Claru Privacy Policy

This Privacy Policy explains how Reelpop Media LLC ("Reelpop," "we," "us," or "our") collects, uses, and protects information when you use the Claru mobile application ("App"). Claru is a migraine and headache tracking app that helps you identify patterns and triggers by analyzing your health data alongside environmental factors such as weather.

We are committed to protecting your privacy and complying with applicable data protection laws, including the EU General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (FADP).

1. Information We Collect

Claru collects only the information needed to provide core app functionality. The categories of data we collect include:

a. Health and Migraine Data

When you log a migraine or headache episode, we collect the information you provide, which may include:

• Date, time, duration, and severity of migraine or headache episodes.
• Symptoms, triggers, and accompanying factors you choose to record.
• Medications or treatments taken and their perceived effectiveness.
• Any additional notes or context you voluntarily enter.

This health data is considered special category data under the GDPR (Article 9). We process it based on your explicit consent, which you provide when you create an account and begin logging data in the App.

b. Weather and Location Data

With your permission, Claru accesses your device's location to retrieve local weather and barometric pressure data. This data is used to help identify potential weather-related migraine triggers.

• Location data is used solely to fetch weather conditions and is not stored on our servers beyond what is necessary to deliver weather correlation features.
• You can disable location access at any time in your device settings. If you do, weather-related features will be unavailable, but all other App functionality will continue to work.

c. Technical and Device Information

• Limited technical information required for app performance, diagnostics, security, and reliability (e.g., device type, OS version, crash logs).

d. Information You Provide Directly

• Support requests, feedback, or messages sent to us via email or in-app contact features.

App Store privacy disclosures are provided in the Apple App Store listing for Claru.

2. How We Use Information

• Operate and maintain the App, including migraine logging, tracking, and pattern analysis features.
• Correlate your migraine data with weather and environmental factors to help you identify triggers.
• Generate personalized insights and reports based on your logged data.
• Provide features and improve app performance.
• Respond to customer support and service requests.
• Detect, prevent, and address security or technical issues.
• Comply with legal obligations.

3. AI Processing and Third-Party Data Sharing

We do not sell your personal information.

a. OpenAI API

Claru uses the OpenAI API to process your migraine and health data in order to generate insights, pattern analysis, and personalized recommendations. When you use these AI-powered features:

• Relevant health data from your migraine logs is sent to OpenAI for processing via their API.
• OpenAI does notuse data submitted via their API to train their models. This is governed by OpenAI's API data usage policy, which states that API inputs and outputs are not used for training purposes.
• Data sent to OpenAI is transmitted securely using encryption in transit and is retained by OpenAI for a maximum of 30 days for abuse and misuse monitoring, after which it is deleted.
• We send only the minimum data necessary for the AI feature to function. No personally identifying information (such as your name or email) is included in API requests unless strictly required for the feature.

b. Other Service Providers

We may share limited information only when necessary with:

• Service providers that help us operate the App (for example, hosting, analytics, and customer support tools). All such providers are contractually required to protect your data and may only use it to provide services to us.
• Legal authorities when required by law.
• Parties involved in a merger, acquisition, or asset sale, where permitted by law.

Any third party with whom we share user data is required to provide the same or equivalent level of data protection as described in this Privacy Policy.

4. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA) or Switzerland, we process your personal data on the following legal bases:

• Consent (Article 6(1)(a) and Article 9(2)(a) GDPR): For processing health and migraine data, location data, and for sending your data to AI services. You may withdraw consent at any time.
• Contract Performance (Article 6(1)(b) GDPR): For processing data necessary to provide the App and its core features to you.
• Legitimate Interest (Article 6(1)(f) GDPR): For app security, fraud prevention, and improving our services, where your rights do not override our interests.
• Legal Obligation (Article 6(1)(c) GDPR): Where we are required to process data to comply with applicable laws.

5. International Data Transfers

Claru is operated by Reelpop Media LLC, based in the United States. If you are using the App from the EEA or Switzerland, your data may be transferred to and processed in the United States.

We ensure that such transfers are protected by appropriate safeguards, including Standard Contractual Clauses (SCCs) approved by the European Commission, or other valid transfer mechanisms under the GDPR and Swiss data protection law.

6. Data Retention

We retain your data only as long as reasonably necessary to provide the App, fulfill the purposes described in this policy, and comply with legal requirements.

• Your migraine logs and health data are retained for as long as your account is active.
• If you delete your account, all associated personal and health data will be permanently deleted within 30 days, except where retention is required by law.
• Technical logs and anonymized analytics data may be retained longer for security and performance purposes.

7. Data Security

We use reasonable administrative, technical, and organizational safeguards to protect information, including encryption of data in transit and at rest. No method of storage or transmission is 100% secure, but we work to protect your data using industry-standard practices.

8. Your Rights

Under the GDPR and applicable data protection laws, you have the following rights regarding your personal data:

• Right of Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: You can request correction of inaccurate or incomplete data.
• Right to Erasure: You can request deletion of your personal data. You can also delete your account and all associated data directly within the App.
• Right to Data Portability: You can request an export of your data in a structured, commonly used, machine-readable format (e.g., JSON or CSV).
• Right to Restrict Processing: You can request that we limit the processing of your data under certain circumstances.
• Right to Object: You can object to processing based on legitimate interests.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at info@reelpop.co. We will respond to your request within 30 days, as required by the GDPR.

You also have the right to lodge a complaint with a data protection supervisory authority in your country of residence.

9. Data Export and Deletion

Claru provides built-in tools to manage your data:

• Export Your Data: You can export all of your migraine logs and personal data at any time from within the App in a portable format.
• Delete Your Data: You can delete your account and all associated data directly from the App settings. Upon deletion, all personal and health data will be permanently removed from our systems within 30 days.

10. Children's Privacy

Claru is not directed to children under 16 (in accordance with GDPR requirements), and we do not knowingly collect personal information from children under 16. If we learn that we have collected data from a child under 16 without appropriate parental consent, we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated version on this page and revise the effective date. If we make material changes, we will notify you through the App or via email before the changes take effect.

12. Contact Us

If you have questions about this Privacy Policy or wish to exercise your data rights, contact us at: