Privacy Policy CLARITY

1. Controller and Contact Information

StreamLogic BV ("StreamLogic", "we", "us", or "our") is an IT service provider based in the Netherlands, located in Blaricum, and registered with the Dutch Chamber of Commerce (KvK) under number 98767313.

StreamLogic BV acts as controller for account, website, contact and its own administrative data. For personal data in documents uploaded by a business Customer, the Customer will generally be the controller and StreamLogic the processor. The applicable Service Terms and, where relevant, the Data Processing Agreement determine the roles for the service.

For questions regarding this policy or the processing of your personal data, you can contact us at:
Email: [email protected]

2. Personal Data We Process

2.1 Data you provide

When using CLARITY, our PDF accessibility tool, we process:

• Uploaded PDF documents
• Account information (such as name, email address, and company name)

2.2 Automatically collected data

We may automatically collect:

• IP address
• Browser type and version
• Device information
• Usage and interaction data

3. Purposes of Processing

We process personal data for the following purposes:

• To convert uploaded PDF files into accessible formats
• To provide, operate, and maintain our services
• To improve functionality, performance, and user experience
• To ensure system security, integrity, and prevent misuse
• To provide customer support and respond to inquiries

4. Legal Basis for Processing

We process personal data based on the following legal grounds:

• Performance of a contract: to provide the CLARITY service
• Legitimate interest: for service improvement, security, and operational management
• Consent: where applicable, such as for cookies or optional features

5. Provision of Data

Providing personal data is necessary to use our services. If required data is not provided, we may be unable to deliver the requested functionality.

6. Processing of Uploaded Documents

Uploaded PDF files are processed to provide CLARITY and for the related security and support purposes described in the applicable agreements. CLARITY may use an external AI service; documents or relevant document parts may be transferred to that service as described in this Privacy Policy, the Service Terms and the current subprocessor information.

• Standard processing is automated
• Access to document content is strictly restricted and only permitted where necessary for technical support, subject to appropriate authorization and controls
• Original uploaded documents are removed as soon as reasonably possible after processing and in any event within a maximum of 24 hours after upload

We do not use Customer Data to train a general AI model unless the Customer has given prior express written permission.

Document and processing metadata may be retained for service delivery, billing, quality, security and audit for a maximum of one month after processing. Anonymised information may be used for product improvement where re-identification is reasonably excluded.

7. Data Retention

We retain personal data only for as long as necessary for the purposes described above. The following maximum periods apply:

• Original uploaded documents: removed as soon as reasonably possible after processing and no later than 24 hours after upload
• Processed documents: available for download for up to 48 hours after completion and then removed
• Document and processing metadata: up to one month after processing
• Account data: for as long as the account is active and up to two years after closure or the last account activity, unless earlier deletion is requested and no legal reason requires continued retention
• Transaction, invoice and statutory accounting data: seven years, or longer where a specific statutory obligation applies
• Security logs: up to six months; relevant extracts may be retained longer where required to investigate or handle a security incident
• Suspected fraud or clearly unlawful material: isolated and retained for up to twelve months. Necessity is reviewed periodically. Data may be retained longer only while a report, investigation, legal claim or legal obligation requires it

8. Data Sharing and Processors

We do not sell personal data.

We may share personal data with trusted third-party service providers ("processors") who support the delivery of our services, including:

• Hosting and cloud infrastructure providers
• IT and security service providers
• Analytics and monitoring services

These processors act on our behalf and process personal data only in accordance with our instructions and applicable data protection laws. Appropriate data processing agreements are in place where required.

9. International Data Transfers

Processing and transfer locations are documented in this Privacy Policy and the current subprocessor information. Where personal data is transferred outside the European Economic Area (EEA), an applicable legal transfer mechanism or safeguard is used.

10. Security Measures

We implement appropriate technical and organizational measures to protect personal data, taking account of the risks, state of the art and nature of the processing, including:

• Encryption of data in transit (HTTPS/TLS)
• Access control and authentication mechanisms
• Least-privilege access principles
• Secure system architecture and monitoring
• Regular review of security practices and controls

No security measure can guarantee absolute security.

11. Automated Processing

Our service uses automated processing to convert PDF documents into accessible formats. This processing does not result in decisions that produce legal effects or similarly significant consequences for individuals.

12. Your Rights

Under the General Data Protection Regulation (GDPR), you have the right to:

• Access your personal data
• Rectify inaccurate or incomplete data
• Request erasure of your data
• Restrict processing
• Object to processing
• Request data portability

Where processing is based on consent, you may withdraw your consent at any time.

Requests can be submitted via: [email protected]

13. Cookies

We use cookies and similar technologies to enhance user experience and analyze usage. For detailed information, please refer to our separate Cookie Policy.

14. Complaints

If you have concerns about how we handle your personal data, we encourage you to contact us first so we can address your concerns.

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

15. Changes to this Privacy Policy

We may update this privacy policy from time to time. The most current version will always be available on our website.