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U.S. Supplemental Notice

Last updated 23 de julho de 2025

This Supplemental Notice (“Supplemental Notice”) describes the practices of Clue (“we,” “us,” “our”) regarding the collection, use, and disclosure of Personal Information about residents of certain U.S. states through both online and offline interactions with you, including through the Clue app and the helloclue.com website. This Supplemental Notice also addresses how you can exercise your privacy rights under each state’s comprehensive privacy legislation (collectively, “U.S. Privacy Laws”). Some portions of this Supplemental Notice apply only to residents of particular states. In those instances, we have indicated that such language applies only to those residents.

For more information about our consumer health data practices, please visit our Consumer Health Data Policy.

If you have a disability and need to access this policy in an alternative format, please contact us at trust@helloclue.com.

1. Definitions

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household. Personal Information also includes “Sensitive Personal Information” that we specifically describe in this Supplemental Notice.

“Sell,” “Sale,” or “Sold” means renting, releasing, or transferring an individual’s Personal Information to a Third Party for money or other valuable consideration.

“Share,” “Shared,” or “Sharing” means transferring an individual’s Personal Information to a Third Party for cross-context behavioral advertising or targeted advertising purposes, whether or not for money or other valuable consideration.

“Third Party” means any non-affiliated person that is not a Vendor.

“Vendor” means a service provider, contractor, or processor which collects, stores, or otherwise handles data for us and is bound by contractual obligations to use your Personal Information only as directed by us.

You may be familiar with different terms that are used to describe similar concepts in this section by the U.S. Privacy Laws in your state of residence. You can treat them as the same for the purpose of our Supplemental Notice. For example, we intend the term “Personal Information” here to have the same definition as “Personal Data” used in specific U.S. Privacy Laws.

2. What Personal Information we Process

We, and our Vendors, collect and have collected in the past 12 months the following categories of Personal Information about you:

Identifiers, such as name, alias, unique personal identifier, online identifiers, Internet Protocol address, email address, account name, or other similar identifiers.
Internet or Other Network Information, such as browsing history, search history, information regarding your interactions with our websites, application or advertisements.
Inferences drawn from any of the Personal Information listed above to create a summary about, for example, an individual’s preferences, characteristics, and predispositions.
Sensitive Personal Information, including:

Personal Information collected and analyzed concerning your health; and
Personal Information collected and analyzed concerning your sex life.

Children’s Personal Information. We generally do not knowingly collect or process Personal Information of children under 13 years of age. If and when we do so, we comply with the Children’s Online Privacy Protection Act (“COPPA”).

3. Why we Process your Personal Information

We, and our Vendors, collect, process, and disclose the Personal Information (excluding Sensitive Personal Information) described in this Supplemental Notice to:

Operate, manage, and maintain our business;
Advance scientific research;
Deliver Clue newsletters;
Provide, develop, improve, repair, and maintain our products and services
Personalize, advertise, and market our products and services,
Conduct research, analytics, and data analysis;
Maintain our facilities and infrastructure;
Undertake quality and safety assurance measures;
Conduct risk and security controls and monitoring;
Detect and prevent fraud;
Perform identity verification, in a limited way, when necessary;
Perform accounting, audit, and other internal functions, such as internal investigations;
Comply with law, legal process, and internal policies;
Maintain records;
Exercise and defend legal claims; and
Otherwise accomplish our business purposes and objectives.

Based on our core health data processing consent, we, and our Vendors, collect and process the Sensitive Personal Information described in this Supplemental Notice only for:

Performing the services or providing the goods reasonably expected by an average Consumer who requests those goods or services;
Performing services on our behalf, including maintaining or servicing accounts, providing customer service, providing analytic services, providing storage, or providing similar services on our behalf;
Verifying or maintaining the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by us, and improving, upgrading, or enhancing the service or device that is owned, manufactured by, manufactured for, or controlled by us; and

Retention of Personal Information. We retain your Personal Information for the period reasonably necessary to provide goods and services to you and for the period reasonably necessary to support our business operational purposes listed in Section 3 above.

4. To whom we disclose your personal information

We have disclosed the following categories of Personal Information to Vendors and Third Parties for a business purpose in the past twelve months:

To our Vendors. Clue discloses the Personal Information we collect to our vendors who act on our behalf. For example, we use vendors to operate our Services; to conduct surveys; and to help us with our marketing efforts.

With Your Consent. Clue may disclose Personal Information with your consent and direction.

In Aggregate or De-Identified Form. Clue may aggregate or de-identify the Personal Information we collect, and we may disclose aggregated and/or de-identified information to our vendors and to third parties for our business operational purposes, scientific research purposes and for any other purposes permitted by applicable law.

Please note that we do not have actual knowledge that we Sell or Share Personal Information of residents who are under 16 years of age. We also do not process Personal Information for purposes of Profiling or to engage in automated decision making in furtherance of decisions that produce legal or similarly significant effects (which means a decision that results in the provision or denial of financial or lending services, housing, insurance, education enrollment or opportunity, criminal justice, employment opportunities, health-care services, or access to essential goods or services).

5. From Whom Do we Collect your Personal Information

We have collected Personal Information from the following sources for a business purpose in the past twelve months:

Directly From You. Clue collects information you provide to us when you use our websites or when you otherwise interact with us. For example, we collect the information you provide when you create an account, ask us a question, or otherwise interact with us. Types of Personal Information we may collect directly from you include your username, data of birth, and email address.

From Vendors & Third Parties. Clue also collects Personal Information from our vendors and from third parties who disclose Personal Information to us.

Via Cookies & Other Tracking Technologies. Clue collects Personal Information passively via cookies and other tracking technologies (“Cookies”). This typically includes information about our website visitors, such as your IP address, the name of your operating system, the name and version of your browser, the date and time of your visit, and the pages you visit. The information we receive may depend on your browser or device settings.

6. Rights of certain data subjects

Residents who reside in states with U.S. Privacy Laws have the following rights regarding our collection and use of their Personal Information, subject to certain exceptions. Please read this section carefully as some rights vary by state.

Rights that Require Verification. You may exercise the data subject rights below by contacting our Privacy Office at<trust@helloclue.com>, by clicking here and submitting details regarding your request. You may also authorize an agent to make data subject requests on their behalf. In such instances, authorized agents may use the same methods as you to submit the requests on your behalf. To verify your identity and protect your Personal Information, we may ask the requestor to provide information that will enable us to verify your identity in order to comply with your data subject request, such as asking your agent to provide proof of signed permission from you or ask you to confirm with us directly that you provided the agent with permission to submit the request. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request consistent with applicable law.
- Right to Know: You have the right to know the following details about our privacy practice at or before the point of collection. We have provided such information in this Supplemental Notice. You may also request that we provide you with information about the following aspects of how we have handled your Personal Information specifically in the 12 months preceding your request:
  - The categories of Personal Information we have collected about you;
  - The categories of sources from which we collected such Personal Information;
  - The business or commercial purpose for collecting Personal Information about you;
  - The categories of Personal Information about you that we disclosed and the categories of Third Parties to whom we disclosed such Personal Information;
  - The categories of Personal Information about you that we shared, or used for targeted advertising purposes, and the categories of Third Parties with whom we shared such Personal Information;
  - If we collect Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is Shared; and
  - The length of time we intend to retain each category of Personal Information, or if that is not possible, the criteria used to determine that period.
- Right to Deletion: You may request that we delete any Personal Information about you that we collected from you.
- Right to Correction: You may request that we correct any inaccurate Personal Information we maintain about you.
- Right to Access Personal Information and Data Portability: You may ask to obtain Personal Information we have collected about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the Personal Information to another entity without hindrance.
- Right to Opt-Out of Sale: We do not Sell your Personal Information.
- Right to Opt-Out of the Sharing of Your Personal Information or the Use of Your Personal Information for Targeted Advertising. We will not Share your Personal Information for Targeted Advertising.
- Right to Revoke Consent for or Limit the Use of Your Sensitive Personal Information. We will not use your Sensitive Personal Information for any purpose not permitted by U.S. Privacy Laws.
- As described above, we do not engage in Profiling or automated decision making that have legal or similarly significant effects. But if we did, you would have the right to opt out of the profiling of data in furtherance of solely automated decisions that have legal effects or similarly significant effects concerning consumers.
Opt-Out Preference Signals. Some web browsers or devices offer settings where you may pre-set a signal to websites that you do not want to have your online activity and behavior tracked, sold, shared or otherwise used for targeted advertising purposes. We do not sell, share or use your Personal Information for targeted advertising purposes and therefore do not recognize opt-out preference signals on our website or app.
Non-Discrimination. We will not discriminate against you for exercising your data subject rights. For example, we will not deny goods or services to you, charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your data subject rights.
Appeals. Residents of certain states have the right to appeal our decisions on their data subject requests. To appeal our decision on your data subject requests, you may contact our team at trust@helloclue.com. Please enclose a copy of or otherwise specifically reference our decision on your data subject request, so that we may adequately address your appeal. We will respond to your appeal in accordance with applicable law.

7. Other Disclosures

Disclosure for California Residents
- Direct Marketing. We do not disclose Personal Information for direct marketing purposes.
- Financial Incentives for California Residents. We do not provide financial incentives to California residents who allow us to collect or retain their Personal Information. We will describe such programs to you if and when we offer them to you.

8. Changes to this U.S. Supplemental Notice

Clue reserves the right to amend this Supplemental Notice from time to time to reflect changes in the law, our data collection and data use practices, the features of Clue’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 Supplemental Notice that we believe requires your consent, we will notify you of the change.