PRIVACY POLICY
Effective Date: February 8, 2026
Version: 1.0 (Alpha)
CleenVerify ("we," "our," or "us") values your privacy. This Privacy Policy explains how we collect, use, and protect your personal data when you use the CleenVerify mobile application ("App") and website (the "Service").
We process personal data in compliance with the General Data Protection Regulation (GDPR) and the Dutch Uitvoeringswet Algemene Verordening Gegevensbescherming (UAVG).
1. WHO WE ARE (Controller)
Trading name: CleenVerify
Registered Address: Noordzijde 309, 1064MG, Amsterdam, Netherlands
KvK Number: 85775746
Contact Email: info@cleenverify.com
2. DATA WE COLLECT
We collect data to provide our media verification service.
A. Data You Provide Directly
- Account Information: Email address, name, and password (when you sign up).
- User Content: Photos and videos you capture using the CleenVerify App.
- Payment Data: Billing address and payment method details (processed securely by Mollie; we do not store full credit card numbers).
- Support Communications: Emails or messages you send us.
B. Data Collected Automatically
- Device Metadata: Device model, OS version, hardware identifiers (for cryptographic signing).
- Media Metadata: GPS location, timestamp, and sensor data associated with the photos you capture (essential for the verification "proof").
- Usage Data: We use privacy-first server-side analytics. We log anonymized usage events (e.g., link generation count, timestamps, anonymized device identifiers) on our own infrastructure. No data is shared with advertising networks or third parties for analytics purposes.
3. HOW WE USE YOUR DATA
- Purpose: To provide the Service: verifying photos, generating links, storing your history. Legal Basis: Performance of Contract (Art. 6.1.b)
- Purpose: To process payments: managing subscriptions and billing.
Legal Basis: Performance of Contract (Art. 6.1.b)
- Purpose: To prevent fraud: detecting tampered images or deepfakes.
Legal Basis: Legitimate Interest (Art. 6.1.f)
- Purpose: To improve the App: analyzing crashes and usage trends.
Legal Basis: Legitimate Interest (Art. 6.1.f)
- Purpose: To comply with laws: tax records, legal requests.
Legal Basis: Legal Obligation (Art. 6.1.c)
4. PHOTO STORAGE & ACCESS
Storage
Photos captured with CleenVerify are uploaded to our secure servers (hosted on Railway) to allow you to share verified links. We aim to store this content permanently so you can access your verification history, unless you request deletion of media, or account deletion.
Access Control
We respect the sensitivity of your content.
- Encryption: Your photos are stored securely with encryption at rest.
- No Unauthorized Access: We do not view, analyze, or sell your photos for advertising or AI training purposes.
- Exceptions: Our technical team may only access specific content if:
1. Required by law (e.g., child safety, valid police warrant);
2. Necessary to investigate a security breach or technical failure;
3. Explicitly requested by you (e.g., for support).
5. SHARING YOUR DATA
We do not sell your data. We share data only with trusted third-party processors necessary to run the Service:
- Railway (USA/EU): Cloud hosting, database infrastructure, and server-side analytics.
- Mollie (Netherlands): Payment processing.
Note: Some processors may be located outside the EEA. We ensure appropriate safeguards (such as Standard Contractual Clauses) are in place.
6. YOUR RIGHTS (GDPR)
You have the right to:
- Access: Request a copy of the data we hold about you.
- Rectify: Correct inaccurate data.
- Erase ("Right to be Forgotten"): Request deletion of your account and all associated photos.
- Restrict Processing: Pause our use of your data.
- Data Portability: Receive your data in a machine-readable format.
- Object: Object to processing based on legitimate interests.
- Withdraw Consent: Where processing is based on consent, withdraw it at any time.
To exercise these rights:
Email us at info@cleenverify.com. We will respond within 30 days.
For account deletion requests during the Alpha phase, please email info@cleenverify.com with your account email address.
7. DATA RETENTION
- User Content: Stored indefinitely while your account is active, to maintain your verification history.
- Deleted Accounts: If you request deletion, we delete your account and photos within 30 days, unless legal retention obligations (e.g., tax laws) apply.
- Inactive Accounts: We reserve the right to archive or delete data from free accounts that have been inactive for more than 24 months.
8. SECURITY
We implement industry-standard security measures to protect your data:
- SSL/TLS encryption for data in transit
- Encryption at rest for stored photos
- Secure hardware-backed cryptographic signing (Android KeyStore)
- Regular security audits and monitoring
However, no internet transmission is 100% secure.
9. INTERNATIONAL DATA TRANSFERS
Some of our service providers (Railway, Firebase) may process data outside the European Economic Area (EEA). When data is transferred internationally, we ensure appropriate safeguards are in place, including:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Adequacy decisions by the European Commission
10. CHILDREN'S PRIVACY
The Service is not intended for users under 16 years of age. We do not knowingly collect personal data from children under 16. If you believe we have collected data from a child under 16, please contact us immediately at privacy@cleenverify.com.
11. COOKIES AND TRACKING
Web Service
Our website uses essential cookies for session management and security. We currently do not use advertising or tracking cookies.
Mobile App
12. CHANGES TO THIS POLICY
We may update this Privacy Policy as our product evolves. We will notify you of significant changes via email or in-app notification. The "Effective Date" at the top indicates when it was last updated.
13. YOUR RIGHT TO COMPLAIN
If you have a concern, please contact us first at info@cleenverify.com. You also have the right to lodge a complaint with the Dutch DPA (Autoriteit Persoonsgegevens): https://autoriteitpersoonsgegevens.nl
14. CONTACT INFORMATION
For questions, requests, or concerns about this Privacy Policy or our data practices:
CleenVerify
Email: info@cleenverify.com
Address: Noordzijde 309, 1064MG, Amsterdam, Netherlands
KvK Number: 85775746
By using CleenVerify, you acknowledge that you have read and understood this Policy and consent to the collection, use, and processing of your personal data as described herein.
Last Updated: February 8, 2026