Privacy Policy

Cluvi AI is a software-as-a-service platform for restaurants. Through the Cluvi AI web application at cluvi.ai (and, where available, the Cluvi AI mobile app) a restaurant's authorized staff can manage guest conversations in one inbox across WhatsApp and other connected channels, run an AI receptionist that answers guests and takes reservation requests, and send campaigns of approved WhatsApp template messages. Where available, the service can connect to the restaurant's Cluvi reservation system through integrations. Cluvi AI is a multi-tenant platform: each restaurant is an organization, and a person can belong to one or more organizations with a role of owner, admin, or member. The service is provided in Spanish and English.

Cluvi AI is operated by Braintu Inc., located at 251 Little Falls Drive, Wilmington, Delaware 19808, USA ("Cluvi AI", "we", "us", or "our"). Throughout this policy we refer to the restaurants and staff members who hold a Cluvi AI account as "you".

Scope. This policy primarily governs the personal information we handle as a controller: chiefly the account and organization information of the people who use Cluvi AI. It also explains, for transparency, the categories of personal information we process on a restaurant's behalf when the restaurant uses Cluvi AI to manage its guest conversations and records. For that processor activity, the restaurant's own privacy notices and the processor terms in our Terms & Conditions govern how the data is used, and an individual's rights run through the restaurant. We say more about this in Sections 2, 5 and 13.

Cluvi AI touches the personal information of two distinct groups of people, and our responsibilities are different for each. Please find the group that applies to you.

Account Users (a restaurant's owners, admins, and members)

Account Users are the people who register for and use the Cluvi AI dashboard: a restaurant's owners, managers, hosts and other authorized staff. For the personal information that relates to your Cluvi AI account and your use of the service, Cluvi AI is the data controller: we decide how and why that information is processed, and the rights described in Section 12 apply directly between you and us.

Guests & Contacts (the restaurant's own community)

Guests & Contacts are the members of a restaurant's own community: the diners who write to the restaurant, the people in its contact list, those who request reservations, and the recipients of its campaigns, whose information the restaurant records and manages through Cluvi AI. For this information, the restaurant is the data controller and Cluvi AI acts only as a processor, handling the data on the restaurant's behalf and under its documented instructions.

If you are a guest and want to exercise your privacy rights (to access, correct, or delete information held about you, or to stop receiving messages, for example) please contact the restaurant. For Guests & Contacts, the restaurant is the controller and must respond to those requests; Cluvi AI will support the restaurant but will not respond to the individual directly without the restaurant's instruction, because the data belongs to that restaurant and is isolated to its workspace. See Section 13 for more.

The information below reflects what Cluvi AI actually collects and stores. Almost all of it lives in our primary backend (Supabase). We do not collect more than we describe here; in particular, we use no advertising trackers. We do run first-party product analytics for Account Users (never for Guests & Contacts), described under Technical & Usage Data below.

Account Information

When you create or use a Cluvi AI account, we collect your full name, email address, your phone number (if you sign in by phone), your role within each organization you belong to, and (optionally) an avatar. Sign-in is passwordless: you sign in with your email address and a one-time code we send to it, with your phone number and a one-time SMS code (delivered through Twilio Verify, where enabled for the service), or with "Sign in with Google" or "Sign in with Microsoft." If you sign in with Google or Microsoft, we receive basic OAuth profile data from that provider (such as your name, email address, and profile image). Cluvi AI accounts have no password: there is nothing for us to store, and authentication (including the one-time codes) is managed by Supabase Auth. See Section 6 for more on third-party sign-in.

Organization Data

For each restaurant, we store configuration such as the restaurant's name, its slug / URL, workspace settings, the connected messaging channels, and the membership and role information that controls who can access the workspace. When an owner or admin invites a colleague, we store the invitee's email address and the invitation's status so the invitation can be delivered and redeemed.

Guest Records

A restaurant records and manages personal information about its own guests through Cluvi AI. Depending on the features the restaurant uses, this can include contact records (names, phone numbers and contact details), the content of conversations the restaurant exchanges with guests through its connected channels, including attachments shared in those conversations (such as photos, documents, and voice notes), reservation requests (date, time, party size, the name the booking goes under, and a contact number), and campaign data (the recipient lists the restaurant provides or builds, delivery results, and the opt-out records the service keeps so people who ask not to be contacted are not messaged again).

Important: this is third-party personal data that the restaurant chooses to collect and manage. For this data the restaurant is the controller and Cluvi AI is the processor, and we process it only on the restaurant's instructions to provide the service (see Sections 4 and 5). The restaurant is responsible for having a lawful basis (including any messaging consents its jurisdiction requires) to collect this information, to message its guests, and to give the notices its guests are owed.

Cookies & Session Data

When you sign in, we process your authentication and session information through the essential cookies described in Section 8. We do not use non-essential or tracking cookies.

Technical & Usage Data

Like any web service, your device's IP address and similar connection information are necessarily handled by our hosting and backend providers (Vercel and Supabase) to deliver and secure the application. Cluvi AI itself does not run geolocation or build advertising profiles, and it does not store IP addresses, device fingerprints, or browser strings about Guests & Contacts at the application layer. We do not use advertising pixels or cross-site tracking.

Mobile App Permissions

If you use the Cluvi AI mobile app, it asks for access to your camera, photo library, and microphone only when you choose to attach a photo or record a voice note in a conversation. The app does not access these in the background, and declining a permission only disables that attachment feature.

Product Analytics, Session Replay & Error Reports (PostHog)

To understand where Account Users get stuck and what errors they hit, we run product analytics through PostHog (one analytics project per product, hosted in PostHog's US cloud). For Account Users only, this collects: usage events (screens opened and actions taken), device and connection metadata, client-side error reports, and session replays, recordings of what your screen showed during a session. Replays capture screen content as you saw it, including text you type; passwords are always masked. Once you sign in, this data is linked to your account id and email so we can see a real session behind a real problem.

Scope and limits. Analytics covers Account Users only: Guests & Contacts are never instrumented. On the web, analytics events are sent through our own domain (first-party); marketing pages set no analytics identifiers until you sign in. We use analytics to improve the product, never for advertising, and we never sell it.

We use Account Users' information to provide and operate the service: creating and securing your account, delivering one-time sign-in codes and transactional email, running your restaurant's workspace, and providing support. We also use it to protect the service (preventing abuse, enforcing our terms, and meeting our legal obligations).

We do not sell personal information, we do not share it with third parties for their own marketing, and we do not use the contents of a restaurant's records to build advertising profiles. Cluvi AI's AI-assisted features operate on the restaurant's data as part of the service, on the restaurant's instructions, and never to train third-party models on your data without your agreement.

For the records a restaurant manages through Cluvi AI, the restaurant decides what is collected and why; Cluvi AI executes the restaurant's instructions: storing the data, displaying it to the restaurant's authorized staff, generating the AI receptionist's replies, sending the messages and campaigns the restaurant initiates, recording opt-outs, and deleting the data when the restaurant asks. Each restaurant's data is isolated to its own workspace, and access within the workspace is controlled by the roles the restaurant assigns.

Messaging and opt-outs. When a restaurant sends campaigns, the recipient lists belong to the restaurant, and having a lawful basis to message every recipient is the restaurant's responsibility as controller. The service keeps opt-out records so a person who asks not to be contacted is excluded from future campaigns; honoring those requests, and complying with the channel's messaging policies (such as the WhatsApp Business and Meta policies), is part of the restaurant's duties under our Terms & Conditions.

If you choose to sign in with Google or Microsoft, the provider shares basic profile data with us (name, email address, profile image) so we can create and match your account. We use this data only for authentication and your account profile. We do not receive your contacts, files, calendar, or any other data from these providers, and we cannot post or act on your behalf. Cluvi AI's use of information received from Google APIs adheres to the Google API Services User Data Policy, including its Limited Use requirements.

Where a legal basis is required, we process Account Users' information because it is necessary to perform our contract with you (providing the service), because of our legitimate interests in securing and improving the service, to comply with legal obligations, or with your consent where we ask for it.

Cluvi AI serves restaurants in Colombia first, and we honor the Colombian data protection framework: Ley 1581 de 2012, its implementing decrees, and the constitutional right of habeas data. Data subjects in Colombia have the right to know, update, rectify and delete their personal data and to revoke consent, as described in Section 13. Where the data is a restaurant's guest records, those rights are exercised through the restaurant, which is the controller under that framework.

Cluvi AI uses essential cookies: the authentication and session cookies our backend (Supabase Auth) needs to keep you signed in securely, and a cookie that remembers your language preference, plus, after you sign in, a first-party identifier for the product analytics described in Section 3, kept in your browser's storage on our own domain. We set no advertising or cross-site tracking cookies, and marketing pages set no analytics identifiers, so no consent banner is required under the applicable rules.

We use a small number of service providers to run Cluvi AI. Each processes personal information only to provide its service to us and under contractual data protection commitments:

• Supabase (database, authentication, and file storage): the primary backend where account data and each restaurant's records are stored.
• Vercel (hosting and content delivery): serves the web application. AI-assisted features route model requests through Vercel's AI Gateway to the AI model providers that generate replies; conversation content is processed to produce the reply and is not used to train those providers' models without your agreement.
• Meta Platforms (WhatsApp Business Platform): delivers the WhatsApp conversations and campaign messages a restaurant exchanges with its guests, under Meta's own terms and messaging policies.
• Resend (transactional email): delivers one-time sign-in codes, invitations, and service email from cluvi.ai addresses.
• Google and Microsoft (optional sign-in): authenticate you when you choose "Sign in with Google" or "Sign in with Microsoft."
• Stripe (payments): processes subscription payments for restaurants when billing features are enabled; Cluvi AI never stores full card numbers.
• Twilio (SMS sign-in codes): delivers the one-time SMS codes when you sign in by phone (Twilio Verify), where enabled for the service.
• PostHog (product analytics): product analytics, session replay, and error reporting for Account Users (one analytics project per product, hosted in PostHog's US cloud). See Technical & Usage Data in Section 3.

Where the restaurant connects its Cluvi reservation system or another integration, the connected provider processes the data the restaurant exchanges with it under that provider's own terms. We will update this list as the service evolves; material changes will be reflected in this policy.

Cluvi AI is operated from the United States, and the service providers listed above store data primarily in the United States. If you use Cluvi AI from Colombia or elsewhere, your information (and the records a restaurant manages) will be transferred to and processed in the United States. We take the safeguards described in this policy and in our contracts with providers wherever the data is processed, and restaurants remain able to meet their local-law duties (including Colombia's international transfer rules) through our processor commitments.

We keep Account Users' information for as long as the account is active. A restaurant's records are kept for as long as the restaurant's workspace exists and are handled on the restaurant's instructions: when a restaurant deletes a record, or deletes its organization, the corresponding data is removed from the live systems, with residual copies in encrypted backups expiring on a rolling basis. Restaurants should retain their own copies of records that local regulations require them to preserve.

We protect personal information with encryption in transit (TLS) and at rest, tenant isolation enforced at the database layer (each restaurant's workspace is segregated with row-level security), role-based access inside each workspace, and passwordless authentication that eliminates stored passwords entirely. No system is perfectly secure, but we design so that the blast radius of any failure is as small as possible, and we will notify affected restaurants without undue delay if a security incident involves their data.

Account Users can access and update their name and avatar in the dashboard, and can ask us to access, correct, delete, or export the personal information we hold about them, or to restrict or object to its processing, by writing to the address in the contact block below. Where processing rests on consent, you can revoke it at any time. If you believe we have not honored your rights, you can complain to your local data protection authority (in Colombia, the Superintendencia de Industria y Comercio).

Guests exercise their rights (including habeas data rights in Colombia) through the restaurant they wrote to, which as controller must respond to requests to know, update, rectify or delete the information it manages, and to stop messaging them. We support restaurants in fulfilling those requests promptly, and the service records messaging opt-outs so they hold.

Cluvi AI accounts are for adults only (18 years or older), and the service is not directed at children. We do not knowingly allow children to create accounts, and we do not knowingly collect personal information directly from children. If a minor's information appears in a restaurant's records (for example, in a conversation or a reservation), the restaurant is the controller of that data and responsible for handling it lawfully. If you believe a child has created an account, please contact us and we will act promptly.

We may update this policy as Cluvi AI evolves. When we make material changes, we will update the effective date above and notify Account Users through the service or by email. Continued use of Cluvi AI after a change takes effect means the updated policy applies.