PRIVACY POLICY

Russell International Consulting (trading as ClearLightAI)

Effective Date: November 3, 2025

Last Updated: November 3, 2025

Russell International Consulting, trading as ClearLightAI ("we," "our," or "us"), is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI automation and consulting services through our website at clearlightai.com (the "Service").

By using our Service, you consent to the data practices described in this Privacy Policy. If you do not agree with the practices described in this Privacy Policy, please do not use our Service.

When you authorize our Service to access your Google services through OAuth authentication, we may collect and access:

• Files and documents from your Google Drive
• Email content and metadata from Gmail
• Contact information from Google Contacts
• Usage analytics and activity data from Google Analytics
• Other information from Google Cloud Services as authorized by you

We may also collect:

• Account information when you register for our services
• Communication records when you contact us
• Usage data about how you interact with our Service
• Technical information such as IP address, browser type, and device information

We use the information we collect to:

• Provide AI automation, content generation, and consulting services
• Analyze and process your data using artificial intelligence tools and models
• Create automated workflows and systems based on your data
• Generate content and insights from your information
• Improve our services and develop new features
• Communicate with you about our services
• Comply with legal obligations and protect our rights

We store your data securely using Supabase, a cloud-based database service. Your information is stored in a vector database format to enable AI processing and analysis. We retain your data until you terminate our services or request deletion, whichever occurs first.

All data is encrypted in transit and at rest using industry-standard security measures. We implement appropriate technical and organizational safeguards to protect your information against unauthorized access, alteration, disclosure, or destruction.

We may share your information with the following third-party services to provide our AI services:

• OpenAI API: We may process your data using OpenAI's artificial intelligence models to provide content generation and analysis services
• Supabase: Our database hosting provider where your data is securely stored
• Google Services: When authorized by you, we access your Google services as described in Section 2.1

We only share the minimum amount of data necessary to provide our services, and all third-party providers are contractually bound to protect your information and use it only for the purposes we specify.

Depending on your location, you may have the following rights regarding your personal information:

• Access: Request access to your personal information
• Correction: Request correction of inaccurate personal information
• Deletion: Request deletion of your personal information
• Portability: Request a copy of your data in a structured format
• Restriction: Request restriction of processing under certain circumstances
• Objection: Object to processing based on legitimate interests
• Withdraw consent: Withdraw consent for processing where we rely on consent

Our operations are based in Indonesia, and we may transfer your data to countries outside your jurisdiction for processing. When we transfer personal data from the European Economic Area (EEA) or other regions with data protection laws, we ensure appropriate safeguards are in place to protect your information in accordance with applicable law.

If you are a resident of the European Union, we process your personal data in accordance with the General Data Protection Regulation (GDPR). Our lawful basis for processing includes:

• Consent: When you provide explicit consent for specific processing activities
• Contract: When processing is necessary to perform our contract with you
• Legitimate interests: When we have legitimate business interests that are not overridden by your rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to delete personal information, and the right to opt-out of the sale of personal information. We do not sell your personal information.

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

Our Service is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us.

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. Your continued use of the Service after any changes constitutes acceptance of the updated Privacy Policy.

If you have any questions about this Privacy Policy or our data practices, please contact us:

Russell International Consulting (trading as ClearLightAI)

Email: privacy@clearlightai.com

Website: https://clearlightai.com

Location: Bali, Indonesia

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