Privacy Policy

Privacy Notice

We are clare&me GmbH of Auguststraße 47, 10119 Berlin.

Clare is an AI-powered voice bot that works conversationally. Clare can be your mental health coach, ready to talk to you whenever you need support. This privacy policy explains how we collect and handle your personal data when you use Clare, contact us for information about our services or browse our website. Please note that you cannot use Clare if you are under 18. 

‍If you have any questions about this privacy policy, including any requests relating to your legal rights, please contact us at hello@clareandme.com. 

How do we use your data?

1. If you register with us.

If you register to use our services, we process information including your name, contact details, location, age and health information such as your anxiety levels, stress levels, emotional status, therapy status and if you have any self-harm or suicidal intentions to verify you are eligible to use our services and if so, onboard you as a customer. We process this information because it is necessary to take steps to enter into our contract and perform our contract with you.

Your health information is considered special category personal data under applicable data protection law and is afforded a higher level of protection. We will only process this information based on your explicit consent. You can withdraw your consent at any time by contacting us at hello@clareandme.com but please note this will result in you not being able to use our services.

2. If you are not eligible to use our services.

If we determine that you are not eligible to use our services, for example because you are under the age of 18, or require immediate medical attention which makes you unsuitable for using Clare, we will keep a record of your name, contact details and reason for the rejection because it is in our legitimate interests to be able to demonstrate why we rejected your request and/or prevent you from accessing our services until you are eligible.

3. If you chat with Clare via a phone call.

If you chat with Clare via a phone call, we will process information including your first name, call schedule, call recording and call transcript which may include health information and any other personal data you choose to provide. We process this information because it is necessary to perform our contract with you.

Your health information is considered special category personal data under applicable data protection law and is afforded a higher level of protection. We will only process this information based on your explicit consent. You can withdraw your consent at any time by contacting us at hello@clareandme.com but please note this will result in you not being able to use our services.

We will also keep a record of the phone log because it is in our legitimate interests to have a record of when the conversation took place and how long it lasted.

4. If you chat with Clare via a message.

If you chat with Clare via a message, we will process information including your first name, message schedule, and conversation which may include your health information and any other personal data you choose to provide. We process this information because it is necessary to perform our contract with you.

Your health information is considered special category personal data under applicable data protection law and is afforded a higher level of protection. We will only process this information based on your explicit consent. You can withdraw your consent at any time by contacting us at hello@clareandme.com but please note this will result in you not being able to use our services.

We will also keep a record of the message log because it is in our legitimate interests to have a record of when conversation took place and how long it lasted.

5. If you make a purchase.

If you make a purchase we will collect your name, contact details and payment detail (which we do not store) because it is necessary to perform our contract with you.

6. If you contact us.

If you contact us with a general enquiry, we will process information including your name, contact details and enquiry details because it is in our legitimate interest to make sure we can properly respond to your enquiry.

7. If you interact with us on social media.

If you interact with us on social media including on Facebook, Instagram and Linkedln we will process your handle, name and email address under our legitimate interest to respond to your comments and queries promptly.

8. If you leave a testimonial.

If you leave a testimonial, we will process your name, photo and testimonial, including publishing on our app or website, if you have provided your consent. You can withdraw your consent at any time by contacting us at hello@clareandme.com.

9. News updates.

We will process your personal information such as your name and email address to provide you with our news updates in line with any preferences you have told us about. When we send you our news updates because you have opted-in to receive them, we rely on your consent to contact you. If we contact you by email and you have not opted-in, this is because we reasonably believe you will be interested in hearing from us, and the lawful basis we rely on to do this is our legitimate interest to promote our business.

You can unsubscribe from our updates at any time by responding to any email you receive from us to tell us you wish to unsubscribe or by contacting us at hello@clareandme.com.

10. Technical information when you use our website or app.

When you consent, we collect information about how you use our website or app. We use this information to improve our website or app and to better understand how people use it. More detail on the information we collect and how we do this is set out in our cookie policy below.

11. If we anonymise your personal data.

In some circumstances we and our sub-contractors may carefully anonymise your personal data so that it can no longer be associated with you. We anonymise your personal data based on our legitimate interests of improving our services. Where we anonymise your health information we will only do so based on your explicit consent.

Who do we share your data with?

We may share your personal data with:

- our suppliers and service providers;
- our professional advisors such as our lawyers, banks, auditors or insurers;
- law enforcement, government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.

Please be aware, that our services interact with third party applications such as WhatsApp. You may be required to register with these third party applications before you can use our services. We are not responsible for their data processing activities.

How long do we keep your data for?

We will only retain your personal information for as long as we need it unless we are required to keep it for longer to comply with our legal or regulatory requirements.

What are my rights under data protection law?

You have various rights under applicable data protection law, including the right in certain circumstances to:

- access your personal data;
- correct incomplete or inaccurate data we hold about you;
- erase the personal data we hold about you;
- restrict our handling of your personal data;
- transfer your personal data to a third party;
- object to how we are using your personal data; and
- withdraw your consent to us handling your personal data.

Please keep in mind that data protection law is complicated, and these rights will not always be available to you all of the time.

You also have the right to lodge a complaint with us or the ICO, the supervisory authority for data protection issues in the UK. If you are based outside of the UK, you can find your relevant supervisory authority here.

Automated Decision Making

When using Clare, we will process your personal data by automated means to predict your behaviour and make decisions about you. Under data protection law this is known as 'profiling'. We profile you so that Clare can provide you with appropriate support and suitably respond to you. We will only profile you if you consent. You can withdraw your consent at any time by contacting us at hello@clareandme.com but please note this will result in you not being able to use our services. You can also contact us if you would like to contest any decision Clare makes based on our use of profiling.

Cookies policy

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. We only use (and store) non-essential cookies on your computer's browser or hard drive if you provide your consent.

- Strictly necessary cookies. These are cookies that are required for the operation of our website or app.

- Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website or app when they are using it. This helps us to improve the way our website or app works.

- Functionality cookies. These are used to recognise you when you return to our website or app. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

- Targeting cookies. These cookies record your visit to our website or app, the pages you have visited and the links you have followed. We will use this information to make our website or app and the advertising displayed on it more relevant to your interests.  We may also share this information with third parties for this purpose. 

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Please note that the following third parties may also use cookies, over which we have no control: Third-party cookies include those set by advertising networks, the partners we use for web analytics, and external websites delivering embedded content and videos. We use the following cookies provided by third parties: Google Analytics - which allows us to improve and analyze your experience on our website or app. Please see their website for more information.
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For the UK Representative appointment: We have appointed a representative in the UK. You can contact them by post at Mishcon De Reya LLP, Assign Service, Africa House, 70 Kingsway, London WC2B 6AH, or by email at representative@mishcon.com.
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