Privacy Policy

1) Who we are & scope

Clearo is a marketing and media company serving clients in Canada and the U.S. This Policy applies to information we collect about:

• Prospective and current clients, vendors, and partners;
• Website/app visitors and subscribers to our newsletters, SMS lists, and other programs;
• Individuals who interact with our ads, social media pages, forms, and surveys.

2) The information we collect

2.1 Information you provide to us

Identity & contact data: name, business name, job title, email, phone number (including mobile), postal address.

Account & preferences: login credentials, communication preferences, marketing interests.

Commercial data: service enquiries, project details, scope, budgets, invoices, payments (processed by PCI-compliant providers).

Content you share: messages, support tickets, survey responses, testimonials, reviews, meeting notes, uploaded files.

Consent records: time/date, method/source (e.g., web form, POS, SMS keyword), IP, and the exact disclosure presented.

2.2 Information we collect automatically

Device/technical data: IP address, device identifiers, browser type, operating system, language, referring/exit pages, crash data.

Usage data: page views, clicks, session duration, features used, emails opened, links clicked.

Cookies & similar tech: pixels, tags, SDKs, and local storage for analytics, performance, personalisation, advertising, and security.

Approximate or precise location data (where enabled by your device or browser permissions).

2.3 Information from third parties

• Lead forms & ad platforms (e.g., Meta Lead Ads, Google Ads forms);
• CRM/automation & communications providers (e.g., email/SMS gateways, call tracking);
• Analytics & measurement partners (e.g., website and app analytics);
• Public sources (e.g., company websites, professional profiles, business registers).

3) How we use information (purposes)

We use personal information to:

• Provide and improve Services — deliver projects, campaigns, and support; operate, maintain, and enhance our Sites and apps.
• Communicate — send transactional notices, service updates, invoices, and administrative messages.
• Marketing (with consent where required) — send email/SMS promotions, offers, event invites, and educational content; personalise content and ads; perform remarketing and look-alike modelling where permitted.
• Analytics & measurement — understand usage, diagnose problems, and improve performance and user experience.
• Security & fraud prevention — monitor, detect, and prevent fraud, abuse, and security incidents.
• Legal & compliance — keep consent logs, enforce our Terms, comply with laws/regulators, and establish/exercise/defend legal claims.
• Business operations — vendor management, procurement, due diligence, accounting, and corporate transactions.

We do not sell your personal information.

4) Our SMS/MMS (text) program

Opt-in: You can subscribe by consenting on a web/POS form with a clear disclosure or by texting a keyword to our sending number (647-691-9195). Consent is not a condition of purchase.

Content & frequency: promotional and informational texts (typically 2–4 messages per month).

Opt-out & help: reply STOP to opt out at any time; HELP for help. Opt-outs are actioned promptly.

Costs: message and data rates may apply. Carriers are not liable for delayed/undelivered messages.

Records: we maintain consent logs (timestamp, source, IP where applicable, and disclosure text).

5) Cookies, pixels, and your choices

We use cookies and similar technologies to operate the Services, remember preferences, measure performance, and personalise content/ads. You can manage cookies in your browser/device settings. Additional advertising choices:

• Network Advertising Initiative: https://www.networkadvertising.org/choices/
• Digital Advertising Alliance (U.S.): https://www.aboutads.info/choices/
• DAAC (Canada): https://youradchoices.ca/en/tools
• Google Analytics Opt-Out Add-On: https://tools.google.com/dlpage/gaoptout

Do Not Track (DNT): Many browsers offer DNT signals. Currently, we do not respond to DNT signals.

6) When we share information

We may share personal information with:

• Service providers/Processors under contract who assist with hosting, cloud infrastructure, CRM/marketing automation, email/SMS delivery, call tracking, analytics/measurement, payment processing, ad platforms, customer support, and security.
• Affiliates (if any) for uses consistent with this Policy.
• Business transfers in connection with a merger, acquisition, financing, reorganisation, insolvency, or sale of assets.
• Legal/compliance where required by law, subpoena, or court/administrative order; to enforce our Terms; protect rights, safety, and security; or prevent fraud or abuse.
• With your direction or consent, including publishing testimonials you submit.

We do not permit service providers to use your information for their own unrelated purposes.

7) International transfers

We may process and store information in Canada, the United States, and other countries where our service providers operate. Those locations may have different data-protection laws than your jurisdiction. We take appropriate measures (e.g., contractual safeguards) to protect personal information transferred across borders.

8) Retention

We retain personal information only as long as necessary to fulfil the purposes outlined in this Policy, comply with legal/contractual obligations, maintain business and financial records, resolve disputes, and enforce our agreements. Consent records for email/SMS marketing are retained for a reasonable period after opt-out to demonstrate compliance.

9) Security

We implement administrative, technical, and physical safeguards designed to protect personal information (e.g., access controls, encryption in transit where appropriate, least-privilege practices, monitoring). No method of transmission or storage is 100% secure; if you believe your interaction with us is no longer secure, contact us immediately using the details in Section 13.

10) Your rights & choices (Canada and certain other regions)

Subject to limited exceptions under applicable law, you may have the right to:

• Access the personal information we hold about you;
• Correct inaccurate or incomplete information;
• Withdraw consent for marketing and other processing based on consent (e.g., unsubscribe links; reply STOP for SMS);
• Challenge compliance with the principles of fair information practices.

To exercise these rights, contact us using the methods in Section 13. We may request information to verify your identity and will respond within a reasonable timeframe.

If you are located in a jurisdiction with additional rights (e.g., certain U.S. states or the EEA/UK), you may have further rights such as deletion or portability. Please indicate your location when you contact us so we can address your request under the appropriate law.

11) Children's privacy

Our Services are not intended for individuals under 18. We do not knowingly collect personal information from children. If you believe a child has provided personal information to us, contact us and we will delete it.

12) Third-party links and services

The Services may contain links to third-party websites, apps, or services. Their privacy practices are governed by their own policies. We are not responsible for third-party content or practices. We encourage you to review their privacy notices.

13) Contact us

Questions, requests, or concerns about this Policy or our data practices can be sent to:

We will respond within a reasonable time. You may also have the right to file a complaint with the Office of the Privacy Commissioner of Canada (OPC) or your provincial privacy regulator.

14) Changes to this Privacy Policy

We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post the updated Policy with a new "Last updated" date. Your continued use of the Services after an update signifies your acceptance of the revised Policy.