ClearNote Labs

Privacy Policy

Last updated: 17 October 2026

1. Scope

This policy explains how ClearNote Labs handles personal data on the website clearnotelabs.com. It applies to this website only.

Our products have their own privacy policies: PitchHighway (https://pitchhighway.com/privacy), PupilBot (https://pupilbot.com/privacy) and Voice Kata (https://voicekata.com/privacy).

2. Who is responsible

The controller of personal data for this website is Gabriel Policiuc, a natural person based in Romania, who uses the trade name ClearNote Labs, trading as ClearNote Labs.

Address: Strada Nicolae Oblu 18, Iași, Romania.

Email for privacy questions: privacy@clearnotelabs.com.

3. Summary

This website has no forms, no user accounts, no analytics, and no advertising or tracking scripts. It sets no cookies of its own.

You can read every page without giving us any personal data.

We process personal data in two cases only: our web server records technical access logs when you load a page, and we receive the messages you send us by email.

4. Server access logs

When your browser requests a page, our web server records: your IP address, the date and time, the requested address, the HTTP status, the amount of data sent, the referring page and your browser's user agent.

Purpose: to keep the website secure and working, and to find faults and attacks.

Legal basis: our legitimate interest in a secure and working website (Article 6(1)(f) GDPR).

Retention: the server deletes these logs automatically after 15 days at most. We do not combine them with other data, and we do not use them to build profiles of visitors.

5. Email

If you write to us, we receive your email address, your name if you give it, the content of your message and any attachments.

Purpose: to answer you and, if you ask, to prepare and carry out an engagement.

Legal basis: steps that you ask for before a contract, and the performance of a contract (Article 6(1)(b) GDPR). For other messages, our legitimate interest in answering correspondence (Article 6(1)(f) GDPR). If a conversation leads to a contract, we keep invoices and related records for as long as Romanian tax and accounting law requires (Article 6(1)(c) GDPR).

Retention: we keep other correspondence only as long as we need it to answer you or to continue a conversation that you started. Then we delete it.

Please do not send us sensitive data, such as health data, by email.

6. Service providers

These providers process data for us, under data processing terms:

  • Hetzner Online GmbH (Germany) hosts our web server and its access logs in a data center in Finland.
  • Cloudflare, Inc. (United States) delivers and protects the website traffic, and forwards email sent to clearnotelabs.com addresses.

Google (Gmail) stores the email that Cloudflare forwards to us.

7. Transfers outside the European Economic Area

Cloudflare can process data, such as your IP address, in the United States and in other countries. These transfers rely on the EU-US Data Privacy Framework adequacy decision (Article 45 GDPR) and on Standard Contractual Clauses (Article 46 GDPR).

Google can process the email that you send us in the United States. These transfers rely on the EU-US Data Privacy Framework adequacy decision (Article 45 GDPR).

8. Cookies

This website sets no cookies of its own and uses no analytics or tracking.

If Cloudflare must check that a request comes from a person and not from an automated program, it can set a short-lived security cookie. This cookie is strictly necessary to protect the website and is not used for tracking.

9. Your rights

Under the GDPR, you have these rights about your personal data:

  • access: get a copy of the data we hold about you (Article 15);
  • rectification: correct data that is wrong (Article 16);
  • erasure: ask us to delete your data (Article 17);
  • restriction: ask us to limit how we use your data (Article 18);
  • portability: get the data you gave us in a common machine-readable format (Article 20);
  • objection: object to processing based on our legitimate interest (Article 21).

Right to object: you can object at any time to processing based on our legitimate interest (sections 4 and 5). We then stop that processing, unless we have compelling legitimate grounds or need the data for legal claims.

To use a right, write to privacy@clearnotelabs.com. We answer within one month, as the GDPR requires. We can ask for information to confirm your identity first.

10. Complaints

You have the right to complain to a data protection supervisory authority. In Romania, this is the Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP), B-dul G-ral. Gheorghe Magheru nr. 28-30, Sector 1, București, Romania, https://www.dataprotection.ro.

You can also complain to the authority in the EU country where you live or work. We ask you to contact us first, so that we can try to solve the problem.

11. Other information

You do not have to give us personal data. If you do not write to us, we cannot answer you.

We do not make decisions about you by automated means, and we do not sell personal data.

12. Changes to this policy

We update this policy when our processing changes. The date at the top of this page shows the current version.