Privacy Policy

1. Overview

Clarevo ("Clarevo," "we," "our," or "us") is a division of Hellhorse Performance, LLC, a Texas limited liability company. Our contact information is listed in Section 14.

This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit clarevo.ai, use our services, or communicate with us. By using our services you agree to the practices described in this policy.

2. Information We Collect

Information you provide to us

• Contact information: Name, email address, phone number, company name, job title.
• LinkedIn profile data: Your LinkedIn profile URL and publicly available profile content (posts, bio, experience) that you provide or that we access during the onboarding intake and ongoing service delivery.
• Voice profile data: Answers to our intake questionnaire — your communication style, topic pillars, POV, frameworks, writing samples, and professional background. This is the core data we use to create your content. See Section 3 for full details.
• Voice memos: Audio recordings you voluntarily submit during onboarding to capture your natural speaking patterns. See Section 4 for handling details.
• Business information: Company size, industry, ICP (ideal customer profile) descriptions, goals, and any documents or materials you voluntarily share.
• Payment information: Billing name, billing address, and payment card details. Card numbers are processed directly by Stripe and are not stored by Clarevo. See Section 6.
• Communications: Emails, Slack messages, and other communications you send us.

Information collected automatically

• Usage data: Pages visited, time on page, browser type, operating system, referring URL, and IP address.
• Device data: Browser version, screen resolution, language settings.
• Cookies and similar technologies: See Section 10.

Information from third parties

• If you request a call through our website, we receive your name, email, phone number, preferred times, and any notes submitted with the request.
• If you connect a LinkedIn profile for publishing, we receive profile data and post performance data through the LinkedIn API (see Section 7).
• Performance analytics from the LinkedIn Analytics API for profiles enrolled in our service.

3. Voice Profile Data

Your Voice Profile is the foundation of our service. This section explains what we collect, how we process it, how long we retain it, and your rights regarding it.

What we collect for your Voice Profile

• Intake questionnaire responses: Your answers to our 40-question voice extraction questionnaire, including communication style preferences, topic pillars, points of view, frameworks, and professional expertise.
• Voice memos: Audio recordings you submit during onboarding to help us capture your natural speaking patterns and vocabulary. See Section 4 for voice memo handling details.
• Writing samples: Email samples, existing LinkedIn posts, articles, or other written content you provide to help us match your voice.
• LinkedIn profile data: Your public LinkedIn profile content (headline, about section, experience, posts) used to understand your current positioning and tone.
• Discovery call notes: Notes and observations from your onboarding discovery call or leadership assessment.

How we process Voice Profile data

Voice Profile data is processed using our proprietary content creation methodology to build a profile of your communication style, vocabulary, expertise, and tone. This profile is used exclusively to create content that matches your authentic voice. Voice Profile data is never shared with other clients, used to create content for anyone other than you, or used to train general-purpose models.

Retention and deletion

Voice Profile data is retained for the duration of your active subscription plus 90 days after cancellation. You may request immediate deletion of your Voice Profile at any time by emailing legal@clarevo.ai. Upon receiving a deletion request, we will permanently delete your Voice Profile data within 30 days. This right applies under both GDPR (for EU/UK residents) and CCPA (for California residents), and is extended as a courtesy to all clients regardless of jurisdiction.

Portability

You may request an export of your Voice Profile data in a portable format at any time during your active subscription or within 90 days of cancellation. Export requests are fulfilled within 14 business days.

4. Voice Memo Handling

If you submit voice memos as part of your onboarding or ongoing content process, the following applies:

• Storage: Voice memo audio files are stored securely on Vercel Blob storage with encryption at rest.
• Transcription: Voice memos are transcribed to extract your speaking patterns, vocabulary, and communication style for Voice Profile creation.
• Deletion after processing: By default, original audio files are deleted within 30 days after your Voice Profile is built and you have confirmed satisfaction with your first batch of content. If you prefer, you may request that audio files be retained for ongoing voice refinement.
• Retention upon request: If you request retention, voice memo audio files are stored for the duration of your active subscription and deleted upon cancellation or upon your request, whichever comes first.
• Access: Only authorized Clarevo personnel involved in your content creation process have access to your voice memo files.

5. How We Use Your Information

We use your information for the following purposes:

• Service delivery: Creating, reviewing, scheduling, and publishing your LinkedIn content based on your voice profile.
• Onboarding: Conducting your discovery call, intake interview, and voice extraction session.
• Client communication: Sending content drafts for approval, performance reports, billing receipts, and service updates.
• Billing and payments: Processing your subscription payment via Stripe, sending invoices, and managing subscription changes.
• SMS communications: Sending account updates and service notifications via text message, only if you have opted in. See Section 5.
• Analytics and improvement: Understanding how our service performs and how we can improve results for clients.
• Legal compliance: Meeting our obligations under applicable federal and Texas state laws.
• Security: Detecting and preventing fraud, abuse, or unauthorized access.

We do not use your information to train general-purpose AI models, sell data to advertisers, or share your content with other clients.

6. Third-Party Processors

We use the following third-party service providers ("processors") to operate Clarevo. Each processor is bound by its own privacy and security commitments and handles specific categories of data per its own privacy policy. We share only the minimum data required for each provider to perform its function.

Each processor handles data per its own published privacy policy. We encourage you to review the privacy practices of any processor whose data handling is relevant to you.

We do not sell, rent, or trade your personal information to any third party for marketing purposes.

Sub-processor changes

We will notify you at least 14 days before adding a new sub-processor that handles your personal data. Notification will be sent to the email address associated with your account. You may object to the addition of a new sub-processor within that 14-day period by contacting legal@clarevo.ai. If you object and we cannot reasonably accommodate your concern, you may terminate your subscription without penalty.

7. SMS & Text Messaging

Clarevo may send text messages (SMS/MMS) to the phone number you provide, only if you have explicitly opted in by checking the SMS consent box on our intake form. SMS opt-in is separate from, and not a condition of, purchasing or using our service.

Texas SB 140 Compliance

Clarevo operates in compliance with Texas Senate Bill 140, effective September 1, 2025, which governs automated SMS communications to Texas residents. Our SMS program is a consent-based program in which recipients affirmatively opt in prior to receiving any messages. Per the Texas Attorney General's guidance, consent-based opt-in programs are outside the registration requirement of SB 140.

All opt-in records are maintained with date, time, and source of consent. If you are a Texas resident and have questions about your SMS rights, contact us at legal@clarevo.ai.

TCPA Compliance

Our SMS program complies with the Telephone Consumer Protection Act (TCPA). We obtain prior express written consent before sending any marketing text messages. Consent is obtained through a clear, separate, unchecked checkbox at the point of intake and is not bundled with any other agreement. You may revoke consent at any time by replying STOP to any message.

For our full SMS Policy, visit: clarevo.ai/sms-policy.

8. Payment Processing

All payment processing is handled by Stripe (Stripe, Inc.). When you enter payment card information on our checkout page, that information is transmitted directly to Stripe's secure servers using industry-standard TLS encryption. Clarevo does not store, transmit, or have access to your full card number, CVV, or magnetic stripe data.

Stripe is PCI-DSS Level 1 certified. Your billing name and address are stored by Stripe and used solely for billing, fraud prevention, and chargebacks. For Stripe's privacy practices, visit stripe.com/privacy.

Clarevo retains billing records (amount, date, description, last four digits of card) as required for accounting and tax purposes.

9. LinkedIn Data & API Usage

Clarevo uses the LinkedIn API and our automated publishing infrastructure to schedule and publish content to your LinkedIn profile on your behalf. By connecting your LinkedIn profile via OAuth, you authorize us to access specific LinkedIn data.

What we access via LinkedIn OAuth

• Profile data: Your name, headline, about section, experience, and education (used for voice extraction and content strategy).
• Post history: Your recent LinkedIn posts (used to understand your current content style and avoid duplication).
• Analytics data: Post impressions, engagement metrics, follower count, and profile view data (used for your monthly performance reports).
• Publishing access: Permission to create and schedule posts on your behalf.

What we store

• Your LinkedIn profile URL and OAuth tokens (encrypted at rest)
• Post performance metrics for reporting purposes
• Content we publish on your behalf

What we do NOT access or store

• Passwords: We never see or store your LinkedIn password. Authentication is handled entirely through LinkedIn's OAuth flow.
• Direct messages: We do not access your LinkedIn inbox or private messages.
• Connections list: We do not access, download, or store your LinkedIn connections or contact information.
• Email address from LinkedIn: We do not retrieve your email address from LinkedIn (we use the email you provide directly to us).

You may revoke LinkedIn API access at any time through your LinkedIn Settings under "Permitted Services." Revoking access will immediately suspend post publishing until access is restored.

All LinkedIn activity performed on your behalf by Clarevo complies with the LinkedIn User Agreement and LinkedIn Platform Terms.

10. Data Retention

We retain your personal information for as long as your account is active or as needed to provide services. Upon cancellation of your subscription:

• Voice profile data is retained for 90 days after cancellation, after which it is deleted. You may request immediate deletion by contacting legal@clarevo.ai.
• Post content and drafts are retained for 90 days post-cancellation, then deleted.
• Billing records are retained for 7 years as required by Texas and federal tax law.
• Communication records (emails, support notes) are retained for 3 years.
• SMS opt-in records are retained for 5 years to demonstrate compliance with TCPA and Texas SB 140.

11. Your Rights

You have the following rights regarding your personal information:

All users

• Access: Request a copy of the personal information we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Deletion: Request deletion of your personal data, subject to legal retention requirements.
• Portability: Request your voice profile data and post history in a portable format.
• Opt-out of SMS: Reply STOP to any text message at any time.

California residents (CCPA/CPRA)

California residents have additional rights under the California Consumer Privacy Act:

• The right to know what categories of personal information we collect and why.
• The right to opt out of the sale of personal information. We do not sell personal information.
• The right to non-discrimination for exercising privacy rights.
• The right to correct inaccurate personal information.
• The right to limit use of sensitive personal information.

To exercise any of these rights, contact us at legal@clarevo.ai. We will respond within 45 days as required by CCPA.

European Economic Area, UK, and Swiss residents (GDPR / UK GDPR)

If you are located in the European Economic Area, United Kingdom, or Switzerland, you have the following additional rights under the General Data Protection Regulation:

• Right of access (Art. 15): Request a copy of the personal data we process about you.
• Right to rectification (Art. 16): Request correction of inaccurate or incomplete personal data.
• Right to erasure (Art. 17): Request deletion of your personal data where it is no longer necessary for the purposes for which it was collected.
• Right to restriction of processing (Art. 18): Request that we limit the processing of your personal data in certain circumstances.
• Right to data portability (Art. 20): Receive your personal data in a structured, commonly used, machine-readable format.
• Right to object (Art. 21): Object to our processing of your personal data based on legitimate interests.
• Rights related to automated decision-making (Art. 22): Clarevo does not make decisions based solely on automated processing that produce legal or similarly significant effects on you. Content is generated with AI assistance but is reviewed by humans before delivery.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw consent at any time without affecting the lawfulness of processing performed before withdrawal.
• Right to lodge a complaint: You have the right to lodge a complaint with your local data protection supervisory authority.

To exercise any of these rights, contact us at legal@clarevo.ai. We will respond within 30 days as required by GDPR.

Legal basis for processing: We process your personal data on the following legal bases: (a) performance of a contract (delivering the service you subscribed to); (b) legitimate interests — including cold outbound prospecting to business professionals who may benefit from our LinkedIn thought leadership service (Art. 6(1)(f)), improving service quality, and preventing fraud; and (c) consent (where applicable, such as SMS opt-in). Where we rely on legitimate interests for outbound email prospecting, recipients are notified at the point of first contact and may object at any time by clicking "Unsubscribe / Object" in any email or by contacting legal@clarevo.ai.

Singapore residents (PDPA)

If you are located in Singapore, your personal data is processed in accordance with Singapore's Personal Data Protection Act 2012 (as amended by the Personal Data Protection (Amendment) Act 2020). You have the following rights under the PDPA:

• Right of access: Request a copy of the personal data we hold about you.
• Right to correction: Request correction of inaccurate or incomplete personal data.
• Right to withdrawal of consent: Withdraw consent to the collection, use, or disclosure of your personal data, subject to legal or contractual restrictions.
• Right to data portability: Request that your personal data be transmitted in a portable format, where technically feasible.

Where we send you outbound prospecting emails, we do so on the basis of legitimate business purpose under Section 15E of the PDPA (business contact information used for business-to-business communications). You may withdraw from receiving such communications at any time by clicking "Unsubscribe / Object" in any email or by contacting legal@clarevo.ai. We will action withdrawal requests within 10 business days.

To exercise any PDPA rights, contact us at legal@clarevo.ai. We will respond within 30 days.

12. Cookies & Tracking

Clarevo uses cookies and similar tracking technologies to operate our website and understand usage patterns.

Types of cookies we use

• Essential cookies: Required for the website to function (session state, authentication tokens, CSRF protection). These cookies are strictly necessary and cannot be disabled. Duration: session or up to 30 days.
• Analytics cookies: Used to understand how visitors use our site. We use privacy-respecting analytics only. These cookies collect anonymized usage data (pages visited, time on page, referral source). Duration: up to 12 months.
• Preference cookies: Remember your settings and choices (e.g., language, display preferences). Duration: up to 12 months.
• Marketing cookies: Not currently used. If we add them in the future, this policy will be updated and consent will be obtained before deployment.

Third-party resources

Our website loads Google Fonts for typography. Google may collect limited technical information (IP address, browser user agent) when fonts are loaded. No tracking cookies are set by Google Fonts. For details, see Google Fonts Privacy FAQ.

Cookie management

You can control cookies through your browser settings. Most browsers allow you to block or delete cookies. Disabling essential cookies may affect website functionality but will not affect your ability to receive Clarevo's services once enrolled.

For visitors from the European Economic Area, United Kingdom, or Switzerland, we will present a cookie consent banner allowing you to accept or reject non-essential cookies before they are set.

13. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include TLS encryption for data in transit, access controls limiting data access to personnel who need it to deliver services, and regular security reviews of our service providers.

No method of electronic transmission or storage is 100% secure. If you believe your information has been compromised, contact us immediately at legal@clarevo.ai.

International data transfers

Clarevo is based in the United States. If you are accessing our services from outside the United States, your personal data will be transferred to and processed in the United States, where data protection laws may differ from those in your jurisdiction. By using our services, you consent to this transfer.

For transfers of personal data from the European Economic Area, United Kingdom, or Switzerland to the United States, we rely on: (a) Standard Contractual Clauses approved by the European Commission; and (b) the data processing agreements of our third-party processors, which include appropriate safeguards for international transfers. You may request a copy of these safeguards by contacting legal@clarevo.ai.

Data breach notification

In the event of a data breach involving your personal information, Clarevo will: (a) investigate the breach promptly; (b) notify affected individuals by email within 72 hours of confirming the breach, or as required by applicable law; (c) notify relevant supervisory authorities as required by GDPR, CCPA, or Texas law (TX Bus. & Com. Code 521.053); and (d) provide a description of the breach, the categories of data affected, and the measures taken to address and mitigate the breach.

14. Children's Privacy

Clarevo's services are intended for business professionals and are not directed at individuals under the age of 18. We do not knowingly collect personal information from anyone under 18. If we become aware that we have inadvertently collected such information, we will delete it promptly.

15. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last updated" date at the top of this page and notify active clients by email at least 14 days before the changes take effect.

Your continued use of Clarevo's services after the effective date of an updated policy constitutes your acceptance of the changes.

16. Contact Us

For privacy-related questions, data requests, or to exercise your rights, contact us:

This Privacy Policy is not legal advice. If you have questions about your legal rights under applicable law, we recommend consulting a qualified attorney.