Clyr

Privacy Policy

Effective Date: September 30, 2025

Last Updated: September 30, 2025

1) Who We Are

This Privacy Policy ("Policy") explains how Aquatech Partners d/b/a Clyrpool ("Clyrpool," "we," "us," or "our") collects, uses, discloses, and protects personal information when you visit our websites, mobile apps, and online services that link to this Policy (collectively, the "Services").

If you are located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, Aquatech Partners d/b/a Clyrpool is the data controller for your personal data unless we state otherwise. If we provide services to a business customer under a contract, we may act as a processor on that customer’s instructions—when that happens, our customer’s privacy notice governs and our processing is subject to our data processing addendum.

Contact

Email: support@clyrpool.com

Postal: Aquatech Partners, Attn: Privacy Team, mailing details available upon request via email.

EU/UK Representative (if applicable): Not currently appointed; we will update this notice when designated.

Data Protection Officer (if applicable): Not currently appointed.

2) Scope

This Policy applies to personal information we collect from or about individuals using the Services, communicating with us, or otherwise interacting with Clyrpool. It does not apply to third-party websites, apps, or services that may link to or from the Services; those are governed by their own policies.

3) Quick Summary (Plain English)

  • We collect first name, last name, email address, postal/shipping/billing addresses, and phone number, plus information you enter into the product (e.g., dosing data, pool/spa details), device/usage data, and cookies/analytics.
  • We do not resell your personal information to third parties, nor do we "sell" or "share" personal information for cross-context behavioral advertising as defined by certain privacy laws (e.g., California).
  • We use your information to operate and improve the Services, provide support, communicate with you, comply with law, and secure our systems.
  • You have privacy rights. Depending on your location, these may include access, correction, deletion, portability, restriction/objection, and choices about cookies and marketing.
  • Dosing outputs are informational only and are not professional, safety, or regulatory advice. You remain responsible for decisions and outcomes based on your use of dosing recommendations. See Section 10.
  • We comply with applicable data protection laws and use safeguards to protect your information.

4) Information We Collect

4.1 Information You Provide to Us

Account & Contact Data: First name, last name, email address, postal/shipping/billing address, and phone number.

Credentials & Security: Account identifiers, hashed passwords, authentication tokens, and security preferences.

Dosing & Pool/Equipment Data ("Dosing Data"): Water test inputs (e.g., pH, chlorine/bromine levels, calcium hardness, alkalinity, cyanuric acid), pool/spa dimensions and volume, equipment details (filters, pumps, feeders, sensors), chemical brands/types on hand, target setpoints, dosage entries, treatment history, schedules, notes, and images you upload (e.g., equipment labels).

Support & Communications: Messages, feedback, problem reports, survey responses, and any content you send us.

We do not intentionally collect "special categories" of personal data (e.g., health, biometric, or sensitive data) unless you choose to provide content that contains such information. Please avoid including sensitive personal data in free-text fields.

4.2 Information Collected Automatically

Usage & Device Data: IP address, device identifiers, browser type, app version, operating system, referring/exit pages, error logs, pages viewed, features used, time on page, and interaction data.

Cookies & Similar Technologies: Cookies, local storage, and similar tools for essential site functions, analytics, remembering your preferences, and (if enabled) first-party marketing measurement. See Section 11.

4.3 Information from Third Parties

Service Providers & Partners: We may receive limited data to operate the Services (e.g., fraud prevention signals, analytics).

Single Sign-On (if enabled): Email and profile basics from identity providers you choose (e.g., Google, Apple).

IoT/Connected Devices (if you connect them): Telemetry like flow rates, temperatures, sensor readings, and equipment status.

5) How We Use Personal Information

  • Provide the Services, including account management, dosing tools, and troubleshooting.
  • Process transactions (if applicable), fulfill requests, and provide customer support.
  • Personalize experiences, save pool profiles, preferences, and targets, and suggest workflows.
  • Analyze and improve the Services through analytics, testing, and quality assurance.
  • Communicate with you about service-related notices, feature updates, security alerts, and—with your consent where required—marketing messages.
  • Ensure security and prevent fraud through monitoring, detection, and incident response.
  • Comply with legal obligations such as tax, accounting, and regulatory requests.
  • Create de-identified or aggregated data for statistical insights without re-identifying individuals.

6) Our Legal Bases (EEA/UK/Switzerland)

  • Contractual necessity for account creation, dosing tools, and support.
  • Legitimate interests to secure the Services, understand usage, prevent abuse, and improve features while balancing your rights.
  • Consent for optional cookies/analytics, certain marketing, and connecting third-party or IoT integrations. You can withdraw consent at any time.
  • Legal obligation to comply with applicable laws and regulations.

7) No Selling or Reselling of Personal Information

We do not sell personal information and do not resell personal information to third parties. We do not "share" personal information for cross-context behavioral advertising under California law. If our practices change, we will update this Policy and provide required opt-out mechanisms before any change takes effect.

8) How We Disclose Information

  • Service Providers / Processors who help us run the Services (hosting, cloud infrastructure, email delivery, analytics, customer support) under written contracts.
  • Affiliates within our corporate group for purposes consistent with this Policy.
  • Legal & Safety disclosures to comply with law or protect rights, safety, and property.
  • Business Transfers in connection with mergers, acquisitions, financing, or sales of assets.
  • With Your Direction or Consent, such as when you connect a third-party device or service.

We do not disclose personal information to third parties for their independent marketing purposes.

9) Data Retention

We retain personal information only as long as necessary for the purposes described in this Policy, including legal, accounting, and reporting requirements. Typical guidelines:

  • Account & Contact Data: Life of the account plus approximately 24 months after closure.
  • Dosing Data & Pool Profiles: While the account is active; you may delete entries in-product. Backups may persist for 30–90 days.
  • Support Communications: Up to 24 months for quality and audit purposes.
  • Transaction Records (if any): Retained for at least seven years to satisfy tax and financial laws.

10) Important Safety/Use Disclosure — Dosing Data & Recommendations

Clyrpool’s dosing calculators, recommendations, alerts, and related outputs (collectively, "Dosing Recommendations") are informational tools intended to assist with pool/spa water maintenance. They do not constitute professional, safety, regulatory, or environmental advice, and are not a substitute for manufacturer instructions, on-site testing, professional services, or compliance with local codes and regulations.

You are solely responsible for selecting, storing, handling, and applying chemicals, verifying measurements, and all decisions you make using the Services. To the maximum extent permitted by law, Clyrpool disclaims liability for loss, damage, or injury arising from your use of Dosing Recommendations. Always follow product labels and safety data sheets, wear appropriate protective gear, maintain adequate ventilation, and keep chemicals away from children and pets.

This disclosure supplements our Terms of Use, which govern your use of the Services and may include additional or superseding terms.

11) Cookies, Analytics, and Similar Technologies

We use essential cookies for core functionality, functional cookies to remember preferences, analytics cookies to understand usage, and (if enabled) first-party marketing measurement. Manage non-essential cookies through our Cookie Settings and your browser/device controls. If you opt out, some features may not function. We honor Global Privacy Control (GPC) signals where required by law.

12) Marketing Communications

We will send service-related emails such as security notices and transactional messages. We may send marketing communications if you opt in or as otherwise permitted by law. You can opt out at any time via the unsubscribe link or by contacting us. Opting out of marketing does not affect service-related communications.

13) International Data Transfers

We may transfer, store, and process your information in countries other than where you live, including the United States. When we transfer personal data from the EEA/UK/Switzerland, we rely on adequacy decisions (where available) and/or Standard Contractual Clauses (SCCs) and implement supplementary measures appropriate to the transfer.

14) Security

We employ administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit, encryption or tokenization at rest where feasible, access controls and least-privilege permissions, multi-factor authentication for administrative access, vendor due diligence and contractual security obligations, and vulnerability management with logging/monitoring. No method of transmission or storage is 100% secure. If we learn of a data incident that affects your information, we will notify you and regulators as required by law.

15) Your Privacy Rights

Your rights depend on your location and applicable law, but may include the ability to access/know, correct, delete, port, restrict/object, withdraw consent, control cookies, and manage marketing communications. To exercise rights, email support@clyrpool.com with your request or, where available, submit a request through the in-product privacy settings. We may need to verify your identity. You may authorize an agent (where permitted) with proof of authorization.

15.1 EEA/UK/Switzerland

You may contact us using the details above or lodge a complaint with your local supervisory authority such as the Information Commissioner (UK) or your EEA authority.

15.2 California (CPRA)

We provide the rights to know, delete, correct, opt out of sale/sharing (not applicable today; see Section 7), and limit use of sensitive personal information (used only to provide the Services, for security, or as permitted by law). We do not retaliate for exercising rights.

Category (CPRA)Examples We CollectPurposeRetention (Typical)Disclosed To
IdentifiersName, email, phone, addresses, IPProvide Services, support, security, communicationsAccount life + ~24 monthsService providers; affiliates
Customer RecordsAccount profile, transaction basics (if any)Provide and support ServicesUp to 7 yearsService providers; affiliates
Internet/Network ActivityUsage logs, device data, analyticsImprove Services, security12–24 monthsAnalytics providers; security vendors
Geolocation (coarse)IP-based regionLocalization, security~12 monthsService providers
InferencesFeature-level preferences (e.g., targets)Personalize experienceWhile account activeNot sold/shared
Sensitive PIAccount credentials (hashed), auth tokensAuthentication, securityWhile account activeSecurity/service providers

We do not sell or share personal information as defined by CPRA. If this changes, we will provide a “Do Not Sell or Share My Personal Information” link before any new practices take effect.

15.3 Other U.S. States

Residents of Colorado, Connecticut, Virginia, Utah, and similar jurisdictions may have rights to access, correct, delete, obtain a copy, and opt out of targeted advertising/sale/profiling. We do not engage in sales or targeted advertising of personal information. You may appeal our response by emailingsupport@clyrpool.com with “Appeal” in the subject line.

15.4 Canada, Australia/New Zealand, Brazil

We honor rights to access, correction, and deletion, subject to legal exceptions. For Brazil (LGPD), we rely on legal bases such as performance of contract, legitimate interest, consent (where required), and legal obligation.

16) Children’s Privacy

The Services are not directed to children and are intended for individuals 16 and older (or the age required by your jurisdiction). We do not knowingly collect personal information from children. If you believe a child has provided personal information, contact us so we can delete it.

17) Your Choices

  • Account Controls: Review and update your profile, dosing targets, and pool data within the app.
  • Cookies: Use our Cookie Settings and your browser/device controls.
  • Marketing: Unsubscribe via our emails or contact us.
  • Third-Party Integrations: Connect or disconnect IoT devices or accounts at any time.

18) De-Identified and Aggregated Data

We may create and use de-identified or aggregated data for analytics, benchmarking, and feature development. We will not attempt to re-identify such data and will contractually require our service providers to do the same.

19) Third-Party Links and Integrations

The Services may link to third-party sites or allow you to enable integrations (e.g., device vendors). Your use of those features is subject to the third party’s terms and privacy policy. We are not responsible for their practices.

20) Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will notify you by posting the updated Policy and adjusting the Effective Date above, and, where required, seek your consent.

21) How to Contact Us

If you have questions or requests regarding this Policy or our privacy practices, contact us at:

Aquatech Partners d/b/a Clyrpool

Attn: Privacy Team

Email: support@clyrpool.com

Postal: Mailing details available upon request via email.

22) Region-Specific Disclosures

EU/UK Representative: Not currently appointed; we will update this notice if one is designated.

Data Protection Officer: Not currently appointed.

Nevada Residents: We do not sell covered information. You may submit inquiries to support@clyrpool.com.

23) Definitions (Selected)

  • “Personal information / personal data” means information that identifies, relates to, or could reasonably be linked to an identified or identifiable person.
  • “Processing” means any operation performed on personal data (collection, use, storage, disclosure, and so on).
  • “Service provider / processor” means a third party that processes data on our behalf under contract and cannot use it for their own purposes.
  • “Dosing Data / Dosing Recommendations” have the meanings described in Sections 4.1 and 10 of this Policy.