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Part A — Cookie Policy This Cookie Policy explains how Cloutly Co Pty Ltd (ACN 637 155 045) uses cookies and similar technologies on our marketing website (cloutly.com), our product-updates site (updates.cloutly.com), our application (app.cloutly.com and white-label domains operated by our partners), our mobile app, the public business pages (“microsites”) we host for customers, and the widgets our customers embed on their own websites. It should be read together with our Privacy Policy. What cookies are A cookie is a small text file stored on your device when you visit a website. Similar technologies — such as local storage, pixels, mobile SDKs and device identifiers — perform comparable functions. Cookies can be “session” cookies (deleted when you close your browser) or “persistent” cookies (which remain until they expire or are deleted), and they can be set by us (“first-party”) or by a third party we use (“third-party”). The categories of cookies we use Category What it does Can you switch it off? Strictly necessary Required to run the site and app — for example, to sign you in, keep your session secure, remember items during a workflow, protect against abuse, and balance load. The Service will not function properly without them. These cannot be switched off through our controls, as the Service depends on them. Functional / preferences Remember your choices and settings — such as language, region, selected location and interface preferences — and power the in-app support chat. Yes, though some features may be less convenient. Analytics / performance Help us understand how the site and app are used so we can measure and improve them — which pages and features are used, where errors occur, and how people move through the interface. In the application this includes product analytics and session-replay tools that record how the interface is used (mouse movement, clicks, scrolling and page structure). Session replay masks form inputs and does not capture keystrokes or passwords. Yes, where required we ask for consent and you can decline. Marketing Used on our marketing website to measure advertising campaigns and understand which content is useful — for example, recording that a sign-up followed an advertisement. We do not use them to sell your personal information or to share it for cross-context behavioural advertising. Yes, where required we ask for consent and you can decline. The specific cookies present can change as we update the Service. Where a consent banner is shown, it lists the current cookies in each category and lets you accept or decline non-essential cookies. On cloutly.com, we use the browser session-storage entry cloutly_campaign_v1 only after you accept both analytics and advertising cookies. It retains the first and latest campaign labels in that browser session so an enquiry can be associated with a campaign. It does not store enquiry form details or advertising click identifiers. This storage lasts for the browser tab’s session and is cleared when you withdraw either consent category through our cookie controls. Widgets and hosted pages on our customers’ behalf Our customers can embed Cloutly review widgets and chat / lead-capture widgets on their own websites, and can publish a Cloutly-hosted public business page. When you interact with one of these, limited cookies or local storage may be used to make it work (for example, to load content, prevent abuse, and remember your interaction). The website you are visiting is operated by our customer under its own privacy and cookie notices; Cloutly processes widget and page data on that customer’s behalf. We do not run marketing cookies on customer widgets or microsites. How to control cookies You can control and delete cookies through your browser settings, and set your browser to warn you before accepting cookies or to refuse them — though some parts of the Service may then not work properly. Where we show a consent banner, you can change your choices there at any time. You can disable push notifications in your device settings. We aim to honour recognised browser-based opt-out signals, such as Global Privacy Control (GPC), where applicable law requires. Part B — Sub-processors To provide the Service, Cloutly uses third-party providers (“sub-processors”) that may process personal information on our behalf. We require each sub-processor to protect personal information under obligations of confidentiality and data protection, to use it only to provide their service to us, and — for AI providers — to process content on a per-request basis under terms that exclude use for model training. This page lists our core sub-processors by name and describes the remaining categories of provider we use. It is current as at the “last updated” date above and changes as our providers change. Customers on an enterprise agreement receive a complete, named sub-processor schedule as part of their contract, together with advance notice of changes and the right to object; the schedule prevails over this page for those customers. Core sub-processors Current as at 4 October 2026. Provider Purpose Primary location Google Cloud Platform Cloud hosting, database, file storage, speech-to-text and language services, push-notification delivery European Union (Belgium, europe-west1); some services United States Cloudflare Content delivery, DNS and network security Global edge OpenAI Large-language-model processing for reply drafting, classification and signals, summaries and briefs, question answering, and embeddings United States Twilio SMS delivery and inbound SMS replies United States Postmark Transactional and campaign email delivery United States Paddle Merchant of record: payments, billing, tax and invoicing United Kingdom & United States Stripe Billing for some long-standing accounts United States PayPal Affiliate commission payouts United States Google and LinkedIn Optional single sign-on for account holders United States / global Other categories of sub-processor Category What they do for us Locations AI observability Monitor the quality of AI requests and outputs; prompts and outputs are retained for a limited period for debugging and evaluation European Union / United States Vector search Store embeddings of reviews and feedback for semantic search and insights United States Conversational widgets Power chat and lead-capture widgets a customer embeds on its own website, including reading the customer's own website content United States Review, listing and public-data collection Collect publicly available reviews and business-listing details from platforms a customer monitors, and check listing consistency United States / European Union / United Kingdom AI-search measurement Submit generic scenario questions to third-party AI assistants and return their answers and citations. Queries contain business and place names, never personal information. United States Business-data enrichment Retrieve a business's public logo, brand colours, description and company details when an account is set up (business data only; no person-level enrichment) United States Product analytics and session replay Understand how the application is used United States / European Union Error and performance monitoring Capture application errors and performance data United States Customer support Help-desk and in-app chat United Kingdom Internal operations Records of sign-ups, onboarding submissions and support queues United States Marketing email Cloutly's own onboarding and marketing email to people who have opted in United States White-label partner platforms Integration with an authorised partner's platform for customers who access Cloutly through that partner Australia Classification and embedding models that Cloutly runs inside its own infrastructure are not third-party sub-processors. Where a customer connects its own accounts on Google Business Profile, Facebook or another platform, those platforms act under their own terms and are not Cloutly sub-processors. The same applies to booking, point-of-sale, reservation, CRM, accounting and messaging systems a customer chooses to connect, and to third-party AI assistants a customer uses to access Cloutly. Payment card details are handled by Paddle (or Stripe, for legacy accounts) as merchant of record, and are not stored by Cloutly. Cloutly Co Pty Ltd (ACN 637 155 045) WOTSO Workspace, Level 2, 194 Varsity Parade, Varsity Lakes QLD 4227, Australia Email: [email protected] · Web: cloutly.com