Privacy Policy

Last updated: 6 July 2026

This Privacy Policy explains how Climent Media ("we", "us", "our") handles personal data. We are an AI adoption and automation studio based in the Netherlands, and privacy is a design principle of everything we build — including this website.

1. Who we are (data controller)

Climent Media
Registered in the Netherlands — Dutch Chamber of Commerce (KVK): 96588012
Based in Utrecht, The Netherlands
Email: manuel@climentmedia.com

Our full registered company details are available in the company details section of our Terms of Service.

2. Data we collect on this website

None, by design. This website:

• sets no cookies (not even "functional" ones);
• uses no analytics (no Google Analytics, no Meta Pixel, no heatmaps);
• loads no third-party resources (no external fonts, scripts or CDNs);
• contains no contact forms — you reach us directly by email or phone.

When you book a call, we link out to Calendly (a third-party scheduling service); its own cookies and privacy policy apply once you land on their page, not on ours.

Our hosting provider may keep short-lived technical server logs (such as IP address, requested URL and timestamp) for security and operational purposes. We do not use these logs to identify visitors.

3. Data we process when you contact us

If you email or call us, we process the personal data you choose to share (name, email address, phone number and the content of your message) to respond to you and to manage our business relationship. Legal basis: our legitimate interest in responding to enquiries (Art. 6(1)(f) GDPR) or steps prior to entering into a contract (Art. 6(1)(b) GDPR).

4. Data we store in our applications

Some of our applications require an account. When you register in one of our applications, we do store the data you provide — such as your name, email address and company — because we need it to deliver the service to you. This is the only context in which we store user data on our own initiative: we only store data of clients and leads, never of casual visitors.

Legal basis: performance of a contract or steps prior to entering into one (Art. 6(1)(b) GDPR). Account data is kept while your account is active and deleted when the account is closed, except where a legal retention duty applies. You can request deletion at any time — see our Data Deletion page.

5. Data we process when delivering services

Climent Media builds AI, reporting and automation systems for clients. In doing so, we may process data on behalf of our clients, typically:

• Business contact data — names, business email addresses and roles of client team members;
• Advertising and analytics data — campaign metrics, spend, performance and measurement data from platforms such as Meta and Google (see section 6);
• Operational data — documents, briefs and workflow data our clients ask us to work with.

Where we process personal data on behalf of a client, we act as a processor under Art. 28 GDPR and enter into a data processing agreement with that client. We follow least-privilege principles: our integrations request the narrowest access the platform offers, are limited to the specific accounts a client designates, and we do not store personal data in logs or documentation.

6. Platform data — Google and Meta integrations

Some of our systems connect to third-party platforms (such as Google Ads, Google Analytics, Google Search Console and Meta advertising accounts) through their official APIs, always with the explicit authorisation of the account owner via OAuth.

This section covers the platform Climent Media builds and operates on a client's behalf — the Google OAuth application registered as “Climent Media”. It does not cover deployments you host yourself; see section 6.4.

6.1 Google API Services

Climent Media's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. In particular:

• we only use Google user data to provide and improve the reporting and automation features the account owner has requested;
• we do not transfer Google user data to third parties, except as necessary to provide those features, to comply with the law, or with the user's explicit consent;
• we do not use Google user data for advertising purposes;
• we do not allow humans to read Google user data unless the account owner has given explicit permission, it is necessary for security or legal reasons, or the data has been aggregated and anonymised;
• we do not use Google user data, including Google Workspace data, to train or develop generalised artificial intelligence or machine learning models.

6.2 Meta Platform Data

Where our systems access Meta Platform Data (such as advertising account metrics), we do so under the Meta Platform Terms: access is authorised by the account owner, limited to the designated accounts, used solely to deliver the requested reporting and automation services, and never sold or shared with third parties.

6.3 Revoking access

Account owners can revoke our access at any time via Google Account permissions or Meta Business Integrations settings, or by asking us to disconnect. See our Data Deletion page for how to request deletion of stored data.

6.4 Self-hosted and open-source deployments

We also publish an open-source version of our ads console that you can run on your own infrastructure. When you self-host it, you connect your own Google and Meta accounts with credentials you control, and the data stays on your machines: Climent Media does not receive, process or store any of it, and is neither controller nor processor for a deployment it does not operate. Responsibility for that instance — access, storage, retention and security — sits with whoever runs it.

If instead we set it up for you or run it as a managed service, the access is granted to the “Climent Media” application and sections 6.1 to 6.3 apply in full.

6.5 Hosted accounts

Where you register an account in a hosted version of the product that we operate, and connect your own Google or Meta advertising accounts to it, the following applies:

• You authorise the connection. It is made through the platforms' official OAuth flows, only with the scopes you approve, and only for the accounts you designate. You are the account owner granting access and you can revoke it at any time — see section 6.3.
• We act as a processor on your behalf under Art. 28 GDPR. The commitments in sections 6.1 and 6.2 — including Google's Limited Use requirements and the Meta Platform Terms — apply in full to that data.
• Nothing changes without your approval. We request the narrowest scopes the platform offers, and no campaign, budget or setting is created, changed, paused or spent from the product unless you have explicitly approved that change.
• What we store. The registration data described in section 4, the connection metadata needed to keep the integration working, and the imported performance data required to produce your reporting. Retention is covered in section 8.
• Leaving. You can disconnect any platform, or delete your account and the data associated with it, at any time — see our Data Deletion page. Disconnecting also stops any further import.

We do not sell your data, do not use it for advertising, and do not use it to train or develop generalised AI or machine-learning models.

7. Sharing and transfers

We do not sell personal data. We share personal data only with:

• Infrastructure providers (hosting and server providers located in the EU) that store data on our behalf;
• Platform providers (Google, Meta) to the extent inherent in operating an authorised API integration;
• Authorities, where required by law.

Where a transfer outside the European Economic Area occurs, we rely on adequacy decisions or Standard Contractual Clauses.

8. Retention

• Correspondence: kept as long as needed to handle the enquiry or relationship, then deleted;
• Client project data: kept for the duration of the engagement and deleted or returned at its end, unless a longer period is agreed or legally required;
• Records we must keep under Dutch tax law (e.g. invoices): 7 years.

9. Security

We apply technical and organisational measures appropriate to the risk, including encrypted connections (TLS), encrypted credential storage, least-privilege API scopes, access controls, and audit logging without personal data.

10. Your rights

Under the GDPR you have the right to access, rectify, erase, restrict or object to the processing of your personal data, and the right to data portability. To exercise any right, email manuel@climentmedia.com. We respond within 30 days.

You also have the right to lodge a complaint with the Dutch supervisory authority, the Autoriteit Persoonsgegevens.

11. Changes to this policy

We may update this policy from time to time. The "Last updated" date at the top reflects the latest version. Material changes will be highlighted on this page.