Ce document est disponible pour l'instant en anglais. La version de référence est la version italienne.
Clarity Privacy Policy
Last updated: 2026-10-21
This policy explains how we process personal data when you use Clarity by Whooho (the clarity.whooho.it website, the dashboard, the API, the MCP server and the connectors for AI assistants), under Regulation (EU) 2016/679 ("GDPR") and Italian Legislative Decree 196/2003. The Italian version is the reference text.
1. Data controller
Alessandro Terracciano, trading as Whooho Digital Experience
Registered office: Via Caruso 21, 80040 Cercola (NA), Italia
Email: info@whooho.it
For any privacy request write to info@whooho.it.
2. Data we process
| Category | Examples | Source |
|---|---|---|
| Account data | name, email, password (stored only as a hash), language, role | provided by you at sign-up |
| Brand and analysis data | brand name and website, competitors, topics, prompts, AI model answers, cited sources, scores, site audits | provided by you or generated by the service |
| Team data | email addresses of people you invite | provided by you |
| Payment data | billing details, subscription and top-up history | processed by Stripe; we never see or store full card details |
| API and connector usage | API keys (stored only as a cryptographic hash), authorised OAuth connections, calls made, credits, costs | generated by your use of the service |
| Content of API/connector requests | questions, brands, competitors and website addresses you send to the tools | sent by you or by your AI assistant |
| Contact messages | name, email, company, website, message | sent through the contact form |
| Technical and security data | IP address, date and time, browser type, sign-in events and failed attempts | generated automatically |
We do not intentionally process special categories of data (Art. 9 GDPR). Do not put third parties' personal data or confidential information in prompts and questions: they are sent to AI models as a normal user would.
3. Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Creating and managing the account, providing analyses, audits, API and connectors | performance of a contract (Art. 6.1.b) |
| Payments, invoicing, tax and accounting obligations | legal obligation (Art. 6.1.c) and contract |
| Security, abuse and fraud prevention, usage limits | legitimate interest (Art. 6.1.f) |
| Service emails (welcome, invitations, payment and account notices) | performance of a contract |
| Answering contact form messages | pre-contractual measures / your consent |
| Aggregated statistics and service improvement | legitimate interest, aggregated data only |
We do not sell your data and do not use it for targeted advertising.
4. How AI analyses work
To measure a brand's visibility, Clarity sends prompts and questions to AI model providers (see section 5) using Clarity's keys or, for BYOK accounts, the customer's own keys. Answers are stored in your account to show trends over time. Website audits only read public pages, like a search engine.
5. Recipients
Only the providers needed to deliver the service, appointed as processors (Art. 28 GDPR) or acting as independent controllers for their own services:
| Provider | Service | Location |
|---|---|---|
| Hetzner Online GmbH | servers and database | Germany (EU) |
| Stripe Payments Europe Ltd. | payments, invoices, fraud prevention | EU (with possible transfers to Stripe, Inc., USA) |
| OpenAI, Google (Gemini) and, when enabled, Anthropic, Perplexity, xAI | processing of prompts and questions by AI models | USA and other countries |
| Whooho email server | service emails | EU |
Transfers outside the European Economic Area rely on adequacy decisions (e.g. the EU-US Data Privacy Framework) or the European Commission's Standard Contractual Clauses. With connectors, the AI assistant you choose (e.g. Claude or ChatGPT) receives the tools' results under its own privacy policy.
Team members you invite can see the data of the brands they have access to. We may disclose data to authorities when required by law.
6. Retention
| Data | Retention |
|---|---|
| Account, brands, analyses | while the account is active; deleted within 30 days of closure, except billing data |
| Invoices and accounting records, including API credits | 10 years (legal obligation) |
| Security and access logs | up to 12 months |
| Contact form messages | up to 24 months |
| Backups | up to 90 days, then overwritten |
7. Security
Servers in the European Union, encrypted connections (HTTPS), passwords and API keys stored only as cryptographic hashes, short-lived access tokens, role-based permissions, abuse limits, protection against requests to internal networks, regular backups. No system is 100% secure: in case of a data breach we will notify you where and when required by law.
8. Cookies and similar technologies
Clarity uses technical cookies only, which are necessary for the service: the sign-in session, request protection and your language. Your browser also stores a few local preferences (e.g. dismissed guides, a discount code you entered). We do not use profiling cookies or third-party analytics, so no consent banner is needed. The corporate website whooho.it has its own cookie policy.
9. Your rights
You can ask at any time for access, rectification, erasure, restriction, portability, and object to processing based on legitimate interest (Arts. 15-22 GDPR). You can withdraw consent at any time without affecting prior processing. Write to info@whooho.it: we reply within 30 days.
You can revoke API keys and disconnect connectors yourself from the dashboard (API & connectors), and close your account by writing to us.
You have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali, www.garanteprivacy.it) or the authority of your country.
10. Minors
Clarity is a professional service for adults only. We do not knowingly collect data of people under 18.
11. Changes
We may update this policy. We will notify significant changes by email or in the dashboard. The date at the top shows the version in force.