Privacy Policy

01Who we are

This policy explains how Jack Summer Ltd, trading as Claromai ("Claromai", "we", "us", "our") collects, uses and protects personal data when you visit this website, get in touch, or book a discovery call. We are the data controller for the personal data described here.

Jack Summer Ltd is registered in England & Wales, company number 11859690, and trades as Claromai for our AI adoption consultancy services. Our registered office is 20-22 Wenlock Road, London, N1 7GU.

02What we collect

We collect personal data you give us directly. We don't buy or scrape lists, and this site uses no cookies, analytics or advertising tags.

• Enquiry form: your name, business name, email address, where you heard about us, and anything you tell us about what's eating your time, submitted via the "Request my free call" form.
• AI Readiness Score: your answers to its questions, your name, business name, email address, phone number if you give it, and the hourly staff cost you choose. We use them to work out your score, prepare your report (a person checks every report before it is sent) and follow up about it. If you tick the box for occasional tips, we'll also email you those until you ask us to stop.
• Free guide: your name, business name and email address, which guide you asked for and the page you were on, submitted via the "Free guide" form. We use them to give you the guide and to see which guides are useful. If you tick the box for practical tips, we'll also email you those until you ask us to stop.
• Advert details: if you reach us by clicking one of our adverts and then send a form on the page you land on, the labels in the page address that say which advert or post it was. If you tick the optional box on the form, this includes the advertising platform's click identifier. See section 07.
• Email and calls: anything you share when you email us or speak with us on a discovery call, including notes we take about your business so we can prepare an Opportunity Map.
• Client data: if you go on to become a client, the personal and business data needed to scope, build and support a workflow, as set out in your engagement agreement rather than this policy.

03How we use it

We use your data to respond to enquiries, arrange and run discovery calls, prepare proposals and, where you become a client, deliver and support the work agreed. We rely on the following legal bases under UK GDPR:

• Legitimate interests: responding to your enquiry and following up about a service you asked us about.
• Contract: where we're taking steps at your request before entering a contract, or performing one already in place.
• Consent: for anything beyond this, such as adding you to a mailing list, or telling Google that you came from our advert (section 07). We'll ask separately and you can withdraw it at any time.

04Who we share it with

We don't sell personal data. We share it only with the service providers ("processors") that help us run the business, for example our email provider, call-scheduling tool and the software we use to build and support client workflows, and only to the extent needed for them to provide that service to us. If you tick the box on one of our forms asking us to tell Google that you came from our advert, we also share the limited details described in section 07 with Google. We may also disclose data where required by law, or to protect our legal rights.

05International transfers

Some of the tools we use to run the business are hosted outside the UK, including in the United States. Where that happens, we rely on adequacy regulations or Standard Contractual Clauses (or an equivalent, approved safeguard) to make sure your data stays protected to a UK standard.

06How long we keep it

We keep enquiry and lead data for as long as reasonably needed to follow up, and delete it if nothing progresses within 24 months. Client data is kept for the duration of the engagement and afterwards only as long as needed to meet our legal, accounting and tax obligations (normally up to 7 years for financial records).

07Cookies and advert measurement

This site sets no cookies and stores nothing in your browser (no cookies, local storage or session storage). It runs no analytics or advertising tags. If that changes, we'll update this policy and, where required, ask for your consent first.

Advert labels. When you click one of our adverts, the advertising platform adds labels to the page address: campaign labels (beginning "utm_", and Google's campaign number "gad_campaignid") and a click identifier (Google's "gclid", "gbraid" or "wbraid", or Meta's "fbclid"). If you send us a form on the page you land on, the campaign labels go with it, together with the name of the page itself, so we know which advert or post brought you. They are not kept anywhere in your browser, and they are not sent if you move to another page first.

Telling Google that our advert worked (optional). When you arrive from an advert, our forms show a box asking whether we may tell the platform that you came from its advert. Only if you tick it do we keep the click identifier with your enquiry. For Google adverts, we then use it to tell Google Ads that the click led to an enquiry, and later whether it became a qualified enquiry and whether you became a client, with the value of the work. We send Google the click identifier, the kind of outcome, when it happened and, for a client, the value. We don't send your name, email address, phone number or answers. We do this to see which adverts work and so that Google can show our adverts to people more likely to need us. Google uses what we send under its own terms and privacy policy.

The legal basis is your consent. Leaving the box unticked makes no difference to your report, guide or call. You can withdraw your consent at any time by emailing hello@claromai.com, and we'll send Google nothing further about you. We keep the click identifier only as long as the rest of your enquiry (section 06).

08Your rights

Under UK GDPR, you have the right to:

• Access: ask what personal data we hold about you.
• Rectification: ask us to correct inaccurate data.
• Erasure: ask us to delete data we no longer need.
• Restriction: ask us to limit how we use your data.
• Portability: get your data in a portable format.
• Objection: object to processing based on legitimate interests.

To exercise any of these, email hello@claromai.com. If you're unhappy with how we've handled your data, you can also complain to the Information Commissioner's Office (ICO) at ico.org.uk.

09Security

We use reasonable technical and organisational measures to protect the data we hold, including access controls and working only with reputable service providers. No method of transmission or storage is completely secure, but we take proportionate steps to keep your data safe.

10Children's privacy

This site and our services are aimed at business owners and are not directed at children. We do not knowingly collect personal data from anyone under 16.

11Changes to this policy

We may update this policy from time to time, for example as our tools or services change. We'll update the date at the top of this page when we do, so please check back periodically.

12Claromai Ops

This section applies to Claromai Ops, our advertising management application, and sits alongside the rest of this policy. It covers people who hold a Claromai Ops account and the data their organisation connects to it.

Account data. We hold each user's name, email address, role, a protected (hashed) form of their password, and a log of sign-ins and administrative actions. We use this to provide and secure the service, on the basis of our contract with the customer.

Advertising platform data. When a customer connects an advertising platform such as Meta (Facebook and Instagram) or LinkedIn, they sign in with that platform and authorise Claromai Ops to read their advertising data. We receive the names and identifiers of ad accounts and campaigns, and daily figures for spend, impressions, clicks and conversions. We use this to show that customer their own reports, forecasts and recommendations. If the customer turns on conversion reporting for Google Ads, Claromai Ops also sets up the conversion actions it needs in their Google Ads account and reports the outcome of their leads to it (see Leads below). Claromai Ops does not create, change or pause adverts, budgets or targeting. We do not sell this data, use it for our own advertising, share it with other customers, or combine it across customers. The access keys issued by each platform are stored encrypted.

Leads. A customer can choose to have enquiries from their own website forms, or from an advertising platform's lead forms, collected in Claromai Ops. These may include a person's name, email address, business name and message. For this data the customer is the data controller and we act as their processor, handling it only on their instructions. We do not store the IP address or browser details of the person who submitted an enquiry. If the customer connects their own CRM, leads are sent to it on their instruction. Where a lead came from a Google advert and the person ticked a box agreeing to it, the lead also holds Google's click identifier, and, if the customer has turned on conversion reporting, Claromai Ops sends Google that identifier with the lead's outcome (enquiry, qualified, client and its value) and the person's consent. It sends no names or contact details.

Where it is held. Claromai Ops is hosted by Netlify, and its database by Turso, both in the United States, under the safeguards described in section 05. Stored access keys are encrypted, and each organisation's data is kept separate from every other's.

How long we keep it. We keep this data for as long as the customer's account is open. Disconnecting an advertising platform in the application removes the stored access key and the advertising data received through it. When an account is closed we delete its data within 30 days, other than records we must keep by law.

Deleting your data. To have data held in Claromai Ops deleted, including data received from Meta or another advertising platform, disconnect the platform in the application or email hello@claromai.com from the address on the account. We will confirm once it is done. You can also withdraw Claromai Ops's access at any time in the advertising platform's own settings.

13Contact us

Questions about this policy or your data? Email hello@claromai.com, call 020 8064 0269 or write to us at Jack Summer Ltd (trading as Claromai), 20-22 Wenlock Road, London, N1 7GU.