Clarbee
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Privacy Policy

Last updated: 11 October 2026

1. Controller

The controller of your personal data is Kamil Mikołajewicz, trading as Clarbee, company number (BCE/KBO) registration in progress, address registration in progress, email [email protected].

2. What data we process and why

  • Emails you send us (name, email address, message content), to answer you. Legal basis: our legitimate interest in replying, or steps before a contract (GDPR art. 6(1)(f) and (b)).
  • Order and customer data (name, email, country, company and VAT number if given, products purchased), to deliver products, provide updates to subscribers and handle refunds. Legal basis: performance of a contract (art. 6(1)(b)) and legal obligations such as bookkeeping (art. 6(1)(c)).
  • Free quiz and checklist (email address, your quiz answers – country you ship from, countries you sell to, packaging types, whether you use AI – language and date/time), only if you tick the consent box, to give you the full checklist and to send you occasional updates on PPWR, the AI Act and Clarbee products. We also store a salted, one-way hash of your IP address only to limit abuse (too many submissions). Legal basis: your consent (art. 6(1)(a)), which you can withdraw at any time by emailing [email protected] or using the unsubscribe link in our emails. Stored in a Cloudflare D1 database.
  • Technical data (IP address, browser type, pages requested) processed by our hosting provider for security and to deliver the website. Legal basis: legitimate interest (art. 6(1)(f)).
  • Anonymous usage statistics via Cloudflare Web Analytics, which does not use cookies or local storage and does not track you across sites. Legal basis: legitimate interest (art. 6(1)(f)).

3. Payments

Payments are processed by Paddle.com, our reseller and Merchant of Record. Paddle collects your payment and billing details and processes them as an independent controller under its own privacy policy. We never see or store your full card details. Paddle shares with us the order data needed to deliver your product.

4. Cookies

We do not use tracking or advertising cookies, so we do not show a cookie banner. When you open the Paddle checkout, Paddle may use strictly necessary cookies to process your payment securely.

5. Recipients and processors

  • Cloudflare, Inc. (website hosting, security, email forwarding and cookie-less analytics).
  • Paddle.com Market Ltd (payments, invoicing, VAT).
  • Google (email mailbox used to receive messages forwarded from [email protected]).

Some of these providers may process data outside the EEA. Where they do, transfers rely on the EU-US Data Privacy Framework or the European Commission's Standard Contractual Clauses.

6. Retention

Quiz leads (email and answers) are kept until you withdraw your consent or unsubscribe, and at most 24 months after you gave consent; IP hashes used for abuse prevention are deleted after 30 days. Emails are kept for up to 3 years after our last exchange. Order data is kept for as long as required by Belgian accounting and tax law. Hosting logs are kept only for a short period by Cloudflare for security purposes.

7. Your rights

You have the right to access, rectify and erase your data, to restrict or object to processing, and to data portability. To exercise them, email [email protected]. You also have the right to lodge a complaint with the Belgian Data Protection Authority (dataprotectionauthority.be) or the authority in your country.

8. Changes

We may update this policy. The current version is always published on this page.