Privacy Policy

1. Who we are

Clearway Design LLC is a Texas limited liability company doing business as Big Push Studio. In this policy, "we," "us," and "our" mean Clearway Design LLC. "You" means the person whose personal data we process.

We design and build mobile applications for ecommerce brands. We are the controller of the personal data described in this policy, except where we act as a processor or service provider on behalf of a client, which is covered in section 2.

2. Scope

This policy applies to personal data we collect through:

• bigpushstudio.com and any subdomain we operate
• Lead forms we run inside Facebook and Instagram, including Meta Instant Forms
• Email, messages, and calls exchanged with us about our services
• Proposals, engagements, and the ordinary course of doing business with us

This policy does not apply to personal data we process on a client's behalf while building or operating an application for that client. In those engagements the client is the controller and the client's own privacy policy governs. It also does not apply to any third party website, platform, or service, including any application we built for a client and the client now operates.

3. Personal data we collect

Information you give us

• Identifiers. Your name and email address.
• Business information. Your website address, your company, your role, what you told us matters most for your business, your budget range if you chose to share one, and anything you wrote in a free text field or sent us in a message.
• Communications. The content of emails, form submissions, messages, and call notes.

Information collected automatically

• Device and connection data. IP address, browser type and version, operating system, device type, screen size, and language.
• Usage data. Pages viewed, time on page, referring site or advertisement, links clicked, and approximate location inferred from IP address at the city or region level.
• Advertising identifiers. Cookies and similar identifiers set by the Meta Pixel, described in section 8.

Information we do not collect

We do not ask for and do not want payment card numbers, bank details, Social Security or other government identification numbers, health information, precise geolocation, biometric identifiers, or account passwords. Do not send them to us. If you send them anyway, we will delete them when we notice, and we are not responsible for information you volunteer that we never asked for.

4. Where we get it

• Directly from you
• Automatically from your device when you visit the site
• From Meta, when you submit a lead form inside Facebook or Instagram
• From publicly available sources, such as your own website, when we research your brand to prepare the app ideas you asked us for

5. How we use it

• To respond to you, prepare the app ideas or quote you requested, and follow up about that request
• To provide, operate, and improve our services and this website
• To evaluate whether we are a fit for a project and to prepare proposals and agreements
• To send you service and transactional messages, and marketing messages you may opt out of at any time
• To measure and improve our advertising, including whether an advertisement led to a visit or an enquiry
• To maintain security, prevent fraud and abuse, and debug and fix errors
• To create aggregated or de-identified information that no longer identifies you, which we may use and retain for any purpose
• To establish, exercise, or defend legal claims, and to comply with law, regulation, subpoena, or other legal process

We do not use your personal data to train machine learning models offered to third parties, and we do not use automated decision making that produces a legal or similarly significant effect on you.

6. Legal bases

Where the UK GDPR or EU GDPR applies to our processing, we rely on the following legal bases:

• Contract. To take steps at your request before entering a contract, and to perform a contract with you.
• Legitimate interests. To operate and secure our website, to understand how our advertising performs, and to grow our business, where those interests are not overridden by your rights.
• Consent. For advertising cookies and marketing email where consent is required. You may withdraw consent at any time, which does not affect processing already carried out.
• Legal obligation. Where we must process personal data to comply with a legal requirement.

7. Who we disclose it to

We do not sell your personal data for money. We disclose personal data only as described here.

Service providers and processors

• Formspree receives, stores, and forwards submissions from the form on this website.
• Meta Platforms, Inc. hosts the lead forms we run inside Facebook and Instagram, and receives website activity through the Meta Pixel. See section 8.
• Cloudflare, Inc. hosts, serves, and protects this website and processes request data including IP addresses.
• Email and productivity providers handle our correspondence, calendars, and documents.
• Professional advisers including accountants, lawyers, and insurers, where they need the information to advise us.

We ask our service providers to process personal data only on our instructions and for no other purpose. We are not responsible for the independent acts of a third party that processes personal data as its own controller.

Other disclosures

• To comply with applicable law, regulation, legal process, or an enforceable governmental request
• To enforce our agreements, including investigating potential violations
• To detect, prevent, or address fraud, security, or technical issues
• To protect the rights, property, or safety of Clearway Design LLC, our clients, our users, or the public as required or permitted by law
• With your direction or consent

8. Advertising, the Meta Pixel, and your opt-out

This website runs the Meta Pixel. The pixel tells Meta when a browser loads a page here, together with the technical data in section 3. We use it to measure whether our advertisements work and to show advertisements to people who have visited this site or who resemble our visitors. The pixel may set cookies and read identifiers in your browser.

We run no other analytics or tracking tool. This website sets no cookies of its own.

How to opt out of targeted advertising

• Send a browser signal. We honor the Global Privacy Control. Turn on GPC in a browser or extension that supports it and we will treat it as an opt-out request for that browser.
• Block the pixel. Use a content blocker, or a browser that blocks third party tracking by default.
• Change your Meta settings. Adjust your Meta ad preferences to control how Meta uses data about you.
• Ask us. Contact us as described in section 13 and say you want to opt out of targeted advertising.

Opting out does not remove advertising. It changes how it is selected.

We do not respond to browser Do Not Track headers, because there is no common standard for them. We do respond to the Global Privacy Control.

9. Sensitive and biometric data

We do not knowingly collect sensitive personal data or biometric personal data as those terms are defined by the Texas Data Privacy and Security Act, the California Consumer Privacy Act, or comparable laws. We do not sell sensitive personal data. We do not sell biometric personal data. We do not use or disclose sensitive personal data for purposes that would require an opt-out right under those laws.

10. How long we keep it

We keep personal data for as long as we need it for the purpose it was collected, and then for as long as we have a legitimate business or legal reason to keep it.

• Enquiries that do not become projects. Up to two years from your last contact with us.
• Clients and projects. For the life of the engagement, and then for as long as needed for tax, accounting, warranty, insurance, and limitation of actions purposes.
• Website and advertising data. As set by the retention settings of the provider, typically no more than two years.
• Records we must keep by law. For the period the law requires.

We may retain aggregated or de-identified information indefinitely. We may also retain a minimal suppression record of your email address after a deletion or unsubscribe request, so that we can honor it.

11. Security

We maintain administrative, technical, and physical safeguards designed to protect personal data, including transport encryption, access controls, and limiting access to the people who need it.

No method of transmission or storage is completely secure. We cannot and do not guarantee the security of personal data, and to the fullest extent permitted by law we disclaim liability for unauthorized access, use, or disclosure that occurs despite reasonable safeguards. You are responsible for keeping your own devices and email account secure.

12. Your rights

Depending on where you live, you may have the right to:

• Know and access. Confirm whether we process your personal data and obtain a copy.
• Correct. Fix inaccurate personal data.
• Delete. Ask us to delete personal data we hold about you.
• Port. Obtain a copy in a portable, machine readable format where technically feasible.
• Opt out. Opt out of targeted advertising, the sale of personal data, and profiling with legal or similarly significant effects.
• Withdraw consent. Where we rely on consent.
• Non-discrimination. We will not deny service, charge a different price, or provide a different quality of service because you exercised a privacy right.
• Complain. Lodge a complaint with your supervisory authority, or with the Texas Attorney General.

These rights are not absolute. We may decline a request where an exception applies, where honoring it would infringe another person's rights, or where we cannot verify who you are. We will tell you why.

13. Making a request

Submit a request through the contact form and say what you want us to do. Write "Privacy request" in your message so it reaches the right place.

We will acknowledge your request and respond within 45 days. We may extend once by a further 45 days where reasonably necessary, and we will tell you if we do.

Verification. To protect you, we will take reasonable steps to verify your identity before acting, usually by matching the information in your request against what we already hold, or by asking you to reply from the email address on file. We may decline a request we cannot verify.

Authorized agents. An agent may submit a request on your behalf with written permission signed by you. We may still contact you directly to confirm.

Requests are free. We may charge a reasonable fee or refuse a request that is manifestly unfounded, excessive, or repetitive, as the law allows.

14. Appeals

If we refuse your request, you may appeal. Reply to our decision, or submit a new message through the contact form with "Privacy appeal" and the reason you think the decision was wrong.

We will review the appeal and respond in writing within 60 days with our decision and the reasons for it. If we deny the appeal, we will give you a method to contact your state attorney general to submit a complaint. Texas residents may contact the Office of the Texas Attorney General.

15. State specific disclosures

Texas

We are a Texas business and the Texas Data Privacy and Security Act may apply to our processing. The categories of personal data we process, the purposes for processing, the categories we disclose to third parties, and the categories of those third parties are set out in sections 3, 5, and 7. Your rights and how to exercise them are in sections 12 through 14. We process personal data for targeted advertising as described in section 8 and you may opt out there. We do not sell sensitive or biometric personal data.

California

In the twelve months before the date at the top of this page we collected the categories of personal information listed in section 3, which correspond to the CCPA categories of identifiers, commercial information, internet or other electronic network activity information, and inferences. We disclosed those categories for business purposes to the recipients in section 7, and we shared internet activity information and identifiers with Meta for cross-context behavioral advertising as described in section 8. We do not sell personal information for money and we do not knowingly sell or share the personal information of consumers under 16 years of age.

Other states

Residents of other states with comprehensive privacy laws, including Virginia, Colorado, Connecticut, Utah, Oregon, Montana, and others as those laws take effect, have rights substantially similar to those in section 12 and may exercise them the same way.

16. International visitors

We operate in the United States. Our service providers are located primarily in the United States. If you access this site or contact us from outside the United States, you understand that your personal data will be transferred to, stored in, and processed in the United States, where privacy laws may differ from those in your country. Where required, we rely on appropriate safeguards such as the European Commission's standard contractual clauses.

We do not target our services to any particular country outside the United States.

17. Children

This website and our services are directed to business owners and operators, not to children. We do not knowingly collect personal data from anyone under 18, and we do not knowingly process the personal data of a known minor under 18 for targeted advertising or sale. If you believe a child has given us personal data, contact us and we will delete it.

18. Third party links

This site and our communications may link to websites, applications, and services we do not operate. We do not control them and we are not responsible for their content, security, or privacy practices. Read their policies before giving them your information.

19. Business transfers

If Clearway Design LLC is involved in a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or dissolution, personal data may be transferred or disclosed as part of that transaction or as an asset in it, subject to reasonable confidentiality protections. We will post a notice on this page if a transaction materially changes how your personal data is handled.

20. Governing law

This policy and any dispute arising from it are governed by the laws of the State of Texas, without regard to its conflict of laws rules. Nothing in this section limits a right you have under a mandatory law of your own jurisdiction, and nothing in this policy is intended to waive a right that cannot be waived.

21. Changes

We may update this policy. When we do, we will change the date at the top of this page. If a change materially affects how we use personal data we already hold, we will provide additional notice, which may include emailing you or posting a notice on this site. Continuing to use the site after a change takes effect means you accept the updated policy.

22. Contact us

Clearway Design LLC, doing business as Big Push Studio, is based in Texas, United States.

For any privacy question, request, or appeal, use the contact form and tell us what you need. We read every message.