Privacy Policy

Updated: 23 June 2023 - Version number: 1.7

This Website (the “Website”) is the property of Clepher (“Clepher” ). Clepher is a sub-brand of Marketing Released B.V. (“MR”). MR is registered at the Chamber of Commerce in The Netherlands under number 62865668. This is the Privacy Policy of Clepher (“Clepher,” “We,” “Us” or “Our”). Our Privacy Policy explains how We collect, use, share and protect information in relation to Our mobile services, Our website, and any software provided on or in connection with Clepher services (collectively, the “Service”), and Your choices about the collection and use of your Personal Data. By using the Service, You understand and agree to the collection and use of information in accordance with this Privacy Policy.

We will NEVER sell your personal data to anyone.

Clepher enables the visitors of its site,, to be in control of their personal data. We also provide controls that allow Clepher’s Customers and its End Users to have control over the privacy of personal data that is captured by Our Service. This Privacy Policy provides information about how Clepher processes and protects this data.

At Clepher we consider the privacy of our visitors, and the security of their personal information, to be extremely important. This Privacy Policy document describes, in detail, the types of personal information we collect and record at, and how we use this information. We consider data protection and privacy to be of the utmost importance. We never sell personal data and we carry out all processing operations in strict compliance with the EU General Data Protection Regulation (“GDPR”).

If you are a Subscriber of a Chatbot which is created by Our Customer(s), and utilize running services, provided by Our Customer(s) (“Clepher Enabled Chatbot”), the ‘End Users’ section of this Privacy Policy applies to you.

For the purpose of this Privacy Policy, personal data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (the “Personal Data”).

What kind of Personal Data is processed and for what purpose?

Some data will be collected automatically by Our Site. Other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out below, for example, when signing up for an Account. Depending upon your use of Our Site and Our Service, We may collect some or all of the following data:

Personal Data
While using our service, we ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Address, State, Province, ZIP/Postal code, City
  • Usage Data and Cookies

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Usage Data
When you visit our website we store the name of your internet service provider, the website from which you visited us from, the parts of our site you visit, the date and duration of your visit, and information from the device (device type, operating system, screen resolution, language, country you are located in, and web browser type) you used during your visit. We capture and store your IP address. We process this usage data to facilitate your access to our services (e.g. to adjust our services to the device you are using), and to recognize and stop any misuse. We also process usage data in an anonymized form for statistical purposes and to improve our site.

Clepher uses cookies to process information including standard internet log information and details of the visitor’s behavioral patterns upon visiting our site. This is done to provide you with a better experience and to facilitate the use of certain functions. Cookies are small data files transferred onto computers or devices by sites for record-keeping purposes and to enhance functionality on our site. Clepher stores this information in a pseudonymized user profile. Clepher does not process this information to identify individual users or to match it with further data on an individual user. Cookies are stored on your individual device and you have full control over their use. You may deactivate or restrict the transmission of cookies by changing the settings of your web browser. Cookies that are already stored may be deleted at any time. Should you visit Clepher’s site with cookies deactivated, you may possibly not be able to use all of the functions on our site to the full extent. For more info about the cookies we make use of, see our Cookie Policy.

Contact with us via email
On our site you have the opportunity to contact us to ask us questions, for example via the contact form, we ask you for your contact information (e.g. name, email address etc.). We use this data solely in connection with answering the queries we receive. If you receive emails from us, we may use certain analytics tools, to capture data such as when you open our email or click on any links or banners our email contains. This data helps us to gauge the effectiveness of our communications and marketing campaigns.

Clepher Account
When you sign up for (and open) an account with Clepher, or sign up for content or offers, we may ask you to provide us with information such as your name, email address and details about your organization. As otherwise detailed in this Privacy Policy, we will solely process this information to provide you with the service you signed up for. Please refer to our Terms of Service for further details on registering and using the services offered by Clepher. You may deactivate your Clepher account and/or unsubscribe from receiving content or offers from us at any time. Following termination of your account, we may retain your personal data (in part or in whole) in order to meet any regulatory and reporting requirements for the timeframes stipulated by law and in order to be able to address customer service issues. Any other Personal Data we would have been processing on your behalf would be deleted permanently within 30 calendar days. We collect several different types of information for various purposes to provide and improve our service to you.

For what purpose is the data collected?

Clepher uses the collected data for various purposes:

  • To provide and maintain our service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

How do we protect your information?

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. We are committed to protecting your personal information against unauthorized use or disclosure.

Duration of Processing

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Data from the third-party services Clepher integrates with is retained until Our Customer(s) wishes to remove that data, or until their account is removed. Clepher will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Access and Disclosure to Third Parties

We use a select number of trusted external service providers for certain technical data analysis, processing and/or storage offerings. These service providers are carefully selected and meet high data protection and security standards. We only share information with them that is required for the services offered and we contractually bind them to keep any information we share with them as confidential and to process Personal Data only according to our instructions. We will only pass your data on to third parties without your express consent if we are obliged to do so by statutory law or an instruction by a public authority or court as outlined in our Terms of Service.

If Clepher is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy. Under certain circumstances, Clepher may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Clepher may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Clepher
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Third-party applications, websites and services

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. We are not responsible for the practices employed by any applications, websites or services linked to or from Our Service, including the information or content contained within them. Please remember that when You use a link to go from Our Service to another application, website or service, Our Privacy Policy does not apply to those third-party applications, websites or services. Your browsing and interaction on any third-party application, website or service, including those that have a link on Our Services, are subject to that third party’s own rules and policies.

However, We employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how Our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.


We use third-party Service Providers to monitor and analyze the use of our Service.

  • Google Analytics 
    • Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
  • Facebook Ads Conversion Tracking
    • Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Website.
  • Facebook Analytics for Apps
    • Facebook Analytics for Apps is an analytics service provided by Facebook, Inc.
  • Pingdom
    • Pingdom is a monitoring service provided by Pingdom AB.

Behavioral Remarketing

We use remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

  • Google AdWords Remarketing (Google Inc.)
    • AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of this Website with the Adwords advertising network and the Doubleclick Cookie.
  • Facebook Custom Audience (Facebook, Inc.)
    • Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.
  • Facebook Remarketing (Facebook, Inc.)
    • Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of Clepher with the Facebook advertising network – Opt Out.

Hosting and backend infrastructure


We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

  • Stripe
    • Stripe is a payment service provided by Stripe Inc.
  • PayPal 
    • PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

Content Commenting

Commenting tools we use

  • Disqus
    • Disqus is a content commenting service provided by Big Heads Labs Inc.
  • Facebook Comments
    • Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User to leave comments and share them on the Facebook platform.

Interaction and customer support

Support tools we use

  • Messenger
    • The Messenger Customer Chat is a service for interacting with the Messenger live chat platform provided by Facebook, Inc.
  • Jira
    • Jira Service DEsk is a support and contact request management service provided by Freshworks, Inc.

User database management

User management tools we use

  • ActiveCampaign
    • ActiveCampaign is a service to send out email messages.
  • SendGrid
    • SendGrid is a service to send out email messages.
  • ElasticEmail
    • ElasticEmail is a service to send out email messages.

Facebook Permissions & Handeling

Clepher may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows Clepher to connect with the User's account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

  • Facebook account access (Clepher)
    • This service allows Clepher to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
    • Facebook permissions asked by Clepher
      • Basic information;
      • Business Management API;
      • Insights;
      • Manage Mailbox;
      • Messenger API;
  • Facebook Authentication (Facebook, Inc.)
    • Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connect to the Facebook social network.


Other tools we use

  • PayKickstart
    • PayKickstart is a checkout system to handle payments and affiliate tracking.
  • UpViral
    • UpViral allows to create marketing campaigns such as giveaways and contests
  • Gravatar
    • Gravatar is an image visualization service provided by Automattic Inc. that allows this Website to incorporate content of this kind on its pages.
  • Vimeo
    • Vimeo is a video content visualization service provided by Vimeo, LLC that allows this Website to incorporate content of this kind on its pages.
  • CloudFlare
    • CloudFlare is a traffic optimization and distribution service provided by CloudFlare Inc. The way CloudFlare is integrated means that it filters all the traffic through this Website, i.e., communication between this Website and the User's browser, while also allowing analytical data from this Website to be collected.
  • Facebook Social Widgets
    • The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
  • Google+ Social Widgets
    • The Google+ +1 button and social widgets are services allowing interaction with the Google+ social network provided by Google Inc.
  • Twitter Social Widgets
    • The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.
  • LinkedIn Social Widgets
    • The LinkedIn share button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn.

    We want to Communicate with You

    We may occasionally send you notification emails about updates to our product, legal documents, offer customer support or marketing emails. Except for cases where we are required to do so by law (e.g. notifying you of a data breach), you shall have the opportunity to unsubscribe from receiving these messages free of charge.

    Your Data, Your Rights

    You have a right to be informed of Personal Data processed by Clepher, a right to rectification/correction, erasure and restriction of processing. You also have the right to receive from Clepher a structured, common and machine-readable format of Personal Data you provided to us. Moreover, You can access the My Data section (coming soon - please send your request to [email protected] for now) section to see, modify and/or delete your Personal Data. Note, we can only identify you with your email address and we can only adhere to your request and provide information if we have Personal Data about you through you having made contact with Us directly and/or you using our site and/or service. We cannot provide, rectify or delete any data that we store on behalf of our users or customers.

    To exercise any of the rights mentioned in this Privacy Policy and/or in the event of questions or comments relating to the use of Personal Data you may contact Clepher’s support team: [email protected].

    Where you have provided consent, you may withdraw it at any time, without affecting the lawfulness of the processing that was carried out prior to withdrawing it. Whenever you withdraw consent, you acknowledge and accept that this may have a negative influence on the quality of the Clepher Site and/or Services. You further agree that Clepher shall not be held liable with respect to any loss and/or damage to your Personal Data if you choose to withdraw consent.

    Where Personal Data is processed for the above purposes on the basis of Clepher’s legitimate interests, under the GDPR, you may object to such processing at any time. To do so please contact: [email protected]. In addition, you have the right to lodge a complaint with the data protection authority in your jurisdiction.

    Children’s privacy

    Our Service does not address anyone under the age of 13 (“Children”). We do not knowingly collect personally identifiable information from children under 13. If You are a parent or guardian and You are aware that Your Children has provided Us with personal information, please contact Us. If We become aware that We have collected personal information from a child under age 13 without verification of parental consent, We take steps to remove that information from Our servers.

    Changes to this privacy policy

    We may modify or update Our Privacy Policy from time to time. We may revise this Privacy Policy from time to time. The most current version of this Privacy Policy will govern our practices for collecting, processing, and disclosing personal data. We will provide notice of any modifications by posting a written notice on our site. If you have an account with us, we will notify you of any material modifications by sending you an email to the email address associated with your account unless you have unsubscribed from all email communications. Your use of the site and/or Services following the effective date of any modifications to the Privacy Policy will constitute your acceptance of the Privacy Policy, as modified. All changes to this Privacy Policy automatically take effect on the sooner of the day you use the site and/or services, or 30 calendar days after they are initially posted on our site. Your use of the site and/or services following the effective date of any modifications to this Privacy Policy will constitute your acceptance of the Privacy Policy, as modified.

    End Users

    If you are an End User (Subscriber) of a Chatbot created with Clepher, this section applies to you.

    This section should always be read in conjunction with the specific Privacy Policy of Our Customer(s), the creator(s) of a Clepher Enabled Chatbot which will contain further details regarding the processing of your Personal Data by Our Customer(s). Clepher is a service that allows its customers to build Chatbots for Messenger. To get a detailed understanding about what Clepher is We suggest navigating to Our public Knowledge Base.

    Clepher has no direct relationship with the End Users whose Personal Data is processed by Our Service. An End User who seeks access, or who seeks to correct, amend, or delete Personal Data from Chatbots provided by Our Customer(s), the creator(s) of a Clepher Enabled Chatbot, should direct their request to Our Customer (which in this case is the Data Controller, the person or organisation who created the Chatbot you as End User subscribed/opted-in to). As Data Processor, We at Clepher, aim to provide Our Customer(s) (the Data Controller/s) with the best tools to make your Personal Data manageable.

    Governing Law and Dispute Resolution

    This Privacy Policy forms an integral part of Our Terms & Conditions. The Governing Law and Dispute Resolution mechanism found in Our Terms & Conditions shall also apply to Our Privacy Policy.

    How to contact Us

    If you have any questions, any concern, about this Privacy Policy of the Service, please send an email containing a detailed description of Your concerns. Clepher will do its best to resolve such issues within a reasonable time frame. Please Contact Us, or send mail to;

    Contact Information:

    Attention: Clepher
    Marketing Released B.V.
    Pauwenkamp, 3607GK 
    Maarssen, The Netherlands
    [email protected]