<\!DOCTYPE html> Privacy Policy — Clerke <\!-- NAV --> <\!-- PAGE CONTENT -->
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Clerke (“Clerke,” “we,” “us,” or “our”) is a product of TBG Shoppe. This Privacy Policy describes how we collect, use, share, and protect information when you use our website, platform, and services — including AI-assisted tax preparation, business formation, notary booking, and the Clerke AI Receptionist (Ava). By accessing or using Clerke, you agree to the practices described in this policy. If you have questions, contact us at contact@tbgshoppe.com.
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Section 1

Information We Collect

We collect information you provide directly, information generated by your use of our platform, and limited information from third parties necessary to deliver our services.

Account Information. When you create an account, we collect your name, email address, password (stored as a bcrypt hash — never in plain text), business name, phone number, and role. If you join as a partner or team member, we also collect your organization details and invitation token.

Tax and Business Documents. To provide AI-assisted tax preparation and business formation services, you may upload documents such as W-2s, 1099s, receipts, invoices, identification documents, and business records. These documents may contain sensitive personal and financial information including Social Security Numbers, Employer Identification Numbers, and income data. EINs and SSNs collected during formation intake are encrypted at rest using AES-256-GCM.

Payment Information. We use Stripe to process payments. When you make a purchase, Stripe collects and processes your payment card details. We receive and store a transaction record, Stripe session identifier, and payment status — we do not store full card numbers, CVVs, or raw banking details on our servers.

Formation and Notary Intake. Business formation orders collect entity-specific information such as entity type, filing state, member and officer details, registered agent information, and selected add-on services. Notary bookings collect scheduling preferences and document type.

Usage and Interaction Data. We automatically collect information about how you interact with Clerke: pages visited, features used, time spent, click events, session identifiers, IP address (hashed for analytics), browser type, operating system, referrer URLs, and UTM campaign parameters.

Communications. When you contact support, chat with Ava (our AI Receptionist), or submit a help ticket, we retain the content of those communications to improve service quality and follow up on your request.

Cookies and Tracking Technologies. We use cookies and similar technologies as described in Section 7.

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Section 2

How We Use Your Information

Service Delivery. We use your information to create and manage your account, process transactions, deliver the services you request (tax preparation, formation filing, notary scheduling), send invoices, and provide customer support.

AI Document Processing. Uploaded tax documents are processed using OpenAI’s GPT-4o Vision model through a proxied API connection to extract, categorize, and summarize line items for your tax preparer’s review. See Section 8 for full details on AI processing.

Communication. We use your contact information to send transactional emails (account confirmation, invoice delivery, formation status updates, document ready notices), service notifications, and — where you have opted in — marketing communications and trial nurture sequences. You may opt out of marketing emails at any time using the unsubscribe link in each message.

Platform Improvement and Analytics. We analyze aggregated usage data, session patterns, and feature engagement to improve the platform, prioritize new features, diagnose technical issues, and understand how users navigate Clerke. Analytics data is aggregated or pseudonymized where possible.

Security and Fraud Prevention. We use account and usage information to detect, investigate, and prevent unauthorized access, abusive activity, and security incidents.

Legal Compliance. We retain and process certain information to meet our obligations under applicable law, including tax record-keeping requirements, financial regulations, and court orders.

Business Operations. We use information for internal purposes such as auditing, partner commission calculations, team management, and compliance program administration.

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Section 3

How We Share Your Information

We do not sell your personal information. We do not sell, rent, or trade your personal data to third parties for their own marketing purposes — ever.

Service Providers. We share information with trusted third-party vendors who help us operate Clerke. These providers are contractually required to protect your information and may only use it to perform services on our behalf:

Partners. If you access Clerke through a white-label or co-branded partner, we share relevant client and intake data with that partner as necessary to deliver the services they have arranged on your behalf. Partners operate under data processing agreements with Clerke.

Professional Service Providers. Your tax documents and extracted data are made available to the tax professional assigned to your account for review, preparation, and filing purposes. This is core to the tax preparation service.

Legal Requirements. We may disclose information when required to do so by law, subpoena, court order, or government regulation; to protect the rights, property, or safety of Clerke, our users, or others; or to investigate fraud or security incidents.

Business Transfers. If Clerke or TBG Shoppe is involved in a merger, acquisition, asset sale, or bankruptcy proceeding, your information may be transferred as part of that transaction. We will notify you by email or prominent notice on our platform if such a transfer occurs and if your data will be subject to a materially different privacy policy.

With Your Consent. We may share information with other third parties when you explicitly authorize us to do so.

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Section 4

Data Security

We take the security of your information seriously and implement multiple layers of protection:

No method of transmission over the internet or method of electronic storage is 100% secure. While we use commercially reasonable security measures, we cannot guarantee absolute security. If you believe your account has been compromised, contact us immediately at contact@tbgshoppe.com.

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Section 5

Data Retention

We retain your information for as long as necessary to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods:

You may request early deletion of non-legally-required data at any time. See Section 6 for how to exercise this right.

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Section 6

Your Rights

Depending on your jurisdiction, you may have the following rights with respect to your personal information. We honor these requests regardless of location to the extent practicable.

To exercise any of these rights, submit a request to contact@tbgshoppe.com with the subject line “Privacy Request.” We will respond within 30 days. We may need to verify your identity before fulfilling a request.

California Residents (CCPA/CPRA). California residents have additional rights including the right to know what categories of personal information are collected and disclosed, the right to opt out of the sale of personal information (we do not sell personal information), and the right to non-discrimination for exercising privacy rights.

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Section 7

Cookies

We use cookies and similar tracking technologies to operate the platform, remember your preferences, and understand how Clerke is used. Cookies are small text files placed on your device by your browser.

Session Cookies. These cookies are essential for platform operation. They maintain your authenticated session after login, preserve form state during multi-step workflows (such as business formation intake), and enable secure navigation between pages. Session cookies are deleted when you close your browser.

Preference Cookies. These persistent cookies remember choices you make on the platform — such as dashboard layout preferences or dismissed banners — so you do not need to reconfigure them on each visit.

Analytics Cookies. We use first-party analytics to understand how users navigate Clerke. These cookies track pages visited, session duration, referral source, and UTM campaign parameters. We use hashed IP addresses rather than raw IPs. We do not use Google Analytics or Facebook Pixel on the core platform.

Visitor Identification. We generate a pseudonymous visitor ID stored in localStorage to count unique visitors and measure campaign reach without associating visits to personally identifiable information unless you are logged in.

Managing Cookies. Most browsers allow you to view, manage, and delete cookies through browser settings. Disabling session cookies will prevent you from logging in. Disabling preference cookies will mean your settings are not remembered between visits.

We do not use cookies to build advertising profiles or share cookie data with advertising networks.

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Section 8

AI Processing

Your documents are never used to train AI models. OpenAI’s API usage terms for enterprise and business customers prohibit using API-submitted data for model training. Document content you upload to Clerke is not used by OpenAI or Clerke to train, fine-tune, or improve any machine learning model.

How AI is used. Clerke uses OpenAI’s GPT-4o Vision model (accessed through a proxied API connection managed by Polsia) for two primary purposes:

  1. Document parsing. When you upload a tax document (W-2, 1099, receipt, etc.), we transmit the document to the OpenAI API to extract and categorize line items, amounts, and relevant tax data. This accelerates review by your assigned tax preparer and reduces manual data entry errors.
  2. Ava AI Receptionist. Ava processes your chat messages to answer questions about Clerke’s services, guide you through intake, and escalate to a human when needed. Ava conversations are sent to the OpenAI API per message to generate responses.

What is transmitted. For document parsing, we transmit the document image or text content along with a structured extraction prompt. For Ava, we transmit your chat message, relevant knowledge base context, and conversation history. We do not transmit unnecessary personal information beyond what is needed for the specific AI task.

Data handling after processing. Document content transmitted for AI parsing is processed in real time. OpenAI does not retain API input data beyond the immediate request per their data retention policy for API customers. Extracted results (line items, amounts, categories) are stored in our database and linked to your account.

Human review. AI-extracted data is not filed, invoiced, or acted upon without review by a qualified tax preparer. AI output is a draft — a human professional reviews all extracted data before your return is prepared.

Entity optimization. We also use OpenAI to generate business structure analysis and entity optimization recommendations based on your profile. These analyses are cached in our database and associated with your client account.

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Section 9

Children’s Privacy

Clerke is intended for use by individuals who are at least 13 years of age. Certain features — particularly those involving financial transactions, tax filing, or business formation — require users to be at least 18 years of age or the age of majority in their jurisdiction.

We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us at contact@tbgshoppe.com and we will promptly investigate and delete the information.

If we learn that we have collected personal information from a child under 13 in violation of this policy, we will take steps to delete that information as soon as possible.

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Section 10

Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or how Clerke handles your personal information, please reach out to us:

Privacy Contact

TBG Shoppe / Clerke

Email: contact@tbgshoppe.com

Subject line: “Privacy Request” or “Privacy Policy Inquiry”

We respond to all privacy inquiries within 30 days. For urgent security concerns, please include “Security” in your subject line.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the “Last updated” date at the top of this page and, where appropriate, notify you by email or in-app notice. Your continued use of Clerke after the effective date of any update constitutes acceptance of the revised policy.


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