Privacy Notice
Last updated: 15.07.2025
Version: 1.01
This Privacy Notice (“Notice”) describes how we collect and process your data through
Clearie: AI Phone Cleaner available at PLINK LABS LIMITED(together, the “App”). The terms “we”, “us”, “our” and “ourselves” refer to . Clearie focuses on reclaiming storage and organizing your device with key features like duplicate photo detection, video compression, contact merging, and large-file cleanup.
We are committed to safeguarding the privacy of our users. We are not going to misuse
your data.
Who is a data controller for your data?
PLINK LABS LIMITED
Registered address: 11 Kimberley Lofts, Kimberley Road, London, United Kingdom,
NW6 7SL
Contact email address: support@plink.gg
Information we collect from you and purposes of processing
User content
We will process certain data on your device that you provide when interacting with our
App.
This data includes materials, files, documents, images, photos, videos, visual and
audio records, voice recording, graphics, media, choices, contact list and any content,
input, record or data that you provide, upload, transmit, create, store, use, edit or share with or through the App.
We may ask for your permission to access your device’s photo file or gallery app or your
preferred cloud services in order to provide our services, when you are using the App,
such as to generate output for photos you share (e.g., determining similar photos in
your gallery). You can choose not to allow us to access your contact application
(thereby the full contact list) photo file or gallery app or cloud services by either rejecting our access or later disabling such access in your mobile device settings. However, you may not be able to use essential features of our services if you choose to opt out.
Please note that we do not store any of your contact list, photos and videos (or images,
materials, files, documents, visual records, graphics, media) on our servers; activities to process these will be carried out on your device or your own cloud services only.
The legal basis for processing this data is Article 6(1)(b) of the GDPR – the processing is necessary for the performance of a contract, specifically to provide core App functionalities such as duplicate photo detection, video compression, contact merging,
large-file cleanup, and reclaiming device storage.
The legal basis for processing this data is Art. 6.1(a) of the GDPR – consent.
Technical data
We may process technical data and device metadata such as your location (IP address),
browser type, device information, operating system. We do so:
● to ensure the App functionality and performance across devices;
● to diagnose and fix bugs or crashes;
● to maintain device compatibility and optimize performance.
The lawful bases for processing this data is:
● Art. 6.1(f) of the GDPR - legitimate interest in improving and maintaining the App;
and
● Art. 6.1(b) of the GDPR - fulfilling our contractual obligations.
Automatically collected and usage data
We may collect information about your activities in the App, including analytics, IP
address, scripts, web browser, pages visited, time spent within the App, clickstream data for the following purposes:
● To understand how users interact with the App (e.g., screen views, session
duration);
● To improve user experience and identify areas for product improvement;
● To analyze overall App performance and stability.
The lawful basis for processing this data is Art. 6.1(f) of the GDPR - legitimate interest in improving and maintaining the App.
Advertising & tracking
We collect behavioral data and ad identifiers to enable third-party analytics and
advertising SDKs to track user behavior across sessions and to evaluate marketing
performance and user engagement.
The lawful bases for processing this data is:
● Art. 6.1(f) of the GDPR - legitimate interest in improving and maintaining the App;
and
● Art. 6.1(a) of the GDPR - consent.
Marketing data
We may collect and process your behavioral data, App interaction and preferences to
evaluate marketing performance and user engagement.
The legal basis for processing this data is Art. 6.1(a) of the GDPR – consent.
Communication and customer support
We may receive your information when you leave a request for support in the App, or
when you inquire about our services. We will use the information given by you to provide you with the help you might need, fix and improve the App, and analyse our efficiency in product efforts. Additionally, we may process other communications between us and you, for example, your inquiries regarding the services.
The applied legal basis for this is the performance of the contract between you and us
(GDPR Art. 6.1.b) and our legitimate interest in improving the App (GDPR Art. 6.1.f).
Sources of personal data
We obtain personal data mostly from you and your device.
Retention of your information
We will store your information for as long as you have an active account with us. We will delete or anonymise most of your information after 24 months of inactivity.
● Technical data & usage data: 24 months.
● Tracking data: 13 months
● Crash logs & device metadata: 13 months
● Marketing data: 13 months
However, we may need to retain some of your personal data for longer if there is a need for it, for example, in order to comply with our tax, accounting and legal requirements. In this case, the applied legal basis for the processing of your information will be the necessity to comply with a legal obligation. We may also retain aggregated and anonymized data indefinitely.
Third-party access to information
Your personal information may be shared with the following third parties:
● Support / communication tools such as Freshdesk
● Cloud storage (hosting) providers such as AWS, Google Cloud, Firebase,
DigitalOcean
● Data analytics providers such as Google Cloud, Appsflyer, Firebase, Crashlytics,
Amplitude, Tableau, Pappertrail
● Marketing partners such as Facebook, Google, TikTok
● Communication service providers such as Apple
The providers listed above process your information based on our instructions only.
In case your personal data is provided to third parties outside the EEA, we will implement appropriate safeguards to protect your personal data, including Standard Contractual Clauses as adopted by the European Commission. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Other disclosures
In addition to the disclosures for the purposes identified before, we may disclose
information about you for the following purposes:
● law enforcement, legal process and compliance: if we are required to do so by
law, in connection with any legal proceedings or to establish, exercise or defend
our legal rights, or in the good-faith belief that such action is necessary to comply
with applicable laws, in response to a facially valid court order, judicial or other
government subpoena or warrant, or to otherwise cooperate with law enforcement
or other governmental agencies. We also reserve the right to disclose personal
data or other information that we believe, in good faith, is appropriate or necessary
to: (i) take precautions against liability; (ii) protect ourselves or others from
fraudulent, abusive, or unlawful uses or activity; (iii) investigate and defend
ourselves against any third-party claims or allegations; (iv) protect the security or
integrity of our services and any facilities or equipment used to make our services
available; or (v) protect our property or other legal rights, enforce our contracts, or
protect the rights, property, or safety of others;
● change of ownership or other business needs: (i) in case we sell, licence or
otherwise assign our company, corporate rights, the App or their separate parts or
features to third parties; (ii) as part of a transaction, financing, or for other business
needs (e.g., if we need to disclose your personal data to the prospective lender or
bank, investor or prospective investor, and/or their professional advisers as part of
certain due diligence processes, as the case may be); (iii) we may also disclose
and otherwise transfer your personal data to an acquirer, successor or assignee as
part of any merger, acquisition, debt financing, sale of assets, or similar transaction
as well as in the event of an insolvency, bankruptcy, or receivership in which
information is transferred to one or more third parties as one of our business assets
and only if the recipient of the information commits to a privacy policy that has
terms substantially consistent with this Notice.
Your rights
You may exercise GDPR rights regarding your personal data. In particular, you have the
right to:
● The right to access your information.
You have the right to know what personal data we process. As such you can obtain
the disclosure of the personal data involved in the processing and you can obtain a
copy of the information undergoing processing.
● The right to verify your information and seek its rectification.
If you find that we process inaccurate or out-of-date information, you can verify the
accuracy of your information and/or ask for it to be updated or corrected;
● The right to have your personal data deleted.
If we are not under the obligation to keep your personal data for legal compliance and
it is not needed in the scope of an active contract or claim, we will remove your
information upon your request. You are able to delete your personal data and user
account by navigating to the profile section and select the “Delete Account” option.
● The right to restrict the processing of your information.
When you contest the accuracy of your information, believe we process it unlawfully
or want to object to the processing, you have the right to temporarily stop the
processing of your information to check if the processing was consistent. In this case,
we will stop processing your personal data (other than storing it) until we are able to
provide you with evidence of its lawful processing.
● The right to have your personal data transferred to another organisation.
Where we process your personal data on the legal basis of consent you provided us
or on the necessity to perform a contract, we can make, at your request, your
personal data available to you or to an organisation of your choosing.
● The right to object against the processing of your information.
If we process your information for our legitimate interests (e.g., for direct marketing
emails or for our marketing research purposes), you can object to it. Let us know what
you object against and we will consider your request. If there are no compelling
interests for us to refuse to perform your request, we will stop the processing for such
purposes. If we believe our compelling interests outweigh your right to privacy, we will
clarify this to you.
You can formulate such requests or channel further questions on data protection by
contacting us directly at support@plink.gg.
If you believe that our use of personal information violates your rights, or if you are
dissatisfied with a response you received to a request you formulated to us, you have the right to lodge a complaint with the competent data protection authority of your choice.
Children data
Our App may be used by children aged 4 and older. We are committed to protecting the
privacy of children and ensuring compliance with applicable data protection laws,
including the General Data Protection Regulation (GDPR) and the Children’s Online
Privacy Protection Act (COPPA), where applicable.
Where required, we rely on parental consent as the legal basis for processing children's
data.
Security of information
We will take all necessary measures to protect your information from unauthorised or
accidental access, destruction, modification, blocking, copying, and distribution, as well
as from other illegal actions of third parties. As we use the services of third-party software providers across several countries outside of the European Union, we may transfer the collected information to those countries for further processing. In such cases, we will make sure that relevant safeguards are in place. More information on such safeguards can be provided upon request.
We also make sure that access to your information stored in our database is only possible via a secure and closed VPN connection. Additionally, all communications exposed to the internet are TLS encrypted to provide the highest level of communications security.
Changes to this Notice
We may update this Notice from time to time by posting a new version on our App. We
advise you to check this page occasionally to ensure you are happy with any changes.
However, we will endeavour to provide you with an announcement about any significant changes.
CCPA Privacy Notice
This CCPA Privacy Notice supplements our main Privacy Notice and applies specifically
to residents of California. It provides additional information regarding your privacy rights under the California Consumer Privacy Act (CCPA). Please read this notice alongside our main Privacy Notice for complete details on our data collection, use, and sharing practices
Your privacy rights
As a California resident, you may have the following rights under the CCPA, as amended by the California Privacy Rights Act (CPRA):
● Right to know (access)
You have the right to request the specific pieces of personal information we have
collected about you in the past 12 months. This may include:
o the categories of personal data we have collected;
o the specific pieces of personal data we have collected;
o the categories of sources from which the personal data was collected;
o the business or commercial purpose for collecting or selling personal data;
o the categories of third parties with whom we share your data.
To request access to your data, please refer to the instructions below on how to submit
your request.
● Right to deletion
You have the right to request that we delete the personal information we have collected
from you, subject to certain exceptions. For example, we may not be required to delete
your information if:
o it is necessary to complete a transaction, provide a service, or fulfill the contract between us;
o it is required for compliance with legal obligations;
o it is used for security purposes, fraud detection, or debugging.
To submit a deletion request, please follow the instructions below.
● Right to correct inaccurate information
You have the right to request that we correct inaccurate personal information that we hold about you. If you believe that your personal data is incorrect, you may request that we correct it.
● Right to opt-out of the sale of personal information
We do not sell your personal information to third parties. However, if we begin selling
personal data in the future, we will update this notice and provide you with the right to opt-out of the sale of your personal information.
You may exercise your right to opt-out at any time by following the instructions provided below.
● Right to limit use and disclosure of sensitive personal information
Under certain circumstances, you may request that we limit the use and disclosure of your sensitive personal information. Sensitive personal information may include data such as social security numbers, financial account information, and certain types of health-related data.
● Right to non-discrimination
We will not discriminate against you for exercising any of your rights under US privacy
laws. This means that if you request access, deletion, correction, or any other action
related to your rights, we will not:
o deny you goods or services;
o charge you different prices or rates for services;
o provide you with a different level or quality of services.
● Right to data portability
You have the right to request a copy of your personal data in a structured, commonly used and machine-readable format so you can transfer it to another service provider.
How to exercise your rights
You may exercise your rights under the CCPA by submitting a request to us at
To verify your identity, we may ask for personal information to confirm that you are the
individual to whom the personal data relates. We may also ask for additional information depending on the type of request. Please note that we may not be able to fulfill your request if we are unable to verify your identity.
Categories of personal information we collect
For a comprehensive list of the types of personal information we collect, please refer to
Section “Information processed by us and purposes of processing” of the main Privacy Notice.
Data sharing and disclosure
We may disclose your personal information to third parties in accordance with applicable US privacy laws. For more information on how we share your data, please refer to Section “Third-party access to information” of the main Privacy Notice.
We do not sell your personal information, but we may share it for business purposes such as analytics or advertising.
Contact information
If you have any questions about this CCPA Privacy Notice or wish to exercise your rights, please contact us at support@plink.gg.