Privacy Policy

Last updated: September 30, 2026

At Clario, we prioritize the protection of your personal data. This privacy policy describes how we collect, use, and protect your information in compliance with the General Data Protection Regulation (GDPR).

1. Data Controller

The data controller is:

• Company: BLACKSWIFT (SASU)
• Trade register: 904 788 775 R.C.S. Saint-Pierre de la Réunion
• Registered office: chemin Baillif, 97410 Saint-Pierre, Réunion Island, France
• Representative: The President
• Email: privacy@clario.re

2. Data We Collect

2.1 Data You Provide

• Profile data: First name (optional), gender, age range
• Account data (optional): Email address, email verification status, sign-in provider used (Google or Apple), technical account identifier, and app language — see Section 3
• Usage data: Priorities, habits, focus sessions, AI Coach conversations, generated programs
• Google Calendar data: Event titles, dates, and times (processed read-only and exclusively stored locally on your device)
• Preferences: App settings, theme, language

2.2 Automatically Collected Data

• Technical data: Device type, operating system, app version
• Performance data: Crash reports (anonymized)

3. Account, Multi-Device Sync, and Communications

Clario works offline by default and without an account: your data stays on your device. You may optionally create an account to sync your data across your devices and recover it when changing phones. This section describes the processing related to this optional feature and to email communications.

3.1 Data Processed

• Account data: Email address, email verification status, sign-in provider used (Google or Apple), technical account identifier, and app language
• Synced data (only if you enable sync): tasks, habits, focus sessions, mood tracking, journal, activities, meals, tags, conversations with the assistant, creations and apps acquired within the application, as well as the profile information you provide
• Communication data (only if you consent): your email address and consent status, in order to send you news and tips

3.2 Purposes and Legal Bases

• Account creation and management, sign-in: Provision of the service you request (performance of the service)
• Sync across devices: Based on your consent, given when you enable sync
• Purchase continuity (Premium / Pro plans): Performance of the contract, via our subscription management provider, so your purchases follow you from one device to another
• Email sending (news, tips): Based on your consent (Article 6.1.a GDPR), which you may withdraw at any time

3.3 Entirely Optional

Creating an account, enabling sync, and subscribing to emails are entirely optional. The app remains fully usable offline without an account. The email opt-in checkbox is unchecked by default, and declining it in no way prevents you from using the app or syncing your data.

3.4 Hosting and Data Location

Account and synced data are hosted via Firebase (Google) and stored in the European Union (data centers located in Belgium and the Netherlands). Server-side processing (cloud functions) runs in Belgium.

3.5 Treatment Support and Health Data

If you choose to, Clario lets you indicate that you are on a GLP-1 type treatment, so that the assistant (Coach) can focus its habit advice (food, hydration, activity, preparing your appointments). This information is health data within the meaning of Article 9 GDPR. It is processed only on the basis of your explicit consent, given by tapping "Turn on" in the window that describes this processing, and can be withdrawn at any time in the Coach settings (the information is then erased).

• Where it is stored: only on your device; it is not synced with your account.
• Who receives it: it goes with your messages to the artificial intelligence service that runs the Coach (see section 7), only to tailor its replies; Clario does not keep it on its servers.
• Your conversations with the Coach follow the rules of section 3 (synced only if you turned sync on): what you write there about your health is part of them.
• The "GLP-1 Companion" app (Store) keeps its log (injections, weight, how you feel, purchases, appointments) only on your device: it is neither synced nor transmitted, and reinstalling or changing phones erases it. You can export or erase it from the app. The protein and water you log there join your Clario meal tracking (section 3.1).
• This data is never used for advertising, sold, or shared with third parties other than the artificial intelligence service mentioned above.

Clario is not a medical device: it gives no dose or treatment advice and does not replace the advice of your doctor or pharmacist.

4. How We Use Your Data

• Provide and improve Clario features
• Personalize your experience (AI Guide, suggestions)
• Tailor the Coach's advice to a treatment you indicated (if you turn it on)
• Manage Premium subscriptions and ensure purchase continuity across devices
• Create and manage your account, sync your data across devices (if you enable it)
• Send you news and tips by email (if you consent)
• Send notifications (if enabled)
• Analyze usage to improve the service (aggregated and anonymized)

5. Legal Basis

• Contract performance: To provide Clario services, manage your account, and ensure purchase continuity
• Consent: For notifications, AI Guide usage, cross-device sync, and email sending (Article 6.1.a GDPR) — withdrawable at any time
• Explicit consent: For treatment support and the GLP-1 Companion app log (health data, Article 9.2.a GDPR) — withdrawable at any time
• Legitimate interest: To improve our services

6. Data Retention

• Account and synced data: Kept for as long as your account exists; permanently deleted from our servers when you delete your account
• Local data: Kept on your device for as long as the app is installed; simply uninstall the app to erase it
• Conversations with the assistant: Stored locally (deletable anytime) and for a maximum of 6 months server-side if sync is enabled
• Email contact: Kept until you unsubscribe or delete your account

7. Recipients, Processors, and Google API

We never sell your personal data. It is processed by the following providers, acting on our behalf:

• Google Ireland Ltd / Google LLC: Firebase infrastructure (database, authentication, server functions, anti-abuse protection) — hosted in the European Union
• Apple: Only if you choose "Sign in with Apple" (authentication)
• RevenueCat, Inc.: Management of in-app purchases and subscriptions
• Vercel: Website hosting
• xAI (Grok): Processing of AI Coach conversations and program generation
• Legal authorities: If required by law

Important note regarding Artificial Intelligence: AI Coach conversations and program generation requests are processed by xAI (Grok). These exchanges are used only to generate responses and are not permanently stored by xAI. Your data is under no circumstances used to train artificial intelligence models by xAI or any third party.

Important note regarding Google Calendar (Google API Services): Clario's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements. No data from Google Calendar is transferred to our servers, shared with third parties, sold, or used to train AI models. Synchronization occurs strictly locally on your device.

Transfers Outside the European Union: The primary storage of your account and synced data remains in the European Union. Some providers (notably for purchase management, Apple sign-in, website hosting, and AI) may process data in the United States; these transfers are governed by the appropriate safeguards provided for by the GDPR (Standard Contractual Clauses and/or adequacy decisions).

8. Your Rights (GDPR)

• Right of access: Obtain a copy of your data
• Right to rectification: Correct your data
• Right to erasure: Request deletion of your data
• Right to restriction: Restrict the processing of your data
• Right to portability: Receive your data in a structured format
• Right to object: Object to certain processing
• Right to withdraw consent: At any time

In practice:

• Delete your online data: From the app settings ("Account & Sync" section), the account deletion option permanently erases your synced data and your email contact from our servers
• Erase local data: Simply uninstall the app from your device
• Unsubscribe from emails: Via the unsubscribe link included in every email, or by deleting your account

To exercise your rights or ask a question, contact us at: privacy@clario.re

You may also lodge a complaint with the competent supervisory authority — in France, the CNIL (www.cnil.fr).

9. Security

• Data encryption in transit and at rest
• Access to synced data restricted to your account only (Firebase authentication): no other user can access it
• Email communication information accessible only to our internal server-side processing
• Secure local storage on your device
• Limited data access by authorized personnel

10. Cookies

The Clario website only uses essential technical cookies (theme preference, language). No advertising or tracking cookies are used.

11. Children

Clario is not intended for children under 16. We do not knowingly collect data from minors.

12. Contact

For any questions about this policy:

Email: privacy@clario.re

Address: BLACKSWIFT, chemin Baillif, 97410 Saint-Pierre, Réunion Island