Privacy Policy – Clany

Effective Date: February 1, 2026

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1. Introduction & Global Scope

Clany is committed to protecting your privacy and your family's data under the strictest security standards. Although our operational base is governed by the GDPR (EU) and the LOPDGDD (Spain), we apply these protection levels globally to all our users, regardless of their geographical location (USA, Latin America, etc.), ensuring world-class privacy.

2. Information Collected

• User Data: Name and email used for registration, authentication, and service access.
• Clan Profiles: Clan users can create internal profiles for agenda management. These profiles may include a name and, optionally and voluntarily, a date of birth for personalization purposes. These profiles do not have their own access accounts.
• Shared Content: Events, dates, and tasks that users associate with the various profiles in the group.
• Metadata: Device tokens for push notifications and advertising identifiers (subject to your consent).

3. Storage and Security (Data Sovereignty)

• Location: Data is stored on self-managed servers provided by OVHcloud located in France (European Union).
• International Guarantee: This location ensures that the information of all our users—including those from the USA, South America, or any other country—is protected by the most robust privacy laws on the planet, preventing unauthorized access or data exploitation permitted in other less restrictive jurisdictions.
• Identity: Access and authentication management is performed through our own instance of Keycloak, ensuring that your credentials are not shared with third parties.
• Encryption: We use secure databases (PostgreSQL, MongoDB) encrypted at rest and SSL/TLS connections in transit.

4. Use of Personal Data

• Service operation: creating and synchronizing calendars, sending event notifications.
• Security and fraud prevention: detecting unauthorized access.
• App improvement: anonymous analytics (Firebase) to optimize performance.
• In-app advertising: Clany displays ads via the AdMob platform. These ads can be personalized based on your interests if you provide consent. Otherwise, you will see generic, non-personalized ads.
• To show personalized ads, Clany may use advertising identifiers (such as IDFA on iOS or Advertising ID on Android). You can enable or disable ad personalization directly in the “Privacy Settings” section of the user profile in the app, or through your device's privacy settings.
• Subscription management: we use RevenueCat to process and validate in-app subscriptions and purchases. We do not store banking data; payments are managed by the app store (App Store or Google Play).

5. Responsibility in Profile Creation

Clany is a collaborative environment. Any Clan user with permissions to create member profiles guarantees that they have the legal authority or necessary consent (such as parental authority in the case of minors) to enter such data into the platform.

6. Third-Party Sharing

We do not sell your personal data. We share the minimum technical information necessary with:

• Google Firebase: Notifications, performance metrics, and technical stability.
• RevenueCat: Technical validation of subscriptions and transactions.

7. User Rights

You have the right to Access, Rectification, Erasure (Right to be Forgotten), Objection, and Portability of your data.

• Exercise of rights: Email us at [email protected] with a request and proof of identity.
• Account Deletion Process: You can request deletion from the Profile section. Upon doing so, access to your account will be revoked immediately (deactivation in the identity system). For security reasons and to prevent accidental deletions, your data will remain in a latent state for 48 hours, after which it will undergo irreversible anonymization definitively.

8. Data Retention

We retain your data while your account is active to provide the service. Once deletion is requested, your information will enter the 48-hour latency period mentioned above, during which deletion is reversible if you re-register. Following this safety period, personal data will be unlinked from any identifier through irreversible anonymization, and will no longer be considered personal data. This excludes minimum data (such as premium subscription transaction records) that we are required to keep in a restricted state to comply with current legal and tax obligations.

9. International Users and Compatibility

Clany respects the principles of transparency and data control. Our practices are designed to meet and exceed the requirements of international regulations such as the CCPA/CPRA (California, USA), the LGPD (Brazil), and local data protection laws in Latin America. If you reside in a country with mandatory consumer laws that grant additional rights, Clany will respect such local regulations as long as they do not conflict with the technical security of the system.

10. Prevalent Language

This Privacy Policy was originally drafted in Spanish. In the event that it is translated into other languages and discrepancies or conflicts of interpretation exist between the Spanish version and any other translation, the Spanish version shall be the only valid and legally binding one.

11. Changes and Jurisdiction

We may update this Policy by notifying you within the app. For any legal controversy, the user agrees to submit to Spanish legislation and the courts of Barcelona.