Privacy Policy

Data Controller

The data controller is:

Katse Holding Oy Business ID: 3274118-8 Registered office: Helsinki, Finland Email: support@clarifo.com

We have not appointed a separate Data Protection Officer (DPO) because our processing does not require one under Article 37 of the GDPR. For privacy matters, please contact us at the email address above.

Data We Collect

We collect only the information necessary to provide and improve the service.

• Account data: name, email address, password hash and authentication events.
• Usage data: search history, analyses performed in the service, session duration and technical log data.
• Payment and subscription data: subscription status and billing history. Payment card details are not stored on our servers but processed by our payment service provider.
• Cookie and analytics data used to monitor performance and improve the user experience.

Purposes and Legal Basis for Processing

We process personal data for the following purposes and on the following legal bases:

• Providing the service and performing the user agreement (GDPR Art. 6(1)(b)).
• Improving the user experience, developing the service, ensuring information security and preventing misuse (legitimate interest, GDPR Art. 6(1)(f)).
• Meeting statutory obligations such as accounting legislation (GDPR Art. 6(1)(c)).
• Marketing communications and newsletters based on the user's consent (GDPR Art. 6(1)(a)).

We do not sell or rent your personal data to third parties.

Sub-processors and Transfers Outside the EU/EEA

We use trusted sub-processors to operate the service. Key sub-processors include:

• Hetzner Online GmbH (Germany, EU/EEA) — server infrastructure and databases.
• Supabase Inc. (EU instance) — user authentication.
• Anthropic, PBC (United States) — AI-powered analysis.
• OpenAI, LLC (United States) — AI-powered analysis.
• Email and payment service providers.

Transfers to the United States and other countries outside the EU/EEA are based on the Standard Contractual Clauses (SCC) adopted by the European Commission and, where necessary, supplementary safeguards. An up-to-date list of sub-processors is available on request from support@clarifo.com.

Automated Processing and AI

The service uses large language models (LLMs) to generate summaries, comparisons and analyses based on financial filings and other public data. Please note:

• AI-generated content may contain errors and does not constitute investment, tax or legal advice.
• We do not make decisions based solely on automated processing that produce legal effects or similarly significantly affect users within the meaning of GDPR Article 22.
• Questions and analysis requests submitted by users are passed on to our LLM sub-processors (see the previous section). We recommend not entering sensitive personal data into the service.

Data Protection

We apply up-to-date technical and organizational security measures to protect personal data against unauthorized access, alteration, destruction or disclosure. Data is stored on secure servers, and access is restricted to employees and service providers who need the data to perform their duties.

Cookies

We use cookies to operate the service, keep you signed in, enhance the user experience and analyze usage. We use both strictly necessary cookies and analytics cookies that require your consent. You can manage or delete cookies in your browser settings, but blocking cookies may affect service functionality.

Data Retention

We retain personal data only for as long as needed to provide the service, meet legal obligations (for example, accounting records for at least 6 years) or ensure security. When a user account is deleted, the related personal data is deleted or anonymized within a reasonable time, unless the law requires longer retention.

Your Rights as a Data Subject

Under the GDPR you have the following rights:

• Access the personal data we hold about you.
• Correct or update inaccurate information.
• Erase your personal data when there is no longer a lawful basis for processing.
• Restrict or object to the processing of your data.
• Receive your data in a portable format and have it transferred to another service.
• Withdraw any consent you have given at any time.
• Lodge a complaint with a supervisory authority. In Finland the competent authority is the Office of the Data Protection Ombudsman (tietosuoja.fi).

You can exercise your rights by sending a request to support@clarifo.com. We respond without undue delay and at the latest within one month of receiving the request.

Changes to This Policy and Contact

We may update this privacy policy, for example when the service or applicable law changes. We will notify users of material changes in the service and/or by email.

Contact information for privacy matters: Katse Holding Oy Business ID: 3274118-8 Registered office: Helsinki, Finland Email: support@clarifo.com