Privacy Policy

Last Updated – 9th April, 2026

1. Introduction and Scope

WizRocket Inc., a Delaware corporation, CleverTap Private Limited (India), and CleverTap Pte. Ltd. (Singapore), together with their affiliated entities doing business as CleverTap (“CleverTap,” “we,” “us,” or “our”), provide a cloud-based customer engagement and analytics platform (the “Service”).

This Privacy Policy describes how CleverTap collects, uses, discloses, transfers, retains, and protects personal data in the course of operating its business and providing its services.

This Privacy Policy applies when:

  • You visit clevertap.com (the “Site”);
  • You communicate with us as a business contact.
  • You interact with our sales, marketing, or support teams;
  • You represent a Customer, vendor, or partner organisation;
  • You apply for employment with CleverTap, or
  • You otherwise provide personal data to us in circumstances where we act as a data controller.

It also explains our role when we process personal data on behalf of our Customers as a data processor through the Service.

CleverTap operates primarily in a business-to-business context. The Site and Service are not directed to minors.

This Privacy Policy is intended to comply with applicable data protection and privacy laws in jurisdictions where CleverTap operates, including but not limited to:

  • The European Union General Data Protection Regulation (GDPR);
  • The UK GDPR;
  • The California Consumer Privacy Act as amended by the California Privacy Rights Act (CPRA);
  • The Digital Personal Data Protection Act, 2023 (India);
  • The Singapore Personal Data Protection Act;
  • The Brazil Lei Geral de Proteção de Dados (LGPD);
  • The UAE Personal Data Protection Law;
  • The Saudi Personal Data Protection Law; and
  • Other applicable legislation.

2. CleverTap Entities and Contact Information

Depending on your location and relationship with CleverTap, the relevant contracting and data-controlling entity may be:

  • WizRocket Inc. in the United States

CleverTap c/o WeWork

535 Mission St, Unit 1624

San Francisco, CA 94105, USA

  • CleverTap Private Limited in India

19th floor, DLH Park, S.V. Road,

Goregaon (W), Mumbai 400064

  • CleverTap Pte. Ltd. in Singapore

CleverTap Pte Limited,

81 UBI Avenue 4, #08-17 UB. One,

Singapore-408830

For privacy-related inquiries, including the exercise of data subject rights or questions about this Privacy Policy, you may contact our Data Protection Officer at:

Email: privacy@clevertap.com

Web: https://clevertap.com/contact-us/

Courier correspondence may be addressed to the relevant CleverTap entity at the applicable address listed above.

Where required under Article 27 of the GDPR or UK GDPR, CleverTap may appoint a representative within the European Union or the United Kingdom. Contact details of such a representative will be made available where required by law.

3. Our Role as Data Controller and Data Processor

CleverTap processes personal data in different capacities depending on the context in which the data is collected and used.

The applicable role determines our responsibilities under relevant data protection laws.

A. When CleverTap Acts as a Data Controller

CleverTap acts as a data controller when we determine the purposes and means of processing personal data.

This applies to personal data processed in connection with:

  • Visits to and interactions with our Site;
  • Communications with business contacts;
  • Personal data relating to representatives of Customers, vendors, and business partners;
  • Job applicants and recruitment processes; and
  • Personal data processed as part of our own marketing, administrative, security, compliance, and business operations.

In these circumstances, CleverTap independently determines why and how personal data is processed and is responsible for ensuring such processing complies with applicable data protection laws.

B. When CleverTap Acts as a Data Processor

CleverTap acts as a data processor (or “service provider” under applicable U.S. state privacy laws) when providing the Service to Customers and processing personal data relating to Customer End Users on their behalf.

In this context:

  • The Customer determines the purposes and means of processing Customer End User data;
  • CleverTap processes personal data solely on documented instructions from the Customer;
  • Processing is governed by the applicable customer agreement and the Data Processing Addendum; and
  • CleverTap does not use Customer End User data for its own independent marketing, advertising, profiling, analytics, or other commercial purposes unrelated to the Service.

CleverTap’s role in this capacity is limited to hosting, supporting, securing, and operating the Service in accordance with contractual obligations.

C. Customer Responsibilities and Direct Requests

Each Customer maintains a direct relationship with its Customer End Users and is responsible for:

  • Providing appropriate privacy notices;
  • Determining the lawful basis for processing; and
  • Responding to data subject rights requests in accordance with applicable law.

If CleverTap receives a request directly from a Customer End User relating to data processed through the Service, and the applicable Customer can be reasonably identified based on the information provided, we will forward the request to the relevant Customer. CleverTap will assist the Customer in responding in accordance with our contractual obligations and applicable law.

4. Personal Data We Collect, Sources of Personal Data, and Context of Processing

CleverTap collects and processes personal data in different contexts depending on whether it acts as a data controller or as a data processor. The categories of personal data collected, the sources of such data, and the purposes for which it is processed vary accordingly.

A. Personal Data Collected from Site Visitors

When individuals visit our Site or otherwise interact with CleverTap through web forms, event registrations, marketing engagements, or direct communications, we collect personal data directly from those individuals.

Information Provided Directly by Individuals

This may include identifiers such as:

  • Name
  • Company name
  • Work email address
  • Telephone number
  • Country
  • Other information voluntarily provided in communications

When individuals communicate with us via a web form, we collect the information submitted through that form, including any additional personal data contained in the message content.

Information Collected Automatically

We also automatically collect certain technical and usage information when users access the Site. This may include:

  • Internet Protocol (IP) address
  • Browser type
  • Browser language
  • Device characteristics
  • Referring URLs
  • Pages viewed
  • Links clicked
  • Timestamps
  • Similar interaction data

Such information is collected using cookies and similar technologies as described in our Cookie Policy.

Aggregated and De-Identified Information

In certain circumstances, we may obtain analytics information in aggregate or de-identified form that does not relate to or identify an individual. Such information does not constitute personal data and may be used and disclosed without restriction.

B. Personal Data Collected from Representatives of Customers

CleverTap collects personal data from Customer representatives in connection with account creation, account administration, and use of the Service.

Information Provided by Customer Representatives

When Customer representatives engage in activities such as creating accounts, configuring settings, submitting feedback, or otherwise interacting with the Service (“Identification Activities”), we may collect personal data, including:

  • Name
  • Business address
  • Email address
  • Telephone number
  • Company name
  • Job title
  • Related contact details

Certain information may be mandatory to enable access to specific features or functionalities of the Service. Failure to provide required information may limit the use of certain Service features.

Technical and Usage Information

As Customer representatives navigate and use the Service, we may collect technical information such as:

  • Browser type
  • Browser language
  • Internet Protocol (IP) address
  • Usage activity within the Service environment

This information is collected to operate, secure, and improve the Service.

Information Uploaded by Customer Representatives

In certain instances, Customer representatives may upload or import personal data relating to other representatives of the same Customer organisation. Where such information is provided, CleverTap processes it solely for the specific purpose for which it was submitted and in accordance with the applicable customer agreement.

Purpose of Processing

Basis contractual necessity, the personal data of Customer representatives is processed to:

  • Administer customer accounts
  • Provide and support the Service
  • Manage billing and contractual obligations
  • Maintain audit and security logs
  • Resolve disputes
  • Troubleshoot technical issues
  • Enforce agreements
  • Comply with applicable legal requirements
  • Operate our business

If the Service includes integrations with third-party platforms or social media features, those third parties may independently collect information in accordance with their own privacy policies.

C. Customer End User Data (Processor Context)

When providing the Service to Customers, CleverTap processes personal data relating to Customer End Users solely on behalf of and under the documented instructions of the Customer.

Source and Control of Customer End-User Data

Customer End User data is submitted electronically by or on behalf of the Customer through configuration and use of the Service.

The Customer determines:

  • What categories of personal data are collected?
  • How such data is configured within the Service;
  • The purposes for which the data is processed; and
  • The lawful basis for such processing.

CleverTap does not independently determine the categories of Customer End User data collected, nor does it control the purposes for which it is processed.

Categories of Data Processed

Depending on how the Customer configures the Service, Customer End User data may include:

  • Identifiers;
  • Device information;
  • Behavioural event data
  • Technical metadata;
  • Application interaction data
  • Geolocation data where enabled by the Customer.

The specific data elements collected are determined entirely by the Customer’s implementation and configuration of the Service.

Scope of Processing

CleverTap processes Customer End User data strictly in accordance with the applicable customer agreement and Data Processing Addendum.

CleverTap does not use Customer End User data for its own independent marketing purposes, does not use such data for unrelated advertising or profiling activities, and does not independently monetise or commercialise such data.

CleverTap does not review, share, distribute, or otherwise access Customer End User data except as necessary to provide, secure, operate, and support the Service in accordance with the Customer’s documented instructions, to fulfil contractual obligations, or to comply with applicable legal requirements.

Relationship with Customer End Users

Customer End Users should review the privacy policy of the applicable Customer’s website or mobile application to understand how their personal data is collected and used.

CleverTap has no direct relationship with Customer End Users whose data is processed through the Service. Requests relating to Customer End User data should be directed to the applicable Customer.

Where a Customer can be reasonably identified based on the information provided, CleverTap will forward such requests and assist the Customer in accordance with contractual and legal obligations.

D. Personal Data Collected from Representatives of Vendors, Business Partners, and Other Businesses

CleverTap collects and processes personal data relating to representatives of vendors, service providers, business partners, and other organisations with which CleverTap has a current or prospective business relationship.

Categories of Personal Data

This may include:

  • Name
  • Business contact details (such as work email address and business telephone number)
  • Company affiliation and job title
  • Communication records exchanged in the course of business interactions

Sources of Personal Data

Such personal data is collected directly from the representatives themselves or obtained in the course of business communications, contractual discussions, networking activities, referrals, or publicly available business contact information.

Purpose of Processing

This personal data is processed for purposes related to:

  • Initiating, managing, and terminating business relationships
  • Contract administration and performance
  • Vendor and partner due diligence
  • Compliance with legal and regulatory obligations
  • Operational and administrative business activities

CleverTap processes this personal data in its capacity as a data controller and in accordance with applicable data protection laws.

E. Personal Data Collected from Job Candidates

Individuals may apply for employment opportunities with CleverTap through the careers section of our Site or through authorised recruitment channels. The recruitment platform used for application submissions is managed by Kula.AI or by other authorised recruitment service providers acting as service providers on behalf of CleverTap, subject to appropriate contractual data protection obligations.

Categories of Personal Data

Job candidates submit personal data directly through the recruitment platform or other authorised submission methods. This may include:

  • Full name
  • Email address
  • Telephone number
  • Resume or curriculum vitae
  • Employment history
  • Educational background
  • Professional qualifications
  • Expected compensation
  • Notice period
  • LinkedIn profile
  • Current location

Candidates may optionally provide additional information, such as current employer, professional portfolio links, social media profiles, cover letters, references, or other information voluntarily submitted as part of the application process.

Sources of Personal Data

Personal data relating to job candidates is collected directly from the candidate at the time of application or during subsequent recruitment communications. In limited circumstances, personal data may also be obtained from authorised third-party recruitment agencies, professional networking platforms, background verification providers (where applicable and legally permitted), or references provided by the candidate.

Purpose of Processing

Personal data collected from job candidates is processed for purposes related to recruitment and hiring, including:

  • Reviewing and evaluating applications;
  • Assessing qualifications and suitability for employment;
  • Communicating with candidates regarding employment opportunities;
  • Conducting interviews and selection processes;
  • Verifying qualifications and references where appropriate;
  • Complying with applicable employment, labour, and legal obligations; and
  • Maintaining records of recruitment activities for internal administrative and compliance purposes.

CleverTap processes this personal data in its capacity as a data controller. Where processing is based on consent, candidates may withdraw consent at any time; however, withdrawal may affect our ability to continue considering the application.

California Residents

For individuals who are California residents and who apply for employment or are employed by CleverTap, additional disclosures regarding the collection, use, retention, and rights relating to employment-related personal data are provided in CleverTap’s Workplace Privacy Notice for California Candidates and Employees. That notice supplements this Privacy Policy with respect to employment-related personal data where applicable.

5. Purposes of Processing

When acting as a data controller, CleverTap processes personal data for legitimate business purposes related to the operation and administration of its business and services.

This includes processing personal data to manage

  • Commercial relationships with Customers, vendors, and business partners;
  • Respond to inquiries;
  • provide product demonstrations;
  • Deliver customer support;
  • Administer contracts;
  • Manage billing and financial transactions;
  • Communicate regarding service-related matters.

Personal data is also processed to operate and improve our website and business operations, enhance website functionality and user experience, conduct lawful marketing activities in accordance with applicable law, and maintain internal administrative records.

CleverTap processes personal data to maintain the security, integrity, and availability of its systems and Services. This includes detecting fraud, preventing unauthorised access, investigating misuse of services, monitoring for security incidents, and protecting the rights, property, and safety of CleverTap, its Customers, and others.

We may also process personal data to comply with applicable legal and regulatory obligations, respond to lawful requests from authorities, enforce contractual agreements, resolve disputes, and protect our legal interests.

CleverTap does not carry out automated decision-making or profiling that produces legal or similarly significant effects on individuals in its capacity as a data controller.

Where Customers use automated segmentation, targeting, analytics, or engagement capabilities within the Service, such activities are determined, configured, and controlled solely by the Customer in their capacity as data controller.

6. Legal Bases for Processing

Where required under applicable data protection laws, including the GDPR and UK GDPR, CleverTap relies on one or more lawful bases for processing personal data in its capacity as a data controller.

These lawful bases may include:

  • Performance of a Contract, where processing is necessary to enter into, perform, or manage a contractual relationship with a Customer, vendor, partner, or job applicant.
  • Legitimate Interests, where processing is necessary for the operation of our business, management of commercial relationships, marketing in a business-to-business context, service improvement, fraud prevention, security monitoring, or enforcement of legal rights, provided that such interests are not overridden by the rights and freedoms of the individual. Where required, CleverTap conducts assessments to ensure that legitimate interests are balanced appropriately against individual rights.
  • Consent, where required by law, including for certain marketing communications, non-essential cookies, or other activities that require prior authorisation. Where processing is based on consent, individuals may withdraw consent at any time, and such withdrawal will not affect the lawfulness of processing carried out prior to withdrawal.
  • Compliance with Legal Obligations, where processing is necessary to comply with applicable laws, regulatory requirements, court orders, or lawful governmental requests.
  • When CleverTap acts as a data processor in relation to Customer End User data processed through the Service, the lawful basis for processing is determined by the relevant Customer in their capacity as data controller. CleverTap processes such data solely in accordance with the Customer’s documented instructions and the applicable Data Processing Addendum.

7. Sharing, Disclosure, and Subprocessors

A. When CleverTap Acts as a Data Controller

CleverTap does not sell personal data for monetary consideration.

Under certain U.S. state privacy laws, including the California Consumer Privacy Act as amended by the CPRA, some disclosures of personal data to advertising and analytics providers may be considered “sharing” for purposes of cross-context behavioural advertising. CleverTap does not knowingly sell personal data. Where advertising-related disclosures may qualify as sharing under applicable law, individuals may exercise their right to opt out through our cookie preference centre or by enabling Global Privacy Control (GPC) signals, as described in this Privacy Policy.

In its capacity as a data controller, CleverTap may disclose personal data to trusted third-party service providers that support the operation of our business and delivery of our services. These service providers may assist with cloud hosting and infrastructure, analytics, customer relationship management systems, marketing automation platforms, recruitment processing, communication tools, payment processing, professional advisory services, security monitoring, and regulatory compliance. Such service providers are contractually required to process personal data only on documented instructions and to maintain appropriate confidentiality and security safeguards.

CleverTap does not authorise third parties to use personal data for their own independent marketing purposes unless a valid legal basis exists and, where required, appropriate consent has been obtained.

B. When CleverTap Acts as a Data Processor

In its capacity as a data processor for Customer End User data, CleverTap engages sub-processors in accordance with the applicable Customer agreement and Data Processing Addendum. Sub-processors are subject to contractual obligations designed to ensure appropriate data protection standards. A current list of sub-processors engaged in connection with the Service is available through our Trust Portal.

C. Corporate Transactions and Legal Requirements

When CleverTap Acts as a Data Controller

Personal data may be disclosed in connection with a merger, acquisition, financing, reorganisation, sale of assets, or similar corporate transaction. In such circumstances, personal data will remain subject to applicable confidentiality obligations and data protection safeguards.

CleverTap may also disclose personal data where required to comply with applicable law, regulation, legal process, court order, or lawful governmental request, or where necessary to protect the rights, property, or safety of CleverTap or others, enforce contractual agreements, or investigate fraud or security incidents.

When CleverTap Acts as a Data Processor

Where CleverTap processes Customer End User data on behalf of a Customer, any disclosure of such data in connection with a corporate transaction or legal requirement will occur only as permitted or required under the applicable Customer agreement, Data Processing Addendum, and applicable law.

CleverTap does not independently determine the disclosure of Customer End User data and will comply with contractual and legal obligations governing such processing.

8. Cookies and Tracking Technologies

CleverTap uses cookies and similar technologies on its website to operate and secure the Site, analyse usage patterns, enhance functionality, and support lawful advertising and analytics activities.

Cookies are small text files stored on a user’s device that enable the website to recognize browsers, understand how users interact with the Site, maintain session integrity, and improve overall performance and user experience. Similar technologies may include pixels, tags, scripts, or other tracking mechanisms used for analytics and advertising measurement.

Certain cookies are strictly necessary for the operation and security of the Site and do not require consent under applicable law. Other cookies, including analytics, functional, and advertising cookies, may require user consent depending on the jurisdiction.

In the European Union and the United Kingdom, non-essential cookies are deployed only after prior consent is obtained through our cookie management platform. Users may withdraw or modify their consent preferences at any time through the cookie settings interface available on the Site.

In the United States and other jurisdictions where applicable law requires opt-out mechanisms, CleverTap provides controls, including “Do Not Sell or Share” options, where advertising-related disclosures may qualify as sharing under applicable state privacy laws. CleverTap also recognises and honours Global Privacy Control (GPC) signals as described in this Privacy Policy. Additional information for U.S. state residents is provided in Section 16.

Detailed information regarding specific cookies, third-party providers, purposes of use, and retention periods is available in our Cookie Policy.

9. Data Retention

CleverTap applies data retention practices in accordance with its role as either a Data Controller or a Data Processor.

A. When CleverTap Acts as a Data Controller

When CleverTap processes personal data in its capacity as a Data Controller, personal data is retained only for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.

Retention periods are determined based on the nature of the personal data, the purposes for which it was collected and processed, contractual obligations, statutory limitation periods, regulatory requirements, dispute resolution needs, and legitimate business interests. Personal data may be retained for the duration of an active business relationship and for a reasonable period thereafter to comply with legal, accounting, or reporting obligations, enforce agreements, or resolve disputes.

Once personal data is no longer required for lawful purposes, it is securely deleted, anonymised, or irreversibly de-identified in accordance with CleverTap’s internal data lifecycle management and security practices.

B. When CleverTap Acts as a Data Processor

When CleverTap processes Customer End User data on behalf of a Customer, retention and deletion are governed by the applicable Customer agreement and Data Processing Addendum.

Upon termination or expiration of a Customer contract, Customer End User data is deleted from active production systems within the timeframe specified in the applicable agreement. Where no specific contractual retention period is defined, deletion is performed through automated system processes within a maximum period of sixty (60) days following termination of the Service.

Customers may request earlier deletion or agree to alternative retention timelines in writing in accordance with the applicable agreement. Any variation from the standard deletion process is handled through documented and authorised procedures consistent with contractual obligations and applicable law.

Following deletion from active systems, limited encrypted copies of Customer End User data may temporarily remain within secure backup or disaster recovery systems as part of standard security safeguards. Such backup data is logically isolated from active processing environments and is automatically overwritten in accordance with established retention schedules.

10. Data Residency and International Transfers

CleverTap applies data residency and international transfer safeguards in accordance with its role as either a Data Processor or a Data Controller.

A. When CleverTap Acts as a Data Processor (Customer End User Data)

Data Residency

When CleverTap processes Customer End User data on behalf of a Customer, such data is hosted in the production region selected by the Customer at the time of account configuration.

CleverTap operates a multi-region cloud infrastructure and does not transfer Customer End User data between hosting regions by default. Data remains in the selected region unless a Customer requests migration in accordance with contractual procedures.

Cross-Region Access for Support and Security

Although Customer End User data is hosted in the selected region, authorised CleverTap personnel may access such data remotely where necessary to provide support, troubleshoot technical issues, maintain system integrity, or respond to security incidents.

Such access is limited to authorised personnel with a defined business need, is protected through role-based access controls and multi-factor authentication, and is logged and monitored. Remote access does not change the underlying hosting location of the data.

International Transfers

Where CleverTap processes Customer End User data on behalf of a Customer, any international transfer or remote access is conducted in accordance with the applicable Customer agreement and Data Processing Addendum.

Where required under applicable data protection laws, CleverTap relies on appropriate transfer mechanisms, including participation in the EU–U.S. Data Privacy Framework (where applicable) or the incorporation of Standard Contractual Clauses, and other lawful safeguards, to ensure that transferred data receives a level of protection consistent with applicable legal requirements.

CleverTap does not independently determine the transfer of Customer End User data and processes such data strictly in accordance with the Customer’s documented instructions.

B. When CleverTap Acts as a Data Controller

When CleverTap processes personal data in its capacity as a Data Controller, personal data may be transferred to countries outside the individual’s jurisdiction, including to the United States, India, Singapore, or other locations where CleverTap or its service providers operate.

Where such international transfers occur, CleverTap relies on appropriate legal safeguards consistent with applicable data protection laws, including:

  • Certification under the EU–U.S. Data Privacy Framework (EU–U.S. DPF)
  • The UK Extension to the EU–U.S. DPF
  • The Swiss–U.S. Data Privacy Framework
  • The 2021 European Commission Standard Contractual Clauses, where applicable
  • The UK International Data Transfer Addendum
  • Other lawful transfer mechanisms recognised under applicable legislation

C. EU–U.S. Data Privacy Framework Participation (Applicable in Both Contexts)

CleverTap complies with the EU–U.S. Data Privacy Framework (EU–U.S. DPF), the UK Extension to the EU–U.S. DPF, and the Swiss–U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce in both its capacity as a Data Controller and, where applicable, as a Data Processor.

CleverTap has certified to the U.S. Department of Commerce that it adheres to the DPF Principles. In the event of any conflict between the terms of this Privacy Policy and the DPF Principles, the DPF Principles shall govern.

CleverTap is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Individuals whose personal data is covered by the DPF may have the right to seek independent recourse and, under certain conditions, invoke binding arbitration as described in CleverTap’s separate EU–U.S. Data Privacy Framework Policy.

11. Security and Data Protection Measures

CleverTap implements technical and organizational measures designed to protect personal data against unauthorized access, alteration, disclosure, loss, or destruction. Security safeguards are applied in accordance with CleverTap’s role as either a Data Controller or a Data Processor.

A. When CleverTap Acts as a Data Processor

CleverTap implements and maintains appropriate technical and organisational security measures in accordance with applicable Customer agreements and the Data Processing Addendum.

These measures include encryption of data in transit and at rest, role-based access controls, least-privilege access principles, multi-factor authentication for administrative and production systems, logging and monitoring of system activity, secure infrastructure management practices, vulnerability management processes, and formal incident detection and response procedures.

Access to Customer End User data within the production Service environment is primarily controlled by the Customer through account-level administration and role-based permissions within the dashboard.

CleverTap personnel do not have routine access to production Customer End User data. Where access is necessary for troubleshooting, incident response, security investigation, or compliance purposes, such access is granted only through documented approval procedures. Access is limited to the specific scope required to resolve the issue, is restricted to authorised personnel with a defined business need, and is protected by role-based controls, multi-factor authentication, logging, and monitoring.

Engineering personnel may have role-based access to non-production or staging environments for development and testing purposes. Production infrastructure changes are governed by controlled deployment processes designed to prevent unauthorised or direct modification of live production environments.

Elevated access to production systems is restricted, auditable, and subject to internal review procedures consistent with the principle of least privilege.

In the event of a personal data breach affecting Customer End User data processed in CleverTap’s capacity as a Data Processor, CleverTap will notify the relevant Customer without undue delay in accordance with contractual commitments and applicable law. The Customer remains responsible for assessing and fulfilling any regulatory notification obligations to supervisory authorities and data subjects, unless otherwise agreed in writing.

B. When CleverTap Acts as a Data Controller

When processing personal data in its capacity as a Data Controller, CleverTap applies appropriate technical and organisational safeguards to protect such data.

These measures include encryption, access controls, monitoring, secure infrastructure management, and formal incident response procedures consistent with industry standards and applicable regulatory requirements.

Where required under applicable law, CleverTap conducts data protection impact assessments or equivalent risk assessments for processing activities likely to result in high risk to the rights and freedoms of individuals.

In the event of a personal data breach affecting personal data processed in CleverTap’s capacity as a Data Controller, CleverTap will notify relevant supervisory authorities and affected individuals in accordance with applicable legal requirements.

C. Additional Security Transparency

Further information regarding CleverTap’s security controls, certifications, audit reports, and compliance programs is available through CleverTap’s Trust Portal at: https://trust.clevertap.com/

12. Your Privacy Rights

CleverTap respects the rights of individuals under applicable data protection and privacy laws. The rights available to you depend on your location and on whether CleverTap acts as a Data Controller or a Data Processor in relation to your personal data.

A. Rights When CleverTap Acts as a Data Controller

Where CleverTap determines the purposes and means of processing personal data, individuals may have the following rights, subject to applicable law:

Right of Access

You may request confirmation of whether we process personal data about you and access to that data, including the purposes of processing, the categories of data involved, and the categories of recipients.

Right to Rectification

You may request the correction of inaccurate personal data and the completion of incomplete personal data.

Right to Erasure

You may request deletion of personal data where permitted by law. This right is subject to lawful retention obligations, contractual requirements, and statutory exemptions.

Right to Restrict Processing

You may request restriction of processing in circumstances permitted under applicable law, such as where you contest the accuracy of the data or object to processing.

Right to Object

You may object to processing based on legitimate interests, including processing for direct marketing purposes.

Right to Data Portability

Where applicable, you may request the receipt of your personal data in a structured, commonly used, and machine-readable format, and its transmission to another controller where technically feasible.

Right to Withdraw Consent

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

Rights Under U.S. State Privacy Laws

Under certain U.S. state privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CPRA), you may have the right to:

  • Request disclosure of personal information collected, used, disclosed, or shared;
  • Request deletion or correction of personal information;
  • Opt out of the sale or sharing of personal information for cross-context behavioural advertising;
  • Not be discriminated against for exercising your privacy rights.

California residents may designate an authorised agent to submit requests on their behalf, subject to verification requirements.

Additional disclosures required under applicable U.S. state privacy laws are provided in Section 16 (Additional U.S. State Privacy Disclosures) below.

Rights Under the Digital Personal Data Protection Act, 2023 (India)

Where applicable, individuals may have the right to seek grievance redressal in relation to the processing of personal data and to withdraw consent where processing is based on consent.

If you are located in India and have a grievance relating to our processing of your personal data as a Data Controller, you may contact our Grievance Officer / Data Protection Officer at privacy@clevertap.com with the subject line “India DPDP Grievance”. We will acknowledge and respond to such grievances within the timelines prescribed under applicable law.

Submitting a Rights Request

Requests may be submitted to privacy@clevertap.com.

We may request information necessary to verify your identity before responding to a request. CleverTap will respond within the timeframes required under applicable law.

Where permitted by law, we may decline requests that are manifestly unfounded, excessive, repetitive, or otherwise not required to be fulfilled. Where a request is denied, we will provide an explanation where required and inform you of any available appeal rights.

CleverTap will not discriminate against individuals for exercising their privacy rights.

B. When CleverTap Acts as a Data Processor

Where CleverTap processes personal data solely on behalf of a Customer through the Service, CleverTap acts as a Data Processor or Service Provider.

In this context:

  • The Customer determines the purposes and means of processing.
  • The Customer is responsible for responding to data subject rights requests.
  • CleverTap processes data only in accordance with the applicable customer agreement and Data Processing Addendum.

If you are a Customer End User and wish to exercise your rights regarding personal data processed through the Service, you should contact the applicable Customer directly.

If CleverTap receives a request directly and the relevant Customer can be reasonably identified, CleverTap will forward the request to the Customer and assist the Customer in accordance with contractual and legal obligations. CleverTap does not independently determine responses to such requests unless required by law.

C. Right to Lodge a Complaint or Seek Regulatory Redress

Where applicable, individuals have the right to lodge a complaint with their local supervisory authority or data protection regulator if they believe their personal data has been processed unlawfully.

Under applicable law, including the Digital Personal Data Protection Act, 2023 (India), individuals may have the right to escalate unresolved grievances to the competent regulatory authority if a satisfactory resolution is not achieved.

CleverTap encourages individuals to contact us first at privacy@clevertap.com so that we may address concerns directly.

Customer End Users should direct requests to the relevant Customer.

13. Links to Third-Party Websites

Our Site and Service may contain links to websites, applications, or services operated by third parties. These links are provided for convenience and informational purposes only.

CleverTap does not own, operate, or control such third-party websites or services and is not responsible for their content, security practices, or privacy practices. Any personal data you provide to third-party websites or services is governed by the privacy policies and terms of those third parties, not by this Privacy Policy.

We encourage you to review the privacy policies and practices of any third-party websites or services before providing personal data or engaging with them.

The inclusion of a link to a third-party website does not constitute endorsement, approval, or affiliation unless expressly stated.

14. CleverTap Demonstration Applications

CleverTap develops and maintains certain demonstration applications to illustrate the capabilities and functionality of its platform. These applications are developed and managed by the CT Device Platforms Team, which operates within CleverTap and is responsible for their development and maintenance.

The following demonstration applications are currently maintained:

  • CT Sample (com.clevertap.demo), which provides a sample implementation that showcases core platform features and capabilities.
  • CleverTap Demo App (com.clevertap.ct_mart), which demonstrates selected functionality of the CleverTap customer engagement platform.

These applications are intended solely for demonstration, training, evaluation, and illustrative purposes. They are not intended for live production deployment or operational use with Customer production data unless expressly authorised under a separate written agreement.

Any personal data processed within these demonstration applications is used solely for demonstration, testing, validation, or internal evaluation. CleverTap does not use personal data collected through demonstration applications for independent marketing, advertising, profiling, monetisation, or other unrelated commercial purposes.

All CleverTap demonstration applications are governed by this Privacy Policy unless otherwise expressly stated. Where such applications are distributed through third-party platforms or app stores, those platforms may independently collect information in accordance with their own privacy policies and terms, for which CleverTap is not responsible.

CleverTap may modify, restrict, suspend, or discontinue demonstration applications at its discretion.

15. Children’s Privacy

CleverTap’s website and Services are intended for business use and are not directed to children.

CleverTap does not knowingly collect personal data directly from children through our Site in our capacity as a Data Controller. For purposes of this section, “child” means a person under the age defined by applicable law in the relevant jurisdiction (for example, under 13 in the United States for COPPA purposes; 13–16 in the European Economic Area and the United Kingdom depending on the applicable country rules; and under 18 in India under the Digital Personal Data Protection Act, 2023).

If we become aware that personal data has been provided to us directly by a child without appropriate authorisation, we will take reasonable steps to delete such information.

In connection with the CleverTap Service, Customers determine whether they collect or process personal data relating to children through their own websites or mobile applications. CleverTap processes Customer End User data solely on behalf of Customers and in accordance with their documented instructions.

Customers are responsible for complying with applicable laws relating to children’s data (including providing appropriate notices and obtaining any required parental/guardian consent), where they choose to collect or process such data through their own websites or applications. Such laws may include, where applicable, the U.S. Children’s Online Privacy Protection Act (COPPA), Article 8 of the GDPR and UK GDPR, the Digital Personal Data Protection Act, 2023 (India), and other applicable local legislation.

If you believe that a child has provided personal data directly to CleverTap through our Site, please contact us at privacy@clevertap.com so that we may take appropriate action.

16. Additional U.S. State Privacy Disclosures (Including California)

This section provides additional disclosures for residents of certain U.S. states, including California, and applies to personal information that CleverTap processes as a data controller (for example, information collected through our Site and business-to-business communications). It does not apply to Customer End User data processed by CleverTap as a data processor/service provider through the Service.

A. Categories of Personal Information We Collect (Controller Context)

Depending on your interactions with us, we may collect the following categories of personal information:

  • Identifiers (such as name, work email address, business telephone number, company name, online identifiers, IP address).
  • Internet or other electronic network activity information (such as pages viewed, links clicked, browser type, device information, referring URLs, timestamps, and similar usage data).
  • Professional or employment-related information (such as job title, employer, and business contact details).
  • Inferences drawn from the above information to understand business interests and improve our communications and Site experience.
  • Job applicant information (such as resume/CV, employment history, education, and recruitment communications), where applicable.

We do not intentionally collect Sensitive Personal Information (as defined under California law) through our Site for the purpose of inferring characteristics about you. If we incidentally receive sensitive information (for example, if you include it in free-text communications), we use it only as necessary to respond to you, for security, and to comply with law.

B. Purposes for Collection and Use

We collect and use personal information for the purposes described in Section 5 (Purposes of Processing), including operating and securing our Site, communicating with business contacts, providing customer support, managing commercial relationships, conducting marketing in accordance with applicable law, and complying with legal obligations.

C. Categories of Third Parties to Whom We Disclose Personal Information

In the last 12 months, we may have disclosed the categories of personal information described above to the following categories of recipients for business purposes:

  • Cloud hosting and infrastructure providers
  • Analytics providers
  • Customer relationship management (CRM) and communication tools
  • Marketing and event platforms
  • Recruitment service providers (for job candidates)
  • Professional advisers (such as legal, audit, and compliance advisers)
  • Security and fraud prevention providers
  • Payment and billing providers (where applicable)

D. “Sale” / “Sharing” of Personal Information; Targeted Advertising

CleverTap does not sell personal information for monetary consideration.

We may permit certain third-party advertising and analytics technologies on our Site that could be considered “sharing” of personal information for cross-context behavioural advertising under some U.S. state privacy laws. Where required, you may opt out of such sharing through our cookie preference centre and any “Do Not Sell or Share My Personal Information” mechanism made available on the Site. We also recognise Global Privacy Control (GPC) signals where required by law.

E. Your Rights (Controller Context)

Subject to applicable law, you may have the right to:

  • Know/Access: request information about the personal information we collected about you, including categories, sources, purposes, and disclosures.
  • Delete: request deletion of personal information, subject to legal exceptions.
  • Correct: request correction of inaccurate personal information.
  • Opt out: opt out of the sale or sharing of personal information and of targeted advertising where applicable.
  • Non-discrimination: not be discriminated against for exercising your rights.
  • Appeal (certain states): appeal a decision regarding your request, where required.

How to submit a request: email us at privacy@clevertap.com. We will verify your request and respond within the timeframes required by law. You may also use an authorised agent where permitted; we may require proof of authorisation and verification of your identity.

F. Retention (Controller Context)

We retain personal information for the periods described in Section 9, based on the purpose for which it was collected, the nature of the information, the duration of our relationship, and legal, accounting, security, and dispute-resolution requirements.

17. Changes to This Privacy Policy

CleverTap may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal or regulatory requirements, or business operations.

When we make changes, we will revise the “Last Updated” date at the top of this Privacy Policy. The updated version will be published on our website and will become effective as of the date indicated.

Where required by applicable law and changes materially affect how we process personal data in our capacity as a Data Controller, we may provide additional notice through appropriate channels, including website notices or direct communication.

Continued use of our Site or Services after the effective date of the updated Privacy Policy constitutes acknowledgement of the revised terms, to the extent permitted by applicable law.

This Privacy Policy does not modify or amend any contractual terms agreed between CleverTap and its Customers, including any applicable Data Processing Addendum. In the event of a conflict between this Privacy Policy and a Customer agreement, the Customer agreement shall govern with respect to Customer End User data processed in a Data Processor capacity.