GDPR
GDPR and EU/EEA information
Who is responsible for your personal data, what we process and why, how long we keep it, where it goes, how to use your rights, and the terms that apply to customers in the EU and EEA.
Start readingKlarstig holds no GDPR certification and does not offer EU data hosting. This page states what we actually do.
Anyone can make a privacy request through the contact form or by post. We answer within one month.
The regional addendum below is the same text that forms part of the Terms of Service.
01Who we are
Klarstig is operated by Daniel Petry, a sole proprietor operating as Klarstig, 11917 Laurel Ave., Forestville, CA 95436, United States. Klarstig has no establishment in the European Union or the European Economic Area. The GDPR can apply to us because we offer the service to people and organisations in the EU and EEA.
No data protection officer has been appointed, because our processing does not require one; Daniel Petry is personally responsible for privacy matters. Klarstig does not hold any GDPR certification or seal, and this page is not a statement that every use of the service is compliant.
02Controller and processor roles
Who decides about your data depends on how it reaches Klarstig.
| Situation | Klarstig’s role | Who to contact first |
|---|---|---|
| Your Klarstig account, subscription, billing, nonprofit verification, enquiries, website and security | Controller | Klarstig |
| Forms, submissions, files, workflows and signature requests that a customer creates or collects with Klarstig | Processor for that customer under the Data Processing Agreement | The customer that sent you the form or document; we forward requests and assist |
| Website usage statistics after you accept analytics | Controller | Klarstig |
03Personal data we process
Depending on the features used: account and workspace details (name, email, hashed password, language, organisation and role); service content and the personal data in it; activity and audit records including IP addresses; subscription and billing identifiers from Stripe (never card details); nonprofit verification details; enquiries and privacy requests; prompts and outputs of AI features you start; technical and bot-protection signals; and, only with consent, usage statistics.
We do not buy personal data or enrich it from other sources, and we do not ask for special categories of data for our own purposes. The Privacy Notice lists each category with its source.
04Purposes and legal bases
For processing we control, we rely on these legal bases under Article 6 GDPR. Processing as a processor follows the customer’s documented instructions.
| Purpose | Legal basis |
|---|---|
| Providing accounts and the features you use, including transactional emails | Contract (Art. 6(1)(b)) |
| Subscriptions and payments through Stripe; nonprofit pricing verification | Contract (Art. 6(1)(b)) |
| Tax and accounting records | Legal obligation (Art. 6(1)(c)) where applicable law requires it; otherwise legitimate interests (Art. 6(1)(f)) |
| Security, rate limiting, bot protection, audit logs and fraud prevention | Legitimate interests (Art. 6(1)(f)); for account holders also contract |
| Answering enquiries and rights requests; legal claims | Legitimate interests (Art. 6(1)(f)); legal obligation for statutory rights requests |
| Website assistant and click-to-play videos | Legitimate interests (Art. 6(1)(f)) |
| Google Analytics and first-party usage statistics | Consent (Art. 6(1)(a)); off until you accept |
05Retention and deletion
The periods below are our retention schedule. Automatic deletion at the end of each period is being put in place and is not yet active; until then, records are deleted when you or the customer delete them in the app, or on request. Erasure requests are never delayed by these periods.
| Record | Retention |
|---|---|
| Active account and workspace content | While the account is active or until the customer deletes it |
| Deleted submissions and files; closed accounts | 30-day recovery period, then deleted |
| Expired trial workspaces not upgraded | 30 days after the trial ends |
| Audit and security logs | 12 months |
| Integration and webhook delivery logs | 90 days |
| Website assistant conversations | 30 days |
| In-app AI assistant threads | 90 days after last activity |
| Enquiries and support messages | 12 months after the last message |
| Billing and tax records | 7 years |
| Consent and agreement-acceptance records | Duration of the relationship plus the applicable limitation period |
| Data export download links | Expire after 24 hours |
06Your rights and how to make a request
You can ask for access and a copy, correction, erasure, restriction and a portable copy of data you provided. You can object to processing based on legitimate interests and withdraw consent at any time, without affecting earlier processing. Klarstig makes no decisions based solely on automated processing with legal or similarly significant effects.
Make a request through the contact form (topic “Privacy & data rights”) or by post to the address above. You do not need an account. We ask only for what is needed to confirm your identity or authority, and requests are free. We reply within one month; for complex or numerous requests we may extend by up to two further months and will tell you why within the first month. If a customer controls the data, we forward your request to it and help it respond.
07Privacy contact and complaints
Privacy contact: the contact form with the topic “Privacy & data rights”, or post to Daniel Petry, Klarstig, 11917 Laurel Ave., Forestville, CA 95436, United States.
You may complain to the data protection supervisory authority of the EU or EEA country where you live, work or where the issue occurred. You do not need to contact us first. In the United Kingdom, the authority is the Information Commissioner’s Office.
08Subprocessors and processing locations
Klarstig and its providers process data in the United States. EU/EEA-only data residency is not offered.
| Provider | Purpose | Location |
|---|---|---|
| Abacus.AI | Application hosting, database, transactional email and AI model access | United States |
| Amazon Web Services (S3, us-west-2) | Storage of uploaded files, signed documents and exports | United States |
| Stripe | Payments and subscription billing | United States and other countries |
| Cloudflare Turnstile (our own Cloudflare account) | Bot protection on sign-up, password reset, contact and public forms | Global network, United States |
| Cloudflare network edge (part of the hosting service; role being confirmed with Abacus.AI) | Delivery and protection of website traffic | Global network |
| Google (YouTube privacy-enhanced mode) | Product videos, only when you press play | United States |
| Google Analytics | Website statistics, only after consent | United States |
09International transfers and safeguards
Transfers of personal data from the EEA to the United States rely on the safeguards below. We state only the mechanisms we have confirmed.
- Amazon Web Services and Stripe: certified under the EU–US Data Privacy Framework and its UK and Swiss extensions, and their published data processing terms incorporate the European Commission’s Standard Contractual Clauses.
- Google: certified under the EU–US Data Privacy Framework and its UK and Swiss extensions.
- Cloudflare Turnstile (our own Cloudflare account): we are confirming that Cloudflare’s published customer data processing terms cover our account and which transfer mechanism applies. No mechanism is claimed until it is confirmed.
- Cloudflare network edge (part of the hosting service): its safeguards are being confirmed with Abacus.AI, together with the Abacus.AI mechanism below.
- Abacus.AI: the transfer mechanism applicable to our account is being confirmed and will be stated here.
- Klarstig itself is not certified under the Data Privacy Framework. For customers that use Klarstig as a processor, our Data Processing Agreement incorporates the Standard Contractual Clauses by reference once a workspace owner accepts it in the app.
10EU representative
Klarstig has not appointed a representative in the European Union under Article 27 GDPR. If one is appointed, the name and contact details will be listed here. Until then, please use the privacy contact above; your rights are not affected.
11EU/EEA Customer Terms (regional addendum)
EU/EEA Customer Addendum, version 1.0. This addendum forms part of the Terms of Service. It applies to consumers habitually resident in, and organisational customers established in, a Member State of the European Union or the European Economic Area. Where it conflicts with the rest of the Terms for those customers, this addendum prevails. Mandatory law always prevails over both.
- A.1 Consumer or organisation. You are a consumer if you use Klarstig for purposes outside your trade, business, craft or profession, for example for personal or household matters. You are an organisational customer if you use it for a business, nonprofit, public body or professional activity. Your status depends on that purpose and on where you live or are established. The language you choose, the language version of a page, the currency shown or the location of our servers never determines your status or the law that protects you.
- A.2 Information before you buy. Before you pay, checkout shows the plan, the total price including any taxes that apply, the billing interval, the fact that the subscription renews automatically and how to cancel. Annual plans are charged as one payment of the total due for the year. We confirm each purchase by email, and you can save or print these terms at any time.
- A.3 Contract language. You can conclude the contract in English, French or Spanish. All three versions have the same content and the same clause numbering; none of them limits the rights you have under the law that applies to you.
- A.4 Consumer right of withdrawal. Consumers may withdraw from a paid contract concluded online within 14 days of its conclusion without giving a reason, using the online withdrawal function, any other clear statement, or the model form in the Terms. We refund all payments for that contract within 14 days of receiving the withdrawal, by the original payment method and without fees. If you expressly asked for the service to start during the withdrawal period, you pay only a proportionate amount for the service provided until you withdrew.
- A.5 Conformity of the service (consumers). We are responsible for any lack of conformity of the digital service that occurs or becomes apparent during the contract, and for a continuous service we bear the burden of proving conformity during that time. You may require the service to be brought into conformity free of charge within a reasonable time. If that is impossible, disproportionate, refused or not done within a reasonable time, or the lack of conformity is serious, you may obtain a proportionate price reduction or end the contract and receive a refund of the price for the period in which the service was not in conformity.
- A.6 Changes to the service (consumers). We change the service beyond what is needed to keep it in conformity only for valid reasons such as security, legal requirements, technical developments or improvements, at no extra cost to you, and with clear notice in advance. If a change negatively affects your access to or use of the service more than in a minor way, you may end the contract free of charge within 30 days of the notice or of the change, whichever is later, and receive a pro-rata refund of prepaid fees for the remaining period.
- A.7 Renewal, price changes and cancellation (consumers). Subscriptions renew for the same period until cancelled. You can cancel at any time, effective at the end of the period already paid for: in the app under Billing, through the contact form or by post. A price change applies only from a renewal that starts at least 30 days after we notify you, and you may cancel before it takes effect. Cancelling never requires more effort than subscribing.
- A.8 Refunds (consumers). Beyond the refunds under A.4 to A.6, you keep any right to a refund or price reduction that the law of your country of residence gives you. Refunds are paid through Stripe to the original payment method. Any additional voluntary refund policy we publish adds to these rights and never reduces them.
- A.9 Liability (consumers). The liability limit for organisational customers in the Terms does not apply to consumers. We are liable to consumers in accordance with the mandatory law of their country of residence.
- A.10 Applicable law and courts (consumers). The choice of California law does not deprive you of the protection of the mandatory provisions of the law of the country where you habitually reside. You may bring proceedings in the courts of your country of residence, and we may bring proceedings against you only there. Please contact us first with any complaint. We do not take part in proceedings before a consumer dispute resolution body. The European Commission’s online dispute resolution platform has been closed, so no link to it is given.
- A.11 Organisational customers. The statutory consumer withdrawal right does not apply to organisational customers. The liability terms for organisations in the Terms apply, subject to mandatory law. Where Klarstig processes personal data for you as your processor, the Data Processing Agreement applies once a workspace owner accepts it in the app settings; it contains the Article 28 GDPR terms and incorporates the European Commission’s Standard Contractual Clauses by reference for transfers to the United States.
- A.12 Switching and data export (EU Data Act). You can export your data at any time and ask to switch to another provider or to your own systems. The notice period is at most two months, the transition period is 30 days (extendable up to 7 months in total where technically necessary), and we charge no switching or data-egress fees, as set out in the Terms.
- A.13 Personal data. The Privacy Notice and the GDPR page explain how personal data is handled, your rights and how to complain to a supervisory authority. Klarstig is established only in the United States and has not appointed a representative in the EU under Article 27 GDPR.
12Related documents
The full Terms of Service, Privacy Notice, Cookie Notice and withdrawal function are available in the language you are reading. The current Data Processing Agreement can be read by anyone on its public reference page. Workspace owners accept it, and download their accepted copy, in the app settings.
