In all cases, individual users, regardless of tier, do not enter into any personal contract with Clu. The contractual relationship is between Clu and the Client organisation. The Client is responsible for ensuring all individuals acting on its behalf comply with this policy.​

 

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2.  Accessing the Platform
 

2.1  Professional Access Only

The Clu platform is a professional tool licensed to organisations for internal workforce planning and decision-making purposes. Access is granted only in a professional capacity. It is not intended for personal use.

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2.2  Authorised Access
You may access the platform only if you have been authorised by your organisation (the Client). Core platform users (Tier B1) must have a named account assigned by an Admin User. Functional approvers (Tier B2) must have received an access link from Tier B1 users. You must not access the platform using credentials or links that were not issued to you.

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2.3  Account Security

Core platform users are responsible for keeping their login credentials secure. Passwords must not be shared with anyone, including colleagues. Multi-factor authentication must be completed where required. If you believe your account has been compromised, notify your Admin User and Clu immediately at accounts@getaclu.io.

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2.4  Age and Working Capacity

The platform is intended for individuals who are of legal working age in their jurisdiction and are accessing it in the course of their professional role. It is not intended for personal or non-professional use.

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3.  Accessing the Platform

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Platform access is granted for the purposes set out in your organisation's Order Form. Authorised uses include:

• Uploading structural HR data for the purposes described in the Order Form

• Reviewing, approving, or commenting on skills and role profiles within your scope

• Accessing and using Diagnostic Outputs to inform your organisation's internal workforce planning, operating model design, and capability decisions

• Navigating the Career Pathways tool to explore role options and skill adjacencies (where the tool has been activated by your organisation)

• Completing a Work Capture Form where you have been asked to do so by your organisation as part of a workforce mapping exercise

• Contacting Clu support in connection with your authorised use of the platform.

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4.  Accessing the Platform

The following uses are prohibited. Breach of this section may result in suspension or termination of access, and may constitute a breach of your organisation's obligations under its agreement with Clu.

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4.1  Data and Content

• Do not upload data you do not have the right to share, or that your organisation has not authorised you to submit to the platform.

• Do not upload personal data beyond what is minimally necessary for the purposes of the engagement, and do not upload sensitive personal data (as defined under UK GDPR Article 9) without explicit authorisation from your organisation and appropriate legal basis.

• Do not use platform outputs for any purpose other than your organisation's internal workforce planning and decision-making.

• Do not share Diagnostic Outputs outside your organisation without your organisation's approval, except as permitted by the Platform Terms of Service (such as sharing with regulators, unions, or professional advisers for governance purposes).

• Do not present Diagnostic Outputs as independently produced analysis in any external or formal context without acknowledging that the analysis was produced using third-party analytical software.

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4.2  Decisions Affecting Individuals

• Do not use Diagnostic Outputs as the sole or primary basis for any automated or semi-automated decision that significantly affects an individual employee, including decisions relating to redundancy, role change, performance, or pay, without adequate human review, in a manner that would constitute automated decision-making under Article 22 of the UK GDPR.

• Do not use platform outputs to discriminate on the basis of any protected characteristic under the Equality Act 2010, whether directly or indirectly.

• Do not use the platform to monitor, profile, or surveil individuals in a manner not disclosed to and authorised by those individuals.

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4.3  Platform Integrity and Security

• Do not attempt to reverse-engineer, decompile, or derive the underlying logic or source code of the platform or its AI models.

• Do not introduce viruses, malware, or any malicious code to the platform.

• Do not attempt to probe, test, or circumvent the platform's security or access controls.

• Do not use the platform in a way that places an unreasonable load on Clu's infrastructure.

• Do not create multiple accounts or use another person's account to circumvent access restrictions.

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4.4  Representations

• Do not represent Clu's Diagnostic Outputs as legal, financial, HR, or regulatory advice.

• Do not use Clu's name, logo, or branding without prior written consent from Clu.

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5.  Data Handling and Confidentiality

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5.1  Client Data

Data submitted to the platform remains the property of the Client organisation. You must handle Client Data in line with your organisation's data protection policies and applicable law, and must not use it for purposes outside the scope of the engagement.

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5.2  Platform Outputs

Diagnostic Outputs produced by the platform reflect the structural data of your organisation and are confidential to it. They must be treated with the same care as any sensitive internal business document. You must not share or distribute Diagnostic Outputs beyond the purposes authorised by your organisation.

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5.3  No Personal Contracting

All data you handle through the platform is handled on behalf of your organisation, not in a personal capacity. No personal data protection obligation under UK GDPR attaches to you individually as a result of accessing or using the platform. Your organisation is the Data Controller for data processed through your access; Clu acts as Data Processor on your organisation's behalf.

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5.4  Reporting Concerns

If you become aware of any potential data breach, misuse of platform data, or inappropriate use of Diagnostic Outputs within your organisation, you should report it to your organisation's nominated platform contact (Admin User) and, if appropriate, to Clu at security@getaclu.io.

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6.  Workforce Decisions and Human Oversight

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Clu's platform improves the quality and clarity of the evidence available to decision-makers. It does not make decisions, recommend a course of action, or solve the underlying organisational challenges that give rise to them.

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All Diagnostic Outputs require human interpretation, expert review, and appropriate oversight before any action is taken. The more consequential the intended decision, the greater the obligation to apply independent judgment, legal advice, and procedural rigour. This applies to decisions affecting individual employees, including those relating to restructuring, redundancy, or role redesign, as much as to decisions at the organisational level.

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Where your organisation uses platform outputs to inform decisions that affect employees, it is responsible for ensuring compliance with applicable employment law, including collective consultation obligations, and for ensuring that affected employees have been appropriately informed.

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7.  Employees Engaging with Optional Tools

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Where your organisation has activated Clu's Career Pathways tool or Work Capture Forms, and you are an employee accessing these via a link, rather than a named platform user, the following applies:

• You are interacting with the tool on your organisation's behalf, as a data subject, not as a licensed user of the platform.

• Your organisation is the Data Controller for any information you provide. You can find out how it uses that information in your organisation's employee privacy notice.

• For the Career Pathways tool and Work Capture Forms, your name and email are not required and are not stored as part of your interaction, unless you are a named approver within the profile approval workflow.

• Where you are a named approver, your name, work email, and approval decision are recorded so your organisation can track progress. You are acting in your professional capacity as an authorised representative of your organisation.

• Participation in Work Capture Forms and the Career Pathways tool is voluntary. You are not obliged to complete them, and declining does not affect your standing with your organisation or with Clu.

• You are not entering into any contract with Clu by engaging with these tools.

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8.  Related Information​

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8.1  Documentation (Some Available on Request)

Clu Platform Terms

Privacy Policy

AI Transparency Statement

Data Processing Agreement (Available on Request)

Compliance & Security Summary (Available on Request)

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8.2  Updates to This Policy

Clu may update this policy from time to time, for example, to reflect changes in platform functionality, applicable law, or regulatory guidance. Material changes will be notified to Client Admin Users at least 14 days before they take effect. The effective date at the top of this document records when it was last revised. Continued use of the platform after the effective date of a revision constitutes acknowledgement of the update.

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8.3.  Contact
For questions about this policy, Clu's AI systems, or about how the platform handles your data, please contact your organisation's Admin User in the first instance, or reach out to Clu directly:

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General queries: hello@getaclu.io
Account access or security concerns: accounts@getaclu.io
Data protection queries: dpo@getaclu.io

Legal or contractual queries: legal@getaclu.io
Post: Included AI Limited, Floor 3, Capital Tower Business Centre, Greyfriars Road, Cardiff, CF10 3AG