Last updated: Sep 4, 2026 · Effective: Sep 23, 2026

Privacy Policy

Clusy runs your code and sends your work to AI models to answer you, so being vague about data would not be much use to you. This policy says what we collect, who receives it, which countries it goes to, how long we keep it, and what you can ask us to do about it.

1.The short version

This summary is not a substitute for the rest of the policy, but these are the things people most want to know.

  • We do not sell or share your personal data, and we do not use third party advertising networks or advertising pixels.
  • We do not train AI models on your content. We run no training, fine tuning or distillation pipeline on customer notebooks, prompts, chat or outputs. Section 8 explains what the AI companies we send content to may do with it, which is a separate question.
  • Your prompts and notebook content are sent to third party AI companies to generate a response, including companies in mainland China and Singapore. Which one depends on the model you pick. Section 8 names every one of them.
  • Your code runs on third party infrastructure, E2B for CPU and Modal for GPU.
  • Automated systems scan code before it runs and produce security alerts. Section 9 explains what that means and what we record.
  • Anything you publish is public, and Hub listings are submitted to search engines and open to AI crawlers. Section 13.
  • You can access, export, correct and delete your data, and you can object to processing. Section 14.

2.Who we are, and our role

This policy explains how Clusy Inc. handles personal data. Clusy Inc. is a Delaware corporation with its registered address at 2093 Philadelphia Pike, Suite #3740, Claymont, DE 19703, United States. For privacy questions and to exercise your rights, contact privacy@clusy.io.

We act in two different roles, and it matters which one applies:

We are the controller
for your account and profile, billing and usage records, product analytics and service telemetry, security and abuse records, support tickets, marketing and attribution data, and meeting bookings. We decide why and how that data is processed, and this policy is your notice for it.
We act for you
for the content you put into the product: your notebooks, cells, code, uploaded files, prompts, chat, execution outputs and sandbox files. You decide what goes in. If you put other people’s personal data into Clusy, you are the controller of it and we process it on your instructions. We keep two exceptions for our own purposes, and we state them openly: security and abuse prevention (section 9), and operating and maintaining the service.

If you are a business customer and need a written data processing agreement covering the second role, email privacy@clusy.io.

This policy covers the Clusy web application, the clusy.io website, our documentation and blog, the meeting booking flow at clusy.io/meet, and our support and marketing communications.

3.What we collect

Account and profile

Your email address, and your display name and avatar if you sign in with Google or GitHub or if you set them. Optionally, a headline, a short bio, and website, GitHub and LinkedIn links, which are public if you fill them in. Your plan and onboarding status. Preferences you set, including custom instructions you write for the agent, your theme and interface settings, your default model and runtime choices, your email and notification preferences, and what you told us you signed up to do. We do not ask for your employer, job title or company at signup.

Content you create in the product

Notebook cells, including code and text. Files you upload and files created inside your sandbox. Your chat with the agent, including your prompts, the agent’s replies, tool calls and their results, and the model’s intermediate reasoning. Execution records, including error messages and Python tracebacks from your own code, and execution outputs, including images, tables and charts. Notes the agent extracts and keeps as project memory, stored with a numeric embedding so it can be recalled. Research results, including the question asked and quotations from the sources retrieved.

Credentials we hold for you

Access and refresh tokens for accounts you connect, your own model provider API keys if you use bring your own key, and any headers or environment values you configure for an MCP server. Clusy API keys you create are stored only as a hash, so we cannot recover the key itself. Section 12 explains how these are protected.

Billing

Your Stripe customer and subscription identifiers, your plan and its history, invoices, and metered usage records. We never receive or store your card number. Card details go directly to Stripe.

Device, usage and logs

Product analytics events about what you do in the app, request and access logs from our servers, your IP address, a coarse city and country derived from it, your browser and device type, language and timezone. Application error reports, which include an error message, a stack trace and the identifiers of the account, project and session involved.

Security and abuse records

Signals produced by the automated checks described in section 9, including categorised detection labels and irreversible hashes of the code that triggered them, records of suspensions and appeals, and hashes of IP addresses used to detect linked accounts.

Marketing and attribution

If you arrive from a campaign link, the referring URL, landing page and campaign parameters, held against your account after you sign up. An advertising click identifier from the link you arrived on is stored in a first party cookie and in your browser, but is not sent to your account record. Clicks on our short links are logged without an account identifier, with a hashed IP and a coarse country.

Meeting bookings and support

If you book a meeting with us: your name, email, timezone, any notes you write, and the email addresses of guests you add. If you contact support: your message, your email, and basic diagnostics about the page you were on. If you use the contact form on our website: your name, email, team or company and your message. If you use the Ask feature on our documentation site, your question and the last few turns of that conversation are sent to an AI model to generate an answer, and we do not store the text of your questions.

Where it comes from

Mostly from you and from your device. Some comes from your connected accounts at your direction, some from Stripe about your payments, and some from other people: someone who adds you as a guest to a meeting gives us your email address, and a person who shares a project with you creates a record involving you.

4.Sensitive data, and what not to upload

We do not ask you for sensitive personal data, and we have no interest in receiving it. But Clusy is a research tool with a filesystem and an upload button, so what ends up in your notebooks is your decision, and we will not pretend otherwise.

Do not upload special category data such as health, genetic, biometric, racial or ethnic origin, political, religious or sexual orientation data; protected health information under HIPAA; payment card data; or export controlled technical data, unless we have signed a separate written agreement covering it. We do not currently sign HIPAA business associate agreements. This is a term of the Terms of Use as well as a request.

Sensitive data we do hold as controller: credentials that grant access to your other accounts. That is the access and refresh tokens for services you connect, and your own model provider API keys. We use them only to authenticate you and to call those services at your direction, to secure the service and to prevent fraud. We do not use them for any other purpose and we do not sell or share them, so no separate opt out is required for them under California law. The only place such a credential goes besides the service you connected is your own sandbox: some publishing operations pass a token into the sandbox so the upload can run there.

We also hold records relating to suspected breaches of our terms, including suspension and ban records. Section 9 explains how those are used.

5.Why we use it, and our legal basis

If you are in the EEA, the UK or Switzerland, the right hand column is our legal basis under the GDPR. These apply to you because we offer services to people in those places, not only where some other law requires it.

Running the product
Providing accounts, projects, notebooks, the agent and the app. Necessary to perform our contract with you.
Executing your code
Provisioning and running cloud sandboxes. Necessary to perform our contract.
Sending content to AI providers
Transmitting prompts and notebook context to a model provider so it can generate a response. Necessary to perform our contract. This is not based on consent, and it is not optional if you use the agent.
Billing and metering
Subscriptions, invoices, usage metering, dunning and credits. Necessary to perform our contract, and to comply with tax and accounting obligations.
Security and abuse prevention
Detecting and acting on cryptomining, proxy and tunnelling abuse, malware infrastructure, scanning and other misuse of compute. Our legitimate interest in protecting other users, third parties on the internet, our providers and our business from real and recurring abuse, and in some cases compliance with law.
Service reliability
Logs, error reports, tracing and capacity work. Our legitimate interest in keeping the service working and diagnosing faults.
Product analytics
Understanding which features are used so we can improve them. Our legitimate interest in improving the product, and consent where required for cookies and similar technologies.
Support
Answering your questions and fixing your problems. Necessary to perform our contract.
Meeting bookings
Scheduling, confirming, reminding and cancelling. Necessary to take steps at your request before a contract, and our legitimate interest in arranging requested meetings.
Marketing
Product updates and announcements. Your consent, or our legitimate interest in telling existing customers about our own similar services, with an unsubscribe link in every message.
Legal compliance
Responding to lawful requests, keeping required records, enforcing our terms and establishing or defending legal claims. Compliance with a legal obligation, and our legitimate interest in establishing and defending claims.

Where we rely on legitimate interests, we have weighed them against your rights and you can ask us for the reasoning at privacy@clusy.io. You can object: see section 14.

6.AI processing and model providers

This is the section most people should read. To answer you, the agent sends your material to a third party AI company. The model you select decides which company handles your chat turn, but it does not decide every request. Two things also route independently of your choice:

  • Background work. Session and notebook titles and tags are generated by Anthropic Claude on AWS Bedrock, project memory embeddings are generated on AWS Bedrock, and inline code completion goes to DeepSeek. These run whatever model you have selected.
  • Fallback. If the provider for your selected model fails part way through a turn, we retry that turn on DeepSeek so your work is not lost. That means content you selected a different model for can reach DeepSeek, in mainland China, without you choosing it. If that is not acceptable for your work, tell us at privacy@clusy.io. Separately, if the safety filter on Claude Opus 5 or Claude Fable 5.1 declines a request, we retry that one turn on Claude Opus 4.8 at the same provider; no new company receives your content in that case.

What is sent

Your prompt and the conversation history. Notebook context, including cell code and text. The contents of files the agent reads, and excerpts of files in your project. Tool call arguments and results. Execution output and error traces. Images, but only when you have selected a model that supports vision. The system prompt also includes your timezone, an approximate city and country, your display name, your profile headline and what you told us you signed up to do.

It also includes your IP address. Where your browser connection has a public IP address, we include it in plain text in the system prompt, alongside the approximate location derived from it, so the agent can answer questions about what is local to you. We also send your IP address to ipapi.co, a geolocation service, to derive that location. If you would prefer this not to happen, tell us at privacy@clusy.io.

Who receives it

The first six entries below are the model providers that receive your content through our own provider accounts. The rest are services the agent calls while working on your behalf: they are not model providers, but they receive your content or your IP address, so they belong in the same list. It is current as of the date at the top of this page and changes when we add or retire a model or a tool.

Amazon Web Services
Amazon Bedrock. Serves the Anthropic Claude models we offer, generates session and notebook titles and tags, and produces the embeddings used for project memory. We call it through US cross-region inference profiles, so the inference itself may run in any United States AWS region. One model is treated differently: Claude Fable 5.1 is offered by AWS only on the condition that AWS may retain the prompts and outputs sent to it for up to 30 days and review them, inside AWS, for misuse. That retention applies to every hosted Fable 5.1 request, it is not shared with Anthropic, and it does not apply to the other Claude models we offer on Bedrock. If you would rather your content never be held that way, do not select Fable 5.1, or use it through your own Anthropic key.
Microsoft
Azure AI Foundry (Azure OpenAI). Serves the GPT model we offer. The account resource is in the Azure East US 2 region, but the deployment uses a global standard capacity type, so requests may be served from Microsoft data centres in other regions.
DeepSeek
api.deepseek.com, in mainland China. Serves the DeepSeek models, including the Auto option that accounts use unless you pick a different model, and inline code completion.
Moonshot AI
Serves Kimi models, on endpoints in mainland China and on its global platform.
Alibaba Cloud
Model Studio, through the Singapore (ap-southeast-1) gateway. Serves the Qwen model.
Cloudflare
Workers AI. Hosts models built by other companies, currently a Kimi model from Moonshot AI and GLM 5.2 from Z.ai, on Cloudflare’s own infrastructure.
ipapi.co
Receives your IP address to return a coarse location, as described above.
Exa and Firecrawl
Web search and page extraction. When the agent searches the web or reads a page for you, these services receive the search query or the URL the agent is working with, and return results into your session.
Our own crawler service
A Clusy operated service, hosted on Microsoft Azure Container Apps in the East US 2 region, that fetches and extracts web pages the agent asks for. It stores nothing beyond a short lived cache.

Bring your own key. If you connect your own Anthropic or OpenAI API key, your content goes to that company on your own account and under your own agreement with them. Their retention, human review and training practices apply, and our commitments here do not extend to them. We send the key to the provider once when you add it, to check that it works. We store it encrypted, decrypt it only to make calls on your behalf, and cache it in memory on the agent so background work in the same session can use it. When you remove the key we delete the stored copy, and a cached copy can persist for up to about a day before it expires.

Training

  • Clusy does not train, fine tune or distil models on your content. No pipeline in our systems exports customer notebooks, prompts, chat or outputs into a training or annotation dataset. Our evaluation suites run on synthetic prompts and public benchmarks.
  • What each provider may do is set by our contract with that provider, and it is not the same everywhere. We do not currently send a no training or zero retention instruction to every provider on every request, and we are not going to claim otherwise. If this matters to your work, use bring your own key with a provider whose terms you control, or ask us at privacy@clusy.io which route a specific model takes.
  • Published content is different. Anything you publish is public and may be collected by anyone, including AI crawlers. See section 13.

Who at Clusy can read your work

There is no screen in our product that shows staff your notebook cells, chat messages or execution outputs. Staff with database access can technically read stored data, and do so only to investigate abuse, to investigate a fault, or where you ask us to look at something in support. Administrators can see session titles, which are generated from your content, and the text of any appeal or support ticket you submit. Staff actions in our admin tools are logged.

7.Automated checks, suspension and appeals

We have had real abuse to deal with, including sandboxes used as network proxies and accounts used to run malware infrastructure. So we monitor, and you should know how.

What runs, and on what

Your chat messages, and the inputs to tools the agent runs, are checked against a fixed set of pattern rules. The rules look for a small, closed list of categories: cryptomining, proxy and tunnelling setups, attempts to break out of the sandbox, reading credentials, moving credentials off the machine, and scanning or denial of service tooling. Separately, we monitor account, authentication and usage signals, and we record execution activity.

Sandbox network traffic is barely restricted. On CPU sandboxes we block inbound public traffic and deny outbound connections to a small fixed list of addresses. Everything else on the internet stays reachable, GPU sandboxes have no outbound restriction, and we do not inspect the contents of what a sandbox sends.

What the check does, and does not, do

The check is alert only, and it runs alongside your work rather than gating it. It cannot block, cancel or alter a turn. Your work proceeds either way and an alert is recorded for review.

What we store is deliberately not your content. A detection record holds a category label, a severity, a fixed confidence value for the rule that fired, the identifiers of the rules that matched, an irreversible hash of the text that triggered it, and a short canned description of the pattern type. That description is chosen from a fixed list we wrote; it is not an excerpt of what you typed. The database additionally rejects any such record containing an email address, an IP address or an identifier. We do not store your raw prompts, code, commands, hostnames or credentials in these records.

Human decisions and automated ones

Suspensions are made by a person. An alert goes to our team, and a human decides whether to act, gives a reason, and is recorded as having done so. Two narrowly scoped automated rules exist that could suspend an account without a person, both aimed at bulk signup abuse, and both are currently switched off. Our automated containment framework runs in a monitoring mode and cannot suspend an account.

Consequences. A restriction can stop a run, limit a sandbox, or remove published content. A suspension blocks access to your account until it is lifted. It does not delete your work. A termination for a serious breach ends the account.

Your rights here

If we suspend your account we tell you the reason. If you want to know whether an automated rule was involved in your case, ask us and we will tell you. You can put your side of it through the appeal form, which is the one thing a suspended account can still reach, and a person reviews every appeal. You can ask us to reconsider, and if we got it wrong we lift it. We do not publish the internal detail of the detection rules, because that would make them trivial to evade, but you will get enough to understand and contest the decision. You keep your right to access and export your own content while suspended.

8.Who we share data with

We do not sell your personal data and we do not share it for cross context behavioural advertising. We do not use advertising networks or advertising pixels on any of our sites. In the twelve months before the date at the top of this page, we did not sell or share personal information as those terms are defined under California law.

We use the following providers to run the service. This list is current as of the date at the top of this page. The AI model providers are listed separately in section 8.

Amazon Web Services
Hosting for the API and agent, container images, object storage for your files, outputs and saved kernel state, and secret storage. United States (us-east-1). Also hosts our web app through AWS Amplify and CloudFront.
Supabase
Our primary database, authentication and some file storage. Holds account records and the content you create.
E2B
Runs CPU sandboxes. Your code, notebook files and workspace data are sent there to execute.
Modal
Runs GPU sandboxes, on the same basis.
Hugging Face
GPU sandboxes carry an access token so that model weights can be downloaded. Also a service you can connect yourself.
Stripe
Payments, subscriptions, invoices and payment recovery emails. Receives your email address and an identifier for your account.
Vercel
Hosts the clusy.io website, the documentation site and the meeting booking flow, and provides the website’s page view analytics.
PostHog
Product analytics, on PostHog’s United States cloud. Receives your account identifier, plan and usage events, and deliberately not your email address.
Cloudflare
Turnstile, the anti bot check on our sign in page. Also hosts two AI models, as described in section 8.
Resend
Sends our email, including sign in related mail, product notices, billing notices and meeting confirmations.
Google
Calendar and Meet, for meeting bookings, and Google Sheets, which receives contact form submissions from our website. Google is also a sign in provider if you choose it.
Microsoft
Outlook and Teams, for meeting bookings.
Slack
Receives internal notifications, including a limited booking notification and security alerts. Security alerts carry categorised labels and hashes rather than your content.

We also disclose personal data:

  • to your instruction, when you connect a third party account or publish content;
  • to professional advisers, such as lawyers and accountants, under confidentiality;
  • in a business transfer, such as a financing, merger, acquisition or insolvency, subject to confidentiality and to this policy continuing to apply; and
  • where the law requires it, or to protect the rights, property or safety of Clusy, our users or the public, as described in the Terms of Use.

9.Where your data goes

We are based in the United States and our infrastructure runs mainly in the United States. If you are in the EEA, the UK or Switzerland, using Clusy involves transferring your data outside your country.

United States
Our own infrastructure and most of our providers, including AWS, Supabase, Stripe, PostHog, Vercel, Resend, Cloudflare, E2B and Modal. Where a provider participates in the EU-US Data Privacy Framework we rely on it; otherwise we rely on the European Commission’s Standard Contractual Clauses, with the UK Addendum for UK transfers.
Singapore
Alibaba Cloud Model Studio, for the Qwen model. Standard Contractual Clauses.
Mainland China
DeepSeek and Moonshot AI. There is no adequacy decision for China. We rely on Standard Contractual Clauses. You should understand that the practical protection those clauses give against access by public authorities in China is limited, and that inference requires your content to be processed in readable form, so encryption is not available as an additional safeguard here.
Other regions
Microsoft Azure AI Foundry serves the GPT model on a global capacity type, so requests may be handled in Microsoft data centres outside the region where the account resource sits.

If you do not want your content processed in China, choose a model served elsewhere. Auto and inline code completion use DeepSeek, so this is a setting you need to change rather than one you need to leave alone. If you need a written commitment that your account will never route to a particular country, contact privacy@clusy.io, because we cannot currently guarantee it through the product alone.

You can ask us for a copy of the safeguards we rely on for any transfer at privacy@clusy.io.

10.How long we keep things

Content you create is kept until you delete it or delete your account, because it is your working material and deleting it for you would be worse than keeping it. Operational records have defined lives. Where we have not set a period we say so rather than implying one.

Your account and content
Notebooks, cells, files, chat history, execution records and outputs: kept until you delete them or delete your account.
Sub agent activity logs
30 days, then deleted automatically. These contain generated text, reasoning and tool results.
IP address hashes
Hashes stored against an account or a sandbox session: 30 days from account creation or session start, then erased automatically. A separate hash used to de-duplicate marketing link clicks is kept with the click record and has no automatic expiry.
Web server access logs
Up to 30 days. These contain raw IP addresses.
Application logs
Kept on the server that produced them and rotated by size rather than by age, so roughly 125 MB per service before the oldest is discarded. We do not operate a central log store.
Error reports
30 days for individual reports; 180 days for the grouped summary.
Performance traces
72 hours in the live store. An archive copy is written to our own object storage and we have not yet set an expiry on it. We are fixing that; ask us if you need the current position.
Security and abuse records
Kept while an account is active and afterwards where we need them to prevent a repeat breach or to defend a claim. We have not set an automatic expiry.
Billing and usage records
Kept for as long as tax and accounting law requires, which is generally seven years, and they survive account deletion.
Support tickets and appeals
Kept with the submitter’s email address after account deletion, so we have a record of what was asked and decided.
Meeting bookings
Kept until no longer needed for the meeting, related communications and our business records. There is no automatic deletion; ask us and we will delete yours.
Marketing and attribution
Click records and attribution data are kept while they remain useful for understanding how people find us. There is no automatic deletion.
Cookie consent record
180 days, after which we ask you again.
Object storage version history
Previous versions of files are retained for 7 days after they are replaced or deleted, then removed automatically.

11.Deleting your account

You can delete your account yourself, in Settings under Account. You will be asked to confirm by typing DELETE. It is not reversible, so export anything you want to keep first.

Deleting your account deletes your profile, your projects and everything in them: notebooks, branches, cells, execution records, outputs, agent chat history and project memory, your share links and their published snapshots, your stored integration credentials, your MCP server entries, and your project workspace files. It cancels any active subscription and shuts down any running or paused sandbox.

Some things are kept, and you should know which:

  • billing, invoice and usage records, which we are required to keep for tax and accounting;
  • security and abuse records, and records of any suspension or ban, so that a terminated account cannot simply be recreated. Where these identify you, they do so through an irreversible hash rather than your account details;
  • support tickets and appeals, including the email address they were submitted with;
  • operational logs and telemetry, which age out on the schedules in section 11 rather than being deleted immediately; and
  • copies of published content that other people made before you deleted, including forks in their own projects and files they downloaded. We cannot reach those.

Some uploaded files and agent generated outputs may take longer to clear from object storage than the database records do. If you want confirmation that everything has gone, email privacy@clusy.io and we will check and confirm in writing.

Deleting your account is different from cancelling a subscription. Cancelling leaves your work in place on the free plan.

12.How we protect it

We would rather understate this than overstate it, so here is what is actually true.

  • Traffic to our services is encrypted in transit with TLS.
  • Object storage is encrypted at rest, and our database is hosted on a managed platform that encrypts stored data.
  • Credentials for services you connect are additionally encrypted by us before they are stored, with a key held outside the database. Your Clusy API keys are stored only as a hash. One exception we will name: headers and environment values you configure for a custom MCP server are stored without that additional layer, so avoid putting a high value secret there.
  • Access to production data is limited to staff who need it, administrative actions are logged, and sensitive internal records are restricted at the database level so that they cannot be read by ordinary accounts.
  • Sign in is protected by an anti bot check, and sessions use short lived tokens.
  • We monitor for abuse as described in section 9.

We do not hold SOC 2, ISO 27001 or any other security certification, and we do not claim to. If you need one before you can use Clusy, tell us at security@clusy.io so we know it matters.

No system is completely secure. If there is a breach affecting your personal data, we will notify the relevant supervisory authority where required and tell affected users without undue delay. If you are a business customer and we process data for you, we will tell you promptly so that you can meet your own deadlines.

To report a vulnerability, see our security page, and note the security research safe harbour in the Terms of Use.

13.Content you publish

When you publish a notebook, it leaves the private part of the product. Two things follow that people are sometimes surprised by.

  • Hub listings are submitted to search engines, and our public pages explicitly permit AI crawlers, including crawlers that collect data for model training. A published notebook can therefore be indexed, copied and ingested by third parties we do not control.
  • Unpublishing does not reach copies. Revoking a share stops new access at once and permanently, but forks other people made, files they downloaded, and search engine or third party caches are outside our control.

A published notebook includes your display name and avatar. Your profile, including any headline, bio and links you add, is publicly readable. Your chat with the agent is not included in a share.

If you publish personal data about other people, you are the controller of it and responsible for having a basis to publish it. To ask for something to be taken down, see the Terms of Use or email privacy@clusy.io.

14.Your rights

We extend these rights to everyone who uses Clusy, wherever you live, whether or not a particular law requires it.

  • Access. Ask what we hold about you and get a copy.
  • Portability. Get your content in a portable form. You can export notebooks from the product, and we can provide an export of your account data.
  • Correction. Fix anything inaccurate. Most profile fields you can edit yourself.
  • Deletion. Delete your account in the product, or ask us. Section 11 sets out what we keep and why.
  • Restriction. Ask us to pause processing while a dispute is resolved.
  • Rights about automated decisions. Ask for human review of a decision, put your point of view, and contest it. See section 9.
  • Non discrimination. We will not give you a worse service for exercising a right.
  • Appeal. If we refuse a request, you can appeal by replying to our decision. We will respond within 45 days with our reasoning, and tell you how to complain to a regulator.

Your right to object

You have the right to object at any time to processing we carry out on the basis of our legitimate interests, including product analytics and reliability work. We will stop unless we have compelling grounds that override your interests, or we need the processing to establish or defend legal claims. Security and abuse prevention is one area where we will usually have those grounds, because it protects other people.

You can object to direct marketing at any time and we will always stop. Use the unsubscribe link in any marketing email or email privacy@clusy.io. Service messages about your account, billing and security are not marketing and continue.

Withdrawing consent

Where we rely on consent, you can withdraw it at any time, as easily as you gave it, using the cookie settings control on our website or the relevant setting in the product. Withdrawing consent does not affect processing done before you withdrew it.

How to exercise a right

Email privacy@clusy.io. You do not need an account to make a request: if you were added as a guest to a meeting, or appear in someone else’s published notebook, write to the same address.

We will acknowledge your request promptly and respond within 45 days, or one month if the GDPR applies to you. If a request is complex we may extend that once, and we will tell you why before we do. If you have an account, we will verify you by having you write from your account email or sign in. If you do not, we will ask you to confirm details that match what we hold. We use that verification data only to check your identity.

A request for a copy of your data will not return secrets: we will not send you API keys, connected account tokens or authentication credentials, because disclosing them by email would create the very risk the right is meant to prevent.

Complaints

Please raise it with us first at privacy@clusy.io, and we will try to put it right. You can also complain to a regulator. In the UK that is the Information Commissioner’s Office. In the EEA it is the supervisory authority where you live, where you work, or where the problem happened. In the United States you can contact your state attorney general.

15.Cookies, storage and analytics

On our website

Our website shows a cookie banner with three categories: strictly necessary, which is always on; performance and analytics; and personalisation and outreach. The two optional categories are off unless you turn them on, and rejecting is one click, exactly like accepting. Your choice is stored in a first party cookie for 180 days, after which we ask again. You can change it any time using the cookie settings control at the bottom of the site.

  • PostHog provides analytics. It starts opted out and only begins capturing if you accept the analytics category. Its traffic is routed through our own domain.
  • Vercel Web Analytics counts page views. It currently loads on all website pages rather than sitting behind the banner, because it is designed not to identify you or store anything on your device. We are reviewing whether to move it behind the analytics category.
  • Attribution. If you accept the personalisation category, we store campaign parameters and any advertising click identifier from the link you arrived on, in a cookie that is readable across clusy.io subdomains, so that we can tell which of our own campaigns brought you. This is not advertising targeting and it is not shared with an ad network.
  • A small amount of storage is always used for things the site cannot work without, such as remembering your light or dark theme and your cookie choice itself.

In the app

The signed in application does not show a cookie banner. It stores your session token and interface preferences in your browser, which is necessary for it to work, and it runs PostHog analytics on our legitimate interest in understanding and improving the product. In the app, PostHog is configured not to record your screen and not to capture what is on the page: it receives your account identifier, your plan, and named events about which features you use, with a filter that drops anything long enough to be content. It is not sent your email address. If you would rather not be included in product analytics, email privacy@clusy.io and we will exclude your account.

Do Not Track and Global Privacy Control

We do not currently detect or respond to Do Not Track or Global Privacy Control signals. We are implementing Global Privacy Control support. In the meantime, the cookie banner is the effective control on our website, and the email address above works everywhere.

We do not permit third parties to collect personal information about your activity across other websites through our services.

16.Accounts you connect

When you connect a third party service, we store the credentials needed to use it on your behalf, encrypted, and a small amount of profile information from that service so we can show you which account is connected. We also keep the last four characters of a token in readable form so we can display a masked version to you.

Some specifics worth knowing:

  • Connecting a GitHub repository means we clone it to our servers, including private repositories, so the agent can work with it.
  • Publishing to Hugging Face or Kaggle sends your notebook with its execution outputs embedded. We keep a record of what was published, where, and whether it was private.
  • Connecting a data warehouse lets the agent run queries with your credentials and bring the results into your notebook, where they are stored like any other output.
  • During some publishing operations, a short lived token is passed into your sandbox so the upload can run there.
  • Disconnecting removes the credential from Clusy but does not revoke it at the provider. Revoke it in that service’s own settings as well if that matters to you. Deleting your Clusy account likewise removes our copy without revoking anything upstream.

17.Children

Clusy is for adults. You must be at least 18 to hold an account, which is the same rule as in our Terms of Use. We do not knowingly collect personal data from anyone under 18 and we do not direct the service to children.

If you believe someone under 18 has an account, email privacy@clusy.io. We will investigate, close the account and delete the personal data.

18.Regional information

EEA, UK and Switzerland

The GDPR and the UK GDPR apply to our processing of your data because we offer services to people in those places. Our legal bases are in section 6, transfers in section 10, and your rights, including the rights to object and to complain to a supervisory authority, in section 14. Clusy Inc. is the controller for the processing described in section 2.

We have not yet appointed representatives under Article 27 of the GDPR and the UK GDPR. Until we do, please direct all requests and complaints to privacy@clusy.io, which is monitored and is the fastest route to a person.

California

The categories of personal information we collect are set out in section 4, with our purposes in section 6, the recipients in section 9, and how long we keep each category in section 11. In statutory terms we collect identifiers, customer records, commercial information, internet and network activity, coarse geolocation, professional information where you volunteer it, audio and visual information only in the form of files you upload, sensitive personal information in the form of account credentials, and inferences.

We do not sell or share personal information, and we have not in the preceding twelve months. We use sensitive personal information only for the limited purposes the law permits, described in section 5, so we do not offer a separate limitation right for it. You have the rights in section 14, including the right to appeal, and we do not discriminate against you for exercising them. Because we deal with users online, requests should come to privacy@clusy.io. You may use an authorised agent, and we will ask for proof of their authority.

Other US states

If you live in a state with a comprehensive privacy law, you have the rights described in section 14 including the right to appeal a refusal, and, if your appeal is denied, to complain to your state attorney general. We give these rights to everyone rather than only where a statute compels them.

19.Changes to this policy

We review this policy at least once a year, and whenever we change a provider, add a model provider, or change how data flows. When we make a material change we will update the effective date at the top and tell you by email or in the product before it takes effect.

If we ever want to use your content for a genuinely new purpose, such as training models, we will tell you first and ask for your agreement separately. We will not do it by quietly editing this page, and we will not apply it to content you created before you agreed.

Need a signed DPA?

Email privacy@clusy.io with your organisation name, the processing roles involved and any template you need us to work from. If you also need a security review, a subprocessor list for your vendor assessment, or a written answer on where a specific model routes, ask in the same message and we will cover it in one reply.