Your personal data and your privacy are important to us. We created this document to describe how Clue handles your personal data in a way that we hope is easy to understand.
You can also read What it Means to be a Good Data Company, by Clue’s CEO, Ida Tin.
Please contact us if you’d like more information.
Clue is made in Berlin, Germany, and the way we handle data meets the legal guidelines required in Germany.
1. How your data is used
We collect data with two goals in mind; (1) to provide you with a great service and (2) to help progress research into female health globally. We collaborate with several highly esteemed academic research institutions. You can read about our ongoing research collaborations here.
The vision of Clue’s founder, Ida Tin, is for Clue to help advance female health globally. There is very little anonymous long-term or large-scale cycle health data available to academic and clinical researchers and Clue can help by providing anonymous data for research. Before Clue provides data for research, the data is anonymized by removing any information that can be used for the identification of individuals. Anonymous cycle health data may be used when Clue collaborates with clinical and academic researchers and Clue may publish the results of academic, clinical or internal research in the form of data visualizations or text findings.
2. Personal data we collect
“Personal data” includes any information that directly or indirectly identifies you. This includes things like your name, address, telephone number, email address or date of birth.
“Non-personal data” is information that cannot be connected to your identity, e.g. the number of users visiting our services or any other kind of aggregated information.
If you use the Clue app without creating an account, your profile and cycle tracking data is only stored on your device and Clue does not have any access to it.
In this instance, Clue only receives usage data provided by your device while you are using Clue, such as your IP address, mobile operating system (e.g. Android or iOS), device type and model, or network provider. This helps to identify app malfunctions and helps us further improve the Clue app.
If you create an account on the Clue app then we will collect and store the following data, providing you have entered it into Clue:
- Profile data including your name, age and email address. You can skip some of this information during Clue’s setup, so you may have chosen not to provide this.
- Your settings data which allows Clue to remember any customizations you have made (i.e. which reminders are active, customized notifications, the order of tracking categories, etc.) This helps Clue continue to work the way you want it to, even if you restore Clue from a backup.
- Your cycle tracking data which includes the things you track in Clue, e.g. period length, bleeding, pain, etc. This could also include information about general health conditions such as weight, body temperature, hair and skin condition and sexual activity, providing you are tracking these using Clue.
If you have an account with Clue, your data stored on your devices will also be stored on Clue’s servers to provide you with a backup functionality and with additional features within the Clue service.
By creating an account with Clue you agree that:
- Clue may store and process personal data you share with Clue in order to provide the Clue service to you. Clue may also store and process this data to improve the services Clue is able to offer. These services include sending you information and reminders featuring personal data through the app or to the email address you shared with Clue.
- Clue may use your cycle tracking data to create anonymous information for academic and clinical research purposes, for which Clue warrants that such research data cannot be associated with you as an individual, or identify you in any way.
You may withdraw your consent at any time by requesting that Clue delete your account. To do that, contact Clue’s support team. You will still be able to continue using the Clue app without an account, but please manually backup your data as this will no longer be stored on Clue’s servers.
Clue does not share your personal data with third party service providers except as required to provide the Clue features you use.
If you recognize a problem with our service and submit a request to our support team or through any other means of communication with Clue, we store the communication history as well as the information submitted by you in the course of the communication (e.g. your email address). We do this in order to respond to inquiries and provide support.
When using our website, our web server will collect information such as:
- Your IP address
- The website from which you were referred to our website (e.g. if you followed a link)
- The webpages you are visiting on our website
- The browser you are using and its display settings
- Your operating system
- The date and duration of your visit
- Further personal data will only be stored and processed if you voluntarily share it with us, e.g. through a contact form
Clue analyzes website usage data to optimize the site’s content and functionality and to identify technical issues.
3. Data Security
We apply security measures to protect against the misuse, loss and alteration of personal information under our control and follow industry best practices, using open and known principles 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.
3.1 How Clue stores your personal data
If you have an account with Clue, your personal profile data is stored separately from your cycle tracking data and your service settings, so that we can assure a very high level of privacy for your cycle information. Your password is stored using one-way encryption ("hashing" plus “salting”), and it cannot be read by us.
Your data is transmitted between your device and Clue’s servers using HTTPS protocol for encryption. HTTPS is the same technology used to create secure connections for your web browser, and is indicated by a padlock icon in your browser.
3.2 Clue’s best-practice recommendations to protect your data
We believe the biggest threat to the security and privacy of your data is if someone – probably someone you know – gains access to any of your devices. The data you enter into Clue is private and it should stay that way. Below we have outlined some ways to keep your devices secure.
- Activate a unique PIN code or activate TouchID (iOS) for Clue. If you share your device, activating a unique PIN code or TouchID will ensure you are still the only person who can access your Clue data via your phone.
- Activate either PIN or TouchID (iOS) authentication for your device. This automatically encrypts your Clue data and prevents any person without permission from using your device.
- Set up a feature that will allow you to erase all the data from your device, even if it’s been lost or stolen. For iOS, activating this feature is a two-step process: first you need to Activate “Find My iPhone” via iCloud (see instructions on Apple Support pages) and then enable “Erase your device” (see instructions on Apple Support pages)
- Use similar features for your Android or other non-iOS device.
If you don’t register an account with Clue, all of your data will be stored on your device and we won’t have access to it. If you delete Clue or lose your device, your data in Clue is also deleted or lost. If you don’t have an account with Clue, we strongly recommend that you make a backup of your Clue data regularly.
To back up Clue on iOS without an account:
- Use Apple’s backup solution via iTunes or iCloud. See Apple’s support pages for instructions.
- Use Clue’s Backup feature to store your data in a location of your choice. This can serve as your own backup that you can import back into Clue if needed, and it does not require you to use Clue’s account feature or backups provided by Apple via iTunes or iCloud.
To back up Clue on Android without an account:
- Use Clue’s Backup/Import features to store your data in a location of your choice. This can serve as your personal backup that you can import back into Clue if needed.
4. Data transfer outside EU and third party applications
Any personal data collected from you may only be transferred to countries outside the European Union / the European Economic Area (EEA) observing applicable privacy regulation and ensuring that your privacy rights remain protected.
4.2 Apple Health
Clue will not exchange any personal data with Apple Health without your prior approval, which can be revoked by you at any time. If you have given your approval, Clue may interact with the Apple HealthKit which is installed on your iOS device and read information or write information between Clue app and Apple Health. You can choose if and to what extent your personal data is exchanged between Clue and Apple Health by granting or revoking permission in the Apple Health settings.
4.3 Google Fit
Clue will not exchange any personal data with Google Fit without your prior approval, which can be revoked by you at any time. If you have given your approval, Clue may interact with Google Fit which is installed on your Android device and read information or write information between the Clue app and Google Fit. You can choose whether or not your personal data is exchanged between Clue and Google Fit by granting or revoking permission in the Google Fit settings.
4.4 Third-party wearable devices (e.g. Fitbit, ŌURA and others)
Clue will not exchange any personal data with your third-party wearable devices (such as Fitbit, ŌURA etc.) without your prior approval, which can be revoked by you at any time. If you have given your approval, Clue may interact with the respective third-party device software which is installed on your Android or iPhone device and read information or write information between the Clue app and your respective third party device. You can choose whether or not your personal data is exchanged between Clue and these third-party devices by granting or revoking permission in their respective settings.
4.5 Google Analytics
Google analyzes this information to offer reports for Clue on website usage and online usage of associated services. Google may also transfer this information to third parties either where this is required by law or where third parties are contracted by Google to process data. Google will not allow your IP address to be linked to any other personal data. You can prevent cookies from being installed on your computer by changing your browser settings; however, if you choose to do this, your visit to our website and use of some features may not work. By using Clue’s website, you have consented to have non-personal data used and processed by Google as described above. You can withdraw consent for your data to be collected and processed at any time, but this withdrawal only applies to future activities.
Clue uses a third-party service, Branch Metrics Inc., a company based in the USA, for features where ‘deep linking’ is required. It is used e.g. to enable you to invite your friends to use Clue and download it from the App Store or Google Play Store. Using this deep linking service will send usage data such as your IP address to Branch Metrics. Using deep linking does not transfer any of your cycle tracking data to third parties.
Clue uses a data analysis service operated by Amplitude. Amplitude uses device identifiers that are stored on your mobile device and allow for analysis of your use of the Clue app. For website analysis, Amplitude uses ‘cookies’ (small text files) that are stored on your computer and allow for analysis of your visit to our website. Data concerning your use will be transferred to and stored on a server in the USA operated by Amplitude.
You can prevent cookies from being installed on your computer by changing your browser settings; however, if you choose to do this, your visit to our website and use of some functionalities of our service may be impaired. By using our Service, you are deemed to have expressly consented to the use and processing of your data collected by Amplitude as described above.
Clue uses an in app performance and analysis service by Adjust, a Berlin-based company that helps us understand how our users are interacting with our apps and how to optimize and analyze mobile ad campaigns. For such analysis and depending on your mobile operating system (iOS or Android), Adjust uses your given advertising identifier (Apple IDFA or your Google Play Services ID), and your IP- and MAC addresses that are modified in such a way that it is not possible to identify you or your mobile device individually.
By using our Service, you are deemed to have expressly consented to the use and processing of your data collected by Adjust as described above.
4.9 Facebook Lookalike Audience
If you have communicated to Facebook that you are using the Clue app, Clue may use this information via a Facebook advertising service called “lookalike audiences” to identify potential new Clue users based on the Facebook characteristics of certain existing Clue users (e.g. what they liked on Facebook.) We use this service so we can reach more people who have similar attributes or behavior of our users. For this purpose we may share your email address with Facebook if you log in to Clue using your Facebook account or downloaded Clue via a Facebook ad. In other words, if you never told Facebook you use Clue, we will not share that information. Additionally, Clue does not in any way share data you are tracking in the app (e.g. when you get your period) or any other personal information with Facebook.
You can read more about Facebook lookalike audiences here.
6. Communications and newsletter activities
Clue uses your personal information, such as your email address, to contact you with messages, emails, and newsletters. These include push notifications and in-app messages, informational content about female health via email, as well as occasional promotional material that may be of interest to you, also via email.
Such newsletter services are only provided to you if you have signed up for the newsletter service or given your consent for these notifications. You can withdraw your consent at any time by unsubscribing from our newsletter. For providing such services, Clue may forward information such as your email address to third-party providers in order to carry out such newsletter service or notification. These providers are the Rocket Science Group LLC (“Mailchimp”), seated in Atlanta, USA, which may process your email address, names and usage data to send you informational and occasional commercial content via email; Leanplum Inc. (“Leanplum”), seated in San Francisco, USA, which may process your email address and a user identifier to send in-app messages, informational and occasional commercial content via email; and Message Systems Inc. (“SparkPost”) seated in San Francisco, USA, which processes names and email addresses as well as the personal information that may be included in transactional emails (e.g “I lost my password” or “verify your Clue account”) and to send you your cycle report via email.
You can find more information about the Privacy Shield Framework here: https://www.privacyshield.gov/welcome
Clue does not knowingly collect or use personal data from children under the age of 13. By registering to a Clue account you are required to confirm that you are at least 13 years old. If Clue gains actual knowledge that the information has been collected from children under the age of thirteen in the United States in contradiction with the Children’s Online Privacy Protection Act of 1998 and the regulation thereunder, Clue will not disclose this data and reserves the right to immediately delete the account. For all COPPA-related questions, please contact us at email@example.com.
Clue is a company operated by Biowink GmbH, a German corporation, located in Berlin.