Last updated: October 5, 2026
Scope of this policy
This Privacy Policy explains how Clearlinks, Inc. ("Clearlinks", "we", "us") collects and processes personal information across our marketing websites, sales activities, and the Clearlinks platform.
When we process student education records, employee records, or other personal data on behalf of a school, district, or other customer, we do so as a service provider under that customer's instructions. The customer's own privacy notice governs the relationship with data subjects in that context; this policy explains our role.
What we collect
From visitors to our marketing sites
- Information you submit through forms (name, email, organization, role);
Our marketing sites do not use analytics or advertising cookies.
From customers using the platform
- Account information (work email, name, role, organization);
- Authentication and audit metadata (login events, IP, user agent);
- A sign-in cookie that keeps you logged in to the platform;
- Content you submit for processing ("Customer Content"), which may contain personal information depending on the materials.
How we use information
We process personal information to:
- Provide, maintain, and improve the Services;
- Communicate with you about your account, support requests, and product updates;
- Detect and prevent fraud, abuse, and security incidents;
- Comply with legal obligations.
We do not use Customer Content to train any AI model — ours or any third party's. We do not sell personal information.
Retention and deletion
Customer Content is retained for the duration of the customer's subscription and for any additional period set out in the Order Form or DPA. A deleted document moves to Recently deleted, where a workspace owner or administrator can restore it for 30 days. When that window closes, the document and its files are queued for permanent removal from our database and storage. An upload removed before its file arrived is deleted at once, with nothing to restore. Account metadata may be retained longer where required for tax, accounting, or compliance purposes.
International data transfers
Clearlinks stores data in the United States and processes it there, with one exception: the OCR and layout model we run on Modal's GPUs. Modal chooses the region for that work, and it may be outside the United States. If you use the Services from outside the United States, your information is transferred to and processed in the United States. Where we transfer personal information across borders, we rely on Standard Contractual Clauses.
Your rights
Depending on your location, you may have rights to access, correct, delete, or restrict the use of your personal information, or to object to certain processing. To exercise these rights, contact privacy@clearlinks.org.
If you submitted personal information through your school, district, or employer, please contact them first; we will support their response to your request.
Student data (FERPA, COPPA)
When we process student education records on behalf of a school under FERPA, we act as a "school official" with a legitimate educational interest under § 99.31(a)(1). We use student personal information only for the purposes authorized by the school.
For services directed to children under 13, we operate as a processor for the school and rely on the school for parental notice and consent as permitted under COPPA. We do not direct marketing to children and do not condition participation in any activity on disclosing more information than is reasonably necessary.
Security
We use administrative, technical, and physical safeguards designed to protect personal information. See our security page for details on our certifications and engineering practices.
Contact us
Questions about this policy? Email privacy@clearlinks.org or write to Clearlinks, Inc., 71 Roundtree Drive, Plainview, NY 11803.
