Privacy Policy

Effective Date: September 10 2025

Clarus Technologies Ltd (“Company”, “we” or “us”) respects your privacy. This Privacy Notice (this “Notice”) describes how we process Personal Data (as defined below) we gather through our app (“App”). It also tells you about your rights and choices with respect to your Personal Data, and how you can contact us if you have any queries or concerns.This Notice applies to you if you submit Personal Data through our App or website, or if your Personal Data is uploaded to our App or website by a third party. If you upload the Personal Data of a third party to our App or website (e.g., information relating to your child or other relative), please note that you must collect the consent of these individuals and make them aware of the information set out in this Notice.

1. Personal Data We Collect

In this Notice, “Personal Data” means any information relating to an identified or identifiable natural person. We may collect and process Personal Data about you in the ways outlined below. Where applicable, we indicate whether and why you must provide us with your Personal Data, as well as the consequences of failing to do so. If you do not provide Personal Data when requested, you may not be able to benefit from our App or website if that information is necessary to provide you with them or if we are legally required to collect it.

Information provided by you

When you upload health information. If you upload health information to the app, such as tests results, you may provide us with Personal Data.

When you create an account. When you register for an account, we will ask you to provide us with Personal Data including your name and contact details (including email address). We will also make a record of information regarding your subscription choices (if applicable) and payment method.

When you contact us. If you contact us via email, or by other means, you may provide us with Personal Data, such as your name and contact details (including email address), and the content, date and time of your communications.

Information collected via automated means

Cookies and similar technologies. We use cookies and similar technologies (collectively “cookies”) to ensure that our App and website function properly and to improve our products and services. Cookies are small text files containing a string of alphanumeric characters. We and third-party service providers may use the following cookies:

Functional cookies. Some cookies are strictly necessary to make our App and website available to you. For example, to provide login functionality or to allow you to fill out forms. We cannot provide you with the App or website without this type of cookie.

Analytics cookies. We use cookies for analytics purposes in order to operate, maintain and improve our App and website.Information collected from other sources

Information from third parties. We may obtain Personal Data about you from third parties, such as individuals who upload Personal Data to the App or website on your behalf. This may include your health information.

2. How We Use Personal Data

We process the Personal Data listed above for the following purposes:

Providing the App and website. We use Personal Data about you to operate, maintain, and provide our App and website, such as providing visualizations of the health information that you have uploaded to the App or website.

Communicating with you. We may use your contact details to contact you for administrative purposes (e.g., to provide services and information that you request) or to assist with customer support.

Analytics and product development. We use Personal Data about you to analyze usage trends and preferences to improve our App and website and marketing campaigns, as well as to develop new products, services, features, and functionalities. We may anonymize the Personal Data you submit to the App or website, or that is generated when you use the App or website, for these purposes.

Marketing. We may use your Personal Data to provide you with relevant marketing materials.

Legal. We may use your Personal Data to enforce this Notice, defend our legal rights and comply with our legal obligations and internal policies.

3. Our Legal Basis for Processing Personal Data

If you are located in the European Economic Area, Switzerland or the United Kingdom (“Europe”), we only process your Personal Data where we have a legal basis to do so. The legal bases we rely on include:

Consent. We may process your Personal Data on the basis of consent (including if your information is submitted to the or website by a third party). For example, we ask for your explicit consent to use your health information to provide you with our services. You may withdraw your consent at any time by contacting us.

Necessary to perform a contract. We will process your Personal Data where it is necessary to give effect to a contract between you and us, for example when you subscribe to our services.

Necessary for compliance with a legal obligation to which we are subject. We may process your Personal Data where we are required to do so to comply with our legal obligations, for example to comply with tax and accounting obligations or to comply with a search warrant or court order.

Necessary for a legitimate interest that we pursue. Where we or a third party have a legitimate interest in processing your Personal Data, we may do so provided that our interest is not overridden by your rights and interests. We may rely on this legal basis to, for example, keep business records, respond to unsolicited communications from you, assert our legal rights and obtain professional advice.

4. How We Share Your Personal Data

We may share your Personal Data with third parties in the following circumstances:

Service providers. We work with third party service providers, such as Amazon Web Services and Google, to operate our App, including for billing, payment processing, analyzing data, providing IT-hosting and maintenance, and other services for us. These third parties may have access to or process your Personal Data as part of providing those services to us.

Legal. We may disclose your Personal Data to third parties if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. We also reserve the right to disclose your Personal Data that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of our App and website and any facilities or equipment used to make our App and website available, or (v) protect our property or other legal rights, including to enforce our agreements, or the rights, property, or safety of others.

Merger. We may disclose or otherwise transfer Personal Data to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

Consent. We may also disclose your Personal Data with your permission.

5. Data Retention

We take measures to delete your Personal Data or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we need to retain certain information as required by law, including to comply with tax requirements, or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse or enforce our terms and conditions. When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the relevant statute of limitations.

6. Your Rights in Relation to Your Personal Data

Depending on where you reside, you may also have the following legal rights:

Access and Portability. You may ask us to provide you with a copy of the Personal Data we maintain about you, including a machine-readable copy of the Personal Data that you have provided to us, and request information about its processing.

Rectification and Deletion. You may ask us to update and correct inaccuracies in your Personal Data, or to have the information anonymized or deleted, as appropriate.

Restriction and Objection. You may ask us to restrict the processing of your Personal Data, or object to such processing.

Consent Withdrawal. You may withdraw any consent you previously provided to us regarding the processing of your Personal Data, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

Complaint. You may lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where an incident took place. We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority, so please contact us in the first instance.You may exercise these rights by contacting us using the contact details at the end of this Notice. Please note that there are exceptions and limitations to each of these rights.

7. Third Parties

Our App or website may contain links to other websites, products, or services that we do not own or operate, and may be supported by third parties (such as payment service providers and app distributors). We are not responsible for the privacy practices of these third parties. Please be aware that this Notice does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

8. Security

We make reasonable efforts to protect your Personal Data by using physical and electronic safeguards designed to improve the security of the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information, to the extent permitted by applicable law.

9.Children’s Privacy

We do not knowingly collect, maintain, or use Personal Data from children under 13 years of age, and no part of our App or website is directed to children. If you learn that a child has provided us with Personal Data in violation of this Notice, then you may alert us by contacting us using the contact details at the end of this Notice.

10. Cross-Border Data Transfers

We may use outsourced services in countries outside Europe from time to time in order to support our business. If we need to transfer your Personal Data to a country outside of Europe where the level of protection of Personal Data may be different than in your country, we will comply with applicable data protection laws. In particular we will rely on (i) an EU Commission, UK or Swiss government adequacy decision, (ii) contractual protections for the transfer of your Personal Data, or (iii) another valid data transfer mechanism. If you are located in Europe, you may contact us as specified below for more information about the safeguards we use to transfer Personal Data outside of Europe.

11. Changes to this Notice

We may update this Notice from time to time to reflect changes in our privacy practices. If we modify this Notice, we will indicate the date of the latest revision at the top of this Notice.

12. Our contact information

Should you have any queries regarding this Notice, about Company's processing of your Personal Data or if you wish to exercise your rights with respect to your Personal Data, you can contact Company by email: support@clarus.com.