Privacy Policy

Effective date: August 4, 2026 · Last updated: September 15, 2026. Clarifications only.

This page describes how Ontevo handles information. Our Terms of Service govern your use of the Services, including the acceptable use rules in Section 6.

Clear Cold Water Holdings LLC, a Wyoming limited liability company doing business as Ontevo (“Ontevo,” “we,” “us,” or “our”), is committed to protecting the privacy and security of your information. This Privacy Policy describes how we collect, use, store, and share information when you use our platform, website, and related services (collectively, the “Services”).

Our Data Promise

We NEVER train our AI models on your business data. Your competitive intelligence stays yours. Period.

Contents

1. Information We Collect
2. How We Use Your Information
3. Data Storage & Security
4. Third-Party Service Providers
5. Your Privacy Rights
6. Data Retention
7. Children’s Privacy
8. Changes to This Privacy Policy
9. Contact Us

1. Information We Collect

We collect the following categories of information to provide and improve our Services.

Business Data

When you use our analysis tools, we process publicly available data about your business and your competitors, including:

• Website content and structure (publicly accessible pages only)
• Product listings, pricing, and descriptions
• Public customer reviews from third-party platforms
• Competitor information available in public domains

The core of our product is analysis of information already visible on the public web, not the contents of your internal systems. What we do not collect: the Services do not accept protected health information. Scanning is outside-in on public signals, with no logins and no access to a practice management system. Submitting PHI is prohibited by Section 6.1 of the Terms.

Account Information

When you create an account or interact with our Services, we may collect:

• Name, email address, and company name
• Billing information (processed securely through our payment provider, see Section 4; we never store full credit card numbers on our servers)
• Account preferences and communication settings
• Business category and service type selections

Usage Data

We automatically collect certain information about how you interact with our Services:

• Pages viewed, features used, and actions taken within the platform
• Device type, browser type, and operating system
• IP address, approximate geographic location, and referring URLs
• Session duration and interaction timestamps

2. How We Use Your Information

We use the information we collect for the following purposes:

• Service delivery: To perform competitive analyses, generate findings, produce reports, and deliver the Fit-Funnel-Fix protocol results
• Analysis & intelligence: To process publicly available data through our proprietary diagnostic engine and provide drafted fixes for your review and approval
• Platform improvement: To improve our algorithms and develop new features using our own public-data corpus and aggregated product telemetry (which pages and features are used). We do not use customer business data, in any form, to build benchmarks or cohorts
• Communication: To send account notifications, service updates, and respond to support inquiries
• Billing: To process payments and manage subscriptions
• Legal compliance: To comply with applicable laws, regulations, and legal processes

3. Data Storage & Security

We take the security of your data seriously and implement industry-standard measures to protect it:

• Encryption: All data is encrypted in transit (TLS 1.3) and at rest (AES-256)
• SOC 2 status: SOC 2 Type I and HIPAA readiness are in progress. We do not currently hold a SOC 2 report.
• Access controls: Strict role-based access controls limit data access to authorized personnel only
• Infrastructure: Data is hosted on enterprise-grade cloud infrastructure
• Monitoring: Continuous security monitoring and regular vulnerability assessments

Security Note

We maintain separate data environments for each customer. Your business intelligence is never commingled with another customer’s data, and is never used to train or improve models for other accounts.

4. Third-Party Service Providers

We work with trusted third-party providers to deliver our Services. These include:

• Payment processing: Billing is handled by Stripe, which maintains PCI-DSS Level 1 compliance. We never store full credit card numbers on our servers.
• Cloud infrastructure: Our platform runs on enterprise cloud infrastructure whose providers maintain ISO 27001 certification.
• Analytics: We use privacy-focused analytics to understand platform usage patterns. No personally identifiable information is shared.
• Communication: We use trusted email service providers for transactional and service communications.
• AI model providers: Certain analysis features are delivered using third-party AI model services. Our Data Promise applies: we do not use your business data to train AI models.

A current description of the third-party service providers material to your account is available on request at privacy@ontevo.ai.

We do not sell your personal information to any third party. We do not share your business data with other customers, advertisers, or data brokers.

5. Your Privacy Rights

You have the following rights regarding your personal information:

• Access: Request a copy of the personal data we hold about you
• Correction: Request corrections to inaccurate or incomplete data
• Deletion: Request deletion of your personal data, subject to legal retention requirements
• Portability: Request your data in a structured, machine-readable format
• Objection: Object to specific types of data processing
• Restriction: Request that we restrict certain processing activities

To exercise any of these rights, contact us at privacy@ontevo.ai. We will respond within 30 days.

6. Data Retention

We retain your information based on the following guidelines:

• Account data: Retained for the duration of your active subscription plus 90 days after account closure
• Analysis reports: Available for the duration of your subscription; archived for 30 days after cancellation, then permanently deleted
• Usage logs: Retained for 12 months for security and operational purposes, then anonymized
• Billing records: Retained for 7 years as required by tax and financial regulations

You may request early deletion of your data at any time by contacting privacy@ontevo.ai.

7. Children’s Privacy

Ontevo is a business-to-business platform designed for use by business professionals. Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from anyone under 18 years of age. If we become aware that we have collected personal data from a minor, we will take immediate steps to delete that information.

8. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the “Last updated” date above and notify you via email or a prominent notice within the platform. We encourage you to review this page periodically.

9. Contact Us

If you have questions about this Privacy Policy or our data practices, or wish to exercise your privacy rights, please contact us:

Clear Cold Water Holdings LLC
d/b/a Ontevo
500 W Superior St
Chicago, IL 60654
privacy@ontevo.ai

See also: Terms of Service · Acceptable Use (Terms §6)