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PRIVACY POLICY

Data Controller

The data controller responsible for the processing of personal data through clear-first.com is: SOLENYA S.à r.l.-s · 4, rue d’Arlon · L-8399 Windhof · Luxembourg · RCS Luxembourg: B 298352 · VAT number: LU36806954 · Email: office@clear-first.com

Personal Data We Process

When you use the contact form, we process the information you provide, including: • your name; • your email address; • the content of your message. Technical information required to operate and secure the website may also be processed, such as IP address, device and browser information, access times and requested pages.

Purposes and Legal Basis

Personal data submitted through the contact form is processed to: • respond to your enquiry; • assess a potential professional engagement; • manage subsequent communications; • protect the website against misuse and security threats. The legal basis is Article 6(1)(b) GDPR where processing is necessary to take steps before entering into a contract, and Article 6(1)(f) GDPR for our legitimate interest in responding to enquiries, operating the website securely and managing professional communications.

Service Providers

We use selected service providers to operate the website and communications, including: • Framer B.V. for website hosting, form processing and website infrastructure; • Namecheap Private Email for professional email services. These providers process personal data only as necessary to provide their respective services and in accordance with their contractual and legal obligations.

International Data Transfers

Where personal data is processed outside the European Economic Area, appropriate safeguards are used where required, including contractual protections recognised under applicable data-protection law.

Retention

Contact enquiries and related correspondence are retained only for as long as necessary to respond to the enquiry and manage any resulting professional relationship. Where no engagement follows, the information will generally be deleted within 24 months after the last relevant communication, unless a longer period is required to establish, exercise or defend legal claims or to comply with legal obligations.

Your Rights

Subject to the conditions of applicable law, you may request: • access to your personal data; • correction of inaccurate data; • deletion of your data; • restriction of processing; • data portability; • objection to processing based on legitimate interests. Requests may be sent to office@clear-first.com. You also have the right to lodge a complaint with the Luxembourg National Commission for Data Protection: Commission nationale pour la protection des données · www.cnpd.public.lu

Cookies and Analytics

This website does not intentionally use advertising or behavioural-marketing cookies. Framer may process limited technical and aggregated usage information required for website delivery, security and performance measurement. If additional analytics, marketing or tracking technologies are introduced, this Privacy Policy and any required consent mechanism will be updated.

Security

Reasonable technical and organisational measures are used to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.

Changes to This Policy

This Privacy Policy may be updated when the website, its services or applicable legal requirements change. The current version will always be available on this page.

Last updated: 16 September 2026

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