Privacy Policy

Last Updated: March 8, 2026

Effective Date: March 8, 2026

This Privacy Policy explains how Clarion ("we," "us," or "our") collects, uses, shares, and protects your personal information when you use the Clarion mobile application ("App").

By using the App, you consent to the data practices described in this Privacy Policy.

---

1. INFORMATION WE COLLECT

1.1 Information You Provide

Account Information:

Health and Wellness Data:

Payment Information:

User-Generated Content:

1.2 Information Collected Automatically

Usage Data:

Device Information:

Location Data:

Screen Time Data (Optional):

Cookies and Similar Technologies:

1.3 Information from Third Parties

Firebase Services:

Social Login Providers:

- Name and email from your social account - Profile picture (if permitted)

Payment Processors:

---

2. HOW WE USE YOUR INFORMATION

2.1 Primary Purposes

We use your information to:

Provide the App:

Improve the App:

Communicate with You:

Legal and Security:

2.2 AI and Personalization

We use your data to power AI features:

AI Processing:

---

3. HOW WE SHARE YOUR INFORMATION

3.1 We DO NOT Sell Your Data

We do NOT sell, rent, or trade your personal information to third parties for marketing purposes.

3.2 Service Providers

We share data with trusted third-party service providers who help us operate the App:

Firebase (Google):

OpenAI / Anthropic:

RevenueCat:

Apple / Google:

Facebook, Inc.:

All service providers are contractually obligated to protect your data and use it only for the purposes we specify.

3.3 Legal Requirements

We may disclose your information if required to:

3.4 Business Transfers

If we merge, are acquired, or sell assets, your information may be transferred to the new owner. We will notify you before your data is transferred and becomes subject to a different privacy policy.

3.5 With Your Consent

We may share your data for other purposes with your explicit consent (e.g., sharing anonymized case studies, testimonials).

3.6 Anonymized Data

We may share aggregated, de-identified, or anonymized data that cannot reasonably identify you:

---

4. DATA RETENTION

4.1 How Long We Keep Your Data

4.2 Backups

---

5. DATA SECURITY

5.1 Security Measures

We implement industry-standard security measures to protect your data:

Technical Safeguards:

Organizational Safeguards:

5.2 Limitations

No system is 100% secure. Despite our efforts:

5.3 Your Responsibilities

To protect your account:

---

6. YOUR RIGHTS AND CHOICES

6.1 Access and Portability

You have the right to:

6.2 Correction and Deletion

You have the right to:

To delete your account: 1. Go to Profile → Settings → Delete Account, OR 2. Email support@clarion.app with your request

Note: Deletion is permanent and cannot be undone. Some data may be retained for legal compliance.

6.3 Opt-Out of Communications

You can opt out of:

You cannot opt out of essential communications (account security, service updates, legal notices).

6.4 Opt-Out of Data Sharing

6.5 Do Not Sell (CCPA)

We do NOT sell your personal information. California residents can confirm this by visiting clarion.app/ccpa-notice.

---

7. CHILDREN'S PRIVACY

7.1 Age Requirement

The App is NOT intended for users under 18 years old.

We do not knowingly collect data from children under 13 (or 16 in the EU). If you are under 18, you must have parental consent to use the App.

7.2 Parental Notice

If we discover we have collected data from a child under 13 without parental consent, we will delete it immediately. If you believe your child has provided us with personal information, contact us at privacy@clarion.app.

---

8. INTERNATIONAL DATA TRANSFERS

8.1 Data Storage Location

Your data is stored on servers located in:

8.2 Cross-Border Transfers

If you are located outside the United States, your data may be transferred to and processed in the United States or other countries where our service providers operate.

By using the App, you consent to the transfer of your data to countries that may have different data protection laws than your country.

8.3 EU-U.S. Data Privacy Framework

For EU users, we comply with applicable data protection laws and rely on:

---

9. REGION-SPECIFIC RIGHTS

9.1 European Union (GDPR)

If you are in the EU, you have additional rights under the General Data Protection Regulation (GDPR):

Legal Basis for Processing:

To exercise your rights, email privacy@clarion.app with your request.

9.2 California (CCPA/CPRA)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA):

To exercise your rights, email privacy@clarion.app or call [INSERT TOLL-FREE NUMBER - REQUIRED FOR CCPA COMPLIANCE - example: 1-800-CLARION].

We will verify your identity before processing requests to protect your privacy.

California Shine the Light Law: We do not share personal information with third parties for their direct marketing purposes.

9.3 Other Jurisdictions

If you are in another jurisdiction with privacy laws (Australia, Canada, Brazil, etc.), you may have similar rights. Contact us at privacy@clarion.app to learn more.

---

10. COOKIES AND TRACKING TECHNOLOGIES

10.1 Types of Technologies Used

10.2 Purposes

10.3 Managing Cookies

You can control cookies through:

Note: Disabling essential cookies may prevent the App from functioning properly.

---

11. THIRD-PARTY LINKS

The App may contain links to third-party websites or services (e.g., crisis resources, befrienders.org). We are NOT responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any information.

---

12. CHANGES TO THIS PRIVACY POLICY

12.1 Updates

We may update this Privacy Policy from time to time to reflect:

12.2 Notice of Changes

We will notify you of material changes via:

Changes will be effective 30 days after notice for material changes, or immediately for non-material changes.

12.3 Continued Use

Your continued use of the App after changes take effect constitutes acceptance of the updated Privacy Policy. If you do not agree, you must stop using the App and delete your account.

---

13. CONTACT US

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data:

Email: privacy@clarion.app Support: support@clarion.app Legal: legal@clarion.app

Mailing Address: Clarion, Inc. [INSERT ACTUAL REGISTERED AGENT ADDRESS - REQUIRED BEFORE LAUNCH] [Example: 123 Main Street, Suite 456] [Wilmington, DE 19801]

⚠️ ACTION REQUIRED BEFORE LAUNCH: Replace brackets above with your actual registered business address. This is legally required for GDPR/CCPA compliance.

Data Protection Officer (EU): dpo@clarion.app

Response Time: We aim to respond to all inquiries within 30 days.

---

14. ADDITIONAL DISCLOSURES

14.1 Sensitive Information

We collect health and wellness data, which may be considered sensitive information. We implement enhanced security measures for this data and limit access to authorized personnel only.

14.2 Automated Decision-Making

We use AI and algorithms to:

You have the right to:

14.3 Crisis Event Logging

If our system detects crisis keywords (suicide, self-harm), we log the event to Firebase for safety monitoring. This helps us:

This data is highly confidential and accessed only by authorized personnel.

14.4 HealthKit Data (iOS Only)

IMPORTANT: Clarion is NOT a HIPAA-covered entity or medical device.

If you choose to connect Apple Health (entirely optional), HealthKit data is:

You can revoke access anytime: iOS Settings → Health → Data Access & Devices → Clarion

Data collected (if you grant permission):

How we use it:

We do NOT:

---

15. SUMMARY OF KEY POINTS

✅ We collect: Account info, health data, usage data, device info ✅ We use it to: Provide the App, personalize features, improve services, ensure safety ✅ We share with: Service providers (Firebase, AI providers, payment processors) ✅ We do NOT sell your data to third parties ✅ You can: Access, correct, delete, export, or opt out of certain data uses ✅ Your data is secure: Encrypted in transit and at rest, with industry-standard protections ✅ You have rights: Especially if you're in the EU (GDPR) or California (CCPA)

For full details, read the complete Privacy Policy above.

---

End of Privacy Policy