Privacy Policy

Who we are

Clossy (clossy.app) is operated by Ihor Slushnyi, a sole proprietor (jednoosobowa działalność gospodarcza) registered in the Central Register and Information on Economic Activity (CEIDG) in Poland.

Tax identification number (NIP): 6762649601

For the purposes of the General Data Protection Regulation (GDPR), Ihor Slushnyi is the data controller responsible for your personal data.

Contact: [email protected]

What data we collect

When you sign up for the waitlist, we collect your email address. That's it.

We may use privacy-friendly analytics to understand how visitors interact with our site (page views, referral sources). This data is aggregated and anonymized — we don't track individual behavior.

We do not currently collect account data, passwords, or personal profiles.

Legal basis for processing

We process your personal data under the following legal bases:

• Consent (Art. 6(1)(a) GDPR) — when you voluntarily submit your email address to join the waitlist. You can withdraw consent at any time.
• Legitimate interest (Art. 6(1)(f) GDPR) — for aggregated, anonymized analytics to improve the site, and for affiliate tracking cookies that enable our business model.

How we use your data

• To notify you when Clossy launches or when we have important updates
• To improve the product based on aggregate usage patterns

We do not sell, rent, or share your personal data with third parties for marketing purposes.

Affiliate links

Clossy contains affiliate links to third-party retailers. When you click a product link and make a purchase, we may earn a small commission. This does not affect the price you pay.

Each retailer has their own privacy policy that governs how they handle your data once you leave Clossy. We encourage you to review those policies before making a purchase.

Cookies

Clossy uses the following types of cookies:

• Affiliate cookies — when you click a product link, our affiliate network partners may set cookies on your device to attribute the referral and any resulting purchase. These cookies typically expire after 30 days.
• Analytics cookies — we may use privacy-friendly analytics (no personally identifiable information) to understand aggregate site usage such as page views and referral sources.

We do not use advertising or behavioral tracking cookies. You can disable cookies in your browser settings at any time. Note that disabling affiliate cookies does not affect your browsing experience but may prevent proper purchase attribution.

Third-party services

We use the following third-party services that may process data on our behalf:

• Supabase (database hosting) — stores waitlist email addresses
• Vercel (web hosting) — serves the Clossy website; may process server logs containing IP addresses
• Affiliate networks — we partner with affiliate networks to earn commissions on product referrals. These networks may process click and purchase data for commission attribution. We will update this section with specific provider names as partnerships are established.

Each provider acts as a data processor under their own terms of service and privacy policies.

International data transfers

Some of our third-party service providers (including Supabase and Vercel) are based in the United States. Where personal data is transferred outside the European Economic Area, we ensure appropriate safeguards are in place, such as the European Commission's Standard Contractual Clauses (SCCs) or the provider's participation in an approved transfer framework.

Data retention

Email addresses: retained until you request deletion or unsubscribe from our communications.

Analytics data: aggregated and anonymized; no personally identifiable records are stored.

Affiliate cookies: typically expire after 30 days as set by the respective affiliate network.

Server logs: automatically deleted by our hosting provider in accordance with their retention policies (typically within 30 days).

Your rights (GDPR)

Under the General Data Protection Regulation, you have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate data
• Request deletion of your data ("right to be forgotten")
• Request restriction of processing
• Data portability — receive your data in a structured, machine-readable format
• Object to processing based on legitimate interest
• Withdraw your consent at any time (without affecting the lawfulness of processing before withdrawal)

To exercise any of these rights, email us at [email protected]. We will respond within 30 days.

You also have the right to lodge a complaint with a supervisory authority. In Poland, this is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, UODO) — uodo.gov.pl.

Children's privacy

Clossy is not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it promptly.

Changes to this policy

We may update this privacy policy from time to time. When we do, we'll update the "Last updated" date at the top of this page. We encourage you to review this page periodically.

Contact

For any privacy-related questions or requests, reach out to:

Ihor Slushnyi
NIP: 6762649601
[email protected]