Legal

Privacy Policy

Scope: the Clowhi website and the Clowhi app
Controller: Reconnect Academy BV
Last updated: 16 July 2026 (draft) · Effective date: [EFFECTIVE-DATE]

Clowhi is built to be local-first: your audio never leaves your Mac, and the website collects only what it needs to sell and deliver the app. This policy explains what we do and do not process, and the rights you have under the General Data Protection Regulation (GDPR).

1. Who is responsible (controller)

The data controller for personal data processed through this website is:

2. The Clowhi app is local-first

The Clowhi application runs on your own Mac. It is designed so that your data stays with you:

• Audio never leaves your Mac. Recording and speech-to-text transcription happen locally on your device. We do not operate a Clowhi transcription server and we do not receive your audio.
• No product telemetry service. The app is not designed to send us analytics or usage tracking about how you use it.
• Automatic update checks. The app periodically contacts clowhi.com to check for signed updates (via the built-in Sparkle updater) and to download an update when you accept one. Like any web request, those checks generate the limited server and security logs described in section 3 (IP address, timestamp, requested URL) at our hosting provider. They carry no account identifier and none of your recordings, transcripts or notes.
• Optional AI summaries use your own API key. If you enable AI meeting summaries, the app can send transcript text (not audio) to a third-party AI provider using your own API key - for example your own Anthropic Claude API account. That processing happens under your account and is governed by that provider's terms and privacy policy. You decide whether to enable it and what you submit.

Because the app processes your content locally under your control, that content is not sent to us and is outside the website flows described below.

3. What the website processes

Depending on how you interact with us, we may process:

• Order and billing data: name, email address, billing address, country, and VAT/company details where relevant.
• Transaction records: order, invoice, payment status, refund and delivery records.
• Support data: the content of messages you send us and technical information you choose to include.
• Server and security logs: limited technical data such as IP address, timestamp and requested URL, generated by our hosting provider.

4. Purposes and legal bases

We process the data above to:

• process your payment and deliver the download - performance of a contract;
• provide support and handle refunds - performance of a contract and our legitimate interest in helping customers;
• prevent fraud and keep the service secure - legitimate interest;
• meet tax, invoicing and accounting duties - legal obligation;
• establish, exercise or defend legal claims - legitimate interest.

We do not send marketing email by default. Any optional marketing would rely on your separate consent, which you could withdraw at any time.

5. Who we share data with (processors and recipients)

We share personal data only with parties that help us run the service, or where the law requires it:

• Stripe - payment processing. See stripe.com/privacy.
• Vercel - website hosting and delivery. Vercel generates the server and security logs described above. See vercel.com/legal/privacy-policy.
• Professional accounting or legal advisers, and public authorities, where required by law.

We do not sell your personal data. As of this version the website does not use any analytics, advertising or third-party tracking tools.

6. Cookies and analytics

This website does not set analytics or advertising cookies and does not embed third-party tracking. It uses only what is strictly necessary to serve the pages and, where applicable, to run the secure checkout and download flow. If we ever add analytics or marketing tools, we will update this policy and put the required consent mechanism in place before those tools run.

7. International transfers

Some of our providers (for example Stripe and Vercel) may process data outside the European Economic Area, including in the United States. Where that happens, the transfer is covered by an appropriate safeguard such as the EU Standard Contractual Clauses or an adequacy mechanism, as described in that provider's own documentation.

8. How long we keep data

We keep order and invoice records for the periods required by Belgian tax and accounting law (currently up to 7 years). Support and security data are kept only as long as reasonably necessary for the purpose they were collected for, or for the duration of a possible legal claim, after which they are deleted or anonymised.

9. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• have data erased where the law allows;
• restrict or object to certain processing;
• receive your data in a portable format;
• withdraw any consent you have given, without affecting past processing.

To exercise any of these rights, contact support@guerillabuild.com. You also have the right to lodge a complaint with the Belgian supervisory authority:

10. Changes to this policy

We may update this policy as our service, providers or legal obligations change. The version in force is the one published here, carrying its "last updated" date.

11. Contact

Privacy questions or requests: support@guerillabuild.com. General support: support@guerillabuild.com.