Privacy Policy

CLU is provided by OLDB LIMITED (“CLU,” “we,” “us,” or “our”), a company registered in England and Wales under company number 16258218, with its registered office at C/O Eaccounts, Ground Floor, Cardigan House, Enterprise Park, Swansea, Wales, SA7 9LA, United Kingdom. CLU is currently offered to users in the United States.

This policy applies to the CLU mobile application and all related features and services (together, the “App” or the “Services”). It explains how we collect, use, disclose, and protect your personal information and the choices and rights you have under US federal and state privacy laws. Because OLDB LIMITED is established in the United Kingdom, UK and EU data protection law also applies to our processing; see Section 13 (UK and EU data protection).

Your use of CLU is also governed by our Terms of Service, including its dispute-resolution (arbitration), class-action waiver, and limitation-of-liability provisions, which apply to any dispute relating to the Services, including matters concerning your personal information.

If you have any questions about this policy or your data, contact us at hello@withclu.com or by post at the registered office address above.

CLU is a consumer health and wellness application. It does not provide medical advice, diagnosis, or treatment, is not intended to diagnose, treat, cure, or prevent any disease, and is not a substitute for professional care from a qualified healthcare provider. Always seek the advice of your physician or another qualified professional with any questions about a medical condition, and never disregard professional advice or delay seeking it because of something you read in the App. If you think you may have a medical emergency, call 911 (or your local emergency number) immediately.

CLU is not a “covered entity” or “business associate” under the U.S. Health Insurance Portability and Accountability Act (HIPAA), and the information you share with CLU is generally not “protected health information” under HIPAA. We nevertheless treat your health information as sensitive and protect it with the heightened care described in this policy.

We collect only the information we need to provide CLU to you. This falls into three groups: information you give us, information CLU’s AI derives from what you share, and technical information collected automatically.

3.1 Account and identity information

You can start using CLU with an anonymous account, so you can try it without giving us any identifying details. If you choose to create or sign in to a permanent account, we collect your email address and, if you use Sign in with Apple or Sign in with Google, the name and email address you choose to share. Sign-in is handled securely through Firebase Authentication, Apple, and Google.

3.2 Health information you provide (sensitive personal information)

This is the heart of what CLU does, and the most sensitive information we hold. It includes:

• symptoms, conditions, allergies, medications, dietary information, family history, and lifestyle habits or exposures you record;
• measurements and notes you enter yourself;
• optional race and ethnicity, which you may choose to provide or leave blank; and
• anything you tell CLU about your health during a conversation.

Race and ethnicity are optional and self-reported. Racial or ethnic origin is treated as sensitive personal information (and, under UK/EU law, as a special category); we use it only to help provide and contextualize your insights, and you can leave it blank or delete it at any time.

With your permission, CLU’s AI also organizes the health details you share — for example, recognizing a medication you mention in a conversation or a value in a document you upload — into your Health Profile, so you don’t have to re-enter them. These entries come from information you provide; CLU does not diagnose you or add findings of its own. You can review, edit, and delete these entries at any time.

3.3 Apple Health (HealthKit) data

If you grant permission, CLU reads health and fitness data from Apple Health to power your insights. Depending on what you choose to share, this can include:

• heart rate, heart-rate variability, resting and walking heart rate;
• sleep, steps and activity, active and resting energy, exercise minutes;
• blood pressure, blood oxygen, respiratory rate, wrist temperature, and cardio fitness (VO₂ max);
• mobility metrics such as walking speed, steadiness, step length, and stair speed;
• body measurements such as weight and height;
• menstrual and cycle data; and
• characteristics such as date of birth, biological sex, blood type, Fitzpatrick skin type, and wheelchair-use status.

You decide which categories to share, and you can change or revoke access at any time in the Apple Health app or in iOS Settings. Revoking access stops future collection; data CLU has already imported remains until you delete it or delete your account. CLU only reads the data you authorize. In line with Apple’s requirements, Apple Health data is never used for advertising or marketing, and is never sold.

3.4 Documents, images, and other content you add

You can upload documents and photos — such as lab reports or clinical letters (PDF or image files, up to 30 MB each) — so that CLU can read and summarize them for you. You can also attach images to a chat. These files are stored privately in your account, and you can delete them at any time.

3.5 Voice input

If you speak to CLU instead of typing, your speech is transcribed into text. See Section 6 for exactly how voice audio is handled.

3.6 Reports you generate

CLU can create “prepare for your appointment” reports that summarize your information to help you make the most of a visit to a healthcare professional. These reports are stored in your account until you delete them.

3.7 Purchase and subscription information

If you buy a subscription or a token top-up (when these are available), the Apple App Store processes your payment — we never receive or store your payment-card details. Apple provides us with limited purchase information, such as your subscription and entitlement status, the product you bought, and transaction identifiers, so we can unlock and manage your plan and token balance.

3.8 Feedback and bug reports

If you send feedback or report a bug, we collect your message and any screenshot you choose to attach. Feedback and bug reports are stored separately from your Health Profile, and any text or screenshots you submit may be reviewed by our support or engineering team to investigate the issue.

3.9 Technical and usage information (collected automatically)

• Device and app information: device model, operating system and app version, language, and time zone.
• Push-notification token: a token from Firebase Cloud Messaging so we can deliver your daily insights and reminders.
• Usage and diagnostics: basic in-app events and error logs to keep CLU working and understand which features are used, including the AI usage totals shown to you on the in-app “Usage & cost” screen.

3.10 Information about other people

Some features let you add documents or information that belong to someone else — for example a family member — and ask you to tell CLU whose information it is. If you provide another person’s information, you confirm that you are allowed to share it with us for that purpose. CLU keeps information you mark as belonging to someone else separate from your own Health Profile and uses it only to provide the feature you requested (for example, reading a document you uploaded). You are responsible for providing any notice to, or obtaining any permission from, that person that the law may require. If someone believes their information is in CLU without authorization, they can contact us at hello@withclu.com and we will address it.

3.11 What we do NOT collect

• We do not collect your precise GPS location.
• We do not use advertising identifiers and do not track you across other apps or websites.
• We do not access your contacts, your photo library (beyond files you explicitly attach), or other files on your device.
• We do not sell your data or share it with advertisers or data brokers.

3.12 At-a-glance summary

We use your information only to run CLU for you, keep it secure, and improve it. Specifically, we use your data to:

• provide the core Services — powering your AI chat, personalized health insights, and daily notifications;
• read and summarize the documents you upload and build your Health Profile;
• generate your “prepare for your appointment” reports;
• remember your history and context so conversations feel continuous;
• keep CLU secure, prevent misuse, diagnose problems, and improve the App; and
• communicate with you about your account and important service updates.

We use AI to derive health-related entries, summaries, and insights from the information you provide, only as needed to deliver the features you request. We do not use your sensitive information to build advertising or marketing profiles, and we do not use it to make employment, insurance, credit, or other similarly significant decisions about you. Where the law requires your consent to collect or process sensitive information (which US privacy laws treat as “sensitive personal information” and UK/EU law treats as a “special category”), we ask for it in the App before those features are enabled, and you can withdraw it as described in Section 12.

CLU’s intelligent features are powered by the OpenAI API. To generate a response, insight, summary, or notification, CLU sends the information relevant to that task to OpenAI over an encrypted connection. Depending on the feature you use, this may include your message or question, relevant parts of your conversation history, summaries of your Health Profile and Apple Health data, and the text or images from documents you have chosen to upload.

When your information is sent to OpenAI

• AI chat: when you ask CLU a question, your message and relevant context are sent to generate a reply.
• Daily insights and notifications: CLU produces your personalized insights on your behalf using the same API, even when you haven’t started a conversation.
• Reading documents: when you upload a report, the text or image is sent so CLU can read and summarize it.
• Voice and audio: your speech is transcribed to text, and CLU can read responses aloud (see Section 6).

What this means for your data — and why you can feel safe

OpenAI acts only as our data processor (service provider), handling your information on our behalf and under our instructions to deliver CLU’s features to you.

OpenAI does not use data submitted through its API to train or improve its models. Your health information is never used to teach an AI. This is a core part of OpenAI’s terms for business and API customers.

Limited, temporary retention for safety only. Under OpenAI’s API data-usage policies, OpenAI may retain limited API inputs and outputs for a short period (generally up to 30 days, and varying by feature) to provide the service and to monitor for misuse and abuse, after which they are deleted — unless OpenAI is legally required to retain them for longer.

Encrypted, and routed through our own secure backend. Data is transmitted to OpenAI only over encrypted channels (HTTPS/TLS). CLU’s connection to OpenAI runs through our own secure server (Google Cloud Functions); the credentials used to access OpenAI are never stored in the app on your phone.

Only what a feature needs. We send the minimum information required for each feature, and your data is never shared with OpenAI for advertising.

You can read OpenAI’s data-usage terms for API customers at openai.com/policies/api-data-usage-policies and its privacy policy at openai.com/policies/privacy-policy.

We tell you this because, when you use CLU’s AI features, the information described above leaves CLU’s own systems to be processed by OpenAI. Because CLU cannot provide these features without this processing, we ask for your consent to it when you start using the App, and you can withdraw that consent at any time — for example in the app’s Data Controls (by disconnecting Apple Health, deleting your data, or deleting your account) or by emailing us. Some features will stop working without this processing.

If you talk to CLU instead of typing, your recording is streamed to OpenAI’s transcription service to convert your speech into text. The audio is used only to produce that transcript — CLU does not keep a separate audio recording of your voice, and only the resulting text is stored as part of your conversation. If you ask CLU to read a response aloud, the text is sent to OpenAI’s text-to-speech service to generate the audio you hear. As with all AI processing described in Section 5, this audio and text are never used to train AI models.

Your CLU account and data are stored on Google Cloud Platform / Firebase, a leading, independently audited cloud infrastructure provider that acts as our data processor. We use:

• Cloud Firestore — your Health Profile, conversations, insights, reports, and settings;
• Firebase Cloud Storage — documents and images you upload;
• Firebase Authentication — secure sign-in;
• Firebase Cloud Functions — our secure backend, which is the only component that communicates with OpenAI; and
• Firebase Cloud Messaging — delivery of your notifications.

Our security measures

• Encryption everywhere: all data is encrypted in transit (HTTPS/TLS) and at rest using strong, industry-standard encryption applied automatically by Google Cloud.
• Strict per-user isolation: database security rules ensure your records can be read and written only by your own authenticated account.
• Protected secrets: our OpenAI API key and other credentials are held in Google Cloud Secret Manager, never inside the app.
• Restricted, logged access: access to production systems is limited to a small number of authorized personnel and is logged.
• Your content is not routinely read: our team does not routinely access the content of your conversations, health records, or documents. Limited access may occur only to respond to a support request you make to us, to investigate a genuine security, safety, or abuse concern, or where we are required to by law.

No method of transmission or storage is ever completely secure. While we use measures appropriate to the sensitivity of your data, we cannot guarantee absolute security, and you also play a part by keeping your device and sign-in credentials safe.

We do not sell your personal information, and we do not “share” it for cross-context behavioral advertising, as those terms are defined under the California Consumer Privacy Act (CCPA/CPRA) and other US state privacy laws. We have not sold or shared personal information in the preceding 12 months. We do not use or disclose your sensitive personal information beyond providing the Services and the limited operational purposes permitted by law, and we do not use your health information for advertising, marketing profiles, or data mining. We also do not make decisions that produce legal or similarly significant effects about you based solely on automated processing.

We share your information only with the trusted providers we need to run CLU. Our processors — OpenAI and Google Cloud (Firebase) — handle your data under data processing agreements, on our instructions, and never for their own purposes. Apple and Google also act as independent controllers when they provide sign-in and platform services (for example, Sign in with Apple or Google, and Apple’s push-notification service), which they handle under their own privacy policies.

We may also disclose your information: (a) to comply with the law or a valid legal request; (b) to protect the rights, safety, and security of our users, the public, or CLU; and (c) as part of a merger, acquisition, or sale of assets — in which case we will notify you beforehand, and any new owner will remain bound by this policy. We will only share your data in other ways with your consent.

CLU is operated by a UK-registered company for users in the United States. Your personal information is stored and processed in the United States by our providers (including OpenAI and Google Cloud). Our team may access your information from the United Kingdom to operate, secure, and support the Services. Where your data is transferred from the UK or EEA to the United States or another country, we rely on recognized safeguards — such as the UK International Data Transfer Agreement/Addendum and the EU Standard Contractual Clauses (and, where a provider is certified, the EU–US Data Privacy Framework and its UK extension) — so that your data continues to receive an equivalent level of protection (see Section 13).

We keep your personal information only for as long as you have a CLU account and use the Services. You are always in control:

• You can delete individual items — a conversation, a document, or a health record — at any time, and they are removed from our active systems.
• You can delete your entire account from within the App. When you do, we permanently erase your personal information from our systems within 30 days, except where we are legally required to keep certain limited records for longer.
• Backups: our databases are backed up for disaster recovery, and deleted data is cleared from those backups as they cycle, typically within a few weeks.
• OpenAI: as explained in Section 5, OpenAI retains limited API data for a short period (generally up to 30 days, varying by feature) for abuse monitoring and then deletes it.
• Anonymized or aggregated information that can no longer identify you may be retained, because it is no longer personal information.

Depending on the state you live in, you may have some or all of the rights below. We extend the core rights to all US users wherever we can. (If you are in the UK or EEA, see Section 13 for your rights under UK/EU data protection law.)

• Know / access: request the categories and specific pieces of personal information we hold about you and how we use and disclose it.
• Correct: ask us to fix inaccurate personal information.
• Delete: ask us to delete your personal information.
• Portability: receive a copy of your data in a portable, machine-readable format.
• Opt out: opt out of the sale or sharing of personal information and of targeted advertising — although we do none of these.
• Limit sensitive data: limit the use of your sensitive personal information; we only ever use it to provide the Services to you.
• Withdraw consent: withdraw your consent to our processing of your health information at any time — for example in the app’s Data Controls (by disconnecting Apple Health, deleting your data, or deleting your account) or by emailing us. Some features may stop working without this processing.
• Non-discrimination: we will never treat you differently for exercising any of these rights.

How to exercise your rights

You can exercise many of these rights directly in the App — by editing your Health Profile, deleting conversations and documents, managing your data in the App’s Data Controls, or deleting your account. For anything else, email us at hello@withclu.com. We respond within 45 days (and may extend once by another 45 days when necessary, with notice). Requests are free. To protect your data, we may first need to verify your identity, and you may use an authorized agent where the law allows. If we decline a request, you may appeal by replying to our decision or emailing us; if your appeal is unsuccessful, you may contact your state attorney general.

12.1 California residents (CCPA/CPRA)

If you are a California resident, you have the rights described above. The categories of personal information we collect (using CCPA definitions) are:

We collect this information from you, from your device, from Apple/Google at sign-in, and (for purchases) from the Apple App Store, for the business purposes described in Sections 3–4, and we disclose it only to the service providers in Section 9 to operate CLU. We do not sell or share any category of personal information, and we do not use or disclose sensitive personal information for any purpose other than providing the Services. We do not disclose personal information to third parties for their own direct-marketing purposes.

12.2 Other US states (Virginia, Colorado, Connecticut, Texas, Utah, Oregon, Montana, and others)

If your state has a comprehensive privacy law, you have rights to access, correct, delete, and obtain a portable copy of your personal data, and to opt out of targeted advertising, the sale of personal data, and certain profiling — none of which we perform. Because your health and racial/ethnic information is “sensitive data,” we obtain your consent before processing it. You may appeal a denied request as described above, and you may contact your state attorney general if you have concerns.

12.3 Consumer Health Data Privacy Notice (Washington, Nevada & Connecticut)

This section is our Consumer Health Data Privacy Notice for residents of Washington (My Health My Data Act), Nevada, and Connecticut. It describes how CLU handles “consumer health data.”

• Categories we collect: the health information in Section 3 — symptoms, conditions, allergies, medications, dietary information, family history, lifestyle habits and exposures, measurements, optional race/ethnicity, uploaded health documents and images, voice you convert to text, and the Apple Health data you choose to connect — together with insights CLU derives from it.
• Why we collect it (purposes): solely to provide the health features you request — your AI chat, personalized insights and notifications, document reading, and appointment-prep reports — and to keep the Services secure.
• Sources: from you (what you enter, say, or upload), from Apple Health with your permission, and from CLU’s AI organizing what you share.
• Who we share it with: only the processors in Section 9 — OpenAI (to power AI features) and Google Cloud / Firebase (to host and secure your data) — under contracts that forbid using it for their own purposes. We do not share consumer health data with any other third parties or affiliates.
• Consent: we collect, use, and share consumer health data only with your consent, which we request in the App before these features are enabled, and only as needed to provide the Services you request.
• No sale: we do not sell consumer health data and never will; a sale would require your separate, valid authorization, which we do not seek.
• No geofencing: we do not use geofences around any healthcare facility.
• Your rights: you may confirm whether we hold your consumer health data and access it, withdraw your consent, and request deletion — using the app’s Data Controls or by emailing hello@withclu.com. When you delete your account, your consumer health data is deleted as described in Section 11.
• Who can access it: you (through your account), our processors acting on our instructions, and the small number of authorized CLU personnel described in Section 7.

Because OLDB LIMITED is established in the United Kingdom, the UK GDPR (and, where it applies, the EU GDPR) governs our processing of personal data, regardless of where our users are located. OLDB LIMITED is the data controller for the personal data described in this policy. This section explains the lawful bases we rely on, your rights, and how your data is transferred and protected.

Our lawful bases

We ask for your explicit consent to process your health information and any race/ethnicity you choose to provide when you begin using CLU’s health features. Because CLU cannot work without processing this data, withdrawing consent means those features will no longer be available; you can withdraw at any time (as easily as you gave it) in the app’s Data Controls — by disconnecting Apple Health, deleting your data, or deleting your account — or by emailing us. Where we rely on legitimate interests, we have balanced those interests against your rights.

Your rights

If UK or EU data protection law applies to you, you have the right to access your personal data; to have it corrected or erased; to restrict or object to processing; to data portability; to withdraw consent at any time; and not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects. To exercise these rights, use the app’s Data Controls or email hello@withclu.com; we respond within one month, free of charge, and may ask you to verify your identity first.

International transfers

Your data is processed in the United States by our providers and may be accessed from the United Kingdom by our team. When data is transferred outside the UK or EEA, we rely on recognized safeguards — the UK International Data Transfer Agreement/Addendum and the EU Standard Contractual Clauses, and (where a provider is certified) the EU–US Data Privacy Framework and its UK extension — so your data keeps an equivalent level of protection.

Complaints

You have the right to complain to a data protection authority. In the UK, that is the Information Commissioner’s Office (ICO), ico.org.uk, telephone 0303 123 1113. In the EEA, you can complain to your local supervisory authority. We would, however, appreciate the chance to address your concerns directly first.

CLU is intended for adults. You must be at least 18 years old to use CLU. We do not knowingly collect personal information from anyone under 18, and — consistent with the U.S. Children’s Online Privacy Protection Act (COPPA) — we never knowingly collect personal information from children under 13. If we learn that we have, we will delete it promptly. If you believe a minor has provided us with personal information, please contact us at hello@withclu.com.

We take the security of your data seriously. In the unlikely event of a security breach that compromises your personal information, we will notify you and any relevant regulators as required by applicable law — including, where applicable, the U.S. Federal Trade Commission’s Health Breach Notification Rule, US state breach-notification laws, and, under UK/EU GDPR, the relevant supervisory authority (and you, where the breach is likely to result in a high risk to your rights) — without unreasonable delay.

We may update this Privacy Policy from time to time. If we make material changes, we will notify you in the App and/or by email before they take effect and update the “Last updated” date at the top. We encourage you to review this policy periodically. Continuing to use CLU after changes take effect means you accept the updated policy.

Where applicable law requires your consent for a new category of health data or a new processing purpose, we will obtain that consent before the new processing begins.

For any privacy question, request, or concern, contact us at hello@withclu.com.

By post: OLDB LIMITED, C/O Eaccounts, Ground Floor, Cardigan House, Enterprise Park, Swansea, Wales, SA7 9LA, United Kingdom.

If you are a California resident with unresolved concerns, you may contact the California Privacy Protection Agency (cppa.ca.gov) or the California Attorney General (oag.ca.gov); residents of other US states may contact their state attorney general. If you are in the UK or EEA, you may complain to a data protection authority — in the UK, the Information Commissioner’s Office (ICO), ico.org.uk. We would, however, appreciate the chance to address your concerns directly first.