Privacy Policy

1. Who is the data controller

Cliencer LLC acts as data controller for the personal data of its registered users (“businesses”). With respect to the end customers of those businesses (“players” or “influencers”), Cliencer LLC acts as data processor on behalf of the business, following its instructions.

Cliencer LLC operates globally. We have users in Argentina, Mexico, and other countries. We apply a uniform privacy standard aligned with the most protective regulations (GDPR, CCPA) and we respect the specific rights granted by the law of your country of residence.

To exercise any right, request clarification, or report an incident, write to info@cliencer.com. We respond within 10 calendar days.

2. Who this policy applies to

This policy applies to you if:

• You signed up on the Cliencer mobile app or on cliencer.com to manage a business.
• You created games, prizes, coupons, campaigns, or business profiles on the platform.
• You contracted a paid subscription through Cliencer.

If you only participated in a game as a customer of a business that uses Cliencer, your primary relationship is with that business. You can ask that business to exercise your rights on your behalf, or write to us directly and we will forward your request.

3. What data we collect

We collect the data the platform needs to work, the data legal obligations require, and the data we use to improve the product and measure our ads, each with the purpose and legal basis in section 4. We group them into eleven categories.

3.1. Account and profile data

When you create an account or edit your business profile, we store:

• First and last name.
• Email.
• Phone.
• Business name and industry, and the address and coordinates of your location when your business has one.
• Business logo and other images you upload (prize photos, banners, etc.).
• Account preferences (language, time zone, settings).

Purpose: identify you, grant access to the platform, display your business info to your customers, and let you manage campaigns.

3.2. Authentication and session data

• Session tokens (JWT) stored securely on the device using the OS keystore (iOS Keychain / Android Keystore, via expo-secure-store).
• Biometric authentication state (if you enabled it). Biometrics are validated locally on your device; we never receive or store your biometric data.
• One-time access codes, sent by email. If you already have an account, they also reach you on WhatsApp so you can sign in with your number or recover your account.

Purpose: keep your session open securely and let you sign in without a password.

3.3. Usage and behavior data

While you use the app, we record product events (e.g., “you created a game”, “you shared a prize”, “you opened screen X”) along with event properties such as the game ID or the plan type.

These events are processed via Amplitude, linked to your account: Amplitude receives your name, email, phone, and role, your account ID and your business ID, and the business name, industry, plan, and language. From each device it also receives the device ID generated by Amplitude, the App Set ID on Android, the IDFV on iOS, the advertising ID on Android (GAID), the model, the operating system, and the IP address, from which it derives your approximate location.

Purpose: understand how the product is used, detect UX issues, improve features, and prioritize the roadmap.

3.4. Device identifiers

• Your push subscription ID in OneSignal and the notification token issued by Apple (APNs) or Google (FCM).
• The device ID generated by Amplitude; on Android, the App Set ID, and on iOS, the identifier for vendor (IDFV).
• Device type, model, OS version, and app version.
• Android advertising ID (GAID): read by the Meta SDK and Amplitude, and sent by the app to our server, which stores it with your business to measure Cliencer's advertising. On iOS the app works with the IDFV and Apple's aggregated measurement, and leaves Apple's advertising identifier (IDFA) unread. Details in section 13.

Purpose: send you push notifications, diagnose device-specific errors, understand how the product is used, and, with the Android advertising ID, measure and optimize Cliencer's ads.

3.5. Payment data

The Cliencer plan is purchased from the app and charged by the App Store or Google Play, depending on your phone. The store takes your payment method under its own terms, and Cliencer never sees it. From that purchase we store:

• Your subscription ID in the store. On Android it is the purchase token, which the app sends to our server to confirm the purchase and keep your plan up to date.
• The plan, its status, and its expiration.

Purchase events, such as the start of the trial and the payment with its price, also reach Amplitude and Meta (section 5).

Subscriptions previously purchased on the website and one-off charges we make from the website are processed by Stripe, which takes your card data directly. Cliencer never sees or stores your full card number or CVV. From those payments we store:

• Your Stripe customer ID.
• The last 4 digits and card brand (e.g., “Visa ****4242”).
• Subscription, invoice, and payment history.
• Billing details (company name, tax ID, fiscal address) if you entered them.

Purpose: process your subscription, keep your plan up to date, issue receipts, and meet tax obligations.

3.6. Location data

We access the device location only if you explicitly grant permission through the OS. We use it to locate your business when you register it or edit its address, in three ways:

• While you type in the address search, the app sends the text and the device location to our server, which asks Google Places for suggestions that favor nearby places.
• When you pick an address, our server searches Google Places for places near that address's coordinates.
• With Mi ubicación (My location), the app turns the device location into an address with the operating system's geocoding service (Apple on iOS, Google on Android), and the coordinates are saved with your business.

Amplitude also derives your approximate location from the IP address (section 3.3).

You can type the address by hand and revoke the permission at any time from your OS settings. The app keeps working the same way.

3.7. Camera, microphone, and files

• Camera: the app requests camera access to scan QR codes (e.g., to validate a coupon). Images captured for QR are processed in memory, not stored or transmitted to our servers.
• Microphone: the app requests it when you choose to talk with Devie. ElevenLabs processes your voice live to sustain the conversation without recording the audio; the transcript and summary are kept for the periods in sections 3.11 and 7.
• Files / gallery: when you upload a logo or prize image, the file is sent to our Cloudflare R2 storage and associated with your business.

3.8. Technical and error data

When an error occurs in the app, we send a report to Sentry with:

• The error stack trace.
• OS version, device model, and app version.
• The minimum state needed to reproduce the error (e.g., which screen you were on).
• The app's latest calls to our server, whose path carries your business ID.

Sentry also receives performance traces from a sample of sessions, with the same technical data. App reports are linked to your business through that ID; your name, email, and phone stay out of them. On the website, reports carry the email and name of the session you signed in with or the email you played with, and Sentry records a sample of visits and the visits with an error, with text and fields masked. The Meta SDK sends its own crash reports to Meta.

3.9. What you write to us through the app, by email, or on WhatsApp

When you close the Google Play payment sheet without subscribing, the app asks what stopped you. If you answer in your own words, we store the text you wrote along with your account and the business you sent it from.

The Cliencer team reads those answers and may receive them by email to contact you. They stay within Cliencer and the providers in section 5, among them Google Workspace, where the team's email inbox lives. Product analytics receives only the length of the answer.

When you write to us through the in-app chat or answer an email from the team, we store your messages and our replies along with your account, in a single support conversation. What someone writes to Cliencer's WhatsApp number is also stored in that conversation. The Cliencer team reads and answers them, and the chat and email messages may also go through the support assistant in section 5, which reads the earlier messages of the conversation as context, including what arrived on WhatsApp. The reply reaches you in the chat and, when you are not looking at it, also as a push notification with its text. If you wrote to us by email or on WhatsApp, we answer you in the chat when you have the app with notifications turned on in your OS, and otherwise at your account email. To those who wrote to us on WhatsApp and have neither the app with notifications turned on in their OS nor an email on their account, the team writes by hand on WhatsApp, to the phone number of that conversation.

Purpose: understand what holds you back from activating your plan and help you solve it, and answer what you ask us through the in-app chat, by email, or on WhatsApp.

3.10. What an AI assistant you connect sees

You can connect an AI assistant, Claude or ChatGPT, to your Cliencer account to look up and manage your businesses from that assistant. To connect it, you sign in with your email and the code we send you, and on the consent screen you see the assistant, your businesses, and what the assistant will be able to do, and you accept it.

With the connection, the assistant reads:

• Your account name and email.
• For each business you manage: its name, industry, and address, its Instagram and Google links, and its contact WhatsApp, phone, and email.
• Your games with their prizes and conditions, your prizes, the plays awaiting your validation, the coupons you look up, and your notifications.
• Your business numbers: visits, plays, distinct people who played, coupons delivered, and redemptions.

With the permission to make changes, which you also accept on the consent screen, the assistant creates prizes and games and pauses or shows a game, under the same rules as the app.

The data of the people who play your games stays in Cliencer: their name, email, phone, birthday, and answers, the files they upload, and the QR and code of their coupons. Notifications that mention someone who played reach the assistant with their own text, which keeps that person anonymous.

Your conversation with the assistant lives with its provider (section 5), under your account and your agreement with that provider. From the connection, Cliencer stores the permission you gave, with your account, the assistant, the permissions you accepted, and their dates, and the tokens the assistant uses to access your account, each with its expiration (section 7). Each request from the assistant leaves a line in the server log with the tool it used, your account, the business, the assistant, the origin of the request, and the IDs of what it created or changed. When Cliencer refuses a request, the line adds the reason, which is the same text the assistant receives and may name your prizes or your games; when the request fails because of a server error, the line adds the technical error. The data Cliencer returns to the assistant when the request succeeds stays out of the log.

Purpose: let you look up and manage your account from the assistant you chose, and protect your account with the log of each request.

3.11. The call with Devie

At cliencer.com/devie-habla you can talk by voice with Devie, the artificial intelligence of the dev-fran team, the studio that makes Cliencer: Devie asks about your business and guides you through the studio's services that Cliencer offers in its Store. The call is processed by ElevenLabs: it listens to your voice live, without recording it, transcribes it, and gives Devie its voice. Devie's replies are written by an Anthropic model that runs through ElevenLabs, and when the call ends, a Google (Gemini) model that also runs through ElevenLabs reads the transcript and builds the call's sales summary. ElevenLabs receives your voice, its transcript, and a call identifier: an anonymous one in the trial call; when you left your email or opened the call from the Store in the app, the ID of the record where Cliencer keeps your email, which only Cliencer links to it. ElevenLabs keeps the transcript for the period in section 7.

The trial call opens with the “Hablar con Devie” (Talk to Devie) button, without asking for your data, and only the call's providers process it (section 5): Cliencer keeps no data about you. If your browser stores the cookie from a link you opened before, the call travels with that link's identifier, and Cliencer keeps the summary of the first call you finish with each link (next paragraph).

When the page asks for your email before the call, we email you a link to join, which expires after 30 minutes, and your browser stores a cookie that recognizes you for 30 days. From that call we store your email and the sales summary the Google model builds when it ends: your name, your business and its industry, your goal, your current situation, what you need, the services Devie recommends, the urgency, the material you have, the next step, and a summary of the conversation. The dev-fran team reads it.

In the Cliencer app, tapping a service in the Store opens this same page with its own link, which expires after 30 minutes, and your browser stores the same 30-day cookie. That call is answered by Devie's agent for merchants, which starts out knowing the business owner's name, your business name, its industry, and the service you tapped: ElevenLabs receives that data along with your voice. With that cookie, the calls you open later from the same browser start with the same business data. When you tap the service we store the business owner's email, that the request came from the Store, the business and the service, even if you never talk with Devie afterwards; from the call we add the sales summary from the previous paragraph. The dev-fran team reads it.

During sign-up in the app, you can also choose an optional interview with Devie to share what you expect from Cliencer. The agent starts with your name, your business name, and its industry; ElevenLabs receives that data along with your voice. When the interview ends, we keep the goal you shared, your current situation, what you need, the next step, and a summary of the conversation, linked to your account and business. The Cliencer team reads it to understand your context and support you better. You can skip the interview and continue signing up.

If you verified your WhatsApp to talk with Devie when the call asked for it, we keep that WhatsApp and the intent you chose then, and the summary if the call ended, for the same period (section 7).

Purpose: guide you through the studio's services Cliencer offers in its Store, understand what you expect from the app during sign-up, and, when you leave your email or open the call from the Store, contact you with a proposal.

4. How we use your data (purposes and legal basis)

If at any time you withdraw your consent for purposes that depend on it, we will stop processing that data for that purpose. This does not affect the lawfulness of processing done before the withdrawal.

5. Who we share data with

We do not sell your data. We share it with the providers that run the service on our behalf, each with the information it needs for its function, and with Meta, which receives app and website events to measure and optimize Cliencer's ads and uses them under its own business terms. When you connect an AI assistant, its provider receives the data you let it read (section 3.10) and handles it under your account and your agreement with that provider.

We sign Data Processing Agreements (DPAs) with providers that allow it, and we choose vendors with recognized security standards (SOC 2, ISO 27001, and equivalents).

We may also share data when required by a competent authority in legal proceedings, when necessary to protect the platform's or people's safety, or in the context of a corporate operation (merger, acquisition, reorganization). In the last case, we will notify you before your data becomes subject to a different privacy policy.

6. International transfers

Cliencer LLC is incorporated in the United States and most of our providers operate from there. If you are located outside the US (for example, in Argentina, Mexico, or the European Union), your data is transferred and processed in the US.

For these transfers we apply, as applicable:

• Standard Contractual Clauses approved by the European Commission, incorporated by reference in provider agreements, when the user is located in the European Economic Area or in countries that require SCCs.
• Adequacy decisions where recognized by local authorities (AAIP in Argentina, INAI in Mexico, European authorities, etc.) with respect to the US.
• Additional technical measures: in-transit encryption (TLS 1.2+), at-rest encryption in databases, and role-based access control.

If you are in a jurisdiction whose authority does not recognize the US as an adequate country, you may request that we not transfer your data by writing to info@cliencer.com. We will evaluate the request on a case-by-case basis; that may mean we cannot provide the service fully.

7. How long we keep data

8. Account deletion and user rights

8.1. How to delete your account

From the app, open the menu with the settings icon in the top bar, tap Eliminar mi cuenta (Delete my account), and confirm with Eliminar cuenta (Delete account). You can also request it by email at info@cliencer.com from the address you signed up with; the team processes it and confirms through the same channel. When you confirm deletion from the app, the following happens:

1. Your account is marked for deletion and scheduled for 30 days later.
2. The app signs you out. During those 30 days your data still exists and your games keep working; if you sign in again within that period, deletion is canceled.
3. If you have an active Stripe subscription, it is canceled when the deletion runs, once the 30 days are up. An App Store or Google Play subscription is managed by the store and is canceled from your Apple or Google account.
4. After 30 days, a daily automated process (2 AM, Argentina time) anonymizes your account: the email is replaced with a value like deleted_xxx@removed.cliencer.com, the name is changed to “Usuario eliminado”, phone, associated addresses, and push tokens are cleared, and the businesses you managed are archived.
5. Historical games, prizes, and coupons are not deleted in order to preserve the integrity of your end customers' results, but they are disconnected from any personally identifiable information about you.
6. Invoices and tax receipts are kept for the period required by law (10 years), per section 7.

When executing the deletion, the services that host the platform (MongoDB Atlas, Render.com, and Cloudflare R2) keep your account as this list describes, with the retention periods in section 7, and we disconnect your account from OneSignal (push notifications) so you stop receiving them. The rest of the providers in section 5 keep what they already received under their own retention periods. If you want your data deleted from those services too, email info@cliencer.com and we'll coordinate the removal manually (or you can do it directly through each provider's public form).

8.2. Your rights

You have the right, at any time, to:

• Access: request a copy of the personal data we hold about you.
• Rectification: correct inaccurate or outdated data.
• Deletion: request that we delete your data, subject to legal exceptions (e.g., retention of billing data).
• Objection: object to processing based on legitimate interest or marketing.
• Portability: receive your data in a structured, commonly used format (e.g., JSON or CSV).
• Withdrawal of consent: when processing is based on your consent, you can revoke it.
• File a complaint with the data protection authority of your country. For example: AAIP in Argentina (Law 25.326, argentina.gob.ar/aaip), INAI in Mexico (LFPDPPP, home.inai.org.mx), your national data protection authority in the EU/EEA, or the California Privacy Protection Agency if you reside in California.

To exercise any of these rights, email info@cliencer.com with the subject “Data Rights” indicating what you want to exercise. We will respond within 10 calendar days. We may ask for identity verification before sharing personal data.

8.3. How to cut an AI assistant's connection

You can cut the connection of Claude or ChatGPT (section 3.10) in two ways:

• From the assistant's settings, where you disconnect Cliencer from your connectors in Claude or your plugins in ChatGPT: the assistant stops using the connection; if it revokes the permission when you disconnect it, we delete it at that moment, and otherwise it expires within the periods in section 7.
• By writing to us at info@cliencer.com (section 15) from your account email: we delete the permission you gave, and the assistant loses access to your account on its next request.

To connect it again, you accept the consent screen again, and you sign in with your email and its code when the session you signed in with to connect (section 7) has expired or when you connect from another browser.

9. Information security

We apply technical and organizational controls to protect your data.

Technical measures

• End-to-end encrypted communications via TLS 1.2 or higher.
• At-rest encryption in the database and file storage.
• Session tokens stored in the OS secure storage (Keychain / Keystore) via expo-secure-store, never in plain text.
• Optional local biometric authentication.
• Credential hashing with industry-standard algorithms.
• Secret management with environment variables isolated per environment and periodic rotation.
• Continuous error and anomaly monitoring (Sentry + infrastructure logs).

Organizational measures

• Least-privilege access: the team accesses only the data strictly necessary for their role.
• Audit logs for administrative access to sensitive data.
• Security reviews before every major release.
• Periodic evaluation of critical providers.

No system is 100% impenetrable. If we detect a security incident affecting your personal data, we will notify you through available channels (in-app, email) and comply with applicable reporting obligations.

10. Minors

To create a business account on Cliencer you must be 18 or older. We do not knowingly collect minors' data as account holders.

If a business runs games that may reach minors among their end customers, that business is responsible for complying with the applicable minor-protection regulations in their jurisdiction. If we detect that a minor's data was uploaded improperly, we will delete it as soon as we become aware.

11. Cookies and similar technologies

The mobile app does not use cookies in the traditional sense. It uses secure local storage (expo-secure-store and AsyncStorage) to store your session and preferences on the device.

The cliencer.com website does use first- and third-party cookies for authentication, analytics, and marketing. Details are shown in the website's cookie banner and governed by this same policy.

12. Push notifications

If you accept push notifications, we may send you alerts about:

• Account and subscription status.
• Game results and customer activity in your campaigns.
• The Cliencer team's replies that reach you through the in-app chat.
• Product news and recommendations.

The push accompanies the team's reply that reaches you through the in-app chat. We answer you in the chat when you wrote to us there or when you have the app with notifications turned on in your OS; if you turn them off there, the reply to what you wrote to us by email or on WhatsApp goes through the channel in section 3.9, without a push.

You can disable them at any time from your OS settings. The switch in the app turns off the notices to grow your business, and the team's replies and your customers' activity keep arriving.

13. Advertising ID and ad measurement

Cliencer measures its ads with Meta: the Meta SDK inside the app, and the Pixel and our server on the website, send it the events described in section 5, and Meta uses them to measure and optimize the campaigns.

• On Android, the Meta SDK and Amplitude read Google's advertising ID (GAID), and the app sends it to our server, which stores it with your business for advertising. You can reset or delete it from the ads section of your Android settings; once it is deleted, the app stops sending it and our server removes the one it had stored.
• On iOS, measurement is aggregated: Meta receives the events with ad tracking disabled and attributes them with SKAdNetwork, Apple's system. The app leaves Apple's advertising identifier (IDFA) unread and never shows you the tracking prompt (App Tracking Transparency).

In the countries where the law requires your prior consent for this measurement, the app and the website cookie banner ask for it before measuring, and in the app you can change your decision at any time from Configuración → Privacidad (Settings → Privacy).

14. Changes to this policy

We may update this policy when we add new features, change providers, regulations change, or we improve data handling. For material changes, we will notify you at least 15 days in advance via:

• An in-app banner.
• An email to the address registered on your account.

The current version is always available at cliencer.com/privacy. The date at the start of the document shows when it was last updated.

15. Contact

If you have questions, complaints, or want to exercise any of your rights:

• Email: info@cliencer.com
• Web: cliencer.com
• Suggested subject: “Privacy” or “Data Rights”

We respond within 10 calendar days. If you don't receive a response or are not satisfied, you can file a complaint with the data protection authority of your country (for example, AAIP in Argentina, INAI in Mexico, your national DPA in the EU/EEA, or CPPA in California).