information across our marketing websites, sales activities, and the Clearlinks platform.

When we process student education records, employee records, or other personal data on behalf of a school, district, or other customer, we do so as a service provider under that customer's instructions. The customer's own privacy notice governs the relationship with data subjects in that context; this policy explains our role.

From visitors to our marketing sites

• Information you submit through forms (name, email, organization, role);
• Usage analytics (pages viewed, referring source, IP-derived region);
• Cookies and similar technologies, as described in our Cookie Notice.

From customers using the platform

• Account information (work email, name, role, organization);
• Authentication and audit metadata (login events, IP, user agent);
• Content you submit for processing ("Customer Content"), which may contain personal information depending on the materials.

We process personal information to:

• Provide, maintain, and improve the Services;
• Communicate with you about your account, support requests, and product updates;
• Detect and prevent fraud, abuse, and security incidents;
• Comply with legal obligations.

We do not use Customer Content to train any AI model — ours or any third party's. We do not sell personal information.

We share personal information only with:

• Subprocessors who provide infrastructure or specific services on our behalf, listed at clearlinks.org/subprocessors;
• Authorized personnel within your organization, consistent with the roles configured by your administrator;
• Legal authorities when required by valid legal process, with notice to the customer where allowed by law.

Customer Content is retained for the duration of the customer's subscription and for any additional period set out in the Order Form or DPA. Default retention is 30 days after deletion or termination, after which data is purged via cryptographic zeroize. Account metadata may be retained longer where required for tax, accounting, or compliance purposes.

Clearlinks operates infrastructure in the United States and the European Union. Customers may choose which region processes their data. Where we transfer personal information across borders, we rely on Standard Contractual Clauses and, where applicable, the EU-US Data Privacy Framework.

Depending on your location, you may have rights to access, correct, delete, or restrict the use of your personal information, or to object to certain processing. To exercise these rights, contact privacy@clearlinks.org.

If you submitted personal information through your school, district, or employer, please contact them first; we will support their response to your request.

When we process student education records on behalf of a school under FERPA, we act as a "school official" with a legitimate educational interest under § 99.31(a)(1). We use student personal information only for the purposes authorized by the school.

For services directed to children under 13, we operate as a processor for the school and rely on the school for parental notice and consent as permitted under COPPA. We do not direct marketing to children and do not condition participation in any activity on disclosing more information than is reasonably necessary.

We use administrative, technical, and physical safeguards designed to protect personal information. See our security page for details on our certifications and engineering practices.

Questions about this policy? Email privacy@clearlinks.org or write to Clearlinks, Inc., 133 Wythe Avenue, Brooklyn, NY 11211. Our EU representative is available at eu-rep@clearlinks.org.