Privacy policy

1. When Caballus is controller or processor

Caballus is a controller for personal data used to operate accounts, administer subscriptions, secure and improve Clearslot, communicate with users, provide support, comply with law, and manage our business.

When a Clearslot business customer (Organiser) uses the Service to collect or manage information about its clients, prospects, staff, invitees or people who book (Bookers), the Organiser normally decides why and how that information is used. The Organiser is the controller and Caballus acts as its processor under the Clearslot Data Processing Addendum.

Bookers should first direct privacy questions about a booking, form or Organiser message to the relevant Organiser. We will assist the Organiser with requests as required by data-protection law.

Some providers, especially payment and customer-authorised integration providers, also process data as separate or joint controllers under their own privacy notices.

2. Personal data we handle

Depending on how you use Clearslot, we handle:

• Account and organisation data: name, email address, telephone number, profile image, organisation, role, language, time zone, account settings and identifiers.
• Booking and contact data: Booker name and contact details, company, time zone, requested service, appointment time, attendees, status, notes, cancellation reason, custom-form answers and related communications.
• Availability and integration data: availability rules, calendar identifiers and metadata, event details, conferencing links, connected-account identifiers, permissions and tokens needed to operate an integration.
• Subscription and transaction data: plan, billing address and tax information, Stripe customer/account identifiers, payment amount, currency, status, refunds and chargeback metadata. Caballus does not receive full payment-card numbers from Stripe.
• Content: booking-page text, images, branding, forms, routing rules, uploaded materials and messages supplied through the Service.
• Business eligibility and withdrawal records: establishment facts, private operator decisions and evidence references, plus necessary media ownership and withdrawal records. These records are not published in Organiser notices and follow the account-retention and applicable legal-hold rules below.
• Support and business communications: messages, attachments, feedback and records of how a request was handled.
• Technical and security data: IP address, device and browser information, timestamps, session identifiers, authentication and security events, request logs, error information and anti-abuse signals.
• Usage data: actions taken in the product and feature/configuration state needed to operate, troubleshoot and improve it. At launch we do not use third-party behavioural advertising or non-essential analytics cookies.

Clearslot is not designed for payment-card numbers in form fields, passwords, authentication secrets, government identity numbers, special-category data or criminal-offence data. Organisers must not request or submit that information at launch or use Clearslot for regulated health workflows.

Required account, security and billing fields are needed to provide the requested service or meet legal obligations. If you do not provide them, we may be unable to create the account, process a payment or provide the feature. Optional profile fields and optional integrations are voluntary. An Organiser decides which booking fields are necessary and must explain the consequences of not providing them; declining an optional answer must not be presented as declining all privacy rights.

3. Where data comes from

We receive data:

• directly from account users, Bookers and people who contact us;
• from the Organiser that configures a booking page or adds team members, contacts or bookings;
• from a connected service when a user enables an integration, such as Stripe or Google Calendar;
• automatically from devices, browsers and our security and application systems; and
• from public sources, reporters, service providers or authorities where needed to prevent abuse, investigate a report or comply with law.

4. Why we use data and our legal bases

When Caballus is controller, we use personal data as follows:

When we process booking data or send operational booking messages solely for an Organiser, we follow its documented instructions under the DPA. Those instructions are not a separate GDPR lawful basis: the Organiser must identify and disclose its own basis. Accepting business Terms or acknowledging this Notice does not supply marketing consent or consent on behalf of Bookers.

Where we rely on legitimate interests, we consider the necessity and impact of the processing and do not use that basis where a person's rights override our interests. You may ask for more information about a balancing assessment relevant to you.

If we ask for consent, you may withdraw it at any time. Withdrawal does not affect earlier lawful processing.

5. Who receives personal data

We disclose only what is reasonably necessary to the following recipients:

Stripe may act as processor, independent controller or joint controller depending on the payment activity. For an Organiser's connected payment account, Stripe also contracts directly with the Organiser. Google processes data under its own terms when a user enables its integration.

We may also disclose data to professional advisers and auditors under confidentiality; to a buyer, investor or successor in a genuine corporate transaction; to competent authorities where law requires it; and to another person where necessary to protect rights, safety or the Service.

We do not sell personal data. We do not share it for cross-context behavioural advertising.

The current list of processors used for Customer Personal Data is in the subprocessor schedule to our DPA. Website font files are served from Clearslot’s own domains; loading a page does not send a font request to Google.

For a Google Calendar/Meet connection, we access the calendar and event information needed for availability, synchronisation and meeting creation requested by the user. Our use and transfer of information received through Google APIs adhere to the Google API Services User Data Policy, including its Limited Use requirements. We do not use that information for advertising or general-purpose model training. You may disconnect the integration in Clearslot and revoke access through your Google account; disconnecting does not itself erase records already lawfully created or records held by the Organiser.

6. International transfers

Our primary application database and compute are hosted in the European Economic Area, and encrypted backups are stored in France. This is not a commitment that all processing takes place in the EU or EEA. Cloudflare, Stripe, Google Workspace and optional Google integrations involve global processing, including in the United States. Resend stores and processes email content and delivery data primarily in the United States; choosing an EU sending region does not change that storage location. Scaleway's agreement also allows safeguarded transfers outside the EU, although our backup storage is in France.

The [DPA subprocessor schedule](/dpa) describes provider functions, locations and contractual transfer safeguards. Connected Google accounts are subject to the terms and safeguards applicable to those accounts; Caballus's own Workspace addendum does not cover every Organiser's Google account.

Where GDPR restricts a transfer outside the EEA, the relevant transfer must be covered by an applicable mechanism, such as an adequacy decision, the EU-US Data Privacy Framework for an eligible certified recipient, or completed Standard Contractual Clauses with supplementary measures where required. The mechanism depends on the recipient and processing, not just its brand name. Contact [email protected] for the applicable safeguards and a copy, subject to lawful redactions protecting confidential information and others' rights.

7. How long we keep data

We keep personal data only for as long as needed for the purpose collected, including providing the Service, following the Organiser's instructions, maintaining security, complying with law, resolving disputes and enforcing agreements.

The launch retention schedule is:

Provider deletion can take additional time after data is removed from active use. Google's Workspace addendum permits up to 180 days to complete deletion after data becomes irrecoverable through the service; ending the Workspace agreement may first involve a recovery period of up to 30 days. Residual copies remain protected and must not be used for ordinary business purposes. We pass on applicable deletion instructions; closing one Clearslot account does not terminate our shared provider accounts or automatically erase records held independently by Stripe or an Organiser's connected services.

An Organiser may set shorter or longer retention for its own booking records where the Service permits. Caballus may retain a minimal suppression record after deletion to honour an opt-out or prevent re-creation of an abusive account.

These are default schedules, not a reason to delay a binding erasure instruction or a shorter legal deadline. Required retrieval periods and restrictions on processor retention remain governed by the DPA and applicable law.

We may preserve relevant data during a legal hold, dispute or investigation. When the hold ends, the ordinary schedule resumes.

8. Account closure is not instantaneous erasure of every record

Closing an account revokes access and begins the applicable deletion or de-identification process. It does not necessarily erase every record immediately. For example, we may retain invoice and transaction records required by law; security evidence; records needed to protect Bookers or resolve disputes; historical booking references that must remain consistent; and encrypted backup copies until automatic expiry.

Where Caballus acts as processor, the Organiser controls deletion instructions subject to the DPA. A Booker requesting deletion should contact the Organiser first. Applicable erasure instructions must be reapplied to recovered data before restored services are reopened.

9. Your data-protection rights

Subject to the conditions and exceptions in applicable law, you may have rights to:

• access your personal data and receive information about its use;
• correct inaccurate data;
• erase data;
• restrict processing;
• object to processing based on legitimate interests or to direct marketing;
• receive data in a portable format; and
• withdraw consent.

To exercise a right concerning a Clearslot account or Caballus's own processing, contact [email protected]. To exercise a right concerning an Organiser's booking page or records, contact that Organiser. We may need information to verify identity and authority. Authorised agents must show their authority.

For requests governed by GDPR, we respond without undue delay and normally within one month of receipt. If complexity or the number of requests requires an extension permitted by law, we explain it within that first month. Requests are normally free; any refusal or charge must meet the legal conditions, and we explain the reason and available complaint rights.

You may object at any time to use of your personal data for direct marketing. We will stop that use. You may also object, on grounds relating to your particular situation, to processing based on legitimate interests; we then apply the tests and exceptions required by law.

You may complain to the data-protection supervisory authority where you live, work or believe an infringement occurred. You may also bring a court claim. We would appreciate the opportunity to address the concern first.

10. Cookies and device storage

Clearslot uses cookies or similar device storage that are necessary to:

• maintain sign-in sessions and remember security state;
• protect forms and requests against forgery, bots and abuse;
• retain language or essential interface preferences; and
• route and secure traffic through Cloudflare.

Where a promotional prompt can be dismissed, a browser preference remembers that choice for 30 days. It is a dismissal preference, not consent to marketing or an advertising-tracking identifier.

These technologies are used because they are necessary to provide or secure the service you request, rather than for advertising. Blocking them may prevent sign-in, booking or other core functions.

At launch we do not set non-essential analytics or advertising cookies. If that changes, we will update this Notice and request consent where applicable before setting them.

11. Security

We use technical and organisational measures intended to protect personal data in proportion to the risk. They include TLS in transit, restricted administrative access, authentication and session controls, network and application security controls, logging and monitoring, vulnerability and patch management, encrypted off-site backups, secrets management, and documented incident and restoration procedures.

No internet service is completely secure. Customers must protect credentials, configure user access appropriately and notify us promptly at [email protected] about suspected compromise.

12. Children

People under 18 may not hold a Clearslot account. The Service is not directed to children.

A child under 13 must not submit a booking form; an authorised adult must make a booking concerning that child. This is a product restriction, not a claim that 13 is a uniform EU age of consent. An Organiser that permits appointments for or concerning children is responsible for an appropriate legal basis, age-appropriate transparency, guardian authority where required, data minimisation and all other safeguards. The launch prohibition on sensitive information applies equally to information about children.

13. Automated decisions

We use technical signals to detect spam, fraud, account takeover and prohibited use and to prioritise review. IP-derived country and our network provider's Tor signals can refuse product requests; missing or inconsistent business or final billing-country information can hold product access pending operator review. Geographic denial alone does not permanently block an organisation. Authorised Caballus personnel review persistent eligibility and blocking decisions. Contact [email protected] to request human review, give your view or contest a decision. We provide any further information and safeguards required by applicable law.

14. European Union information

Caballus is incorporated in Ireland. For processing where Caballus is controller, the purposes, legal bases, recipients, retention and rights information required by Articles 13 and 14 GDPR are set out above. You may complain to the data-protection supervisory authority where you live, work or believe an infringement occurred.

Where an Organiser controls Booker data, the Organiser must provide its own complete privacy information. The layered notice on a booking page identifies that Organiser and links to its notice. Caballus does not use consent as the legal basis merely because a user acknowledges this Notice.

15. Languages and mandatory rights

Privacy information must be understandable to the people we target. Localized notices describe the same processing and rights; they are not separate business contracts. The English-language provision in our Business Terms does not override this transparency duty or your mandatory privacy rights. Contact us if a notice is unclear or you identify a translation error.

16. Changes and contact

We may update this Notice to reflect changes in law, providers or the Service. We will post the current version and give additional notice of material changes where appropriate.

Privacy questions and rights requests: [email protected]

Support: [email protected]

Postal address: CABALLUS LIMITED, 2 Bridge Street, Athlone, Co. Westmeath, Ireland