Draft: to be reviewed by a lawyer before launch.

Privacy policy

Last updated: [DATE]

This policy covers the Clickable website and the Clickable extension for Google Chrome. Clickable shows you where to click on a website. You do every click yourself: Clickable never clicks, types, submits, signs or pays for you.

Who is responsible

The data controller is [COMPANY OR FULL NAME], NIF [NIF], [ADDRESS]. Contact: [CONTACT EMAIL].

The Chrome extension

When it reads a page

Only after you type a goal (for example “Download last month’s statement”) and pressGuide me, and then on each page you reach while that task is running. When the task ends, or you close it, it stops reading.

What it reads and sends

To pick the next step, the extension sends a short summary of the page to our server:

• the goal you typed, and your answers if Clickable asks you a question;
• the page address (URL) and title;
• the visible buttons, links, menus and form fields: their labels, position on the page, and whether a field or a rich-text box (such as an email body) is empty or filled, a box ticked, or which menu option is selected;
• up to 15 headings, and a short excerpt of the visible text on the page (at most 1,500 characters), including warnings and error messages. Text typed into rich-text boxes is cut out of the excerpt;
• the steps already taken in the current task;
• a random install ID, made by the extension the first time it runs, and the extension version. The ID says nothing about you; we use it only to apply fair-use limits (how many steps one install can ask for per minute and per day).

To stop one person from bypassing those limits, our server also counts requests per network (IP) address. It keeps only a scrambled (hashed) form of the address, in memory, for the current day, and never writes it to its logs.

What it never reads or sends

• The text you type into a website’s fields or rich-text boxes (such as an email body or a chat box). It sees only whether they are empty or filled.
• Passwords.
• The sign-in pages of Cl@ve, Google, Microsoft, GOV.UK One Login, Government Gateway and NHS login. Clickable pauses there and sends nothing unless you press Help me on this page. On any other website’s login form, your password and what you type are never sent either.
• Sections embedded from other websites (iframes): they aren’t read at all for now.
• Pages you haven’t asked for help with, and your browsing history.

Visible text on a page can still contain personal information (for example your name shown in a page header). Use Clickable only on pages where you are comfortable sharing the visible text for this purpose.

What stays on your computer

• Your settings (such as the guide quality), the install ID and, if you sign in, a sign-in token, in Chrome’s extension storage.
• The current task, in Chrome’s session storage. It is deleted when you close Chrome.
• The website name shown at the top of the panel, and the suggested goals. They are worked out on your computer and not sent.

If you press Copy on a suggested text, Clickable writes it to your clipboard. You paste it yourself.

Your account, plan and usage

• Without an account: we count your tasks per month against the random install ID. To stop the free tasks being reset by reinstalling, we also count them against a scrambled (keyed hash) form of your network address, kept for at most two months.
• With an account: we keep your email address, how you signed in (email code or Google; with Google we receive only your email address), your sign-in sessions and your plan.
• Usage counts: for each task we keep only when it started, how many steps it took and whether it finished. Never the goal you typed, the page address or the page content.
• Feedback: if you answer “Did this work?” or report a problem, we keep your answer and comment. The summary of the page is included only if you tick “Include what Clickable saw on this page” for that report.
• Uninstall survey: the optional goodbye page sends your answer anonymously.
• You can delete your account, and with it your usage history and feedback, from the extension at any time.

Payments

If you buy Plus, Paddle.com Market Limited processes the payment as our reseller (merchant of record): it collects your payment details, billing address and VAT information under its own privacy policy. We receive only a customer ID, the subscription status and its renewal date, which we link to your account.

How the page summary is processed

Our server forwards the summary to our AI model provider, Anthropic, which returns the next element to highlight. Our server’s logs record only the outcome and timing of each step, not the page address, the goal or the page content. [HOW LONG THE HOSTING PROVIDER KEEPS THESE LOGS.] We don’t use your page summaries to train AI models, and Anthropic doesn’t train its models on data sent through its API under its commercial terms. [CONFIRM how long Anthropic keeps API requests under our agreement.]

The website

• The website sets no cookies. [IF CLOUDFLARE WEB ANALYTICS IS TURNED ON: “We count visits with Cloudflare Web Analytics, which doesn’t use cookies or fingerprinting and doesn’t track you across sites.”] See the cookie policy.
• Fonts and images are served from our own site. Other companies are involved only when you submit a form (the email box goes to our CRM) or open the checkout (Paddle’s payment page).
• Our hosting provider (Cloudflare, through Cloudflare Pages) processes technical data such as your IP address to deliver the page and protect it from attacks.
• If you leave your email to get the install link or to request a pilot call, we keep your email, what you’d use Clickable for (if you chose), whether you asked for news, the page you signed up on and any campaign tags in its address. We use them to send you the install link or reply about the call and, only if you ticked the box, to send occasional news. These are stored in our CRM (HubSpot) for [HOW LONG]. You can ask us to delete them at any time.
• If you email us, we use your email only to reply.

Why we process data (legal basis)

• Extension page summaries: to provide the service you asked for (contract, art. 6.1.b GDPR).
• Hosting and security logs: our legitimate interest in running a secure service (art. 6.1.f GDPR).
• Account, plan, usage counts and payments: to provide the service and the plan you chose (contract, art. 6.1.b GDPR).
• The address-based count against free-tier abuse, and voluntary feedback: our legitimate interest in a fair, working service (art. 6.1.f GDPR).
• Email box: your request to get the install link or a call (art. 6.1.b GDPR); news emails only with your consent (art. 6.1.a GDPR), which you can withdraw at any time.
• Emails you send us: to answer you (art. 6.1.b or 6.1.f GDPR).

Who processes data for us

Where data leaves the European Economic Area, we rely on [STANDARD CONTRACTUAL CLAUSES / ADEQUACY DECISION].

Chrome Web Store: limited use

Clickable’s use of information received from Chrome follows theChrome Web Store User Data Policy, including its Limited Use requirements. We use page data only to show you the next step. We don’t sell it, don’t use it for advertising or credit decisions, and don’t let people read it except where needed for security, to comply with the law, or with your permission.

Your rights

You can ask to access, correct, delete, restrict or move your data, and object to processing, by writing to [CONTACT EMAIL]. You can also complain to your data protection authority (in Spain, theAEPD). Uninstalling the extension deletes everything it stored on your computer.

Children

Clickable is not meant for children under [AGE, e.g. 14 in Spain].

Changes

If we change this policy, we’ll update the date at the top and, for important changes, tell you in the extension.