1. Introduction
Poiro Ltd trading as Cluso respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Notice applies to personal information that we collect through our website at https://mycluso.com/ and when you use or interact with our audio insights platform (the "Platform").
If you have any questions or concerns about our use of your personal information, then please contact us at product@mycluso.com.
We recommend that you read this Privacy Notice in full to ensure you are fully informed.
2. Who we are
Poiro Ltd trading as Cluso with registered office at Office 01-121, Shoreditch Exchange Gorsuch Place, London, England, E2 8JF
("Cluso", "us", "we" or "our") operates an audio insights platform that enables clients to launch voice surveys to their audiences. We collect and process audio recordings and transcripts to help businesses understand customer needs and preferences.
For more information about us, please see our website https://mycluso.com/
3. What we do
The Platform is a web-based platform that allows clients to launch voice surveys to their own audience or a Cluso-affiliated audience (‘Platform’). Clients can create surveys that can be answered by participants through voice responses. In this creation process, Clients may upload media to the platform under their account that can be viewed by and responded to by the participants.
When a voice survey is launched, participants can respond by uploading an audio recording in response to specific questions within the surveys. Clients are provided with the audio of the participant as well as AI-generated transcripts.
The Platform is not designed for nor intended for use by children under 13.
What personal information does Cluso collect and why?
The personal information that we may collect about you broadly falls into the following categories:
4.1 What personal information does Cluso collect and why?
Services. We process your input (which may include text, audio, or other content) and output and any other information you provide in connection with your use of the Platform, including any Personal Information contained therein. When participants respond to surveys on the Platform, we collect:
audio recordings uploaded by participants in response to survey questions
AI-generated transcripts of these audio recordings
Text descriptions and media uploaded by participants
4.2 Information That You Provide Voluntarily
Certain parts of our Platform may ask you to provide personal information voluntarily:
Client account information: We may ask you to provide your contact details in order to register an account with us (name, email address, company name)
Participant identification: Except where participants agree to participate without anonymity and provide their name and email address, all participants are anonymous to Cluso
Media and content: Clients may upload media, images, and other content to the Platform
The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information. Some of the personal information that you provide may include sensitive personal information, such as health-related information. Where these types of sensitive information are requested, we require you to provide your explicit consent.
4.3 Information That We Collect Automatically
When you visit our website (mycluso.com), respond to a survey (go.mycluso.com) or use the Platform (app.mycluso.com), we automatically collect certain information.
Usage analytics.
We collect:
device type, browser type, operating system and screen size
the pages or screens you view and how you reached them
what you click on, and where on the page you click and scroll, which we view as aggregated heatmaps
how quickly pages load
We do not record anything you type into a field. Your IP address is used momentarily to count visits and is then discarded; it is not stored in our analytics, and no location is recorded from it.
We use PostHog, an analytics service, to collect this information. PostHog is configured to work without cookies and does not store anything on your device. Instead, visits are counted on PostHog's servers using an anonymised value that changes every day, so you cannot be identified or recognised from one day to the next.
We do not link this information to your name, email address, account or survey responses. PostHog processes it on our behalf on servers in the European Union. We do not use it for advertising and do not share it with anyone else.
Our website is built on Framer, and our survey pages and Platform are hosted on Vercel. Both provide built-in statistics that count page visits without cookies and without identifying visitors.
You can opt out of usage analytics by contacting us at product@mycluso.com.
Error reports.
On the survey pages and the Platform we use Sentry, an error-monitoring service, to find and fix faults. When an error occurs, Sentry receives technical details of the error, your device and browser type, and a short recording of the screen at the time, with all text blanked out.
Error reports never include your name, email address or survey answers. For signed-in Client users, the report includes a randomly generated account ID so that we can tell which customer was affected. For participants, it includes only a scrambled identifier that cannot be traced back to you.
Security check.
The survey pages and the Platform use Cloudflare Turnstile to confirm that visitors are human and to protect against automated abuse. Turnstile sets a cookie once the check is passed.
Embedded video.
If a survey includes a video hosted by YouTube, Vimeo or Loom, that provider's player loads only when you choose to play the video. The provider then receives information such as your IP address and may set its own cookies.
Fonts.
Fonts on our website are delivered by Google Fonts, which means your browser connects to Google's servers to load them.
LinkedIn.
The homepage of our website uses the LinkedIn Insight Tag, which sets cookies and shares information about your visit with LinkedIn so that we can measure our LinkedIn advertising.
4.4 Information That We Obtain From Third Party Sources
From time to time, we may receive personal information about you from third party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us. The types of information we collect from third parties may include broad demographic information and we use the information we receive from these third parties to maintain and improve the accuracy of the records we may hold about you.
5. How do we use your personal information?
We use the personal information we collect for the following purposes:
To provide and operate the Platform and related services
To process audio recordings and generate transcripts
To manage Client accounts and authenticate users
To communicate with you about your accounts and services
To improve and develop our Platform and services
To ensure security and prevent unauthorised access
To comply with legal obligations
6. Our role as data controller and processor
6.1 For Client Data
Poiro Ltd is the data controller of Client account information, contact details and any personal data you provide when creating or managing your account.
6.2 For Participant Data
Cluso acts as a data processor for participant audio recordings and transcripts. Our clients are the data controllers for this participant data. We process participant data on behalf of Clients in accordance with their instructions and applicable data protection legislation, including the UK GDPR and the UK Data Protection Act 2018.
6.3 For Usage Analytics And Error Reports
Poiro Ltd is the data controller of the usage analytics and error reports described in section 4.3, across our website, survey pages and the Platform.
7. Who does Cluso share personal information with?
We may disclose your personal information to the following categories of recipients:
To our third party service providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Platform), including data storage services, AI transcription services, analytics services (PostHog), error-monitoring services (Sentry), and hosting and security services (Framer, Vercel and Cloudflare)
To our Clients: participant audio recordings and transcripts are shared with the client who commissioned the survey
To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person
To a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice
To any other person with your consent to the disclosure
8. Legal basis for processing personal information
If you are a visitor from the European Economic Area or the United Kingdom, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
8.1 For Client Data
We process Client data on the following legal bases:
Contract performance: to provide the Platform services and fulfill our contractual obligations
Legitimate interests: platform operation, improvement, and security
Legal obligations: where required to do so by law
8.2 For Participant Data
We process participant data as a processor on behalf of our Clients based on:
Consent: where sensitive personal data is shared by participants as part of the survey
Legitimate interests: collecting survey responses and customer insight research
However, we will normally collect personal data from you only where we need the personal data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person.
When we rely on legitimate interest as the legal grounds to process your Personal Data, you have the right to object to that processing by contacting us.
We will process your personal data to provide the services to you, to communicate with you, to prevent fraud, data storage, technical support, legal and compliance purposes and for research and development.
8.3 For Usage Analytics, Error Reports And Security Checks
We process the information described in section 4.3 on the basis of our legitimate interests in understanding how our website and Platform are used, improving them, fixing errors and keeping them secure.
9. How does Cluso keep personal information secure?
We use industry-standard technical, logical, and physical security measures and practices for the Platform and any systems on which your content is stored or processed to preserve the security and integrity of, and prevent unauthorised access to, the Platform and your data.
The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures include:
Encryption of your personal information at rest and in transit
Secure authentication and access controls
Regular security assessments and updates
Restricted access to personal information on a need-to-know basis
Clients are responsible for maintaining the security of their unique login credentials and keeping them confidential. Login credentials cannot be shared with anyone. You must immediately inform us of any suspected unauthorised use of the Platform or unauthorised disclosure of your login credentials.
10. International data transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country and, in some cases, may not be as protective.
Specifically, our Platform infrastructure and third party service providers may operate around the world. This means that when we collect your personal information, we may process it outside of the UK and/ or EU.
However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. We have implemented appropriate safeguards with our third party service providers and partners and further details can be provided upon request.
11. Data retention
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Participant audio recordings and transcripts are kept for the period set by the Client that commissioned Cluso. At the end of that period, or earlier if the Client asks, we delete them.
12. Your data protection rights
You have the following data protection rights:
If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided below
In addition, if you are a resident of the European Union or United Kingdom, you can object to the processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by contacting us using the contact details provided below
Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent
You have the right to complain to a data protection authority about our collection and use of your personal information. In the UK, the Information Commissioner is the appropriate data protection authority (see https://ico.org.uk/).
12.1 Access to Voice Recordings and Transcripts
To the extent a participant has registered and account with us, participants may request:
A copy of their audio recording
A copy of their transcripts
Exercise their right to deletion
For participants: These requests should be directed through the client who commissioned the survey, as they are the data controller. We have enabled features on client accounts to allow them to respond to such requests.
For Clients: You can make requests directly to us using the contact details below. As a client and data controller for participant data, it is your responsibility to respond to data subject requests including data deletion requests from your participants.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
13. Children's data
The Platform is not intended for anyone under 13.
If you are a parent or guardian agreeing to these Terms for your child, you are legally responsible for his or her use of the Platform.
We are not responsible for the collection of children's data on the Platform. If a client uses the Platform to collect children's data, the client warrants that it will comply with applicable data protection legislation to the extent applicable to children's data.
14. Third-party services and content
Our services rely on or interoperate with third-party products and services, including data storage services and AI transcription services.
Cluso may make available content from third parties, including data provided by third party services, via the Platform. We are not responsible for the accuracy or completeness of third party content. If we are required to remove third party content, or are notified that certain third party content may breach applicable law or third party rights, we may remove such third party content without notice.
We are not responsible for the content or practices of third party websites. Any links to third party websites are provided for your convenience only, and you access them at your own risk.
Certain items of code provided with or accessed via the Platform are subject to \"open source\" or \"free software\" licenses. Each item of open source software is licensed under the terms of the license that accompanies such software.
15. Cookies and similar tracking technology
We use cookies and similar tracking technology to collect and use personal information about you. For further information about the types of cookies we use, why, and how you can control cookies, please see our Cookie Notice available on our website.
16. Feedback
Any feedback, comments, or suggestions you may provide regarding us on the Platform or other services we offer is entirely voluntary. By providing feedback, you grant Cluso a perpetual, irrevocable, and royalty-free right and license to use all feedback in any lawful manner whatsoever, without any obligation to you.
17. Updates to this privacy notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.
You can see when this Privacy Notice was last updated by checking the \"last updated\" date displayed at the end of this Privacy Notice.
18. How to contact us
If you have any questions or concerns about our use of your personal information, please contact us at product@mycluso.com.
The data controller of your personal information is Poiro Ltd, with registered office at Office 01-121, Shoreditch Exchange Gorsuch Place, London, England, E2 8JF.
19. Date of this privacy notice
This Privacy Notice was last updated on 8th October 2026.