Clatch Privacy Policy
Last updated July 4, 2024
1. How Clatch values data privacy
At Clatch, we believe that technology and data present a groundbreaking opportunity to empower people to take control of their health. Clatch gives people the ability to understand what is going on inside of their bodies and minds based on individual tracked health data, providing self-insight and self-advocacy that’s powered by data processing.
We also fully acknowledge the responsibility that comes with being the safekeepers of so much intimate data which is tracked by people using Clatch. Which is why we are always striving to achieve the highest standards of privacy and security. Keeping your data safe is at the core of everything we do.
We see it as our job to be clear and transparent so that you can truly understand what we do with your data, even though the digital ecosystem of an app is complex. To provide our service as a health app, we rely on a number of other providers as summarized below to help us.
Please read the whole of this Privacy Policy to understand how we handle your data. We have done our best to make it as clear and comprehensible as possible. If you have any questions, reach out to us at <clatch@mts.ru>.
2. The types of data we process
We process three types of data in order to provide our services on Clatch and https://clatch.app/ website. All of our data is securely stored on servers.
Account data: In order to create your Clatch account, we process some of your personal data such as a username, date of birth and email address.
Usage data: In order to provide our services and technically improve performance, we process how you interact with our products using different data points. Such data includes device data, which informs us about the device you use to access our app services (such as device model, name and identifiers, device settings, application identifier, crash information). On our website, we also collect information about your browser (such as browser settings, operating system, system settings). Other usage data includes the IP address provided by your browser or mobile device, which we collect in order to deliver the service to your device. We also use the IP address to determine your approximate location for statistical and analytics purposes, and for regulatory compliance in different countries. We do not collect your precise location.
Health data: In order to provide our service as a health app, we process health data and other sensitive data that you choose to track in Clatch. Such health data may include your cycle information (e.g. period length, pain, or spotting), and depending on the data you provide, it may also contain other sensitive data about your experiences (e.g. weight, body temperature, hair quality, sexual intercourse). We only process the health data you choose to share with Clatch via tracking. You may use different methods provided by the app to track your health data in the app. This can include manually entering your data into the app, or importing your data from other integrations or devices supported by Clatch (such as Apple Health or fitness trackers).
3. How and why we process your data
Data processing is essential to providing the service of Clatch. Whenever you use our services, some personal and non-personal data is collected, stored, and analyzed using internal and third-party tools.
Below are the purposes for which we process your data, and the type of data that’s processed to fulfill each purpose:
3.1 To provide our core service to you
To provide our service, we process the following:
3.1.1 Essential third party providers:
We use several third party providers to help us perform our core services.
Firebase (Android users only): Clatch uses a suite of performance analysis and monitoring tools called Firebase, which is provided by Google Inc. Firebase allows us to monitor the overall performance and stability of our app, implement internal version control, identify bugs and prioritize fixes. For this purpose Firebase collects your IP address, device identifier, as well as event and usage data related to your use of Clatch. This data will be transferred to and stored on a server in the EU and operated by Google, LLC.
It is not possible to opt-out of Firebase as it is an essential tool that we require in order to provide a functioning Clatch to you.
3.1.2 Integrations to track your data:
In addition to manually tracking your health data in Clatch, importing data from other sources is supported for the integrations listed below.
Apple Health (iOS): This section is only applicable to users who choose to sync their Apple Health app with Clatch. Clatch will not exchange any personal data with Apple’s Health app unless you specifically approve this. Approval can be given by you in the relevant settings of the Health app or with in Clatch via your Settings. If you have given your approval, Clatch may interact with the Health app on your iOS device and read and/or write information between Clatch and the Health app. This may include a transfer of your personal data to Apple servers located outside the European Union.
You can choose if and to what extent your personal data is exchanged between Clatch and the Health app by granting or revoking the relevant permissions in your Health app settings. This can be done at any time. Please refer to the Privacy Information of Apple Health for further information.
Sign in with Apple: Clatch uses “Sign in with Apple” to allow users to create and sign in to their Clatch account with their Apple credentials.
If you sign up to Clatch using Apple, Clatch will exchange certain data with Apple like device data, IP-address, and information you provided to Apple when creating an account with Apple Inc. This may include a transfer of your personal data to Apple servers located outside the European Union. It is your choice if and to what extent you use the “Sign in with Apple” service and what information you provide to Apple. Absolutely no health data will be exchanged with Apple for the purpose of using the “Sign in with Apple” service.
Sign in with Google: Clatch uses “Sign in with Google” to allow users to create and sign in their Clatch account with their Google credentials. If you use this service, you authorize us to collect your basic information from Google, like your email address. You can manage this any time in your Google account. Please see Google's resources for more details on this.
If you sign up to Clatch using Google, Clatch will exchange with Google the types of data you provided to Google when creating an account with them (such as name, email address). This may include a transfer of your personal data to Google servers located outside the European Union. It is your choice if and to what extent you use the “Sign in with Google” service and what information you provide to Google. Absolutely no health data will be exchanged with Google.
Legal basis: Our legal basis for processing the above mentioned data is Art. 6 b) General Data Protection Regulation (GDPR), which means that we use it to perform the contract that you have entered into with Clatch, via Wellhub. We also process your Clatch account data and usage data on the legal basis of Art 6 Sec.1 lit b) GDPR to provide our services to you. The processing of health data to provide our service to you is based on the following consent according to Art 9 Sec.2 lit a) GDPR:
I agree to Clatch processing the health data I choose to share with the app, so they can provide their service.
All personal data collected for providing our service is deleted by us as soon as it is no longer required for the purpose for which it was collected.
Legal basis:The legal basis for processing your account data and usage data for customer service is Art 6 Sec. 1 lit b) GDPR, and Art 9 Sec.2 lit a) GDPR for your health data.
When you contact the Clatch 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.
All personal data collected for our customer service is deleted by us as soon as it is no longer required for the purpose for which it was collected.
3.3 To help advance scientific research
To help advance menstrual and reproductive health studies, we share relevant de-identified health data you’ve tracked in Clatch with carefully selected research partners to be used in their scientific studies.
When you track in Clatch, your data becomes something powerful. It can help answer questions to better understand menstrual and reproductive health. Women and people with cycles are still widely underrepresented in health research. We believe that the data tracked in Clatch can change this. By teaming up with our trusted research partners we can advance research, break harmful taboos and lay the groundwork for better healthcare.
We only share data that is directly relevant to the research question and follow strict protocols to ensure your data always remains anonymous to the researchers. We use a de-identification technique which means all personal identifiers like your name and email address are erased. Your dataset is then assigned a random ID, making sure you can’t be identified by the researchers.
If you are a participant in a scientific study that is run by a research facility using Clatch as a tool to collect information for that study, then Clatch will share your personal information with the research facility only under the terms of your consent as given to that research facility. When you use Clatch as part of a scientific study, we will otherwise treat your personal data with the same care as we do all user data. The research facility will be solely responsible for the usage of your personal data, including health data, in the context of their scientific study. We consider that Clatch and our partnered research facilities have joint responsibility ("joint controllership" under GDPR) in this case.
Research partners: We team up with carefully selected research partners both in and outside of the European Union.
Whenever data is transferred to partners outside of the European Economic Area (EEA), we always apply the appropriate safeguards as outlined by the General Data Protection Regulation (GDPR) (see Section 4).
Legal basis: The processing of your health data for scientific research is based on the following consent according to Art 9 Sec.2 lit a) GDPR, if you have toggled this on in your privacy settings:
I agree to the health data I track in the app being de-identified and shared with carefully selected research partners in and outside of the European Union to advance menstrual and reproductive health studies.
You can toggle this off at any time. All personal data collected for scientific research is deleted by us as soon as it is no longer required for the purpose for which it was collected.
3.4 To improve Clatch features with health analytics
To help us build more valuable features in Clatch, we process health data you’ve tracked in the app to better understand which features are most useful to you. By processing data such as period dates and cycle experiences, we can better understand how our community uses the app and further tailor the experience to fit their needs.
By analyzing how our community uses the app, we can understand which features are most valuable. We use these insights to drive feature development, so we can make sure to deliver what’s most important. This could include things like improving the accuracy of predictions, building new algorithms to offer you more health insights, or creating content about topics we see our community wants to read about more.
The processing of health data for analytics purposes is managed internally by Clatch. We store your data on servers in the EU and it’s always de-identified, removing personal identifiers like your name and email address. These procedures ensure your privacy.
Third party providers: We do not use any third party providers for this purpose.
Legal basis: The processing of your health data for health analytics is based on the following consent according to Art 9 Sec.2 lit a) GDPR, if you have toggled this on in your privacy settings:
I agree to the health data I track in the app being processed for analytics purposes so Clatch can improve my predictions, develop new algorithms and create more valuable features with personalized insights.
You can toggle this off at any time. All personal data collected for the health data analytics is deleted by us as soon as it is no longer required for the purpose for which it was collected.
3.5 To technically improve Clatch
To help us improve Clatch experience, we process and analyze certain data so we can improve the app and make features easier to use. This includes usage data like your device ID and IP address.
By improving the app and its technical platform, we can deliver a better experience for you and the wider Clatch community. It allows us to tailor the app to different types of devices, and most importantly, strive to make the app experience the best it can be.
Third party providers: We do not use any third party providers for this purpose.
Legal basis: We process your usage data on the legal basis of Art 6 Sec.1 lit f) GDPR to technically improve Clatch based on Clatch’s legitimate interest as a company to continuously improve the app and deliver an improved service to you. We do not believe there is anything you could have against this. However you can always opt out of this data processing at any time in your Clatch app’s privacy settings by toggling off:
As outlined in Clatch’s Privacy Policy and based on Clatch’s legitimate interest as a company to continuously improve the app, certain usage and technical data is processed. I have the right to opt out of this at any time.
All personal data collected to technically improve Clatch is deleted by us as soon as it is no longer required for the purpose for which it was collected.
3.6 To allow recommendations from Clatch
To make personalized recommendations, we process certain usage data to understand how you interact with Clatch, as well as the health data you’ve tracked to deliver you more personalized insights. This includes data such as your period dates and cycle experiences. We also collect your account data so we can then send you these recommendations via in-app messages, emails, and push notifications (if you’ve enabled permissions on your device). By personalizing your experience, we can provide information that’s more tailored to you and your needs. This might look like sending you updates about new Clatch features based on what you’ve tracked, or suggesting interesting products from partnerships we support that may be relevant to you. For example, if you’re trying to conceive, we might recommend services that can support you on your conception journey. We strive to be mindful about what we communicate and how often, as providing you with the most comfortable experience possible is our main priority.
Third party providers: We use certain third party software providers to help us send these updates, such as Braze (see Section 3.1.1). These providers are not permitted to use the data for any other purpose other than to help Clatch personalize your experience.
Whenever data is transferred outside of the European Economic Area (EEA), we always apply the appropriate safeguards as outlined by the General Data Protection Regulation (GDPR) (see Section 4).
Be assured that the sensitive health data you track in Clatch is never shared with or sold to advertisers, or any partners whose services we may recommend in Clatch.
Legal basis: The processing of your account data and usage data for recommendations from Clatch is based on the following consent according to Art 6 Sec.1 lit a) GDPR, and the processing of health data for recommendation from Clatch is based on the following consent according to Art 9 Sec.2 lit a) GDPR, if you have toggled this on in your privacy settings:
I agree to my account data, usage data and health data I track in Clatch being processed so Clatch can send me personal recommendations for relevant products based on my tracked experiences. Certain third-party providers, including some located outside of the European Union, are used to help with this.
You can toggle this off at any time. All personal data collected for providing personal recommendations is deleted by us as soon as it is no longer required for the purpose for which it was collected.
3.7 To help Clatch optimize their advertising efforts
To help us analyze how Clatch’s advertising performs, we process certain types of usage data (for example when you install Clatch) including your device ID and IP address. This helps us identify whether you’ve already downloaded Clatch and find out which Clatch ads you interacted with (if any).
By doing this, we can optimize our advertising efforts. For example, if you’ve already downloaded Clatch, we won’t show you an ad to download Clatch. It also helps us understand on which platforms people find out about us, and learn what kind of Clatch advertising performs best. With better advertising, we can help raise awareness about Clatch and empower more people to take charge of their health.
Legal basis: The processing of your usage data to promote Clatch is based on the following consent according to Art 6 Sec.1 lit a) GDPR, if you have toggled this on in your privacy settings:
I agree to my usage and device data being processed so Clatch can optimize their advertising efforts to more effectively tell more people about Clatch. Certain third party providers, including some located outside of the European Union, are used to help with this.
You can toggle this off at any time. All personal data collected to help to promote Clatch is deleted by us as soon as it is no longer required for the purpose for which it was collected.
3.8 To optimize advertising with activity tracking (iOS users only)
To help us optimize our advertising and to spread the word about Clatch, we enable activity tracking on iOS devices when permissions are turned on. Activity tracking means that limited technical data (like your device ID) and usage data (for example installing Clatch) is shared with advertisers so you don’t see Clatch ads that aren’t relevant to you. You can turn off activity tracking any time in your iOS Settings.Activity tracking is strictly limited to technical and usage data. Your health data is never shared with advertisers and always protected.
Legal basis: The processing of your usage data for activity tracking is based on the following consent according to Art 6 Sec.1 lit a) GDPR, if you selected “Allow” when presented the following prompt from Apple:
Allow “Clatch” to track your activity across other companies’ apps and websites?
All personal data collected for activity tracking is deleted by us as soon as it is no longer required for the purpose for which it was collected.
3.9 To improve https://clatch.app/ with website analytics
To improve our website, we process usage data such as your IP address and device data. This helps us track the performance of our website, understand how you use our website, and offer you an improved experience. For this purpose we use cookies and third party tracking services. Cookies are small text files that are intended to make the site better for you to use.
In general, cookies are used to retain preferences, store information for things like shopping carts, provide tracking data to third-party applications like Google Analytics, Taboola or Outbrain, or identify your device for special advertising purposes such as retargeting. You can learn more about the specific cookies and tracking services used on https://clatch.app/ in Section 7.
Legal basis: The processing of your usage data for website analytics is based on the following consent according to Art 6 Sec.1 lit a) GDPR:
By using our website you consent through an opt-in in the cookie banner that Clatch may use cookies and third-party services, and collect your usage data under a unique identifier for the purposes of tracking, analysis, and improvement of our website, as well as advertising purposes such as showing you relevant Clatch content.
The usage of non-essential cookies on our website is based on a consent according to § 25 of the German Telecommunication and Telemedia Data Protection Act (TTDSG). When visiting our website, you can decline the use of non-essential cookies in the pop-up notification. If you consent to the non-essential cookies, you may withdraw your consent again at any time in your browser’s cookie settings.
All personal data collected for website analytics is deleted by us as soon as it is no longer required for the purpose for which it was collected.
3.10 To deliver Clatch newsletters
To provide newsletter and email services, we process certain contact data of those people who have opted in so we can send such communications.
If you’ve registered for a newsletter service of Clatch, without being a Clatch user with an account, we will process your information provided in the registration on https://clatch.app/. This may include your name and email address, which is needed to send you the newsletters you’ve subscribed to.
If you’re a Clatch user with an account, Clatch will process the email address you provided with your account registration to send you the newsletters you’ve subscribed to, as well as occasional emails with promotional content. The content of these communications will be for similar Clatch services to what you use, or may include promotion for third party products which may be relevant to you from partnerships we support.
Third parties: Clatch may share information such as your email address to third-party providers for the sole purpose of carrying out our newsletter services. Our current provider for this service is Braze. For more information about Braze, see Section 3.1.1. Whenever data is transferred outside of the European Economic Area (EEA), we always apply the appropriate safeguards as outlined by the General Data Protection Regulation (GDPR) (see Section 4).
Legal basis: The legal basis for sending you our newsletter is based on your consent according to Art 6 Sec.1 lit a) GDPR. The legal basis for promotional emails is based on Art 6 Sec.1 lit a) and lit f) GDPR. The legal basis for Cycle Review emails is based on your consent according to Art 9 Sec.2 lit a) GDPR.
You can unsubscribe from our newsletters, promotional emails, and Cycle Review emails at any time by clicking the unsubscribe link at the bottom of the emails.
All personal data collected for providing our newsletter services is deleted by us as soon as it is no longer required for the purpose for which it was collected.
4. Data transfer outside the European Union
Any personal data collected from you may only be transferred to countries outside the European Economic Area (EEA) if we observe applicable privacy regulations and ensure that your privacy rights remain protected.
To ensure an adequate level of data protection in accordance with Art 46 GDPR, we have entered into Standard Contractual Clauses with all non-EEA third parties whose data processing tools we use (data processors) if there is no adequacy decision by the EU Commission for their particular country. For U.S. based data processing, we also use third-party providers that are certified under the EU-US Data Privacy Framework as a guarantee under Art 46 GDPR.
You can read more about the Standard Contractual Clauses here. The Standard Contractual Clauses help us to implement an adequate level of data protection between Clatch and our processors, who must agree to follow strict data protection rules. However, they do not bind the governmental bodies of the non-EEA country in which our processor operates. In some cases, governments may have powers of surveillance that run contrary to EU law data protection principles.
We choose our processors very carefully. We do not work with processors based in countries where we are concerned about the rule of law with respect to privacy. We follow the guidance of the European Data Protection Board on additional contractual and technical measures to ensure a sufficient level of privacy in different situations.
5. Your data protection rights
We believe that privacy—including data privacy—is a basic human right. At Clatch we strive to ensure that your rights are respected.
Here are some key facts about your privacy that we would like you to know:
i. Our products and services have been designed to collect only the data necessary to provide our services. We only collect and process your data for the purposes outlined above and detailed in this Privacy Policy.
ii. The security of our servers is routinely verified by experts to protect your data from unauthorized access. You can contact us at clatch@mts.ru if you have any questions about the security of our services.
iii. We do not retain your data in an identifiable format for longer than necessary to deliver our services.
iv. Clatch does not engage in any automated decision-making or profiling activities.
As a user of Clatch and website, you may exercise your rights under the EU General Data Protection Regulation (GDPR) to:
i. Request information on your personal data processed by Clatch. Upon your request, this information will be provided to you electronically. You can contact us to request your information at clatch@mts.ru.
ii. Gain access to your information by requesting a copy of your data in a format that is readable by other companies or organizations (data portability). iii. Correct your personal information and health data in the app settings and in the tracking categories available in Clatch.
iv. Withdraw your consent from ongoing data processing at any time by deleting your account (for details see the Support section of Clatch, under “Account Questions”), changing your privacy preferences in Settings, and/or unsubscribing from our newsletter or other email communications by clicking the link at bottom of the email.
v. Request the complete deletion of your data, including all past data sent to third-party services used for tracking and analysis, by reaching out to clatch@mts.ru. Your data will be deleted within 1 month.vi. Lodge a complaint with the relevant supervising authority if you believe Clatch is processing your personal data in violation of applicable data protection regulations.
6. Data security procedures
Protecting your data privacy is at the core of what we do. We apply security measures to protect against misuse, loss, and/or alteration of personal information under our control. We follow industry standards when transferring and storing your data. Though we cannot ensure or guarantee that misuse, loss or alteration of information will never occur, we use all reasonable efforts to prevent it.
6.1 How Clatch secures your personal data
When you create an account with Clatch, your personal profile data is stored separately from your health data and your service settings. Doing this means your health data has an even higher level of protection. Clatch uses servers located in the European Union to process and store your personal data.
When you create your Clatch password, it’s stored using one-way encryption with both “hashing” and “salting” techniques. This means your password is combined with a random string of characters and then scrambled up so it's unreadable. Not even Clatch staff have access to your password. Doing this ensures extra protection for your password. Note that if you use social login to create your account (see Section 3.1.3), Clatch does not receive your original password.
When your data is sent between your device and our Clatch servers, we use hypertext transfer protocol secure (HTTPS). This is a type of encrypted data transmission, which scrambles the information being sent so it’s unreadable. Doing this increases the security of your data transfer. HTTPS is the same technology used to create secure connections for your web browser and is indicated by a padlock icon in the URL bar of your browser.
6.2 Clatch’s recommendations for protecting your data
Usually, the biggest threat to the security and privacy of your data is that someone—probably someone you know—gains access to any of your devices without your consent. The data you enter into Clatch is private and it should stay that way. If you actively choose to share your data, for example if you are using Clatch Connect, make sure to regularly review whether it still makes sense for you to share that information with your connections. Here are some tips on how to keep your devices secure:
Protect your Clatch account: Make sure to create a unique long password for your Clatch account. We recommend using a password manager for this purpose.
Protect your device:
i. Activate either passcode, TouchID, or FaceID authentication for your device. This automatically secures your Clatch data and prevents any person from using your device without your permission.
ii. Set up a feature that will allow you to erase all the data from your device if it’s been lost or stolen.
7. Cookies on https://clatch.app/
For the purpose of tracking the performances of our services and to improve Clatch, we use cookies on our https://clatch.app/website. For more information on this purpose and its legal basis, please see Section 3.9.
Cookies are small text files that are intended to make the website better for you to use. In general, cookies are used to retain preferences, store information for things like shopping carts, provide tracking data to third-party applications like Google Analytics, or identify your device for special advertising purposes such as retargeting.
We use third-party analytics and tracking services to help us measure the performance of our website. Whenever data is transferred outside of the European Economic Area (EEA), we always apply the appropriate safeguards as outlined by the General Data Protection Regulation (GDPR) (see Section 4). Be assured that the sensitive health data you track in Clatch is never shared with or sold to advertisers. We do share a minimal amount of technical data with advertising networks, for example, so that you won’t see a Clatch ad if you’ve already downloaded the app.
Such third parties and services are listed below.
7.1 Google Analytics - Website
Our website uses Google Analytics, a web analysis service operated by Google LLC. (“Google”). Google Analytics uses cookies (text files) stored on your computer to allow for analysis of your visits to websites and interactions with them in order to personalize your experience and improve our services. Information produced via cookies will be transferred to and stored on a server in the USA operated by Google. You can find out more about Google Analytics here.
Google analyzes this information to offer reports to Clatch on website usage and online usage of associated services. Under the terms of Google's analytics service, Google may also transfer this information to third parties, either when this is required by law or when third parties are contracted by Google to process this data. Google must not allow your IP address to be linked to any other personal data. By opting in via the cookie banner on Clatch's website, you consent to data being used and processed by Google as described above. You can withdraw consent for this use of your data at any time. Please note that this withdrawal only applies to future activities.
8. Young users of Clatch
Clatch does not knowingly collect or use personal data from children under the age of 16. When creating a Clatch account, you are required to confirm that you are at least 16 years old or that your parents have agreed that you can use Clatch.
If you are located in the EU, you can only use our services if you are over the relevant age at which you can provide explicit consent to the processing of your data under the laws of your country (e.g if you are at least 16 years old in Germany), or if you have the consent of your parent or legal guardian.
If you are a parent and learn that your child is using Clatch without your permission, or if you have a specific question about data privacy at Clatch, do not hesitate to get in touch with us at clatch@mts.ru.
If you are located in the United States, you cannot use Clatch if you are under 13 years old. If Clatch gains actual knowledge that information has been collected from children under the age of 13 in the United States contrary to the Children’s Online Privacy Protection Act of 1998 and the regulation thereunder, Clatch will not disclose this data and reserves the right to immediately delete the account and wipe all related information, including health and sensitive data of the user, from our servers.
9. Changes to this Privacy Policy
Clatch reserves the right to amend this Privacy Policy from time to time to reflect changes in the law, our data collection and data use practices, the features of Clatch’s services, or advances in technology.
Please check this page periodically for changes and refer to the “last updated” date at the top of the page to know if it has been revised since your last visit. If we make any changes to this Privacy Policy that we consider to be material to your consent, we will notify you of them.
10. Prevailing language of this Privacy Policy
Clatch is used by women and people with cycles around the world. This wider Clatch community accesses Clatch in a multitude of different languages. We use professional translators and proofreaders to translate all of our communications, including this Privacy Policy, as accurately as possible into those languages.
However, please understand that we cannot assure 100% accuracy for all of our translations, in particular with respect to any legal content. Please note that the English version of this Privacy Policy is therefore the original version, which prevails over all other versions in case of deviation from the English original.
1. How Clatch values data privacy
At Clatch, we believe that technology and data present a groundbreaking opportunity to empower people to take control of their health. Clatch gives people the ability to understand what is going on inside of their bodies and minds based on individual tracked health data, providing self-insight and self-advocacy that’s powered by data processing.
We also fully acknowledge the responsibility that comes with being the safekeepers of so much intimate data which is tracked by people using Clatch. Which is why we are always striving to achieve the highest standards of privacy and security. Keeping your data safe is at the core of everything we do.
We see it as our job to be clear and transparent so that you can truly understand what we do with your data, even though the digital ecosystem of an app is complex. To provide our service as a health app, we rely on a number of other providers as summarized below to help us.
Please read the whole of this Privacy Policy to understand how we handle your data. We have done our best to make it as clear and comprehensible as possible. If you have any questions, reach out to us at <clatch@mts.ru>.
2. The types of data we process
We process three types of data in order to provide our services on Clatch and https://clatch.app/ website. All of our data is securely stored on servers.
Account data: In order to create your Clatch account, we process some of your personal data such as a username, date of birth and email address.
Usage data: In order to provide our services and technically improve performance, we process how you interact with our products using different data points. Such data includes device data, which informs us about the device you use to access our app services (such as device model, name and identifiers, device settings, application identifier, crash information). On our website, we also collect information about your browser (such as browser settings, operating system, system settings). Other usage data includes the IP address provided by your browser or mobile device, which we collect in order to deliver the service to your device. We also use the IP address to determine your approximate location for statistical and analytics purposes, and for regulatory compliance in different countries. We do not collect your precise location.
Health data: In order to provide our service as a health app, we process health data and other sensitive data that you choose to track in Clatch. Such health data may include your cycle information (e.g. period length, pain, or spotting), and depending on the data you provide, it may also contain other sensitive data about your experiences (e.g. weight, body temperature, hair quality, sexual intercourse). We only process the health data you choose to share with Clatch via tracking. You may use different methods provided by the app to track your health data in the app. This can include manually entering your data into the app, or importing your data from other integrations or devices supported by Clatch (such as Apple Health or fitness trackers).
3. How and why we process your data
Data processing is essential to providing the service of Clatch. Whenever you use our services, some personal and non-personal data is collected, stored, and analyzed using internal and third-party tools.
Below are the purposes for which we process your data, and the type of data that’s processed to fulfill each purpose:
3.1 To provide our core service to you
To provide our service, we process the following:
- Health data: This is processed whenever you track your health data in Clatch, either manually or through import integrations, in order to provide our core service as a health tracking app. This includes both your cycle information data and other sensitive data that you choose to track in Clatch.
- Device data, event data, usage data, IP address: This is processed when you use Clatch or https://clatch.app/, to understand how you interact with our services and to technically improve performance.
- Account data: This is processed when you set up your Clatch account in the app or in the website, to enable you to sign in to Clatch, and additionally to communicate with you on service-related topics. Such communications may include information about your account, essential app updates, or insights and recommendations based on health data you have tracked. These communications can be sent to you via in-app messages, reminders, notifications, or emails.
3.1.1 Essential third party providers:
We use several third party providers to help us perform our core services.
Firebase (Android users only): Clatch uses a suite of performance analysis and monitoring tools called Firebase, which is provided by Google Inc. Firebase allows us to monitor the overall performance and stability of our app, implement internal version control, identify bugs and prioritize fixes. For this purpose Firebase collects your IP address, device identifier, as well as event and usage data related to your use of Clatch. This data will be transferred to and stored on a server in the EU and operated by Google, LLC.
It is not possible to opt-out of Firebase as it is an essential tool that we require in order to provide a functioning Clatch to you.
3.1.2 Integrations to track your data:
In addition to manually tracking your health data in Clatch, importing data from other sources is supported for the integrations listed below.
Apple Health (iOS): This section is only applicable to users who choose to sync their Apple Health app with Clatch. Clatch will not exchange any personal data with Apple’s Health app unless you specifically approve this. Approval can be given by you in the relevant settings of the Health app or with in Clatch via your Settings. If you have given your approval, Clatch may interact with the Health app on your iOS device and read and/or write information between Clatch and the Health app. This may include a transfer of your personal data to Apple servers located outside the European Union.
You can choose if and to what extent your personal data is exchanged between Clatch and the Health app by granting or revoking the relevant permissions in your Health app settings. This can be done at any time. Please refer to the Privacy Information of Apple Health for further information.
Sign in with Apple: Clatch uses “Sign in with Apple” to allow users to create and sign in to their Clatch account with their Apple credentials.
If you sign up to Clatch using Apple, Clatch will exchange certain data with Apple like device data, IP-address, and information you provided to Apple when creating an account with Apple Inc. This may include a transfer of your personal data to Apple servers located outside the European Union. It is your choice if and to what extent you use the “Sign in with Apple” service and what information you provide to Apple. Absolutely no health data will be exchanged with Apple for the purpose of using the “Sign in with Apple” service.
Sign in with Google: Clatch uses “Sign in with Google” to allow users to create and sign in their Clatch account with their Google credentials. If you use this service, you authorize us to collect your basic information from Google, like your email address. You can manage this any time in your Google account. Please see Google's resources for more details on this.
If you sign up to Clatch using Google, Clatch will exchange with Google the types of data you provided to Google when creating an account with them (such as name, email address). This may include a transfer of your personal data to Google servers located outside the European Union. It is your choice if and to what extent you use the “Sign in with Google” service and what information you provide to Google. Absolutely no health data will be exchanged with Google.
Legal basis: Our legal basis for processing the above mentioned data is Art. 6 b) General Data Protection Regulation (GDPR), which means that we use it to perform the contract that you have entered into with Clatch, via Wellhub. We also process your Clatch account data and usage data on the legal basis of Art 6 Sec.1 lit b) GDPR to provide our services to you. The processing of health data to provide our service to you is based on the following consent according to Art 9 Sec.2 lit a) GDPR:
I agree to Clatch processing the health data I choose to share with the app, so they can provide their service.
All personal data collected for providing our service is deleted by us as soon as it is no longer required for the purpose for which it was collected.
Legal basis:The legal basis for processing your account data and usage data for customer service is Art 6 Sec. 1 lit b) GDPR, and Art 9 Sec.2 lit a) GDPR for your health data.
When you contact the Clatch 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.
All personal data collected for our customer service is deleted by us as soon as it is no longer required for the purpose for which it was collected.
3.3 To help advance scientific research
To help advance menstrual and reproductive health studies, we share relevant de-identified health data you’ve tracked in Clatch with carefully selected research partners to be used in their scientific studies.
When you track in Clatch, your data becomes something powerful. It can help answer questions to better understand menstrual and reproductive health. Women and people with cycles are still widely underrepresented in health research. We believe that the data tracked in Clatch can change this. By teaming up with our trusted research partners we can advance research, break harmful taboos and lay the groundwork for better healthcare.
We only share data that is directly relevant to the research question and follow strict protocols to ensure your data always remains anonymous to the researchers. We use a de-identification technique which means all personal identifiers like your name and email address are erased. Your dataset is then assigned a random ID, making sure you can’t be identified by the researchers.
If you are a participant in a scientific study that is run by a research facility using Clatch as a tool to collect information for that study, then Clatch will share your personal information with the research facility only under the terms of your consent as given to that research facility. When you use Clatch as part of a scientific study, we will otherwise treat your personal data with the same care as we do all user data. The research facility will be solely responsible for the usage of your personal data, including health data, in the context of their scientific study. We consider that Clatch and our partnered research facilities have joint responsibility ("joint controllership" under GDPR) in this case.
Research partners: We team up with carefully selected research partners both in and outside of the European Union.
Whenever data is transferred to partners outside of the European Economic Area (EEA), we always apply the appropriate safeguards as outlined by the General Data Protection Regulation (GDPR) (see Section 4).
Legal basis: The processing of your health data for scientific research is based on the following consent according to Art 9 Sec.2 lit a) GDPR, if you have toggled this on in your privacy settings:
I agree to the health data I track in the app being de-identified and shared with carefully selected research partners in and outside of the European Union to advance menstrual and reproductive health studies.
You can toggle this off at any time. All personal data collected for scientific research is deleted by us as soon as it is no longer required for the purpose for which it was collected.
3.4 To improve Clatch features with health analytics
To help us build more valuable features in Clatch, we process health data you’ve tracked in the app to better understand which features are most useful to you. By processing data such as period dates and cycle experiences, we can better understand how our community uses the app and further tailor the experience to fit their needs.
By analyzing how our community uses the app, we can understand which features are most valuable. We use these insights to drive feature development, so we can make sure to deliver what’s most important. This could include things like improving the accuracy of predictions, building new algorithms to offer you more health insights, or creating content about topics we see our community wants to read about more.
The processing of health data for analytics purposes is managed internally by Clatch. We store your data on servers in the EU and it’s always de-identified, removing personal identifiers like your name and email address. These procedures ensure your privacy.
Third party providers: We do not use any third party providers for this purpose.
Legal basis: The processing of your health data for health analytics is based on the following consent according to Art 9 Sec.2 lit a) GDPR, if you have toggled this on in your privacy settings:
I agree to the health data I track in the app being processed for analytics purposes so Clatch can improve my predictions, develop new algorithms and create more valuable features with personalized insights.
You can toggle this off at any time. All personal data collected for the health data analytics is deleted by us as soon as it is no longer required for the purpose for which it was collected.
3.5 To technically improve Clatch
To help us improve Clatch experience, we process and analyze certain data so we can improve the app and make features easier to use. This includes usage data like your device ID and IP address.
By improving the app and its technical platform, we can deliver a better experience for you and the wider Clatch community. It allows us to tailor the app to different types of devices, and most importantly, strive to make the app experience the best it can be.
Third party providers: We do not use any third party providers for this purpose.
Legal basis: We process your usage data on the legal basis of Art 6 Sec.1 lit f) GDPR to technically improve Clatch based on Clatch’s legitimate interest as a company to continuously improve the app and deliver an improved service to you. We do not believe there is anything you could have against this. However you can always opt out of this data processing at any time in your Clatch app’s privacy settings by toggling off:
As outlined in Clatch’s Privacy Policy and based on Clatch’s legitimate interest as a company to continuously improve the app, certain usage and technical data is processed. I have the right to opt out of this at any time.
All personal data collected to technically improve Clatch is deleted by us as soon as it is no longer required for the purpose for which it was collected.
3.6 To allow recommendations from Clatch
To make personalized recommendations, we process certain usage data to understand how you interact with Clatch, as well as the health data you’ve tracked to deliver you more personalized insights. This includes data such as your period dates and cycle experiences. We also collect your account data so we can then send you these recommendations via in-app messages, emails, and push notifications (if you’ve enabled permissions on your device). By personalizing your experience, we can provide information that’s more tailored to you and your needs. This might look like sending you updates about new Clatch features based on what you’ve tracked, or suggesting interesting products from partnerships we support that may be relevant to you. For example, if you’re trying to conceive, we might recommend services that can support you on your conception journey. We strive to be mindful about what we communicate and how often, as providing you with the most comfortable experience possible is our main priority.
Third party providers: We use certain third party software providers to help us send these updates, such as Braze (see Section 3.1.1). These providers are not permitted to use the data for any other purpose other than to help Clatch personalize your experience.
Whenever data is transferred outside of the European Economic Area (EEA), we always apply the appropriate safeguards as outlined by the General Data Protection Regulation (GDPR) (see Section 4).
Be assured that the sensitive health data you track in Clatch is never shared with or sold to advertisers, or any partners whose services we may recommend in Clatch.
Legal basis: The processing of your account data and usage data for recommendations from Clatch is based on the following consent according to Art 6 Sec.1 lit a) GDPR, and the processing of health data for recommendation from Clatch is based on the following consent according to Art 9 Sec.2 lit a) GDPR, if you have toggled this on in your privacy settings:
I agree to my account data, usage data and health data I track in Clatch being processed so Clatch can send me personal recommendations for relevant products based on my tracked experiences. Certain third-party providers, including some located outside of the European Union, are used to help with this.
You can toggle this off at any time. All personal data collected for providing personal recommendations is deleted by us as soon as it is no longer required for the purpose for which it was collected.
3.7 To help Clatch optimize their advertising efforts
To help us analyze how Clatch’s advertising performs, we process certain types of usage data (for example when you install Clatch) including your device ID and IP address. This helps us identify whether you’ve already downloaded Clatch and find out which Clatch ads you interacted with (if any).
By doing this, we can optimize our advertising efforts. For example, if you’ve already downloaded Clatch, we won’t show you an ad to download Clatch. It also helps us understand on which platforms people find out about us, and learn what kind of Clatch advertising performs best. With better advertising, we can help raise awareness about Clatch and empower more people to take charge of their health.
Legal basis: The processing of your usage data to promote Clatch is based on the following consent according to Art 6 Sec.1 lit a) GDPR, if you have toggled this on in your privacy settings:
I agree to my usage and device data being processed so Clatch can optimize their advertising efforts to more effectively tell more people about Clatch. Certain third party providers, including some located outside of the European Union, are used to help with this.
You can toggle this off at any time. All personal data collected to help to promote Clatch is deleted by us as soon as it is no longer required for the purpose for which it was collected.
3.8 To optimize advertising with activity tracking (iOS users only)
To help us optimize our advertising and to spread the word about Clatch, we enable activity tracking on iOS devices when permissions are turned on. Activity tracking means that limited technical data (like your device ID) and usage data (for example installing Clatch) is shared with advertisers so you don’t see Clatch ads that aren’t relevant to you. You can turn off activity tracking any time in your iOS Settings.Activity tracking is strictly limited to technical and usage data. Your health data is never shared with advertisers and always protected.
Legal basis: The processing of your usage data for activity tracking is based on the following consent according to Art 6 Sec.1 lit a) GDPR, if you selected “Allow” when presented the following prompt from Apple:
Allow “Clatch” to track your activity across other companies’ apps and websites?
All personal data collected for activity tracking is deleted by us as soon as it is no longer required for the purpose for which it was collected.
3.9 To improve https://clatch.app/ with website analytics
To improve our website, we process usage data such as your IP address and device data. This helps us track the performance of our website, understand how you use our website, and offer you an improved experience. For this purpose we use cookies and third party tracking services. Cookies are small text files that are intended to make the site better for you to use.
In general, cookies are used to retain preferences, store information for things like shopping carts, provide tracking data to third-party applications like Google Analytics, Taboola or Outbrain, or identify your device for special advertising purposes such as retargeting. You can learn more about the specific cookies and tracking services used on https://clatch.app/ in Section 7.
Legal basis: The processing of your usage data for website analytics is based on the following consent according to Art 6 Sec.1 lit a) GDPR:
By using our website you consent through an opt-in in the cookie banner that Clatch may use cookies and third-party services, and collect your usage data under a unique identifier for the purposes of tracking, analysis, and improvement of our website, as well as advertising purposes such as showing you relevant Clatch content.
The usage of non-essential cookies on our website is based on a consent according to § 25 of the German Telecommunication and Telemedia Data Protection Act (TTDSG). When visiting our website, you can decline the use of non-essential cookies in the pop-up notification. If you consent to the non-essential cookies, you may withdraw your consent again at any time in your browser’s cookie settings.
All personal data collected for website analytics is deleted by us as soon as it is no longer required for the purpose for which it was collected.
3.10 To deliver Clatch newsletters
To provide newsletter and email services, we process certain contact data of those people who have opted in so we can send such communications.
If you’ve registered for a newsletter service of Clatch, without being a Clatch user with an account, we will process your information provided in the registration on https://clatch.app/. This may include your name and email address, which is needed to send you the newsletters you’ve subscribed to.
If you’re a Clatch user with an account, Clatch will process the email address you provided with your account registration to send you the newsletters you’ve subscribed to, as well as occasional emails with promotional content. The content of these communications will be for similar Clatch services to what you use, or may include promotion for third party products which may be relevant to you from partnerships we support.
Third parties: Clatch may share information such as your email address to third-party providers for the sole purpose of carrying out our newsletter services. Our current provider for this service is Braze. For more information about Braze, see Section 3.1.1. Whenever data is transferred outside of the European Economic Area (EEA), we always apply the appropriate safeguards as outlined by the General Data Protection Regulation (GDPR) (see Section 4).
Legal basis: The legal basis for sending you our newsletter is based on your consent according to Art 6 Sec.1 lit a) GDPR. The legal basis for promotional emails is based on Art 6 Sec.1 lit a) and lit f) GDPR. The legal basis for Cycle Review emails is based on your consent according to Art 9 Sec.2 lit a) GDPR.
You can unsubscribe from our newsletters, promotional emails, and Cycle Review emails at any time by clicking the unsubscribe link at the bottom of the emails.
All personal data collected for providing our newsletter services is deleted by us as soon as it is no longer required for the purpose for which it was collected.
4. Data transfer outside the European Union
Any personal data collected from you may only be transferred to countries outside the European Economic Area (EEA) if we observe applicable privacy regulations and ensure that your privacy rights remain protected.
To ensure an adequate level of data protection in accordance with Art 46 GDPR, we have entered into Standard Contractual Clauses with all non-EEA third parties whose data processing tools we use (data processors) if there is no adequacy decision by the EU Commission for their particular country. For U.S. based data processing, we also use third-party providers that are certified under the EU-US Data Privacy Framework as a guarantee under Art 46 GDPR.
You can read more about the Standard Contractual Clauses here. The Standard Contractual Clauses help us to implement an adequate level of data protection between Clatch and our processors, who must agree to follow strict data protection rules. However, they do not bind the governmental bodies of the non-EEA country in which our processor operates. In some cases, governments may have powers of surveillance that run contrary to EU law data protection principles.
We choose our processors very carefully. We do not work with processors based in countries where we are concerned about the rule of law with respect to privacy. We follow the guidance of the European Data Protection Board on additional contractual and technical measures to ensure a sufficient level of privacy in different situations.
5. Your data protection rights
We believe that privacy—including data privacy—is a basic human right. At Clatch we strive to ensure that your rights are respected.
Here are some key facts about your privacy that we would like you to know:
i. Our products and services have been designed to collect only the data necessary to provide our services. We only collect and process your data for the purposes outlined above and detailed in this Privacy Policy.
ii. The security of our servers is routinely verified by experts to protect your data from unauthorized access. You can contact us at clatch@mts.ru if you have any questions about the security of our services.
iii. We do not retain your data in an identifiable format for longer than necessary to deliver our services.
iv. Clatch does not engage in any automated decision-making or profiling activities.
As a user of Clatch and website, you may exercise your rights under the EU General Data Protection Regulation (GDPR) to:
i. Request information on your personal data processed by Clatch. Upon your request, this information will be provided to you electronically. You can contact us to request your information at clatch@mts.ru.
ii. Gain access to your information by requesting a copy of your data in a format that is readable by other companies or organizations (data portability). iii. Correct your personal information and health data in the app settings and in the tracking categories available in Clatch.
iv. Withdraw your consent from ongoing data processing at any time by deleting your account (for details see the Support section of Clatch, under “Account Questions”), changing your privacy preferences in Settings, and/or unsubscribing from our newsletter or other email communications by clicking the link at bottom of the email.
v. Request the complete deletion of your data, including all past data sent to third-party services used for tracking and analysis, by reaching out to clatch@mts.ru. Your data will be deleted within 1 month.vi. Lodge a complaint with the relevant supervising authority if you believe Clatch is processing your personal data in violation of applicable data protection regulations.
6. Data security procedures
Protecting your data privacy is at the core of what we do. We apply security measures to protect against misuse, loss, and/or alteration of personal information under our control. We follow industry standards when transferring and storing your data. Though we cannot ensure or guarantee that misuse, loss or alteration of information will never occur, we use all reasonable efforts to prevent it.
6.1 How Clatch secures your personal data
When you create an account with Clatch, your personal profile data is stored separately from your health data and your service settings. Doing this means your health data has an even higher level of protection. Clatch uses servers located in the European Union to process and store your personal data.
When you create your Clatch password, it’s stored using one-way encryption with both “hashing” and “salting” techniques. This means your password is combined with a random string of characters and then scrambled up so it's unreadable. Not even Clatch staff have access to your password. Doing this ensures extra protection for your password. Note that if you use social login to create your account (see Section 3.1.3), Clatch does not receive your original password.
When your data is sent between your device and our Clatch servers, we use hypertext transfer protocol secure (HTTPS). This is a type of encrypted data transmission, which scrambles the information being sent so it’s unreadable. Doing this increases the security of your data transfer. HTTPS is the same technology used to create secure connections for your web browser and is indicated by a padlock icon in the URL bar of your browser.
6.2 Clatch’s recommendations for protecting your data
Usually, the biggest threat to the security and privacy of your data is that someone—probably someone you know—gains access to any of your devices without your consent. The data you enter into Clatch is private and it should stay that way. If you actively choose to share your data, for example if you are using Clatch Connect, make sure to regularly review whether it still makes sense for you to share that information with your connections. Here are some tips on how to keep your devices secure:
Protect your Clatch account: Make sure to create a unique long password for your Clatch account. We recommend using a password manager for this purpose.
Protect your device:
i. Activate either passcode, TouchID, or FaceID authentication for your device. This automatically secures your Clatch data and prevents any person from using your device without your permission.
ii. Set up a feature that will allow you to erase all the data from your device if it’s been lost or stolen.
7. Cookies on https://clatch.app/
For the purpose of tracking the performances of our services and to improve Clatch, we use cookies on our https://clatch.app/website. For more information on this purpose and its legal basis, please see Section 3.9.
Cookies are small text files that are intended to make the website better for you to use. In general, cookies are used to retain preferences, store information for things like shopping carts, provide tracking data to third-party applications like Google Analytics, or identify your device for special advertising purposes such as retargeting.
We use third-party analytics and tracking services to help us measure the performance of our website. Whenever data is transferred outside of the European Economic Area (EEA), we always apply the appropriate safeguards as outlined by the General Data Protection Regulation (GDPR) (see Section 4). Be assured that the sensitive health data you track in Clatch is never shared with or sold to advertisers. We do share a minimal amount of technical data with advertising networks, for example, so that you won’t see a Clatch ad if you’ve already downloaded the app.
Such third parties and services are listed below.
7.1 Google Analytics - Website
Our website uses Google Analytics, a web analysis service operated by Google LLC. (“Google”). Google Analytics uses cookies (text files) stored on your computer to allow for analysis of your visits to websites and interactions with them in order to personalize your experience and improve our services. Information produced via cookies will be transferred to and stored on a server in the USA operated by Google. You can find out more about Google Analytics here.
Google analyzes this information to offer reports to Clatch on website usage and online usage of associated services. Under the terms of Google's analytics service, Google may also transfer this information to third parties, either when this is required by law or when third parties are contracted by Google to process this data. Google must not allow your IP address to be linked to any other personal data. By opting in via the cookie banner on Clatch's website, you consent to data being used and processed by Google as described above. You can withdraw consent for this use of your data at any time. Please note that this withdrawal only applies to future activities.
8. Young users of Clatch
Clatch does not knowingly collect or use personal data from children under the age of 16. When creating a Clatch account, you are required to confirm that you are at least 16 years old or that your parents have agreed that you can use Clatch.
If you are located in the EU, you can only use our services if you are over the relevant age at which you can provide explicit consent to the processing of your data under the laws of your country (e.g if you are at least 16 years old in Germany), or if you have the consent of your parent or legal guardian.
If you are a parent and learn that your child is using Clatch without your permission, or if you have a specific question about data privacy at Clatch, do not hesitate to get in touch with us at clatch@mts.ru.
If you are located in the United States, you cannot use Clatch if you are under 13 years old. If Clatch gains actual knowledge that information has been collected from children under the age of 13 in the United States contrary to the Children’s Online Privacy Protection Act of 1998 and the regulation thereunder, Clatch will not disclose this data and reserves the right to immediately delete the account and wipe all related information, including health and sensitive data of the user, from our servers.
9. Changes to this Privacy Policy
Clatch reserves the right to amend this Privacy Policy from time to time to reflect changes in the law, our data collection and data use practices, the features of Clatch’s services, or advances in technology.
Please check this page periodically for changes and refer to the “last updated” date at the top of the page to know if it has been revised since your last visit. If we make any changes to this Privacy Policy that we consider to be material to your consent, we will notify you of them.
10. Prevailing language of this Privacy Policy
Clatch is used by women and people with cycles around the world. This wider Clatch community accesses Clatch in a multitude of different languages. We use professional translators and proofreaders to translate all of our communications, including this Privacy Policy, as accurately as possible into those languages.
However, please understand that we cannot assure 100% accuracy for all of our translations, in particular with respect to any legal content. Please note that the English version of this Privacy Policy is therefore the original version, which prevails over all other versions in case of deviation from the English original.
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