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Privacy Policy

Federico Szarfer Barenblit Effective Date: 2026-08-03

This Privacy Policy explains how Federico Szarfer Barenblit ("Company," "we," "us," or "our") collects, uses, stores, and shares personal data when you use Clinbox ("Service"), available at https://clinbox.cc.

Swipe away inbox clutter. The AI learns what you hate.

We are committed to protecting your privacy and complying with the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA).

1. Data We Collect

1.1 Account & Authentication Data

| Data | Purpose | Basis (GDPR) | |------|---------|---------------| | Email address | Account creation, login, communications | Contract performance | | Name (if provided) | Account personalization | Contract performance | | OAuth provider ID (Google) | Federated authentication | Contract performance | | Hashed password (if email/password auth) | Authentication | Contract performance | | Session token | Maintaining your authenticated session | Contract performance |

Authentication is handled via Neon Auth / Better Auth. Session tokens are stored server-side in our PostgreSQL database.

1.2 Billing Data

| Data | Purpose | Basis (GDPR) | |------|---------|---------------| | Stripe customer ID | Link your account to payment records | Contract performance | | Subscription status & plan | Provision correct feature access | Contract performance |

All payment information (card numbers, billing addresses) is collected and processed exclusively by Stripe. We never receive, store, or transmit your card details. See Stripe's Privacy Policy.

1.3 Gmail Data (Google restricted-scope)

Clinbox integrates with Gmail. Gmail is a Google restricted-scope API; this section describes exactly what we access, store, and do.

What we read and store (metadata only — no message bodies):

  • Sender name and sender email address
  • Subject line
  • Short snippet (the preview excerpt Gmail itself generates)
  • Date/time received
  • Gmail labels attached to the message

We do NOT store email message bodies. Email body content is read transiently in memory only if needed to compute a snippet; it is never persisted to our database. (A separate workstream is removing any residual body persistence; once complete the bodies are not read at all.)

What we do with it:

  • Learn your own patterns from your swipe decisions (keep / delete) and the metadata above.
  • Surface emails in the swipe deck so you can decide on them.
  • Generate automated, probabilistic AI suggestions for which emails you might want to delete.
  • Move the emails you explicitly approve to your Gmail Trash via the Gmail API. We do not permanently delete email ourselves.

Retention: Synced Gmail metadata is kept until you delete it, delete your account, or disconnect Gmail — whichever comes first. Deleting your account erases your synced email metadata, swipe decisions, AI suggestions, batch history, and consent records (self-service from Settings → Danger Zone).

Human access: No human reads your Gmail data. Automated systems process it to provide the features above. Access to production data is restricted and logged.

Google API Services User Data Policy / Limited Use statement: Our use of Gmail data complies with the Google API Services User Data Policy, including the Limited Use requirements:

  • We use Gmail data only to provide the user-facing Clinbox features described above.
  • We do not transfer Gmail data to others, except as needed to provide those features (e.g., to our hosting and database sub-processors listed in Section 4) or as required by law.
  • We do not use Gmail data for advertising.
  • No human reads your Gmail data.

Trash and revocation: When you approve a deletion, the email is moved to your Gmail Trash. Google retains trashed email for approximately 30 days, during which you can restore it from inside Gmail; after that Google permanently removes it per Gmail's own rules. To stop all access to your Gmail account at any time, revoke Clinbox at https://myaccount.google.com/permissions — this immediately stops all further access.

1.4 Other Product Data

  • Swipe decisions (keep / delete) you make in the swipe deck
  • AI-generated deletion suggestions (action, confidence, reasoning)
  • Batch execution records (your cleanup history)
  • Aggregated cleanup stats per account

Legal basis (GDPR): Contract performance — this data is necessary to provide the Service's core functionality.

1.5 Analytics Data (Opt-In Only)

We use PostHog for product analytics. PostHog tracking is disabled by default and only activated if you explicitly opt in via our cookie consent banner.

When opted in, PostHog may collect:

  • Page views and navigation paths
  • Custom product events (e.g., feature usage)
  • User properties (e.g., subscription plan, account creation date)
  • Device type, browser, operating system
  • Approximate location (derived from IP; IP is not stored long-term)

Legal basis (GDPR): Consent. You can withdraw consent at any time through the "Cookie settings" link in the footer (which re-opens the consent banner) or by clearing your cookie-consent preference in your browser.

1.6 Technical / Automatically Collected Data

| Data | Purpose | Basis (GDPR) | |------|---------|---------------| | IP address | Security, abuse prevention, infrastructure routing | Legitimate interest | | Server logs (request method, URL, status code, timestamp) | Debugging, security monitoring | Legitimate interest |

Server logs are generated by Vercel (edge/serverless hosting) and retained for a limited period as described in Section 5.

2. Cookies & Local Storage

| Cookie / Storage | Type | Consent Required | Purpose | |-----------------|------|-------------------|---------| | Auth session cookie | Strictly necessary | No | Maintains your login session | | PostHog analytics cookies | Analytics | Yes — opt-in only | Product analytics (disabled until you consent) | | Cookie-consent preference | Strictly necessary | No | Remembers whether you accepted/declined analytics | | Theme preference | localStorage | No | Stores your UI theme preference client-side |

Cookie Consent Mechanism

On first visit, analytics cookies are not set. A cookie consent banner is displayed. PostHog is only initialized if you actively opt in. You may change your preference at any time via the "Cookie settings" link in the footer, which re-opens the consent banner. Declining or withdrawing consent does not affect your access to any Service functionality.

3. How We Use Your Data

We use your data to:

  1. Provide and operate the Service — account management, authentication, core product functionality (swipe deck, AI suggestions, batch cleanup).
  2. Process payments — via Stripe; we interact only with Stripe customer IDs and subscription status.
  3. Improve the Service — if you opt in to analytics, we use aggregated usage data to identify bugs and improve features.
  4. Communicate with you — transactional emails (password resets, billing receipts, service updates). We do not send marketing emails without separate consent.
  5. Ensure security — fraud detection, abuse prevention, and infrastructure monitoring.
  6. Comply with legal obligations — tax records, lawful data requests.

4. Third-Party Services & Data Sharing

We share personal data only with the following categories of service providers, and only as necessary:

| Provider | Data Shared | Purpose | |----------|-------------|---------| | Vercel | IP address, request metadata | Hosting, edge functions, serverless compute | | Neon (PostgreSQL) | All application data (encrypted at rest) | Database storage | | Stripe | Stripe customer ID, subscription events | Payment processing | | PostHog | Analytics events, device info (if opted in) | Product analytics | | Google (Gmail) | Email metadata (sender, subject, snippet, date, labels) as described in Section 1.3 | Provide the Gmail sync, swipe, AI suggestion, and trash features you requested | | Resend | Transactional email content (to addresses you control) | Transactional email delivery |

Hosting & Sub-processors

This Service is operated by Federico Szarfer Barenblit (the "Operator"). The Operator uses Nori Labs, Inc. (which operates the "Venture City" platform) to build, host, and maintain the Service on the Operator's behalf. With respect to personal data of the Service's end users, the Operator is the data controller and Nori Labs, Inc. acts as a data processor, processing such data only on the Operator's documented instructions.

The Service relies on the following infrastructure providers and sub-processors:

  • Nori Labs, Inc. (Venture City): platform hosting, build, and operational tooling
  • Vercel: application hosting and serverless compute
  • Neon: PostgreSQL database hosting
  • Stripe: payment processing
  • PostHog: product analytics (opt-in)
  • Resend: transactional email delivery

We do not sell, rent, or trade your personal data to third parties for marketing purposes.

We may disclose data if required by law, regulation, legal process, or governmental request, or to protect the rights, safety, or property of Federico Szarfer Barenblit, Nori Labs, Inc., our users, or the public.

In the event of a merger, acquisition, or asset sale, your data may be transferred to the successor entity. We will notify you before your data becomes subject to a different privacy policy.

5. Data Retention

| Data Category | Retention Period | |---------------|-----------------| | Account data | Until you delete your account + 30 days for backup purge | | Billing records (Stripe customer ID, invoices) | 7 years after last transaction (tax/legal compliance) | | Gmail metadata (sender, subject, snippet, date, labels) | Until you delete it, disconnect Gmail, or delete your account — whichever comes first | | Swipe decisions, AI suggestions, batch history, cleanup stats | Until you delete your account | | Analytics data (PostHog) | 12 months, then auto-deleted | | Server logs (Vercel) | Up to 30 days | | Auth session tokens | Expire after inactivity period; purged on logout or account deletion |

Upon account deletion, we delete or anonymize your personal data within 30 days, except where retention is required by law (e.g., billing records). Self-service account deletion in Settings → Danger Zone immediately removes your synced email metadata, swipe decisions, AI suggestions, batch history, cleanup stats, and consent records.

6. Data Security

We implement industry-standard security measures including:

  • Encryption in transit: All data is transmitted over TLS/HTTPS.
  • Encryption at rest: Database storage (Neon PostgreSQL) encrypts data at rest.
  • Secure authentication: Passwords are hashed using modern algorithms; session tokens are stored server-side.
  • Payment security: Stripe is PCI DSS Level 1 compliant. Card data never touches our servers.
  • Infrastructure: Vercel serverless architecture minimizes attack surface; no persistent servers to compromise.
  • Access control: Internal access to production data is restricted and logged. No human reads your Gmail data.

No system is 100% secure. If we discover a breach affecting your personal data, we will notify you and relevant authorities as required by GDPR (within 72 hours) and applicable law.

7. Your Rights

Under GDPR (EEA, UK, Switzerland residents)

You have the right to:

  • Access — request a copy of the personal data we hold about you.
  • Rectification — correct inaccurate or incomplete data.
  • Erasure ("right to be forgotten") — request deletion of your personal data.
  • Restriction — request that we limit processing of your data.
  • Portability — receive your data in a structured, machine-readable format (JSON or CSV).
  • Object — object to processing based on legitimate interest.
  • Withdraw consent — for any processing based on consent (e.g., analytics), at any time, without affecting the lawfulness of prior processing.
  • Lodge a complaint — with your local data protection authority.

Under CCPA (California residents)

You have the right to:

  • Know — what personal information we collect, use, and disclose.
  • Delete — request deletion of your personal information.
  • Opt out of sale — we do not sell your personal information. No opt-out is necessary.
  • Non-discrimination — we will not discriminate against you for exercising your rights.

How to Exercise Your Rights

Most rights are self-service:

  • Export your data — Settings → Danger Zone → "Export my data" downloads a JSON copy of your account, synced Gmail metadata, swipe decisions, AI suggestions, cleanup history, and consent records.
  • Delete your account and all associated data — Settings → Danger Zone → "Delete my account" hard-deletes your synced email metadata, swipe decisions, AI suggestions, batch history, cleanup stats, consent records, and subscriptions.
  • Withdraw analytics consent — "Cookie settings" link in the footer.

For any other request, email us at support@venturecity.ai. We will verify your identity and respond within 30 days (GDPR) or 45 days (CCPA). For data portability requests, we will provide your data in JSON format.

8. International Data Transfers

Our infrastructure is hosted in the United States (Vercel, Neon). If you are located outside the US, your data will be transferred to and processed in the US. We rely on:

  • Standard Contractual Clauses (SCCs) where required for GDPR compliance.
  • Selecting processors (Vercel, Neon, Stripe, PostHog) that maintain appropriate safeguards.

9. Children's Privacy

The Service is not intended for anyone under the age of 16 (or the applicable minimum age in your jurisdiction). We do not knowingly collect data from children. If you believe a child has provided us with personal data, contact us at support@venturecity.ai and we will delete it promptly.

10. Do Not Track

The Service does not respond to browser "Do Not Track" signals. However, analytics tracking (PostHog) is disabled by default and requires your explicit consent.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes at least 30 days in advance via email or an in-app notice. The "Effective Date" at the top reflects the latest revision. Continued use of the Service after the effective date constitutes acceptance.

12. Data Protection Contact

For any privacy-related questions, requests, or complaints:

Federico Szarfer Barenblit (data controller)

Email: support@venturecity.ai

If you are in Spain or the EU/EEA and believe we have not adequately addressed your concerns, you have the right to lodge a complaint with the Spanish Data Protection Authority (Agencia Española de Protección de Datos, AEPD) at https://www.aepd.es, and with your local supervisory authority.

13. Liability

To the maximum extent permitted by applicable law, neither Federico Szarfer Barenblit nor Nori Labs, Inc., nor any of their respective officers, directors, employees, contractors, or agents, is liable for any indirect, incidental, special, consequential, or punitive damages arising out of or related to this Privacy Policy or your use of the Service. This limitation is without prejudice to any liability we cannot exclude by law (e.g., for damage caused by our gross negligence or wilful misconduct, or for breaches of data-subject rights under the GDPR).