Privacy Policy

Effective Date: May 16, 2026 Last Updated: October 17, 2026 Version: 1.10.1 (reconciled with Terms of Service v1.10.0 + Data Processing Agreement v1.8.1 — v1.10.1 [2026-10-17]: §2.1 account information includes the date you accepted the Terms of Service and the version you accepted; §5.1 Sign in with Apple is also used at signup in the iPhone app. v1.10.0 [2026-10-16]: subscriptions bought in the ClearDeduct iPhone app are billed by Apple through the App Store: §2 what we receive from Apple about them, including renewal status and dates and Apple's notifications (never Apple payment details), §3 purposes, §5.1 Apple (App Store) listed, and Stripe, Apple and Google act under their own terms as well, §5.1b the app sends Apple your account ID with a purchase, which is not a sale or sharing, and Apple processes landlord account data only, §7.1 the plan ends only when no subscription or granted plan keeps it, an App Store subscription that expires or that Apple refunds ends it, Apple collecting a failed payment cancels the deletion, a late second email moves the deletion date, deleting the account cancels a website subscription but not an App Store subscription, the payment-delinquency ground for termination for cause is removed (Terms of Service §8.2), retention of App Store purchase records with billing records; §2.4 cites Cal. Civ. Code §1798.140(ae)(1)(C) and (w) for precise geolocation; §4 the legal-obligation basis covers billing records only (not AB 2801); §5.1a no longer cites the subsection of §1798.100 that governs third parties that control collection. v1.9.1 [2026-09-25]: §9 adds the password checks — common, personal and breached passwords are refused; the breach check sends only the first five characters of a hash of the password. v1.9.0 [2026-09-24]: the operator is named, Efkan Turen, doing business as ClearDeduct, with a mailing address (§1, §15); §9 lists only the security measures in place; the sub-processor authorization cites CPRA §1798.140(ag)(2), the service-provider subcontracting rule (§5.1). v1.8.0 [2026-09-24]: descriptions matched to what the Service does: photos are stored unchanged, with no overlay; the camera make and model are not kept; location is optional and the app keeps working without it; product analytics (PostHog) and email routing (Cloudflare) are listed; no Android push provider; Sign in with Apple is also in the iPhone app; Stripe and PostHog handle landlord account data only (§5.1b); share links stop working when a report is deleted; the export includes each photo's fingerprint list; the four-year period is stated as while your plan is active; an unverified tax-code citation was removed (§2.2, §2.3, §2.4, §3, §5.1, §5.1a, §5.1b, §5.2, §7, §8.1, §8.4). v1.7.0 [2026-09-24]: retention rewritten to what the Service does: Your Content is kept while your plan is active; 60 days to download after a plan ends, with two emails, then permanent deletion; 30 days after account deletion; the four-year post-cancellation archive and the §1798.105(d)(8) retention claim are withdrawn (§7, §7.1, §8). v1.6.1 [2026-09-24]: Download My Data gives ZIP files (original photos and PDF reports) and spreadsheets instead of a JSON file (§8.1, §8.4). v1.6.0 [2026-09-23]: Download My Data is also on the web account page (§7.1, §8.4). v1.5.0 [2026-09-23]: in-app paths match the app (More → Profile & Account → Download My Data / Delete Account; profile corrections by email; no in-app DPA link); v1.4.0 corrects the retention basis [BUG-112, 2026-09-22]: Civil Code §1950.5 requires taking and furnishing photographs and sets no retention period; the four-year period is the written-contract limitations period, Cal. Code Civ. Proc. §337; v1.3.1 added §7.2 "Pre-Upload Local Storage on Your Device" per 5G.28 to disclose the factory-reset / pre-upload risk and the mitigations layered on top of it)

ClearDeduct ("we," "our," or "us") provides software that helps California landlords comply with Assembly Bill 2801 (AB 2801) by documenting rental property condition through timestamped photographs. This Privacy Policy explains how we collect, use, share, and protect your personal information when you use the ClearDeduct mobile application or website (collectively, the "Service").

By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree, do not use the Service.

1. Who We Are

Operating entity: Efkan Turen, doing business as ClearDeduct Privacy contact: privacy@cleardeduct.com Mailing address: 5040 Haven Place #302, Dublin, CA 94568, USA

1.1 Data Controller and Service Provider Roles

ClearDeduct's role under applicable privacy law depends on which data is being processed:

1.2 Data Processing Agreement (DPA)

For all tenant data and other third-party data uploaded through the Service, ClearDeduct acts as a Service Provider (CCPA/CPRA) and Data Processor (GDPR Art. 28). Our processing of such data is governed by ClearDeduct's standard Data Processing Agreement (incorporated by reference into the Terms of Service §15.1), which:

• Prohibits ClearDeduct from selling or sharing the data;
• Restricts use to the contracted services only;
• Bars combining the data with information from other sources;
• Specifies sub-processor obligations consistent with this Privacy Policy §5.1 and Terms of Service §16;
• Establishes data-return / deletion procedures upon contract termination (per ToS §4.5: a sixty-day download period after a plan ends, then deletion);
• Sets breach-notification timelines aligned with this Privacy Policy §9.1.

Full DPA text: publicly available at cleardeduct.com/dpa. Enterprise customers may request a signed counter-party version by emailing privacy@cleardeduct.com with subject line "Signed DPA Request"; we deliver within 10 business days.

2. Information We Collect

2.1 Information You Provide

• Account information: name, email address, phone number (optional), password (hashed; we never store plaintext), and the date you accepted the Terms of Service and the version you accepted.
• Property and tenancy data: property address, unit details, tenant name and contact information, lease dates, deposit amount.
• Inspection data: photos taken through the Service, room and area annotations, deduction line items, contractor invoices.
• Billing information: processed by our payment provider Stripe, Inc. We do not store full credit card numbers on our servers. For subscriptions bought in the iPhone app, Apple processes the payment; we receive from Apple the subscription's transaction identifiers, product, price, currency, storefront, status, renewal status and dates — never your Apple ID payment details.
• Support communications: any messages you send to us, including the contents of those messages.

2.2 Information We Collect Automatically

• Device data: operating system and version, app version, and time zone.
• Usage data: features used, screens visited, actions taken, error logs, crash reports.
• Photo metadata: the date, time and time-zone offset of each inspection photo, and its GPS coordinates when you allow location access, recorded inside the photo file (EXIF). We do not keep your camera's make, model or serial number. The date and time are always recorded; the GPS coordinates depend on your location permission (§2.4).
• Precise location (optional): if you allow location access, we record the GPS coordinates at the moment each inspection photo is taken. The app asks for location only while you use it, never in the background. You may turn this off at any time in your device settings; the app keeps working and saves new photos without GPS coordinates.

2.3 Information We Receive From Third Parties

• Payment information from Stripe (subscription status, last 4 digits of card, billing country) for accounting purposes only.
• Subscription information from Apple for purchases in the iPhone app: signed transaction records, which we verify with Apple's App Store Server API, and Apple's notifications when a subscription renews, changes, ends or is refunded.
• Push notification tokens from Apple Push Notification service (APNs), through Expo's push service, when you allow notifications.
• Identity provider information from Apple Inc. (Sign in with Apple, in the iPhone app and on cleardeduct.com) or Google LLC (Sign in with Google, on cleardeduct.com) when you choose those signup or login methods: your email address, your display name (Apple transmits the name only on first authentication; Google transmits it on each), and an OAuth/OIDC authentication token used solely to establish your ClearDeduct session. We do not receive your Apple ID password, your Google password, your contacts, calendars, photo library, or any other personal data from your Apple or Google account. If you use Apple's "Hide My Email" feature, the email address we receive is an Apple-relay address (e.g., xxxxx@privaterelay.appleid.com) — our outbound system emails reach you through Apple's relay infrastructure, and we never see your real address.

2.4 Sensitive Personal Information (SPI) — Precise Geolocation

Under the California Privacy Rights Act (CPRA), "precise geolocation" — defined as location data that locates a consumer within a geographic radius of 1,850 feet or less (Cal. Civ. Code §1798.140(w)) — is classified as Sensitive Personal Information (Cal. Civ. Code §1798.140(ae)(1)(C)). When you allow location access, the GPS coordinates recorded in inspection photographs (§2.2) are precise enough to meet this statutory threshold. Civil Code §1950.5 requires the photographs but not their location; we record the location because it shows where each photograph was taken.

We accordingly disclose:

1. We do collect SPI in the form of precise geolocation recorded in photo EXIF metadata, only when you allow location access.
2. Purpose: This SPI is collected and processed solely to (a) record where each inspection photograph that California Civil Code §1950.5(g) (as amended by AB 2801) requires landlords to take was taken, (b) print that location, with the date and time, under each photograph in the PDF reports you generate, and (c) let you show where a photograph was taken if the condition of the unit is disputed.
3. Statutory exemption invoked: Pursuant to CPRA §1798.121(a) and 11 Cal. Code Regs. §7027, ClearDeduct invokes the "performing the services or providing the goods reasonably expected" exemption. We do not use this SPI to infer characteristics about you or your tenants, and we do not use it for cross-context behavioral advertising, profiling, or any purpose outside AB 2801 compliance.
4. Right to Limit: We use this SPI only for the purposes above, so we do not offer a separate "Limit the Use of My Sensitive Personal Information" link. You can limit it yourself at any time by turning off location access for ClearDeduct in your device settings: the app keeps working, new photos are saved without GPS coordinates, and the app tells you when a photo has none. Photos already taken keep their recorded location, because each photo is stored exactly as captured. To request review of our SPI processing, email privacy@cleardeduct.com.

We do not knowingly collect other categories of SPI: racial or ethnic origin, religious beliefs, union membership, mail/email/text message contents, genetic data, biometric identifiers used to identify a person, health/sex-life/sexual-orientation information, citizenship or immigration status, financial account credentials.

3. How We Use Information

We use your information for the following purposes ("legitimate business interests" under GDPR Art. 6(1)(f) where applicable, and "business purposes" under CCPA §1798.140):

4. Legal Bases for Processing (GDPR / UK GDPR)

If you are in the European Economic Area, the United Kingdom, or Switzerland, we rely on the following legal bases:

• Contractual necessity (Art. 6(1)(b)): to deliver the Service you have purchased.
• Legitimate interests (Art. 6(1)(f)): to operate, secure, and improve the Service, where these interests are not overridden by your rights.
• Legal obligation (Art. 6(1)(c)): to retain billing records for tax and accounting purposes.
• Consent (Art. 6(1)(a)): for optional marketing emails and location permission. You may withdraw consent at any time.

5. How We Share Information

We share information only with the following categories of recipients:

5.1 Service Providers (Sub-Processors)

To deliver the Service, ClearDeduct directly engages the following third-party service providers. Those that may process Your Content and tenant personal data on your behalf are our sub-processors; by using the Service, you grant general written authorization under GDPR Article 28(2) and CPRA §1798.140(ag)(2) for ClearDeduct to engage them, as also reflected in Terms of Service §16 and Data Processing Agreement §4. Stripe, Apple (App Store), PostHog and the identity providers handle landlord account data only (§5.1a, §5.1b).

Downstream infrastructure transparency: Our direct vendors (Supabase, Stripe, Resend) themselves rely on upstream cloud infrastructure providers (typically Amazon Web Services). ClearDeduct does not maintain a direct contractual relationship with these upstream providers; downstream sub-processor chains are published by each direct vendor in their own sub-processor disclosures (e.g., stripe.com/legal/service-providers, supabase.com/security, resend.com/legal/subprocessors).

We require each provider that processes information on our behalf to do so only on our instructions and to maintain appropriate security safeguards; Stripe and Apple process your payments, and Apple and Google your sign-in, under their own terms as well (§5.1a, §5.1b). We do not authorize any provider to use your information for their own marketing, profiling, or model-training purposes.

You may request the current sub-processor list at any time by emailing privacy@cleardeduct.com. If you object to a newly added sub-processor on legitimate data-protection grounds, you may exercise the termination rights described in Terms of Service §16.3.

5.1a Scope Limitation — Identity Sub-Processors (Apple, Google)

The two identity sub-processors above (Sign in with Apple, Sign in with Google) are functionally distinct from the data sub-processors that handle tenant evidence (Supabase, Resend, etc.). Their processing scope is strictly limited to landlord-account authentication:

1. What they see: your landlord email address, your display name (at signup), and standard OAuth/OIDC handshake metadata (PKCE codes, ID tokens, refresh tokens). Apple may also see — and conceal from us via "Hide My Email" — the email address you registered with Apple.
2. What they never see: tenant personal information, photographs, inspection records, deduction line items, disposition statements, share links, or any other AB 2801 evidence. ClearDeduct does not transmit Tenant Personal Data to Apple's or Google's identity APIs under any circumstance.
3. Data Processing Agreement (DPA) scope: Because identity providers do not process Tenant Personal Data, the Sub-processor obligations defined in DPA §4 (which govern tenant-data processors) do not apply to Sign in with Apple or Sign in with Google. They are disclosed in this Privacy Policy for full transparency under GDPR Article 13 and the CPRA, but the contractual data-processing obligations imposed on Supabase / Resend / etc. are not contractually applicable to identity verification.
4. Opt-out: If you prefer not to use third-party identity verification, you may always create your ClearDeduct account using email + password. SSO is a convenience feature, not a requirement.

5.1b Scope Limitation — Billing and Analytics (Stripe, Apple, PostHog)

Stripe processes your subscription and payments: your email address, billing details and payment card, which you enter on Stripe's own checkout page — we never see the full card number. Apple bills subscriptions bought in the iPhone app to the payment method of your Apple ID. When you buy, the app sends Apple your ClearDeduct account ID (a random identifier) so the purchase is linked to your account; we receive from Apple the subscription's transaction identifiers, product, price, currency, storefront, status, renewal status and dates — never your Apple ID payment details. Because you direct this purchase with Apple yourself, this is not a sale or sharing of personal information (Cal. Civ. Code §1798.140(ad)(2)(A), (ah)(2)(A)). PostHog receives usage events from the iPhone app (for example, that an inspection was started), linked to a random account ID; the events never contain your name, email address, property addresses, photos or tenant information. None of them receives Tenant Personal Data, so the Sub-processor obligations in Data Processing Agreement §4 do not apply to them; they are disclosed here for transparency.

5.2 Other Disclosures

• Tenants: when you generate a Move-Out Disposition Statement and email it via the Service, the tenant's email address you provide and the report contents are delivered to the tenant. Secure share links expire after 90 days, and stop working earlier if you delete the report.
• Legal authorities: if required by law, lawful subpoena, court order, or to defend legal claims.
• Successors: in the event of a merger, acquisition, or asset sale, your information may transfer to the successor entity, subject to this Privacy Policy.

5.3 We Do Not Sell or Share for Cross-Context Behavioral Advertising

ClearDeduct does not sell personal information for monetary or other valuable consideration, and we do not "share" personal information for cross-context behavioral advertising as those terms are defined under the CPRA. We have not done so in the preceding 12 months and have no plans to do so.

6. International Data Transfers

ClearDeduct is operated from the United States. If you access the Service from outside the United States, your information will be transferred to and processed in the United States and other countries where our service providers operate.

For transfers from the EEA, UK, or Switzerland, we rely on the European Commission's Standard Contractual Clauses (SCCs) and, where applicable, the UK International Data Transfer Addendum, supplemented with appropriate technical measures.

7. Data Retention

7.1 When Your Plan Ends or You Delete Your Account

When your plan ends — every subscription on your account has ended (you cancel and the period you paid for runs out, you receive a refund under Terms of Service §4.4, a payment fails, or an App Store subscription expires or Apple refunds it) and no plan we granted remains, or we terminate for convenience under ToS §8.2(c)–(e) — you have sixty (60) days to download Your Content with Download My Data in the ClearDeduct app (More → Profile & Account) or at cleardeduct.com/account/data. If one subscription ends while another keeps your plan, your plan does not end. We email you when this period starts and again seven (7) days before it ends; if the second email goes out late, the deletion date moves so that you always have seven (7) days after it. At the end of it we permanently delete Your Content — properties, tenancies, inspections, photographs, reports and deductions — together with the related notifications and activity records. Subscribing again before that date, or Apple collecting a failed payment, cancels the deletion.

When you delete your account, you have thirty (30) days to change your mind (Terms of Service §8.1). After that we permanently delete Your Content in the same way and delete or anonymize your personal information. Deleting your account cancels a subscription bought on our website at once; it does not cancel one bought in the iPhone app — cancel it on your iPhone (Settings → your name → Subscriptions).

Exception — termination for cause: If your account is terminated for cause under Terms of Service §8.2(a)–(b) (Terms violation or evidentiary falsification), the sixty-day download period does not apply; we may keep the records needed to establish, exercise or defend legal claims arising from the violation.

What remains after deletion: billing records for seven (7) years (§7), a record of the deletion itself, and backups, which expire within thirty (30) days. We do not keep your photographs or reports after deletion, and we do not decline deletion requests for them.

7.2 Pre-Upload Local Storage on Your Device

Photos captured through the mobile app are first written to your device's local storage and queued for upload to ClearDeduct's cloud. The upload is automatic, but it requires network connectivity (Wi-Fi or cellular) and that the mobile app be allowed to run. Until a given photo has been uploaded — at which point it appears with a green status indicator in the inspection view and you receive an optional confirmation email — that photo exists only on your device.

This means:

• We cannot recover photos that are lost before they reach our servers. If your device is factory-reset, the ClearDeduct app is uninstalled, the device is replaced or wiped, or the local app data is otherwise cleared while photos are still pending upload, those photos are permanently unrecoverable from ClearDeduct.
• We take several steps to minimize this exposure: an in-app banner persistently displays the count of pending uploads, the app retries automatically on reconnection, and we send a warning email if any photo remains queued for more than 24 hours. You can also disable these emails at any time from Account → Sync Status.
• Recommended user practice: keep the app open on Wi-Fi after an inspection until all photos show the green "uploaded" indicator, and avoid factory-reset / device-transfer until that point.

The local-storage stage is required to support offline inspections in basements, rural properties, and units with poor reception — these are exactly the units AB 2801 documentation matters most for. We treat the small window of device-only existence as an engineering trade-off that we mitigate aggressively rather than eliminate.

8. Your Privacy Rights

8.1 California Residents (CCPA / CPRA)

You have the right to:

• Know what personal information we have collected, used, disclosed, and sold (we do not sell).
• Access a copy of your personal information in a portable, readily usable format: each inspection as a ZIP file with the original photos, its PDF reports and a list of every photo's fingerprint, time and location, and your records as spreadsheets (CSV).
• Delete your personal information. When you delete your account we permanently delete your Content after the 30-day grace period described in §7.1; we keep only billing records for seven (7) years, a record of the deletion, and backups that expire within 30 days.
• Correct inaccurate personal information.
• Limit the Use of Sensitive Personal Information. We use precise geolocation — the GPS location recorded in inspection photos — only to provide the Service: recording where each photo was taken and printing it in your reports. That is a permitted purpose under the CPRA §1798.121(a) "performing the services" exemption, so we do not offer a separate limit facility (see also Terms of Service §5.4). You can limit it yourself at any time by turning off location access for ClearDeduct in your device settings: the Service keeps working, and new photos are saved without GPS coordinates. We do not use this SPI for any other purpose, and we do not infer characteristics about you or your tenants from it.
• Opt out of sale or sharing for cross-context behavioral advertising (we do not engage in either).
• Non-discrimination — we will not deny service, charge different prices, or provide a different level of service because you exercised your rights.

To exercise these rights, email privacy@cleardeduct.com from the email address on your account, or use Download My Data and Delete Account in the ClearDeduct app (More → Profile & Account). We will verify your identity before responding and will respond within 45 days.

You may also designate an authorized agent in writing to make a request on your behalf.

8.2 European, UK, and Swiss Residents (GDPR / UK GDPR)

You have the right to:

• Access your personal data (Art. 15)
• Rectify inaccurate data (Art. 16)
• Erasure ("right to be forgotten") (Art. 17; see §7.1 for what remains after deletion)
• Restrict processing (Art. 18)
• Data portability in a machine-readable format (Art. 20)
• Object to processing based on legitimate interests (Art. 21)
• Withdraw consent at any time, where consent is the legal basis
• Lodge a complaint with your local supervisory authority. EU/EEA residents may contact their national Data Protection Authority; UK residents may contact the Information Commissioner's Office (ICO at ico.org.uk). A complete list of EU supervisory authorities is available at edpb.europa.eu.

Data Protection Officer (DPO): Based on the scale and nature of our processing, ClearDeduct is not required to designate a Data Protection Officer under GDPR Art. 37 (we are not a public authority, our core activities do not consist of large-scale systematic monitoring of data subjects, and we do not engage in large-scale processing of special categories of data outside the AB 2801 compliance context, for which we have invoked the CPRA "performing the services" exemption). For privacy inquiries, contact privacy@cleardeduct.com.

EU Representative: Because ClearDeduct is a California-only service that does not target EU/EEA residents as customers, we have not appointed an EU Representative under GDPR Art. 27. If you are an EEA resident who has nonetheless interacted with our website, you may contact privacy@cleardeduct.com directly.

To exercise these rights, email privacy@cleardeduct.com.

8.3 Your California Privacy Rights (Cal. Civ. Code §1798.83 — "Shine the Light")

California's "Shine the Light" law (Cal. Civ. Code §1798.83) entitles California residents to request, once per year, a notice describing what categories of personal information businesses share with third parties for those third parties' direct marketing purposes.

ClearDeduct does not disclose, share, sell, or rent personal information to third parties for those third parties' direct marketing purposes. We have not done so in the preceding 12 months and have no plans to do so. Accordingly, no "Shine the Light" notice is applicable.

To submit a request or verify this status, email privacy@cleardeduct.com with subject line "California Privacy Rights".

8.4 All Users

Regardless of where you live, you can:

• Correct your profile information (name or email) by emailing privacy@cleardeduct.com.
• Download your data via Download My Data in the ClearDeduct app (More → Profile & Account) or at cleardeduct.com/account/data: each inspection as a ZIP file with the original photos, its PDF reports and a list of every photo's fingerprint, time and location, and your records as spreadsheets (CSV).
• Delete your account via Delete Account in the ClearDeduct app (More → Profile & Account): a 30-day grace period, then your Content is permanently deleted (§7.1).
• Disable push notifications and location permissions in your device settings.

9. Data Security and Breach Notification

We protect your information with technical and organizational measures appropriate to its sensitivity:

• Encryption in transit and at rest: all connections to the Service use TLS, and our database and file storage provider (Supabase) encrypts all stored data, including photographs, with AES-256.
• Database ownership rules: every database table enforces, in the database itself, that an account reaches only its own records; evidence, legal and billing records are written only by our servers, never directly by the app.
• Limited access: access to production systems is limited to the operator of the Service.
• Dependency checks: software dependencies are checked for known security advisories whenever they change.
• Password checks: a new password is refused if it is common, contains your name, your email address or ClearDeduct, or has appeared in a data breach. For the breach check, only the first five characters of a hash of the password are sent to the checking service (Have I Been Pwned) — never the password itself.

9.1 Breach Notification Timelines

No system can be 100% secure. If we become aware of a breach affecting your personal information, we will notify you and the appropriate regulators within the strict statutory timelines required by applicable law.

California residents (Cal. Civ. Code §1798.82, as amended by Senate Bill 446, effective January 1, 2026): We will notify affected California individuals within thirty (30) calendar days of discovering a security breach involving unencrypted personal information (or encrypted personal information together with the encryption key). If a single breach affects more than 500 California residents, we will additionally submit a sample copy of the consumer notification to the California Attorney General within fifteen (15) calendar days of notifying affected consumers. Notification may be delayed only if a law-enforcement agency determines that immediate notification would impede a criminal investigation, or to the extent strictly necessary to determine the scope of the breach and restore reasonable data-system integrity.

EU / EEA / UK residents (GDPR Art. 33): We will notify the relevant supervisory authority of a personal data breach within 72 hours of becoming aware of it, where feasible. If the breach is likely to result in a high risk to the rights and freedoms of natural persons, we will also notify affected individuals without undue delay (GDPR Art. 34).

Other jurisdictions: We will comply with applicable breach-notification laws in your jurisdiction.

10. Children's Privacy

The ClearDeduct Service is a business-to-business compliance tool intended for adult landlords and property professionals. The Service is not directed to minors, and we apply the following age-specific standards:

• Under 13 (federal COPPA — 15 U.S.C. §§6501-6506): We do not knowingly collect personal information from children under the age of 13. The Service requires account holders to be at least 18 years of age (Terms of Service §1).
• Ages 13–16 (CCPA/CPRA opt-in — Cal. Civ. Code §1798.120(c)): For California minors between 13 and 16 years of age, CCPA/CPRA requires affirmative opt-in consent before any sale or sharing of personal information. Because ClearDeduct does not sell or share personal information (see §5.3 and §8.3), this opt-in requirement does not arise. We nonetheless do not knowingly accept account registrations from individuals in this age group.
• Under 18 (general): Per Terms of Service §1, the Service is only available to individuals 18 years of age or older capable of forming a binding contract under California law.

If you become aware that a minor has provided personal information through the Service, contact privacy@cleardeduct.com immediately and we will delete it without the download periods described in §7.1 (the underlying account registration would have been unauthorized).

11. Cookies and Similar Technologies (Web Only)

The ClearDeduct website (cleardeduct.com) uses only strictly necessary cookies to keep you signed in and to remember your preferences. We do not use advertising cookies, third-party trackers, or analytics that profile individual users.

The mobile application does not use cookies. It uses local device storage to cache your data for offline use; this storage is removed when you uninstall the app or delete your account.

12. Third-Party Links

The Service may contain links to third-party websites (such as the official California Legislature page for AB 2801). We are not responsible for the privacy practices of those sites. We recommend you review their privacy policies.

13. Do Not Track

Some browsers send a "Do Not Track" (DNT) signal. Because there is no industry consensus on how to interpret DNT, we currently do not respond to DNT signals. We do, however, honor the Global Privacy Control (GPC) signal as required by California law: when our website detects a GPC signal, we treat it as a valid opt-out request.

14. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email and through the app at least 30 days before the changes take effect. The "Last Updated" date at the top of this page indicates the most recent revision.

If you do not agree with a material change, you may delete your account before the change takes effect.

15. Contact Us

For privacy questions, requests, or complaints, contact:

• Email: privacy@cleardeduct.com
• Subject line: "Privacy Request"
• Mailing address: 5040 Haven Place #302, Dublin, CA 94568, USA

For all other inquiries, see the Help & Support section in the app.

This Privacy Policy is provided in English. Translations are for convenience only; the English version controls in the event of any discrepancy.