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Plain-English summary
The policy indicates that your data may be transferred to countries outside the European Economic Area, including Australia and the United States, for customer service purposes even though these countries may not provide adequate data protection (risk_flags-1). For AI-powered features, your health data is processed based on your explicit consent, and this processing may involve third-party service providers (data_use-1). Similarly, when you contact customer support, you explicitly consent to the processing of your personal and health data to answer your query (data_use-2).
85% confidence
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Risk Flags
Critical issues and red flags that could lead to significant harm. These include hard-to-reverse situations like money you cannot easily recover, lasting privacy exposure, loss of account access, or weakened dispute rights.
high90% confidence
Transfer of data to countries without adequate data protection for customer service
Data may be transferred to countries outside the European Economic Area (EEA), including Australia and the United States, which do not provide an adequate level of data protection when providing customer service. There may be risks associated with such transfers, particularly regarding access by public authorities and the enforceability of data subject rights by users.
Why it matters: Your personal data, limited to information you have chosen to make publicly available, may be transferred to countries outside the EEA, such as the US and Australia, which may not offer the same level of data protection. This could expose your data to access by public authorities and may limit your ability to enforce your data subject rights in these jurisdictions.
Please note that despite these safeguards, there may be risks associated with such transfers, in particular with regard to access by public authorities and the enforceability of data subject rights. However, the data processed in this context is limited to information that you have chosen to make publicly available.
3.2 To provide customer service, paragraph 3 · Citation strength: strong
Data Use
This section outlines how your data is collected, processed, and shared. It focuses on the purposes for data use, who it's shared with, and the types of data involved.
medium90% confidence
Health data processing for AI-powered features is based on user consent
The processing of your health data for AI-powered features requires your explicit consent. You agree that Clue may process health data tracked in the app, along with additional information provided when using AI-powered features, to generate personalized insights and answers using artificial intelligence technology. This processing may involve carefully selected third-party service providers acting on Clue's behalf.
Why it matters: If you activate AI-powered features, your health data and other information you provide will be processed to generate personalized insights and answers. This processing may involve third parties. You have control to withdraw your consent at any time.
**I agree that Clue may process the health data I track in the Clue app, together with additional information I provide when using AI-powered features within the Clue app, to generate personalised insights and answers using artificial intelligence technology. I understand that this processing may involve carefully selected third-party service providers acting on Clue's behalf. I can withdraw my consent at any time in my privacy settings.**
3.1.7. To use AI based service features, paragraph 11 · Citation strength: strong
medium90% confidence
Health data is processed for customer service with explicit consent
When you contact the Clue Support Team, you explicitly provide your consent for the processing of your personal data, including your health data, so that your query can be answered.
Why it matters: When seeking customer support, you explicitly consent to Clue accessing and processing your personal and health data to address your query. This means information you share related to your health may be reviewed by customer service.
When you contact the Clue Support Team, you explicitly provide your consent for the processing of your personal data, including your health data, so that your query can be answered.
3.2 To provide customer service, paragraph 6 · Citation strength: strong
Cancellation & Renewal
This section examines policies related to subscription, cancellation, and renewal, including terms for account termination and data retention post-cancellation.
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Other Gotchas
This section covers a variety of other stipulations and less common, but important, clauses that might impact you.
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No hidden gotchas
Verbaterm only flags concerns it can cite. Nothing easy-to-miss stood out in this section.
Protections
These clauses outline commitments and features designed to protect users, including explicit data minimization, user controls, data deletion, and advance notice of changes.
Protection95% confidence
User control over Apple Health data exchange
You can choose if and to what extent your personal data is exchanged between Clue and the Apple Health app by granting or revoking the relevant permissions in your Health app settings at any time.
Why it helps: This clause ensures you maintain control over which of your personal data is shared between Clue and Apple Health, allowing you to manage your privacy settings. You can adjust these permissions whenever you want.
You can choose if and to what extent your personal data is exchanged between Clue and the Health app by granting or revoking the relevant permissions in your Health app settings. This can be done at any time.
3.1.2 Integrations to track your data:, paragraph 3 · Citation strength: strong
Protection90% confidence
Withdrawal of consent for AI-powered features
You can withdraw your consent for processing health data for AI-powered personalised insights at any time in your privacy settings. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
Why it helps: This clause gives you control and flexibility over the use of your health data for AI-powered features, allowing you to opt-out at any point. While past processing remains lawful, you can prevent future use of your data for these features.
You can toggle this off at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
3.1.7. To use AI based service features, paragraph 12 · Citation strength: strong
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