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://cluso.ai/ 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 and we will respond within 48 hours.
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 Better Space, 127 Farringdon Rd, London EC1R 3DA ("Cluso", "us", "we" or "our") operates an audio insights platform that enables clients to launch voice surveys to their audiences.
We collect and process voice recordings and transcripts to help businesses understand customer needs and preferences.
For more information about us, please see our website https://cluso.ai/
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. 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 a voice 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 aimed at those aged 18 and over (or the age of majority in the jurisdiction from which you are accessing the Platform). The Platform is not intended for anyone 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?
When participants respond to voice surveys on the Platform, we collect:
Voice recordings uploaded by participants in response to survey questions
AI-generated transcripts of these voice recordings
Text descriptions and media uploaded by participants
Where voice recordings are transcribed, we may correct inaccuracies in the transcript where the AI tool has not correctly identified words spoken by participants. We will not change the context of what participants say, only correct the transcript for accuracy.
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.
4.3 Information That We Collect Automatically
When you visit our Website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include:
IP address, device type, unique device identification numbers
Browser type, broad geographic location (e.g. country or city-level location)
Information about how your device has interacted with our Website, including pages accessed and links clicked
We use this information for our internal analytics purposes and to improve the quality and relevance of our Platform. Some of this information may be collected using cookies and similar tracking technology.
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 demographic information and we use the information we receive from these third parties to maintain and improve the accuracy of the records we hold about you.
5. How do we use your personal information?
The Platform is controlled and operated by Cluso. All material on the Platform, including, but not limited to text, images, illustrations, audio clips, and video clips, voice data, is protected by copyright, trademarks, and other intellectual property rights which are owned and controlled by us or by other parties that have licensed their material to us. Material on the Platform is solely provided to you for personal, non-commercial use. Such material may not be copied, reproduced, republished, uploaded, posted, transmitted, or distributed in any way, including by e-mail or other electronic means. Without the prior written consent of the owner, modification of the materials, use of the materials on any other website or computer environment, or use of the materials for any purpose other than personal, non-commercial use is an infringement of the copyrights, trademarks, and other proprietary rights, and is strictly prohibited.
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 voice 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.
Important: Except where participants agree to participate without anonymity and provide their name and email address, all participants are anonymous to Cluso. We will not knowingly process participant personal information for identification purposes and do not know who participants are.
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 and AI transcription services, or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information
To our Clients: participant voice 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: compliance with UK GDPR and data protection laws
Consent: where you have provided specific consent for certain processing activities
8.2 For Participant Data
We process participant data as a processor on behalf of our Clients based on:
Processing on behalf of Clients (as data processor) pursuant to our contractual obligations
Consent: where participants agree to participate in surveys
Legitimate interests of the Client: for survey purposes and customer insight research
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the "How to contact us" section below.
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 Cluso 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 in any of these countries.
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).
We will only retain Client information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Participant voice recordings and transcripts are retained according to Client instructions and survey purposes. 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.
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 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 process 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
12.1 Access to Voice Recordings and Transcripts
Participants may request:
A copy of their voice 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 aimed at those aged 18 and over (or the age of majority in the jurisdiction from which you are accessing the Platform). 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 Policy 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. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
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 Better Space, 127 Farringdon Rd, London EC1R 3DA.
Real voices. Real impact.
