Privacy Policy

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Effective Date: November 4, 2025

Cleo (“we,” “our,” or “us”) values your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, and disclose personal information through our website and related online services (the “Platform”).

By using the Platform, you consent to the terms of this Privacy Policy and acknowledge that you may withdraw consent at any time as described below.

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1. Information We Collect

We collect only the minimum information necessary to operate the Platform and provide our services.

(a) Information You Provide Directly

• Account and Transaction Details: We collect your name and email address (mandatory) when you engage with us or complete a transaction. Other details such as phone number and company name are optional.

• Payment Information: Credit card transactions are processed by a secure third-party payment provider. Cleo does not store or access your full payment details.

• Communication Details: We may collect information you share with us through emails, chat messages, or other forms of communication.

Supervised or Educational Use: If Cleo is used by minors under 18 as part of a supervised or educational setting, any personal information is collected only from the supervising adult or organization (e.g., school, caregiver, or program facilitator). Cleo does not knowingly collect personal information directly from minors at all, with or without verified consent.

(b) Automatically Collected Information

• Device and Browser Data: We automatically collect certain technical data such as IP addresses, browser type, device identifiers, and screen resolution to ensure optimal site functionality.

• Usage Data: We may collect general data about how you interact with the Platform, including visited pages, clicked links, and general usage patterns.

We do not collect, track, or store any personal data beyond the minimal information required to process your purchase and maintain your account. Cleo does not collect location data, microphone, camera, or other device sensor data.

2. How We Use Your Information

We use your information solely for the following purposes:

• Service Delivery: To process transactions, respond to inquiries, and operate the Platform.

• Quality Improvement: To improve and enhance the Platform through research, development, and evaluation of overall functionality.

• Marketing: To provide information about new products, services, and promotions, and to personalize these communications.

• Security: To protect against fraud, misuse, and unauthorized activity.

We do not collect or share data for behavioral tracking, advertising, or profiling purposes.

3. Data Sharing

We do not sell, rent, or trade your personal information.
We only share limited data as necessary to:

• Complete secure transactions through trusted third-party service providers (e.g., payment processors, hosting services).

• Comply with applicable legal obligations, enforce our policies, or protect rights, property, or safety.

All third parties handling personal information on our behalf are required to maintain appropriate security and confidentiality standards and may only use the information to provide contracted services to Cleo.

4. Data Security and Retention

We prioritize the protection of your personal information and follow widely accepted standards to secure your data during transmission and after receipt.

We implement appropriate technical, administrative, and physical safeguards to protect your data from unauthorized access, destruction, loss, alteration, disclosure, or misuse.

While we strive to maintain robust security, no system is entirely secure. If you suspect unauthorized use of your account or credentials, please contact us immediately at contact@cleoarts.com.

We retain personal information only as long as necessary to fulfill our obligations or as permitted by law. Retention decisions are based on:

1. The duration of your relationship with us.

2. Applicable legal requirements.

3. Legitimate business needs (e.g., ongoing transactions, compliance, or legal defense).

5. Cookies and Tracking Technologies

When you visit our Platform, we may use cookies and similar technologies (including third-party cookies) to support essential site functions, analyze performance, maintain security, personalize content, and deliver relevant information. We do not use cookies or similar technologies for advertising, profiling, or behavioral tracking. Data collected through cookies is anonymized or aggregated whenever possible.

Where legally required, we will request your consent before placing cookies or provide an option to decline. You may also manage preferences through browser settings or opt-out tools such as the Global Privacy Control (GPC).

For more details, please refer to our Cookie Policy.

6. Your Privacy Rights

We believe in empowering you with control over your personal data. You may exercise the following rights by contacting contact@cleoarts.com, or where available, through features on the Platform:

• Access: Request information about the personal data we hold and how it is used.

• Correction: Request correction of inaccurate or incomplete personal data.

• Portability: Request a copy of your personal data in a structured, machine-readable format.

• Deletion: Request deletion of your personal data under certain conditions.

• Restriction: Request limits on specific processing activities.

• Withdraw Consent: You may withdraw your consent for optional data uses (such as marketing) at any time.

• Non-Retaliation: You will not face any discrimination for exercising your privacy rights.

We may request additional information to verify your identity. We aim to respond promptly, and will inform you if more time is required.

In limited circumstances, we may not be able to fulfill a request, such as where retention is required by law, affects others’ rights, or interferes with legitimate legal claims.

Residents of certain U.S. states may have additional rights under their local laws.

7. Children’s and Youth Privacy

Cleo is primarily designed for individuals aged 18 and older. However, Cleo also offers educational and sensory programs intended for early development, youth, and adolescent users (under 18), which may be accessed only under the supervision of or with verified consent from a parent, guardian, or authorized supervisor.

• Cleo does not knowingly collect personal information directly from minors under 18.
• If Cleo content is used in a supervised environment, all registration, data management, and communication occur through the supervising adult or organization.
• If we become aware that a child or minor has provided personal data directly, we will promptly delete it.
• These measures are designed to ensure compliance with applicable privacy laws, including the Children’s Online Privacy Protection Act (COPPA) for users under 13, and to support safe, supervised use for individuals under 18.

8. Data Storage and International Transfers

Our Platform and its services are hosted and supported by trusted third-party providers that may store or process information on servers located in various regions, including outside the United States.

While Cleo primarily serves U.S. customers, your information may be transferred to and maintained on systems in other jurisdictions, where data protection laws may differ from those in your state or country of residence.

We take appropriate measures to ensure that such transfers comply with applicable data protection laws and that your information remains protected through contractual and technical safeguards.

9. Third-Party Links

Our Platform may contain links to third-party websites or services. We are not responsible for the privacy practices or content of those third parties. We encourage users to review the privacy policies of any external sites before providing personal information.

10. Updates to This Policy

This Privacy Policy is effective as of the date listed above. We may update it periodically to reflect changes to our Platform, legal requirements, or internal practices.

If we make material updates, especially those affecting how personal information is handled for minors or supervised users, we will provide clear notice on the Platform and, where appropriate, notify registered supervisors or account holders by email before changes take effect.

We encourage you to review this Privacy Policy periodically to stay informed about how we handle your information.

11. Contact Us

If you have any questions or concerns regarding this Privacy Policy or Cleo’s data practices, please contact us at:

contact@cleoarts.com

www.cleoarts.com

12. Governing Law and Contact Information

This Privacy Policy is governed by the laws of the State of Massachusetts, without regard to its conflict of law principles.

For inquiries regarding this Privacy Policy or to exercise your rights, contact:

Cleo Privacy Office
contact@cleoarts.com
Address: P.O. Box 5016, Wayland, MA, 01778.
United States