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View our Cookie PolicyHow we protect and handle your personal data
Under the General Data Protection Regulation (GDPR) and UK Data Protection Act 2018, you have comprehensive rights over your personal data. We are committed to protecting your privacy and providing transparent information about how we handle your data.
ACLUE LIMITED operates as the data controller for personal data processed through our platform. We are responsible for determining how and why your personal data is processed.
You may choose to create an account or sign in using a third-party provider such as Google (“Continue with Google”). When you do so, the provider shares limited profile information with us. We only request the minimum data needed for authentication and do not request access to any additional Google services (such as Gmail, Drive, or Contacts).
Our platform uses a personality quiz to understand your preferences and generate personalised gift recommendations.
Our platform allows you to connect with other users and share your gift profile.
Under GDPR, we must have a legal basis for processing your personal data. Here are the legal bases we rely on:
Processing necessary to provide our gift recommendation service, maintain your account, and deliver the core platform functionality. This includes processing your personality quiz responses and generating your SATNAM personality profile, as these are essential to delivering the personalised recommendations that form the core of our service.
Processing necessary for our legitimate business interests, such as improving our service, analytics, security, fraud prevention, and rate limiting to protect our platform from abuse.
Processing based on your explicit consent, which you can withdraw at any time by contacting us at contact@aclue.app.
Processing necessary to comply with legal obligations, such as tax requirements and regulatory compliance.
We use your personal data for the following purposes:
Providing personalised gift recommendations based on your personality profile, managing your account, and delivering core platform features
Using your personality quiz results and interaction history to tailor recommendations and improve suggestion accuracy
Sending service updates, responding to enquiries, providing customer support
Meeting legal obligations, maintaining records, complying with regulations
Analysing usage patterns, improving our algorithms, enhancing user experience
Protecting your account, detecting suspicious activity, rate limiting to prevent abuse, maintaining platform security
Sending promotional emails, product updates, and relevant offers (only if you have opted in)
When you click a product link and make a purchase on Amazon, ACLUE LIMITED earns a commission as an Amazon Associate. We track affiliate link clicks to support our free service model.
Our platform uses automated profiling to provide you with personalised gift recommendations. Under Article 22 of the GDPR, you have the right to be informed about how we use automated processing of your personal data.
When you complete our personality quiz, your responses are used to generate a personality profile consisting of six trait scores: Social, Aesthetic, Technology, Nature, Audio, and Motion. This profile is stored as part of your account.
Your personality profile is compared against our product database using automated similarity matching. Products with trait profiles similar to yours are identified as potential recommendations. These results are then refined through diversity reranking (to ensure variety) and calibration (to balance trait representation). Your interaction history (likes, dislikes) further influences subsequent recommendations.
This profiling determines which gift products are recommended to you and in what order. It does not produce legal effects or similarly significantly affect you beyond the personalisation of product suggestions. You are free to browse all products regardless of your profile.
You have the right to:
To exercise any of these rights, contact us at contact@aclue.app.
We never sell, rent, or trade your personal data to third parties for their marketing purposes.
We share data with trusted service providers who help us operate our platform:
We may disclose your data if required by law, legal process, or to protect our rights, your safety, or the safety of others.
In the event of a merger, acquisition, or sale of assets, your data may be transferred to the new entity, subject to the same privacy protections.
Your data may be transferred to and processed in countries outside the UK/EU. We ensure adequate protection through the following safeguards for each provider:
| Provider | Location | Safeguard |
|---|---|---|
| Supabase | EU/UK | Data processed within UK/EU adequacy area |
| US/Global | EU-US Data Privacy Framework | |
| Vercel | US/Global | Standard Contractual Clauses (SCCs) |
| Amazon | US/Global | Standard Contractual Clauses (SCCs) |
| Upstash | US | Standard Contractual Clauses (SCCs) |
We retain your personal data only for as long as necessary to fulfil the purposes outlined in this policy:
| Data Type | Retention Period | Reason |
|---|---|---|
| Account Data | Until account deletion + 30 days | Service provision and security |
| Personality Profile (SATNAM) | Until account deletion | Personalised recommendations |
| Preference and Interaction Data | Until account deletion | Personalisation and recommendations |
| Connection Data | Until connection removal or account deletion + 30 days | Social features and GDPR compliance |
| Usage Analytics | 26 months (aggregated data retained permanently) | Service improvement and analytics |
| Communication Records | 6 years | Legal compliance and support |
| Transaction Data | 7 years | Tax and legal compliance |
Anonymised Data: We may retain anonymised and aggregated data indefinitely for research and service improvement purposes, as it cannot be used to identify you.
Under GDPR and UK data protection law, you have the following rights regarding your personal data. To exercise any right, email us at contact@aclue.app and we will respond within 30 days.
Request a copy of the personal data we hold about you and information about how we process it.
Submit Access Request →Correct any inaccurate or incomplete personal data we hold about you.
Request Rectification →Request deletion of your personal data in certain circumstances.
Request Account Deletion →Receive your personal data in a structured, machine-readable format.
Request Data Export →Limit how we process your personal data in certain circumstances.
Request Restriction →Object to processing based on legitimate interests or for direct marketing.
Object to Processing →Withdraw your consent for processing at any time where we rely on consent.
Withdraw Consent →Lodge a complaint with the Information Commissioner's Office (ICO) if you are unsatisfied with how we handle your data.
ICO Complaints →Our service is intended for users aged 16 and over. We do not knowingly collect personal data from children under the age of 16.
If you are under 16: Please do not create an account or provide any personal data to us. If you believe that we have inadvertently collected personal data from a child under 16, please contact us immediately at contact@aclue.app and we will take steps to delete the data promptly.
If we become aware that we have collected personal data from a child under 16 without appropriate parental consent, we will delete that data as soon as reasonably practicable. Parents and guardians who believe their child may have provided data to us are encouraged to contact us using the details in Section 12.
We implement appropriate technical and organisational measures to protect your personal data:
In the unlikely event of a personal data breach that poses a risk to your rights and freedoms, we will notify the Information Commissioner's Office (ICO) within 72 hours as required by GDPR Article 33. Where a breach is likely to result in a high risk to you, we will also notify you directly without undue delay as required by Article 34, with details of the breach and recommended protective actions.
If you have any questions about this Privacy Policy, want to exercise your rights, or have concerns about how we handle your data:
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:
We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.
Last updated: 17 February 2026