Privacy Policy
Last updated on 6 October 2025
Clayground GmbH
Vordergasse 37
8200 Schaffhausen, Switzerland
Registered: 1685029 in the Federal Office for the Commercial Register
Contact: privacy@clayground.ai
Last updated: 02.10.2025
Introduction
At Clayground, we take your privacy seriously. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use Tricle (the "Service").
This policy applies to all users of Tricle, including visitors to our website, account holders, and users of our Service.
For information about data processing in a business context (where you are the data controller and we act as processor), please also refer to our Data Processing Addendum (DPA), available upon request.
1. How Do We Use Your Data?
1.1 When You Register for Tricle
When you sign up for an account with us, we collect:
Your name
Your email address
Your company name and details
Billing and payment information (collected by our payment processor, Paddle)
Why we collect this: We collect these details to establish the contract between us that enables you to access our platform, and to process your payments.
Legal basis: Contract performance and legitimate business interests.
1.2 When You Use Tricle
When you use the Service, we collect:
Usage information (how you interact with features, pages visited, time spent)
Technical information (IP address, browser type, device information)
CRM data and contact information you connect to Tricle
Communication preferences and settings
Why we collect this: We use this information to:
Provide and maintain the Service
Monitor and analyze usage patterns
Improve your experience and optimize our Service
Ensure security and prevent abuse
Provide customer support
Send you service-related notifications
Legal basis: Contract performance, legitimate business interests, and where applicable, your consent.
1.3 CRM and Integration Data
When you connect your CRM (such as HubSpot, Salesforce, or similar) and other data sources to Tricle, we process the data you choose to share, which may include:
Contact names and email addresses
Company information
Deal and opportunity data
Communication history
Custom fields and metadata
Why we process this: We process this data solely to provide the Service as described—to monitor your CRM, identify re-engagement opportunities, and generate drafts and insights.
Your role: You are the data controller for this data. We act as a data processor on your behalf. You are responsible for ensuring you have all necessary rights, consents, and legal bases to share this data with us.
Legal basis: Contract performance (we process this data to provide the Service you've contracted for).
1.4 AI Processing
Your data may be processed by third-party AI model providers, including:
OpenAI
Anthropic
Similar or successor AI providers
Why we use AI: We use AI to generate email drafts, insights, and recommendations based on your CRM data.
Important commitment: We do not use any personal data, including data received through the Service or third-party integrations, for developing, improving, or training general-purpose AI and/or ML models. We only process your data to provide and improve the Tricle Service specifically for you.
Your responsibility: AI-generated outputs are suggestions only. You are solely responsible for reviewing, approving, and sending any messages.
Legal basis: Contract performance and legitimate business interests.
1.5 When You Contact Us
When you contact us via email, our website, or through the Service with questions or support requests, we collect:
Your name
Your email address or other contact details
The content of your message
Any attachments or files you share
Why we collect this: It's in our legitimate interest to respond to your queries and provide customer support.
Legal basis: Legitimate business interests.
1.6 When You Subscribe to Our Updates
If you opt-in to receive our newsletter, product updates, or marketing communications, we collect:
Your name
Your email address
Your communication preferences
Why we collect this: To provide you with the updates and information you've requested, in line with your preferences.
Legal basis: Your consent (when you opt-in) or our legitimate interest to promote our business (where permitted by law).
How to unsubscribe: You can unsubscribe at any time by clicking the unsubscribe link at the bottom of any email, or by emailing privacy@clayground.ai.
1.7 Technical Information When You Use Our Website
When you visit our website, we may collect:
Cookies and similar tracking technologies
IP address
Browser type and version
Device information
Pages visited and time spent
Why we collect this: To understand how visitors use our website and to improve it. With your consent, we may use analytics tools (such as Google Analytics or PostHog) to better understand user behavior.
Legal basis: Your consent (for non-essential cookies) and legitimate business interests (for essential functionality).
More information: Please see our Cookie Policy for detailed information about our use of cookies.
1.8 When You Apply for a Job With Us
If you apply for a position at Clayground, we may collect:
Your name and contact details
Your CV/resume
Cover letter and application materials
Right to work documentation
References
Interview notes and assessment results
Why we collect this: To assess your suitability for available roles and to fulfill our legal obligations as an employer.
Legal basis: Contract performance (to take steps at your request before entering into an employment contract) and legal obligations.
1.9 If Our Business Is Sold
In the event of a merger, acquisition, or sale of all or part of our business, we may transfer your personal information to the buyer.
Why we do this: We have a legitimate interest to ensure our business can be continued by the buyer.
Your rights: If you object to this use of your personal information, the buyer may not be able to continue providing services to you.
Legal basis: Legitimate business interests.
2. Where Is Your Data Stored?
We store your data primarily in:
Switzerland (Zurich) for primary data storage
European Union (Germany - Frankfurt am Main) for backend hosting
International transfers: Your data may be processed by third-party service providers (including AI model providers) that operate in jurisdictions outside Switzerland and the EU. Whenever we transfer your personal data internationally, we ensure it receives appropriate protection as required by law, including through:
Standard Contractual Clauses (SCCs)
Adequacy decisions by the Swiss Federal Data Protection and Information Commissioner
Other appropriate safeguards under applicable data protection law
For more detail: Contact us at privacy@clayground.ai for specific information about international data transfers.
3. Who Do We Share Your Data With?
We share your data only with trusted partners who help us provide the Service:
3.1 Subprocessors
We use the following categories of subprocessors:
AI model providers (OpenAI, Anthropic, and similar providers) - to generate drafts and insights
Hosting providers - to host our infrastructure and store data
Payment processors (Paddle) - to process payments
Analytics providers - to understand usage and improve the Service
Customer support tools - to provide support
Email service providers - to send service and marketing emails
Subprocessor list: We maintain an up-to-date list of subprocessors. You can request this list at any time by contacting privacy@clayground.ai.
Changes to subprocessors: We may change subprocessors from time to time. If you have signed our DPA, we will notify you of any changes as specified in that agreement.
3.2 Legal Requirements
We may disclose your personal information if required to do so by law, or if we believe in good faith that such disclosure is necessary to:
Comply with legal obligations or court orders
Protect and defend our rights or property
Prevent fraud or security issues
Protect the safety of our users or the public
3.3 With Your Consent
We may share your information with third parties when you have given us explicit consent to do so.
4. How Long Do We Keep Your Data?
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including:
For the duration of your contract with us
To comply with legal, accounting, or reporting requirements
To resolve disputes and enforce our agreements
For our legitimate business interests
Specific retention periods:
Account data: Retained for the duration of your active account, plus any legally required retention period after termination
Support communications: Typically retained for 3 years after the last interaction
Marketing data: Retained until you unsubscribe or object, plus any legally required period
Payment records: Retained as required by tax and accounting laws (typically 10 years in Switzerland)
After termination: Upon termination of your account, we will delete or return your personal data per our Data Processing Addendum and retention schedules, subject to legal obligations.
Anonymized data: We may anonymize your personal data so it can no longer be associated with you. We may use this anonymized information indefinitely for:
Analytics and insights
Product improvement
Research and development
Creating aggregated statistics
5. How Do We Protect Your Data?
We implement commercially reasonable technical and organizational measures to protect your personal data, including:
Encryption of data in transit and at rest
Access controls and authentication
Regular security assessments
Employee training on data protection
Incident response procedures
Secure development practices
Important note: While we take security seriously, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your data.
Security certifications: We do not currently provide SOC 2 or equivalent attestations unless expressly agreed in writing for enterprise customers.
6. Your Rights Under Data Protection Laws
Depending on your location and applicable law (including GDPR and Swiss Federal Act on Data Protection), you have the following rights:
6.1 Right to Access
You have the right to request a copy of the personal data we hold about you (also known as a "subject access request").
6.2 Right to Rectification
You have the right to correct incomplete or inaccurate data we hold about you.
6.3 Right to Erasure
You have the right to request that we delete the personal data we hold about you (subject to certain exceptions, such as legal obligations).
6.4 Right to Restriction
You have the right to request that we restrict our processing of your personal data in certain circumstances.
6.5 Right to Data Portability
You have the right to request that we transfer your personal data to another service provider in a structured, commonly used format.
6.6 Right to Object
You have the right to object to how we are using your personal data, particularly for:
Direct marketing (you can object at any time)
Processing based on legitimate interests
Automated decision-making and profiling
6.7 Right to Withdraw Consent
Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time.
6.8 Right to Lodge a Complaint
You have the right to lodge a complaint with your relevant supervisory authority:
For Switzerland: Federal Data Protection and Information Commissioner (FDPIC)
For EU residents: Your local data protection authority
How to exercise your rights: To exercise any of these rights, please contact us at privacy@clayground.ai. We will respond within the timeframes required by applicable law (typically 30 days).
Verification: We may need to verify your identity before responding to your request to protect your privacy and security.
Limitations: Please note that these rights are not absolute and may not apply in all circumstances. We will explain our reasoning if we cannot fulfill your request.
7. Children's Privacy
Tricle is not intended for use by individuals under the age of 16. We do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us immediately at privacy@clayground.ai, and we will take steps to delete such information.
8. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.
How we notify you: If we make material changes, we will notify you by:
Email to your registered email address
A prominent notice on our website or within the Service
Other appropriate means
Effective date: Changes become effective on the date specified in the notice. Your continued use of the Service after the effective date constitutes acceptance of the updated Privacy Policy.
Review regularly: We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.
9. Additional Information for Specific Regions
9.1 European Economic Area (EEA) and Switzerland
If you are located in the EEA or Switzerland, the data controller for your personal information is:
Clayground GmbH
Vordergasse 37
8200 Schaffhausen, Switzerland
We process your data in accordance with the EU General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (nFADP).
9.2 United States
If you are located in the United States, certain state privacy laws may provide you with additional rights. Please contact us at privacy@clayground.ai for more information about your specific rights.
10. Third-Party Links
Our Service may contain links to third-party websites or services that are not operated by us. This Privacy Policy does not apply to those third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.
We are not responsible for the privacy practices or content of third-party websites.
11. Contact Us
If you have questions, comments, or concerns about this Privacy Policy or our privacy practices, please contact us:
Email: privacy@clayground.ai
Mail:
Clayground GmbH
Vordergasse 37
8200 Schaffhausen
Switzerland
Response time: We aim to respond to all privacy inquiries within 30 days.
12. Questions, Comments, and Feedback
Your feedback on this Privacy Policy is welcome. If you feel we have overlooked an important perspective or used language that could be improved, please let us know at privacy@clayground.ai.
We've worked hard to create a policy that's clear and easy to understand, and we're committed to continuous improvement.
For more information about data processing in a business context, including our role as a data processor when you use Tricle, please refer to:
Our Terms & Conditions
Our Data Processing Addendum (DPA) - available upon request at privacy@clayground.ai
For technical documentation about data collection, subprocessors, and security measures, please contact privacy@clayground.ai.