This Privacy Policy explains how CleverUpps CommV ("CleverUpps", "we", "us") collects, uses, and protects personal data when you use the CleverBooking platform at clever-booking.com and any related services (collectively, the "Service").
1. Who is the data controller?
The data controller for the personal data we process is:
- CleverUpps CommV
- Stationslaan 39, 1980 Zemst, Belgium
- BTW / VAT: BE0724738765
- Email: info@cleverupps.be
2. What personal data we collect
2.1 Account & business data
- Name, email address, profile picture (via Google or Kinde sign-in).
- Business name, address, working hours, services, employees.
- Branding assets (logo, colors, custom domain) you upload.
2.2 Customer data you submit
When you (as a CleverBooking customer) manage your end-clients in the platform, you may store their name, email, phone number, and appointment history. You are the data controller for that data; we act as a processor on your behalf.
2.3 Usage & technical data
- IP address, browser type, device information, referring URL.
- Pages visited, features used, error logs (for debugging and security).
2.4 Payment data
Payments are processed by Stripe. We never see or store your full card details; we only retain a Stripe customer/subscription identifier.
3. Why we process your data (legal basis)
- Contract: to provide the Service you signed up for.
- Legitimate interest: to keep the Service secure, prevent abuse, and improve the product.
- Legal obligation: to comply with Belgian and EU law (e.g. invoicing, tax).
- Consent: for non-essential cookies and optional marketing emails.
4. How long we keep your data
- Account data: while your account is active and up to 12 months after deletion.
- Invoicing & accounting data: 7 years (Belgian tax law).
- Support emails: up to 3 years after the last interaction.
- Backups: rotated within 30 days.
5. Sub-processors we use
To deliver the Service, we share data with the following processors:
- Kinde — authentication.
- Stripe — payments and subscription billing.
- Brevo — transactional email (booking confirmations, invitations).
- Twilio — SMS notifications.
- Hostinger — hosting (EU region).
All sub-processors are bound by data-processing agreements compliant with the GDPR.
6. International transfers
Your data is hosted in the EU. Where a sub-processor transfers data outside the EU/EEA (e.g. Stripe, Twilio), the transfer is covered by the European Commission's Standard Contractual Clauses or an adequacy decision.
7. Your rights under the GDPR
You have the right to:
- Access the personal data we hold about you.
- Rectify inaccurate data.
- Erase your data ("right to be forgotten") subject to legal retention obligations.
- Restrict or object to processing.
- Data portability — receive your data in a structured, machine-readable format.
- Withdraw consent at any time, where consent is the legal basis.
- Lodge a complaint with the Belgian Data Protection Authority (gegevensbeschermingsautoriteit.be).
To exercise any of these rights, email info@cleverupps.be. We respond within 30 days.
8. Cookies
We use a minimal set of cookies that are strictly necessary to operate the Service (authentication, session, CSRF protection). We do not use third-party advertising or cross-site tracking cookies. Analytics, when enabled, are privacy-preserving and first-party only.
9. Security
We protect your data with TLS in transit, encryption at rest where supported by our hosting provider, role-based access controls, audit logging, and regular security reviews. In the unlikely event of a personal-data breach, we will notify affected users and the Belgian DPA within 72 hours where required by law.
10. Children
The Service is not directed to children under 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us and we will delete it.
11. Changes to this policy
We may update this Privacy Policy. We will post the updated version on this page and update the "Last updated" date. Material changes will be communicated via email or in-app notice.
12. Contact
For any privacy question, contact info@cleverupps.be.