Privacy Policy

1. Who we are

Clement is operated by Julian Schoen (Einzelunternehmer), Rudolf-Carsten-Str. 29, 23611 Bad Schwartau, Germany ("Clement", "we", "us"). For privacy questions, contact privacy@clement.so.

USt-IdNr.: DE341423078

2. What we collect

When you use Clement, we collect:

• Account data — your email, name, profile photo (from Google sign-in), and the workspace you create.
• Billing data — handled by Stripe; we store only customer IDs and subscription status.
• Connected inbox credentials — Gmail OAuth tokens or SMTP/IMAP passwords for the inboxes you connect, encrypted at rest with envelope encryption (XSalsa20-Poly1305) before being written to our database.
• Lead and campaign data — recipient email addresses, attributes, and message content that you upload or compose.
• Usage data — pages visited, actions taken, error logs, and aggregated performance metrics.
• Website visitor data — on our marketing website (clement.so), RB2B identifies the company and, where available, the business profile of visitors, so we can follow up with businesses interested in Clement. This doesn't apply to the Clement app.
• Email metadata from connected inboxes — for incoming messages: sender, subject, date, thread identifiers and our classification (reply, out-of-office, bounce, unrelated). See section 4.
• Tracking events — opens and clicks for emails sent via Clement (you control whether tracking is on per campaign).

3. Why we collect it

We process your data to:

• Provide the Clement service (lawful basis: contract performance, GDPR Art. 6(1)(b));
• Bill you (lawful basis: contract performance);
• Improve the product, debug issues, and prevent abuse (legitimate interest, Art. 6(1)(f));
• Understand which businesses visit our website and follow up with them (legitimate interest, Art. 6(1)(f));
• Comply with legal obligations (Art. 6(1)(c)).

4. Google API data — Limited Use

Clement's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

When you connect a Gmail inbox, you grant Clement two permissions:

• Send email on your behalf (gmail.send) — to send the campaign emails, follow-ups and replies you schedule or write in Clement.
• Read your email (gmail.readonly) — to detect replies, out-of-office responses and bounces to your campaign emails, so sequences stop when a lead responds, and to show your incoming mail, sorted by type, in Clement's unified inbox.

What we store. New mail in a connected inbox is checked as it arrives and its metadata is stored so it can appear in Clement's unified inbox: sender, subject, date, message and thread identifiers, and our classification. Message bodies and attachments are not stored; when you open a message in Clement, its body is fetched from Gmail for display.

How we use it. Gmail data is used only to provide the user-facing features described above and to keep them secure and working. We do not use Gmail data to serve advertisements, we do not sell it, and we do not use it to train or improve artificial intelligence or machine-learning models.

AI features. When you ask Clement's Slack assistant for something, it reads the data needed to answer, which can include the content of messages in your connected inboxes, and sends it to our AI provider, Anthropic, to generate the answer. The assistant only reads email when you ask it to. Anthropic processes this data under our agreement with them, does not use it to train its models, and keeps it for up to 30 days for safety and security monitoring before deleting it.

Assistant history. Your conversations with the assistant, including any email content it retrieved for you, are kept as a history log so you can look back at past requests and what the assistant did on your behalf, and so it can continue a conversation where you left off. The history is kept until you delete your workspace or ask us to delete it.

Who it is shared with. We do not transfer Gmail data to third parties, except to the sub-processors in section 5 as needed to provide the service, to comply with applicable law, or as part of a merger, acquisition or sale of assets with notice to you.

Human access. No one at Clement reads your Gmail data unless you give explicit permission for a specific message (for example, in a support request), it is necessary for security purposes such as investigating abuse, or it is required by law.

Deleting it. When you disconnect an inbox, we revoke Clement's access at Google and delete the stored credentials immediately. Deleting your workspace deletes all stored data from your connected inboxes. You can also remove Clement's access at any time from your Google Account permissions.

5. Sub-processors

We use the following service providers to operate Clement. They process data on our behalf under data processing agreements:

• Cloudflare, Inc. (USA / global) — application hosting (Workers, queues), DNS, edge network, DDoS protection.
• PlanetScale, Inc. (USA; data stored in AWS us-east-1) — database hosting and backups.
• Stripe Payments Europe Ltd. (Ireland) — payment processing and invoicing.
• Google LLC (USA) — Gmail API for sending and receiving on inboxes you've connected; Google Sign-In for authentication; Google Analytics for website analytics.
• Anthropic, PBC (USA) — AI features, including the Slack assistant.
• Slack Technologies, LLC (USA) — delivering the Slack assistant and notifications, if you install Clement in your Slack workspace.
• Resend, Inc. (USA) — transactional email such as sign-in links and notifications.
• MillionVerifier — checking whether lead email addresses you upload are deliverable.
• Amplitude, Inc. (USA) and Microsoft Corporation (Clarity; USA) — product analytics.
• RB2B (USA) — identifying business visitors to our marketing website.

Where data is transferred outside the EEA, we rely on Standard Contractual Clauses and additional safeguards as required by GDPR.

6. Where data lives

Our database and its backups are hosted by PlanetScale in AWS's us-east-1 region (USA), encrypted at rest. The application runs on Cloudflare's network, which may process requests in data centres worldwide. Other sub-processors process data in the locations listed above.

7. How long we keep it

• Account data — for as long as your workspace exists, plus 30 days after deletion.
• Billing records — 10 years (German tax law).
• Inbox credentials — until you disconnect the inbox or delete the workspace; disconnecting deletes them immediately.
• Lead, campaign, and stored response data — until you delete it or your workspace.
• Slack assistant conversation history — until you delete your workspace or ask us to delete it.
• System logs — up to 30 days.
• Tracking events — 12 months, then aggregated.

8. Your rights (GDPR)

You have the right to:

• Access the personal data we hold about you (Art. 15);
• Correct inaccurate data (Art. 16);
• Request deletion (Art. 17);
• Restrict processing (Art. 18);
• Receive your data in a portable format (Art. 20);
• Object to processing (Art. 21);
• Lodge a complaint with a supervisory authority.

To exercise any of these, email privacy@clement.so. We respond within 30 days.

9. Customer data and DPA

When you upload lead lists or send campaigns through Clement, you are the data controller and Clement is the data processor for that information. A Data Processing Agreement is available at privacy@clement.so.

10. Cookies

We use a strictly necessary session cookie for authentication and minimal product analytics (Amplitude, Microsoft Clarity, Google Analytics). On our marketing website, RB2B also uses cookies to recognise business visitors. Analytics never record the content of your emails. No advertising cookies. No third-party retargeting.

11. Changes to this policy

When we make material changes, we'll notify active customers by email and post an updated version here with a new "last updated" date.