House of Cleo LLC ("House Cleo," "we," "us") respects your privacy. This Privacy Policy explains what personal information we collect, why we collect it, who we share it with, and what you can ask us to do about it. It covers our website, the House Cleo portal, and the assurance, verification and advisory work we do on an engagement — including the site data and survey records we receive and hold.
House of Cleo LLC is the controller of the personal information described here. Questions and requests go to admin@housecleo.com.
// SECTION 01Information we collect
We collect information necessary to provide our services effectively:
- Account information
- Name, email address, company details, role, and authentication credentials when an account is created for you.
- Contact form
- Name, email address, company, and whatever you write in the message when you use the contact form on our website. We use it to answer you and to scope potential work.
- Newsletter
- Email address, when you subscribe. We use it only to send the newsletter, and every send includes an unsubscribe link.
- Project data
- Point clouds, scans, models, drawings, images, and related project files you upload, a subcontractor delivers to us, or we produce for your engagement.
- Usage data
- Information about how you interact with our portal, including access logs, feature usage, and performance metrics.
- Device information
- Browser type, IP address, device identifiers, and operating system for security and optimization.
We do not knowingly collect sensitive personal information — government IDs, financial account numbers, health data, biometric identifiers, precise consumer location — and we ask that you do not send it to us.
// SECTION 02Site data & survey records
House Cleo writes the survey specification for an engagement; a specialist subcontractor performs the survey work against it, and the resulting data is delivered to us. We review it, hold it, and issue it as part of the project record. That data deserves its own explanation.
- Survey data
- Laser scans, photographic panoramas, and site photography delivered to us by a specialist subcontractor, which we review against the survey specification and hold as part of the record.
- Our own site documentation
- Notes, measurements, mark-ups, and photographs taken by us when attending site to observe and verify.
- Client drawings and design data
- Drawings, models, specifications, control data, and site addresses supplied by you or your consultants. These sometimes contain names, contact details, and signatures in title blocks and revision histories.
- Site contacts
- Names, phone numbers, and email addresses of the people who arrange access, escort attendance, or sign off on work.
Site addresses, drawings, control data and datums, and site-contact details are passed to the specialist subcontractor so it can perform the survey work. That disclosure is described in Section 05.
People recorded incidentally
A survey on an active site can incidentally record people who happen to be in the space — workers, occupants, passers-by. This is a by-product of measuring a building, not the point of it, and it is true of every measured record held for a project, whoever produced it.
We do not use scans or site imagery to identify, track, or monitor anyone. We do not run facial recognition or any other biometric process on the data we hold, we do not extract, index, tag, or analyse incidental personal imagery, and we do not sell or license it to anyone. Subcontractors are engaged under written confidentiality terms that hold them to the same restriction. Scan and image data is held for the project it was recorded for, released only to the client and the people that client authorizes, and retained under Section 10. If you believe you appear in a scan and want to ask about it, write to admin@housecleo.com — practical note: we will need enough detail about the site and date to locate the data at all.
// SECTION 03How we use your information
Your information enables us to deliver and improve our services:
- Service delivery
- Specify the survey work and instruct a subcontractor, review and store the data returned, verify and document what was built, and manage your account and project files.
- Enquiries and quoting
- Respond to contact form submissions, scope work, and issue proposals and quotes.
- Communication
- Send updates about your projects, account security, and service changes.
- Marketing
- Send the newsletter to people who have asked for it. You can unsubscribe at any time.
- Platform improvement
- Analyze aggregate usage patterns to improve performance and the user experience.
- Security
- Detect and prevent unauthorized access, fraud, and technical issues.
- Legal compliance
- Meet regulatory requirements, keep business records, and respond to lawful requests.
We do not use your project data to train machine learning models, and we do not use it for any purpose outside your engagement.
// SECTION 04Data storage & security
These are the measures actually in place:
- Encryption in transit
- All traffic to our website and portal is served over TLS.
- Encryption at rest
- Stored data is encrypted at rest by our infrastructure providers.
- Reputable infrastructure
- Data is held on Firebase and Google Cloud Platform rather than on hardware we manage ourselves, so it sits behind their physical and network security.
- Access limited to those who need it
- Role-based access controls in the portal, and internal access restricted to the people working on your project.
- Authentication
- Firebase Authentication, with multi-factor authentication available.
We are a small practice, not a security vendor. We do not claim certifications we do not hold, and no system is completely secure. Keep independent backups of anything critical.
// SECTION 06Your rights & choices
Whoever and wherever you are, you can ask us to:
- Access & export
- Give you copies of your personal data and project files.
- Correct
- Fix inaccurate or incomplete information.
- Delete
- Delete your account and associated data, subject to legal and contractual retention requirements.
- Port
- Export your scan data and deliverables in standard formats.
- Opt out
- Unsubscribe from the newsletter and other marketing while still receiving essential service emails.
Write to admin@housecleo.com. We may need to verify your identity before we act, and we will not charge you or treat you differently for making a request. Sections 08 and 09 add specific rights for California, UK, and European residents.
// SECTION 08California privacy rights
This section applies to California residents under the California Consumer Privacy Act, as amended by the CPRA. It is also our notice at collection: we collect the categories below at the point you contact us, subscribe, or are given portal access, for the purposes described in Section 03, and we retain them as described in Section 10.
Categories we collect and disclose
- Identifiers
- Name, email address, phone number, company, IP address, account identifiers. Disclosed to our hosting, email, and analytics providers, and — for site contacts on a project needing field survey work — to the specialist subcontractor engaged for it.
- Commercial information
- Services enquired about, quoted, and delivered; invoicing records. Disclosed to our accounting and payment providers.
- Internet and network activity
- Portal access logs, website usage, device and browser information. Disclosed to our hosting and analytics providers.
- Geolocation data
- Addresses of the sites we are engaged on, and approximate location derived from IP address. Disclosed to our hosting and analytics providers, and to the specialist subcontractor where survey work is specified for the site.
- Audio, visual, and similar information
- Site photography and laser scan data received from a specialist subcontractor or recorded by us when attending site, which may incidentally include images of people (Section 02). Disclosed to our hosting provider and to the people you authorize on the project.
- Professional information
- Job title, employer, and role on the project. Disclosed to our hosting and email providers.
We collect these from you directly, from your colleagues and consultants, from your use of our website and portal, from what we observe when attending site, and from the survey data our subcontractors deliver to us. We do not collect personal information from data brokers.
No sale, no sharing
We do not sell personal information, and we do not share it for cross-context behavioural advertising. We have not done so in the preceding twelve months, including for consumers under 16. We also do not use or disclose sensitive personal information for purposes requiring a right to limit.
Your rights
- Know — what we have collected, the sources, the purposes, and who we disclosed it to
- Access — a copy of the specific pieces of personal information we hold
- Delete — deletion of your personal information, subject to legal exceptions
- Correct — correction of inaccurate personal information
- Opt out — of sale or sharing (we do neither, so there is nothing to opt out of)
- Non-discrimination — we will not deny service, charge a different price, or provide a lesser quality of service because you exercised a right
How to make a request
Email admin@housecleo.com with "California privacy request" in the subject line and tell us what you want. We will confirm receipt within 10 business days and respond within 45 days, extending once by a further 45 days where the request is complex, in which case we will tell you why before the first period expires.
We will ask for information sufficient to verify that you are the person whose data is at issue. An authorized agent may make a request on your behalf by providing written permission signed by you; we may also contact you directly to confirm the authorization, unless the agent holds a valid power of attorney.
// SECTION 09UK & European privacy rights
This section applies if you are in the United Kingdom, the European Economic Area, or Switzerland.
Controller
The controller of your personal data is House of Cleo LLC, Miami, FL, United States. Contact: admin@housecleo.com.
Lawful bases
- Performance of a contract
- Delivering an engagement, instructing a specialist subcontractor and receiving the survey data it returns, providing portal access, issuing and collecting invoices, and communicating about your project.
- Legitimate interests
- Responding to enquiries, securing our systems, understanding website usage, keeping records of work performed, and establishing or defending legal claims. We balance these against your rights and use the least intrusive approach that works.
- Consent
- Sending the newsletter. We set no non-essential cookies, so there is nothing else here that runs on consent (Section 07). You can withdraw consent at any time, without affecting processing carried out before you withdrew it.
- Legal obligation
- Tax, accounting, and other record-keeping required by law.
Your rights
- Access — a copy of the personal data we hold about you
- Rectification — correction of inaccurate or incomplete data
- Erasure — deletion, where we have no overriding basis to keep it
- Restriction — pause our processing while a dispute about it is resolved
- Portability — data you gave us, in a structured, machine-readable format
- Objection — to processing based on legitimate interests, and at any time to direct marketing
- Withdraw consent — for anything we do on the basis of consent
- Automated decisions — we do not make decisions about you by automated means or profile you
Email admin@housecleo.com. We respond within one month and will tell you if we need a permitted extension.
Complaints
You have the right to lodge a complaint with your supervisory authority — in the UK, the Information Commissioner's Office; in the EEA, the data protection authority of the country where you live, work, or where the issue arose. We would appreciate the chance to address it first.
International transfers
We are based in the United States and your data is processed there. The safeguards we rely on for transfers out of the UK, EEA, and Switzerland are set out in Section 13.
// SECTION 10Data retention
We retain information for as long as necessary to provide our services and comply with legal obligations:
- Active accounts and engagements
- Data is retained while your account is active or your engagement is live.
- Closed accounts
- You have 30 days to retrieve your data, and we delete personal information and project files within 90 days of closure, except where retention is required by law.
- Project files
- Scan data and deliverables follow the same 30-day retrieval, 90-day deletion timeline, or the period agreed in your engagement if it is longer. This matches Section 08 of our Terms of Use.
- Inactive accounts
- We may close an account after 24 months of inactivity, with written notice and a retrieval window before anything is deleted.
- Business records
- Invoices, contracts, and correspondence are kept for as long as tax and limitation periods require.
- Newsletter
- Your email address is kept until you unsubscribe, plus a suppression record so we do not re-add you.
Backups are overwritten on a rolling cycle and are purged in the ordinary course.
// SECTION 11Security incidents
If personal information we hold is subject to a breach of security that is likely to cause harm, we will investigate, take steps to contain it, and notify affected individuals and the relevant regulators without undue delay where notification is required by applicable law — including within any statutory deadline, such as the 72-hour window that applies to regulators under UK and EU law. Notices will describe what happened, what information was involved, what we are doing about it, and what you can do.
If you believe you have found a security problem in our website or portal, tell us at admin@housecleo.com.
// SECTION 12Children's privacy
Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected data from a child, we will take prompt steps to delete it.
// SECTION 13International data transfers
House of Cleo LLC is based in Miami, FL, and our infrastructure providers process data in the United States. If you are outside the United States, using our services means your information is transferred there, where data protection law may differ from your own.
For transfers out of the UK, EEA, or Switzerland we rely on the European Commission's Standard Contractual Clauses and, where applicable, the UK International Data Transfer Addendum. These are incorporated into our agreements with our infrastructure and email providers, and they sit alongside the technical measures described in Section 04. The rights that go with those transfers are in Section 09.
// SECTION 14Changes to this policy
We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will change the "Last Updated" date at the top, and for material changes we will notify you by email or through a prominent notice on the portal before they take effect.
// CONTACTContact us
If you have questions, concerns, or requests regarding your privacy or this policy, please contact us:
House of Cleo LLC
Miami, FL, US
Email: admin@housecleo.com
Web: housecleo.com/contact