Privacy Policy

Clear CMS is run by Slava Solutions (slavasolutions.com), [legal entity name], [business address], Ontario, Canada. We are responsible for the personal information described here, except where we say we act on a client's behalf.

This policy is written to meet Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and, where it applies, the European Union and UK General Data Protection Regulation (GDPR).

Effective date: [effective date]. Last updated: [last updated date].

Account holders: people who sign in to Clear CMS to edit a site, including people invited by a client. For them, we decide how their information is used (we are the "controller").

Visitors of client sites: people who visit a website hosted with Clear CMS. For them, our client (the site owner) decides what is collected and why. We host the site and handle that information only on the client's instructions (we are the "processor"). Questions about a particular site's use of your information should go to that site's owner first.

• Account details: name, email address, profile photo if you sign in with Google, and which sites you can edit.
• Sign-in information: sign-in times, device and browser type, and IP address, used to keep accounts secure.
• Your activity in the editor: which changes were made, when, and by whom, so a site can show its edit history and restore earlier versions.
• Messages: emails you send us and our replies.
• Billing details, once paid plans exist: [to be completed when billing launches; card details would be handled by the payment provider, not stored by us].

We do not collect more than we need, and we do not ask for sensitive information.

When a person visits a site hosted with Clear CMS, our hosting provider handles their request and may briefly record technical information such as IP address, browser type, the page requested and the time, to deliver the page and protect against attacks.

Sites hosted with Clear CMS use Cloudflare Web Analytics to count visits. It sets no cookies, does not build a profile of any visitor, and does not follow people across sites. It gives the site owner and us only overall totals: page views, where visitors came from (referring site), country, and device or browser type.

The site itself sets no tracking or advertising cookies from us. If a client adds their own forms, embeds or tools to their site, those are the client's responsibility.

We use personal information only to:

• create and run accounts and let people sign in;
• host, publish, back up and secure websites;
• send service emails, such as sign-in codes, invitations and important notices;
• answer questions and support requests;
• keep the service safe, prevent abuse, and meet legal obligations.

We do not sell personal information, and we do not use it for advertising.

Under GDPR, our legal bases are: performing our contract with you, our legitimate interest in running a secure service, meeting legal obligations, and your consent where we ask for it.

We share information with these providers only as needed to run Clear CMS. Each is bound to protect it.

• Cloudflare, Inc. (United States): website hosting, file storage, domain connections and security for all sites and the editor, and Cloudflare Web Analytics for cookieless, overall visit counts on client sites.
• Clerk, Inc. (United States): sign-in and account management.
• Resend (United States): delivery of service emails.
• Google LLC (United States): only if you choose "Sign in with Google"; Google shares your name, email and profile photo with us.

If we add or change a provider (for example for forms, an AI helper or payments), we will update this list before we start using it.

Some of these providers store or process information outside Canada, mainly in the United States. That information may be accessible to courts and authorities there under local law. Where GDPR applies, we rely on appropriate safeguards such as Standard Contractual Clauses.

Clear CMS uses only the cookies it needs to work:

• Sign-in session cookie: keeps you signed in to the editor. Set only for account holders.
• Preview cookie: lets an editor see unpublished changes on their site while editing. Set only for signed-in editors.

We do not use advertising or tracking cookies, and our visit counting (Cloudflare Web Analytics) uses no cookies at all. Because these cookies are strictly necessary, we do not ask for consent to set them. Visitors who never sign in to the editor receive neither.

• Account details: while your account is active, then deleted within [period, e.g. 90 days] after it closes.
• Site content and edit history: while the site is active; after it closes, available for export for [export window, e.g. 30 days], then deleted.
• Backups: kept for up to [backup retention period] and then overwritten.
• Security and sign-in logs: kept for up to [log retention period].
• Billing records: kept as long as tax law requires.

We keep information longer only when the law requires it.

We protect information with encrypted connections, access limited to people who need it, and providers with strong security programs. No system is perfectly secure, so if a breach puts you at real risk of significant harm, we will tell you and the relevant regulator as the law requires.

You can ask us to:

• see the personal information we hold about you;
• correct it if it is wrong;
• delete it, or stop using it for a purpose;
• give you a copy in a common format;
• withdraw consent you have given.

Email privacy@clearcms.app. We will reply within 30 days. If you are a visitor of a client's site, we will pass your request to the site owner and help them answer it.

If you are not satisfied with our answer, you can complain to the Office of the Privacy Commissioner of Canada or, in the EU or UK, to your local data protection authority.

Clear CMS is not meant for children, and we do not knowingly collect information from anyone under [minimum age, e.g. 16] for account holders.

We may update this policy. If a change is significant, we will tell account holders by email or in the editor before it takes effect. The date at the top shows when it last changed.

Privacy questions and requests: privacy@clearcms.app.
Privacy officer: [name of person responsible for privacy], Slava Solutions, [business address].