Privacy Policy

Last revised: March 17, 2026

1. Introduction

This Privacy Policy ("Policy") describes how CLAROS AI LLC, a Washington limited liability company ("Company," "we," "us," or "our"), collects, uses, processes, and discloses information in connection with the website, mobile application, software platform, and related products, tools, features, and services made available by Company (collectively, the "Services").

The Services are designed for use by licensed dental professionals and authorized personnel operating within dental practices or other healthcare-related organizations. The Services may include functionality for recording patient encounters, transcribing audio, generating documentation, facilitating communications, supporting integrations, and processing information in connection with clinical and administrative workflows.

The Services may also involve the processing of Protected Health Information ("PHI") on behalf of a dental practice, covered entity, or business associate customer. In such cases, Company acts solely as a technology service provider and business associate, and its processing of PHI is governed exclusively by the applicable Business Associate Agreement ("BAA") and applicable law, including HIPAA.

IMPORTANT DISTINCTION BETWEEN PERSONAL INFORMATION AND PROTECTED HEALTH INFORMATION. This Privacy Policy governs the collection, use, and disclosure of "personal information" as defined under applicable privacy laws. To the extent the Services involve the creation, receipt, maintenance, or transmission of Protected Health Information ("PHI") on behalf of a dental practice or other covered entity, such PHI is not governed by this Privacy Policy and is instead governed solely by the applicable Business Associate Agreement ("BAA") and applicable law, including HIPAA. Company's handling of PHI is limited to its role as a business associate and is subject to the restrictions, conditions, and safeguards set forth in the BAA.

2. Agreement to Terms of Privacy Policy and Terms of Use

All of Your activities on the Site are voluntary. You are not required to provide any personal information unless You choose to access features on the Site that require such information. If You do not agree with the terms of this Policy or with Our Site Terms, then You should immediately exit the Site and discontinue using it. Our Site Terms are expressly incorporated into this Policy by reference and form a part of this Policy. By using the Site, You signify that You agree to the terms of this Policy as well as to Our Site Terms.

In addition, Your use of the Services is governed by the Company's End User License Agreement ("EULA") and, where applicable, a Business Associate Agreement ("BAA"). In the event of any conflict between this Policy and an applicable BAA with respect to Protected Health Information, the BAA shall control solely with respect to such Protected Health Information. This Privacy Policy does not modify or expand Company's obligations with respect to PHI under any BAA.

3. Changes to Privacy Policy

This Policy is effective as of the date indicated below and will remain in effect until updated by Company. Company may amend this Policy from time to time to reflect changes in Our practices, legal requirements, or the features of the Site. Any revisions to this Policy will become effective on the date they are posted on the Site. In certain cases, where required by applicable law, We will provide additional notice of material changes or obtain Your consent before such changes take effect. In addition, Your use of the Services is governed by the Company's End User License Agreement ("EULA") and, where applicable, a Business Associate Agreement ("BAA"). In the event of any conflict between this Policy and an applicable BAA with respect to Protected Health Information, the BAA shall control solely with respect to such Protected Health Information. This Privacy Policy does not modify or expand Company's obligations with respect to PHI under any BAA.

4. Policy Applicable to Online Activities

This Policy applies to Your activities on or through the Services, including Company's website, platform, mobile application, and related online interactions. This Policy shall be applied in a manner consistent with applicable laws and regulations in the jurisdictions where Our users are located.

5. Personal Information We May Collect

We collect information in connection with the provision, operation, marketing, and improvement of the Services. The categories of information collected depend on how You use the Services, the features You enable, and the choices You make.

For purposes of this Policy, "personal information" refers to information that identifies, relates to, describes, or can reasonably be linked to an individual, as defined under applicable privacy laws. Personal information does not include Protected Health Information processed by Company on behalf of a covered entity or business associate customer, which is governed exclusively by the applicable BAA.

A. Information You Provide Directly

We may collect information that You provide directly, including:

  • Account Information: such as name, email address, username, organization, role, and account credentials.
  • Practice Information: including dental practice details, user roles, and operational information.
  • Customer Data: including information submitted, uploaded, recorded, or processed through the Services, which may include patient information, recordings, transcripts, clinical notes, images, videos, and other materials.
  • Communications: including support requests, feedback, and other communications with Company.

B. Protected Health Information (PHI)

To the extent Customer Data includes information relating to identifiable individuals, including patients, such information may constitute Protected Health Information. Company processes such PHI solely on behalf of its customers and in accordance with the applicable BAA, and such processing is not governed by this Privacy Policy.

C. Information Collected Automatically

We may automatically collect certain technical and usage information, including:

  • Device and Technical Information: such as IP address, browser type, operating system, and device identifiers.
  • Usage Information: including access times, pages viewed, features used, interactions with the Services, and system logs.
  • Performance and Diagnostic Data: used to monitor, maintain, and improve system performance and security.

D. Information from Integrations and Third Parties

We may receive information from third-party systems designated by You, including electronic health record systems, practice management systems, or other integrations, to the extent necessary to provide the Services.

E. De-Identified and Aggregated Information

We may derive de-identified or aggregated information from data processed through the Services. Such information does not identify any individual and may be used for lawful business purposes as described in this Policy.

Information You Provide to Us

We collect information you provide directly to us, as follows:

Account Information includes personal information collected when You create an account, are provisioned as an authorized user, or manage Your profile, such as Your name, business email address, username, password or authentication credentials, organization name, role, and other account-related information.

Practice and Professional Information includes information relating to Your dental practice or organization, professional role, office location, practice contact information, subscription details, and information needed to administer the Services in a business or clinical setting.

We use this information to:

  • create, provision, and manage user accounts and access credentials;
  • administer subscriptions, customer relationships, and account preferences;
  • provide access to the Services and associated functionality;
  • send technical notices, updates, security alerts, and administrative communications;
  • communicate with You regarding the Services, features, updates, events, and offerings;
  • provide customer support and respond to inquiries;
  • comply with legal, tax, regulatory, and contractual obligations.

Identifiers include information such as Your name, email address, phone number, IP address, device information, and other identifiers that may be provided by You during checkout or account creation, or collected automatically through cookies, pixels, analytics tools, or similar technologies used on the Site.

We use this information to:

  • provide, operate, maintain, and improve the Services and related functionality;
  • authenticate users and maintain system security;
  • detect, investigate, and prevent fraud, unauthorized activity, and security incidents;
  • support analytics, performance monitoring, and system optimization;
  • support lawful marketing, advertising, and measurement activities;
  • comply with legal, regulatory, and compliance obligations.

Communication Information includes the content of any communications You send or receive, such as customer service inquiries, emails or messages You send to Us, product reviews, feedback, and any photos or videos.

We use this information to:

  • provide, maintain, and improve Our products, services, and customer experience;
  • detect, investigate and prevent fraudulent transactions and other illegal or unauthorized activities and protect the rights and property of Company and others;
  • respond to your comments, questions and requests and provide customer service;
  • support legal, regulatory, and compliance obligations.

Customer Data and Health-Related Information includes data submitted to, uploaded to, recorded through, transmitted through, or otherwise processed in connection with the Services, which may include patient information, audio recordings, transcripts, notes, summaries, photographs, videos, scans, scheduling data, communication content, and other materials provided by or on behalf of a customer. To the extent such information constitutes Protected Health Information, it is processed in accordance with applicable law and any applicable BAA.

We use this information to:

  • provide, operate, maintain, and improve the Services and related functionality;
  • process, store, and transmit Customer Data in accordance with the EULA and applicable agreements;
  • enable recording, transcription, summarization, and generation of outputs using automated systems;
  • support integrations with third-party systems designated by You;
  • provide customer support and troubleshoot issues;
  • ensure system security, integrity, and fraud prevention;
  • comply with legal, regulatory, and contractual obligations.

Information Collected Automatically When You Use Our Services

When you access or use our services, we may automatically collect information about you, as follows:

Usage Information. We collect log information about Your use of the Site, including the type of browser You use, access times, pages viewed, Your IP address, the page You visited before navigating to the Site, and information regarding Your interactions with pages, links, products, and features.

We use this information to:

  • present the Services and its features to You;
  • select a language and region in which to present our services to you;
  • provide, maintain, and improve the Site and the services We offer;
  • send you technical notices, updates, security alerts and support and administrative messages;
  • detect, investigate, and prevent fraudulent or unauthorized activities and protect the rights and property of Company and others;
  • analyze traffic patterns and understand how users engage with the Site;
  • communicate with you about products, services, offers, promotions, rewards, and events offered by Company and others, and provide news and information we think will be of interest to you;
  • link or combine with other information We receive to improve service and personalization.

Device Information. We collect information about the computer or mobile device You use to access the Site, including hardware model, browser type, operating system and version, mobile network information, device identifiers, and similar technical data.

Location Information. We may collect general location information derived from Your IP address when You access the Site. We do not collect precise or GPS-level location data.

Cookie Information. We use cookies, pixels, tags, and similar technologies to operate the Site and to understand user activity, including through service providers, analytics providers, customer support tools, payment processors, advertising partners, and technology vendors, Google Analytics 4, Meta Pixel, Meta Conversion API, and TikTok Pixel. Most browsers are set to accept cookies. You may adjust Your cookie preferences through browser settings or any consent tools provided on the Site. Company may implement additional cookie consent tools in the future to comply with regional legal requirements.

Inferences. We may derive inferences from the information We collect, such as interests, browsing tendencies, or general location, to help improve the Site, personalize Your experience, or support marketing and analytics.

User Content. User-generated content includes product reviews, feedback, photographs, videos, or other content You voluntarily submit through the Site or through campaigns, collaborations, or promotional programs. We do not collect job postings, work history, or similar information.

All Information Set Forth Above

We use this information to:

  • provide, maintain, fulfill, and improve Our products, services, and Site functionality;
  • detect, investigate, and prevent fraudulent transactions and other illegal or unauthorized activities, and protect the rights and property of Company and others;
  • support security, compliance, auditing, and record keeping requirements;
  • defend against potential legal claims and cooperate with lawful requests;
  • comply with all applicable legal, regulatory, and tax obligations;
  • carry out any other purpose that We describe to You at the time the information is collected, or for which You provide consent.

6. Additional Information We May Collect

Types of Information Collected. There may be other instances in which We collect information from You that is more general in nature ("General Information"). General Information may include Your Internet Protocol (IP) address, device identifiers, browser type, and other technical information used to identify Your computer or device on a TCP/IP network. This information may be collected whenever You access the Site, whether or not You provide Us with any Personal Information. General Information may also include device-level information collected through service providers, analytics providers, customer support tools, payment processors, advertising partners, and technology vendors, including GA4, Meta Pixel, Meta Conversion API, TikTok Pixel, and other technologies used to operate the Site and related digital properties.

Click Stream Data. When You visit the Site, We may collect click stream data, including but not limited to server address, domain name, pages viewed, products browsed, the time and length of visits, referral URLs, and related browsing activity ("Click Stream Data"). This information may be combined with other information You provide to Us and may be used for traffic analysis, analytics, personalization, ad performance measurement, and to determine which features of the Site are most or least effective.

Web Beacons. A web beacon is an object that is embedded in a webpage or email that is usually invisible to and allows website operators to check whether the user has viewed a particular page or email ("Web Beacon"). We may use web beacons, pixels, tags, SDKs, APIs, and similar technologies on the Site, within communications, or through third-party advertising and analytics services or in Our emails to determine whether users have viewed specific pages or emails and to gather related information for analytics, security, advertising, and operational purposes. These technologies may be used in connection with service providers, analytics providers, customer support tools, payment processors, advertising partners, and technology vendors, GA4, Meta Pixel, Meta Conversion API, and TikTok Pixel. Personal Information is generally not collected directly through the use of Web Beacons. Users may adjust their browser or cookie settings to limit certain types of tracking.

Mobile Device Data. If You access the Site or services using a mobile device, We may collect information relating to Your mobile device, including device ID, model, manufacturer, operating system and version, IP address, mobile network information, browser type, and other device-level data. This information may be used for functionality, analytics, security, fraud prevention, and performance optimization.

Geo-Location Information. Information relating to Your location, and the location from which You are accessing Our services, may be collected, including general location data derived from Your IP address, region-level location, and other geolocation information provided by Your device or browser. We do not collect precise GPS-level location data unless You expressly authorize such collection. General location information may be used for analytics, security, fraud prevention, personalization, and compliance with regional legal requirements.

Push Notifications. We may send You push notifications if You choose to receive them, including notifications related to orders, promotions, or account activity. To opt out of these types of communications, You may turn them off in Your device or browser notification settings at any time.

Non-Identifying Information. We may collect other information that does not identify You directly, such as demographic information, zip codes, aggregated browsing data, information about Your use of the Site, and other non-personally identifiable data ("Non-Identifying Information"). We may combine information collected from users into hashed or coded formats ("Hashed Information"). While Hashed Information does not identify You directly, it may be used by Company or its partners to understand user interests, measure Site performance, and improve advertising and analytics.

Third Party Analytics Providers and Similar Vendors. Company works with (and may in the future work with) ad networks, ad agencies, analytics providers, and other vendors to provide Us with information regarding traffic on the Site, including pages viewed and actions taken; to measure ad effectiveness; and to serve advertisements to You on other websites, within mobile applications, or online services. Our service providers, including Google Analytics 4, Meta Pixel, Meta Conversion API, or others, may collect certain information about Your visits to and activity on the Site and may set and access their own tracking technologies (including cookies, pixels, and web beacons). These parties may use that information to provide Us with analytics, personalize content, and show You advertisements that may be of interest to You. Some of these parties may collect Personal Information when You visit the Site or other online websites and services.

We may also share certain Non-Identifying Information, including Hashed Information, with these parties in connection with the services they provide. If You wish to opt out of interest-based advertising from participating companies, You may use the opt-out tools provided by Your browser settings, through Your account settings where applicable, through any cookie consent tools made available on the Site, or through industry opt-out tools such as those offered by the Network Advertising Initiative and the Digital Advertising Alliance. You must opt out on each device and each browser for Your preferences to apply. If You choose to opt out, You will continue to receive advertisements, but they may be less relevant to You.

While We may use a variety of service providers to perform advertising services, some of these companies are members of the Network Advertising Initiative ("NAI") or the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. You may visit networkadvertising.org/managing/opt_out.asp to learn more about targeted advertising and opt-out procedures for NAI members. You may also visit aboutads.info/choices for information regarding targeted advertising and opt-out options offered by participating companies in the DAA Self-Regulatory Program.

COMPANY DOES NOT USE PROTECTED HEALTH INFORMATION FOR CROSS-CONTEXT BEHAVIORAL ADVERTISING OR FOR MARKETING TO PATIENTS, AND TO THE EXTENT INFORMATION CONSTITUTES PROTECTED HEALTH INFORMATION, SUCH INFORMATION IS HANDLED IN ACCORDANCE WITH APPLICABLE LAW AND ANY APPLICABLE BAA.

TRACKING, ANALYTICS, COOKIES, PIXELS, AND SIMILAR TECHNOLOGIES DESCRIBED IN THIS SECTION APPLY ONLY TO PERSONAL INFORMATION COLLECTED THROUGH COMPANY'S WEBSITE, MARKETING PAGES, AND GENERAL PLATFORM USAGE. THESE TECHNOLOGIES ARE NOT USED BY COMPANY TO TRACK OR ANALYZE PROTECTED HEALTH INFORMATION.

7. Uses of Your Information

The uses of information described in this Section apply solely to personal information and do not apply to Protected Health Information processed by Company on behalf of its customers. Uses and disclosures of PHI are governed exclusively by the applicable BAA and applicable law. For the avoidance of doubt, any references in this Policy to advertising, targeted advertising, sale, sharing, analytics, cookies, or similar concepts apply only to personal information and do not apply to Protected Health Information.

  • To provide, operate, maintain, and improve the Services;
  • To process and manage personal information in accordance with this Policy, and to process Customer Data as necessary to provide the Services in accordance with the EULA and any applicable agreements;
  • To enable recording, transcription, summarization, and generation of outputs using automated systems;
  • To provide, operate, maintain, secure, troubleshoot, and improve the Services, including recording, transcription, summarization, integration, messaging, scheduling, and related workflow functionality;
  • To support integrations with third-party systems designated by You;
  • To provide customer support and respond to inquiries;
  • To ensure system security, integrity, and fraud prevention;
  • To comply with legal, regulatory, and contractual obligations;
  • To enforce agreements, including the EULA and BAA;
  • To develop, test, and improve functionality, including artificial intelligence and machine learning systems using de-identified data;
  • To the extent required by law, we process personal information based on applicable legal bases, including performance of a contract, legitimate interests, legal obligations, and consent where required;
  • In response to a request for information if We believe disclosure is in accordance with, or required by, applicable law, regulation, legal process, or governmental request;
  • If We believe Your actions are inconsistent with Our user agreements or policies, or if necessary to protect the rights, property, or safety of Company, its employees, its users, or the public;
  • In connection with, or during negotiations of, any merger, sale of Company assets, financing, acquisition, divestiture, bankruptcy, dissolution, or other transaction or proceeding involving the transfer of all or part of Our business or assets, to the extent permitted under applicable law;
  • Between and among Company and Our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership;
  • With service providers and processors that assist Us in operating the Site, fulfilling orders, processing payments, delivering products, providing analytics and advertising services, hosting data, preventing fraud, or delivering customer support;
  • With advertising and marketing partners, such as Meta, Google, TikTok, and similar platforms, to support analytics, measurement, and advertising activities permitted by law, including the use of hashed or otherwise pseudonymized identifiers and event data;
  • On an aggregated, anonymized, or de-identified basis that does not identify You personally; and
  • With Your consent or at Your direction.
  • Company does not use Protected Health Information for advertising, marketing, analytics, or any purpose other than those permitted under the applicable BAA and applicable law.

BY REGISTERING TO USE THE SERVICES, YOU CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS POLICY.

7.1 Additional Uses of Personal Information Provided

We may use the Personal Information You provide and any General Information We receive from You to provide products and services to You and other visitors and/or users, including, but not limited to, the following:

  • To administer accounts, subscriptions, demos, trials, onboarding, customer success programs, webinars, events, promotional campaigns, referral programs, and other business development or customer engagement activities.
  • To send You information, materials, and communications by email, text message, phone, or other channels regarding the Services, updates, features, offers, events, and other information that may be of interest to You, subject to applicable law and Your communication preferences.
  • To analyze use of the Services and related websites, understand customer and prospective customer interests, improve user experience, refine messaging and marketing strategy, and support analytics, measurement, and advertising.
  • To share information with service providers, advertising partners, analytics providers, and similar vendors that support Company's marketing, advertising, customer relationship management, and business operations, subject to applicable law.
  • To share information with vendors and service providers that assist in operating the Services, processing payments, hosting data, providing customer support, managing communications, providing security, supporting integrations, delivering analytics, and conducting business operations.

7.2 Other Uses

To the extent You voluntarily provide personal information in interactive areas of the Services (such as reviews, comments, or user-generated content), such information may be visible to others and may be shared accordingly.

Use of information to:

  • Provide and improve the Service.
  • Address inquiries.
  • Verify the information you provide is valid.
  • Support compliance, risk management, and internal business purposes.
  • Contact for administrative communications.
  • Tailoring content, offers, and advertising displayed on the Site and, where permitted by law, on other websites or online services.
  • Administering and developing Our business relationship with You and, if applicable, the corporation or other legal entity You represent, including affiliate or partnership relationships.
  • Assessing proposals, applications, or business opportunities that You submit to Company, and preparing related internal business statistics and reports.
  • Using Device Identifiers and other technical information to identify Company users for purposes such as fraud prevention, security, analytics, and personalization.
  • Honor contractual commitments to users.

Legitimate Interests, which include:

  • Providing the Site and Our services.
  • Detecting, investigating, and responding to security incidents and malicious activities.
  • Measuring interest and engagement in the Site and Our services.
  • Short-term, transient use, such as contextual customization of ads or content.
  • Improving, upgrading, or enhancing the Site and Our services.
  • Developing new products, features, and services.
  • Ensuring internal quality control and safety.
  • Authenticating and verifying individual identities.
  • Debugging to identify and repair errors.
  • Auditing relating to interactions, transactions, and compliance activities.
  • Enforcing agreements, terms, and policies.
  • Analyzing and improving the business and user experience.
  • Addressing information security needs and protecting users, Company, and others.
  • Using and disclosing Personal Information as necessary to comply with legal obligations, including those relating to tax, accounting, regulatory reporting, and law enforcement requests.

7.4 Access and Rectification

You have the right, subject to applicable law, to access and request correction of Your personal information. You may exercise these rights by contacting Us at hello@clarosai.co or by using any other contact method provided in this Policy. We will respond to such requests in accordance with applicable law and may take reasonable steps to verify Your identity before fulfilling a request. In certain circumstances permitted by law, We may charge a reasonable fee or decline a request if it is excessive, repetitive, or manifestly unfounded.

These rights apply to personal information only. Requests relating to Protected Health Information should be directed to the applicable dental practice or covered entity, except where Company is required by law or contract to assist.

7.5 Automated Decisions

Company does not use Personal Information to make automated decisions that produce legal or similarly significant effects.

7.6 Protected Health Information

To the extent Company processes Protected Health Information on behalf of a dental practice, covered entity, or business associate, such processing is governed exclusively by the applicable Business Associate Agreement and applicable law, including HIPAA. Company acts solely as a technology service provider and business associate with respect to such PHI. Company does not determine the purposes or means of processing PHI except as necessary to provide the Services in accordance with the EULA and the BAA. Company does not use Protected Health Information for advertising, marketing, cross-context behavioral advertising, analytics unrelated to permitted operations, or independent commercial purposes. Requests relating to Protected Health Information, including requests for access, amendment, correction, or deletion, should be directed to the applicable dental practice or covered entity, except to the extent Company is required by law or contract to assist. Nothing in this Privacy Policy is intended to modify, limit, or expand Company's obligations with respect to Protected Health Information under the applicable BAA.

8. Do Not Track Policy

This Section applies to personal information. Disclosures of Protected Health Information are governed exclusively by the applicable Business Associate Agreement and applicable law.

Some browsers offer a "Do Not Track" ("DNT") setting that allows You to signal to websites that You do not wish to be tracked across different online sites and services. At this time, the Site does not respond to DNT signals because there is no industry-standard method for interpreting such signals. However, We will honor legally recognized browser-based opt-out preference signals, such as Global Privacy Control (GPC), to the extent required under applicable United States state privacy laws.

Third parties that provide analytics, advertising, or embedded content on the Site, including Google Analytics, and similar service providers, may set cookies or use tracking technologies on Your browser and may collect information about Your online activities over time and across different websites and applications. These third parties may use such information to provide measurement, analytics, or advertising services.

Third parties cannot collect Your Personal Information from the Site unless You provide it to them directly or unless such collection is allowed under applicable law and disclosed in this Policy.

Company will also honor universal opt-out mechanisms recognized under applicable state laws where technically feasible.

9. Protection of Your Personal Information and General Information

9.1 Risk of Interception

Whenever You give out Personal Information online, there is a risk that third parties may intercept or access that information. While Company strives to protect Your Personal Information and privacy through reasonable administrative, technical, and physical safeguards, no method of transmission over the Internet or electronic storage is completely secure. By using the Site, You acknowledge and agree that We cannot guarantee absolute security of any data transmitted to or from the Site, and that You provide such information at Your own risk. Company follows the security practices made available through service providers, and We limit access to Personal Information to authorized personnel who require such access to perform their duties.

9.2 Law Enforcement

We reserve the right to disclose any information We may have obtained about You to law enforcement authorities, governmental agencies, or other third parties when We believe such disclosure is necessary or appropriate to comply with the law, respond to lawful requests or legal processes, prevent fraud or abuse, protect the rights, property, or safety of Company or others, or otherwise fulfill legal obligations.

9.3 Shine the Light Laws

If You are a resident of a State that permits its residents to request information regarding the disclosure of Personal Information to third parties for their direct marketing purposes during the preceding calendar year, You may submit such a request by contacting Us in writing using the contact information provided below.

With respect to Protected Health Information, Company's privacy and security obligations are governed by the applicable Business Associate Agreement.

10. No Use of This Site by Persons Under 18 Permitted

10.1 Registration Declined

Only persons who are 18 years of age or older are permitted to use this website or submit Personal Information through the Site. Personal registration information submitted by a person under the age of 18 will not be accepted. Company is committed to protecting the privacy of children and has no intention of collecting Personal Information from children under the age of 18. We encourage parents and guardians of minors to regularly monitor their children's online activities and use of e-mail and other communications.

10.2 Notice Concerning Children

PLEASE NOTE: We are a general audience site and do not direct any of Our Services, Site, or marketing to children under 13 years of age. We understand and are committed to respecting the sensitive nature of children's privacy online. If We learn or have reason to suspect that a Site user is under age 13, We will promptly delete all Personal Information from that user's account, consistent with applicable law. If You are a parent or guardian of a child under the age of 13 who has become a member of the Site or has otherwise provided Personal Information to Us, please contact Us using the information below so that We may take appropriate action to terminate the account and delete the information.

11. Third Parties

11.1 Who May Have Access to Your Information

We do not sell personal information. We may share personal information with service providers, contractors, affiliates, and other partners that assist Us in operating the Services, processing payments, hosting data, providing customer support, supporting analytics and advertising, maintaining security, supporting communications, enabling integrations, and conducting other business operations (collectively, "Service Partners").

Service Partners may use Your Personal Information only to perform services on Our behalf and are required to protect such information in accordance with applicable laws and contractual obligations. While We encourage Our Service Partners to adopt and maintain privacy practices, the use of Your Personal Information by those Service Partners is governed by their own privacy policies and is not subject to Our control. To the extent service providers create, receive, maintain, or transmit Protected Health Information on behalf of Company, such providers are subject to contractual protections consistent with applicable law, including HIPAA where applicable.

11.2 Release of Information

Company may release Personal Information or General Information without Your consent when We believe such disclosure is necessary or appropriate for security purposes, to comply with the law, or to respond to lawful requests from courts, law enforcement, or regulatory authorities. This may include responding to subpoenas, court orders, or legal processes in civil, criminal, administrative, or other proceedings, including those originating outside the United States. We may also disclose information to prevent imminent harm to any person or entity, to detect or prevent fraud, to investigate suspected unlawful activity, or to protect Our legal rights. Company fully cooperates with law enforcement agencies in identifying individuals who use Our services for illegal activities. Any release of Your Personal Information or General Information will be made based on a good-faith determination by Company that such disclosure is necessary and appropriate.

11.3 Links to Third Parties

For Your convenience and to enhance Your experience, the Site may contain links to third-party websites, content, or services. This Policy does not apply to such third-party websites. Links may take You outside the Site and are beyond Our control. These third-party sites may have their own privacy policies, which may differ from Ours, and Company is not responsible for the content, activities, or privacy practices of such sites. Your visits and interactions with third-party sites are at Your own risk. These third parties may send their own cookies or tracking technologies to Your device, may collect data, or may solicit Personal Information from You, and their practices may involve greater, lesser, or different types of information than those collected through Our Site.

12. Privacy Rights

You may have certain rights and choices regarding Your personal information, including the right to access, delete, correct, or opt out of certain uses of personal information, depending on Your location. These rights apply to personal information only and do not apply in the same manner to Protected Health Information processed by Company on behalf of a covered entity. Individuals seeking to exercise rights with respect to PHI should contact the applicable healthcare provider.

Only You, or a person authorized by You to act on Your behalf, may make a request related to Your Personal Information. For certain requests, including access and deletion, Your request must be verifiable before We can fulfill it. Verification may require You to provide sufficient information for Us to reasonably confirm that You are the individual whose Personal Information We collected or an authorized agent of that individual. We will only use the Personal Information provided in connection with a verifiable request to verify the requestor's identity or authorization.

We cannot respond to a request or provide Personal Information if We cannot verify Your identity or authority. In certain circumstances permitted by applicable law, We may charge a reasonable fee or deny a request if it is excessive, repetitive, or manifestly unfounded. You will not receive discriminatory treatment for exercising any of Your privacy rights.

Authorized agents may submit privacy requests on a consumer's behalf by providing proof of authorization along with verification of the consumer's identity.

13. For Individuals Located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland

You have a number of rights under applicable data protection laws in relation to Your Personal Information. Under certain circumstances, You have the right to:

  • Have access to Your Personal Information by submitting a request to Us;
  • Have Your Personal Information deleted;
  • Have Your Personal Information corrected if it is inaccurate or incomplete;
  • Have the processing of Your Personal Information restricted;
  • Object to further processing of Your Personal Information, including objecting to marketing from Us;
  • Make a data portability request;
  • Withdraw any consent You have provided to Us at any time, without affecting the lawfulness of processing carried out prior to such withdrawal;
  • Restrict or object to certain types of automated processing of Your Personal Information; and
  • Lodge a complaint with an appropriate Supervisory Authority.

To exercise any of these rights, please contact Us at hello@clarosai.co or by using any additional contact methods provided in this Policy. We will respond to requests in accordance with applicable EEA, UK, or Swiss data protection laws and may take reasonable steps to verify Your identity before fulfilling a request.

14. Notice for California Residents

"Shine the Light" and "Eraser" Laws: Residents of the State of California may request a list of all third parties to whom We have disclosed certain categories of Personal Information during the preceding calendar year for those third parties' direct marketing purposes. You may submit such a request by contacting Us as described in the "Contact Us" section below.

California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA): The CCPA, as amended by the CPRA, provides California residents and their authorized agents with specific rights regarding the collection, processing, and disclosure of their Personal Information.

Your Right to Know: California residents have the right to request that we disclose the following information to you about our collection and use of your personal information over the past twelve (12) months. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Upon verification, we will disclose to you:

  • The categories of Personal Information We have collected about You.
  • The categories of sources from which the Personal Information was collected.
  • The specific pieces of Personal Information We have collected about You.
  • The business or commercial purpose for collecting, using, or "selling" or "sharing" the Personal Information (as those terms are defined under the CCPA).
  • The categories of third parties to whom We have "sold" or "shared" Your Personal Information, if any, and the categories of Personal Information disclosed to each category of third-party recipient.

Your Right to Opt-Out of "Sale" or "Sharing" of Personal Information: California residents have the right to opt-out of the "sale" or "sharing" of their Personal Information as defined by the CCPA. We do not "sell" Personal Information in the traditional sense. However, certain uses of Meta, Google, TikTok, and other advertising or analytics partners may be classified as "sharing" under the CCPA for cross-context behavioral advertising. You may opt-out of such sharing at any time by contacting Us using the information provided in the "Contact Us" section below, by using any opt-out tools offered on the Site, or through browser-based opt-out signals such as Global Privacy Control (GPC). We do not knowingly "sell" the Personal Information of individuals under the age of 18. Company will make an opt-out mechanism for targeted advertising and data sharing available on the homepage or within a "Your Privacy Choices" link, consistent with applicable law.

Your Right to Limit Use of Sensitive Personal Information: Under the CPRA, California residents may have the right to request that a business limit the use of any "sensitive personal information" to those uses necessary to perform the services or as otherwise permitted by the CPRA. Company does not use sensitive personal information for any purpose other than those necessary to provide the Site and services or as permitted under applicable law.

Your Right to Delete: California residents have the right to request that We delete Personal Information We have collected from them, subject to certain exceptions. We may ask You to provide sufficient information to verify Your identity before fulfilling a deletion request. If Your request is verified and no exception applies, We will delete Your Personal Information and direct Our service providers to delete it as well. Your request may be denied if retaining the information is necessary for Us to comply with legal obligations or for other reasons permitted under the CCPA.

Your Right to Correct: California residents have the right to request that We correct inaccurate Personal Information that We maintain about them. We will use commercially reasonable efforts to correct such information, taking into account the nature of the Personal Information and the purposes for which it is processed.

Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA.

15. Notice for Nevada Residents

Under Nevada law, certain Nevada residents may opt out of the sale of "personally identifiable information" for monetary consideration to a person for that person to license or sell such information to additional persons. "Personally identifiable information" includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.

We do not engage in such activity; however, if You are a Nevada resident who has purchased or leased goods or services from Us, You may submit a request to opt out of any potential future sales under Nevada law by emailing hello@clarosai.co. We will take reasonable steps to verify Your identity and the authenticity of the request. Once verified, We will maintain Your request in the event Our practices change.

16. Notice for Residents of Certain Other States

Residents of certain U.S. states may have additional rights regarding their personal information under applicable state privacy laws, including without limitation laws in Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island, and other jurisdictions with similar laws, as amended from time to time.

Your Right to Confirm and Access: You have the right to confirm whether We are processing Personal Information about You and to access the Personal Information We process about You.

Your Right to Portability: You have the right to obtain a copy of the personal information we maintain and process about you in a portable and, to the extent technically feasible, readily-usable format.

Your Right to Delete: You have the right to request that We delete Personal Information that We maintain or process about You, subject to applicable legal exceptions.

Your Right to Correct: You have the right to request that We correct inaccuracies in the Personal Information We maintain or process about You, taking into consideration the nature of the Personal Information and the purposes for which We process it.

Your Rights to Opt-Out: You have the right to opt out of certain types of processing of Personal Information, including:

  • Opt-out of the "sale" of Personal Information as defined by Applicable State Law;
  • Opt-out of targeted advertising by Us;
  • Opt-out of automated profiling that produces legal or similarly significant effects.

Please note, as explained above, We do not "sell" Personal Information as that term is traditionally defined. However, We do share certain Personal Information with third parties to provide You with personalized advertising and to better understand how users interact with the Site. Through the use of cookies, analytics tools, and advertising technologies, We may make certain Personal Information available to third parties for targeted advertising purposes. You may opt-out from such targeted advertising under Applicable State Law by using any opt-out links or tools provided on the Site, by using browser-based opt-out signals where required (such as Global Privacy Control), or by contacting Us as described in the "Contact Us" section.

Company does not knowingly sell or share the Personal Information of consumers under 16 years of age.

17. Appeals Process & Other Concerns

Certain information may be exempt from the rights described above under applicable law. If we deny your request in whole or in part, you may have the right to appeal the decision. In such circumstances, we will provide you with information regarding the appeals process, including how and where to submit an appeal and the time frame for our response. Depending on your location, you may also email hello@clarosai.co with the subject "Data Privacy Request Appeal" to provide us with details about why you are appealing the decision.

If you have an unresolved privacy or data use concern that we have not addressed to your satisfaction, you may also have the right to lodge a complaint with your local data protection authority, consumer protection agency, or other supervisory authority, as permitted by applicable law.

18. Security

We take a number of steps to protect your data, but no security is guaranteed. Company takes reasonable steps to help protect and secure the information it collects and stores about users. We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information that we receive against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

Among other things, access to customer data is limited to authorized personnel, and we use the security features made available by our service providers, including payment processors, and other vendors. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security of your information.

With respect to Protected Health Information, Company's privacy and security obligations are further governed by any applicable Business Associate Agreement.

19. Cross-Border Data Transfers

Company and its service providers may process and store personal information in the United States and in other jurisdictions. If personal information is transferred across borders, Company will take steps designed to ensure that such transfers are made in accordance with applicable data protection laws.

Where required, Company will implement appropriate safeguards, which may include contractual protections, data processing agreements, or other legally recognized transfer mechanisms, to protect personal information during such transfers.

20. Deleting or Modifying Personal Information

You may cancel your account on the Site, where applicable, and you may opt out of receiving marketing emails from Company at any time by using the unsubscribe links provided in our emails or by contacting us. Additionally, subject to applicable law and our legitimate business and legal obligations, you may request that we delete or modify certain personal information that we maintain about you.

You may request to opt out, or request deletion or modification of your personal information, by contacting us at hello@clarosai.co or by using any additional methods described in this Policy. We may retain certain personal information as required or permitted by law, including for tax, accounting, fraud prevention, and other legitimate business purposes. We encourage you to promptly update your personal information when it changes so that our records remain accurate and complete.

Company retains Personal Information for as long as necessary to fulfill the purposes described in this Policy, including to provide products and services, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods may vary depending on the category of information and applicable law.

Certain information, including recordings, transcripts, backups, logs, and archived materials, may be retained for legal, compliance, security, backup, operational, or dispute-resolution purposes, and certain Customer Data may be retained for a minimum of seven (7) years or longer where permitted or required by law, contract, or Company's retention practices.

To the extent Company processes Protected Health Information on behalf of a covered entity or business associate, retention, deletion, and requests relating to such Protected Health Information are governed by the applicable Business Associate Agreement and applicable law, and such requests should be directed to the applicable healthcare provider or customer except to the extent Company is required by law or contract to assist.

21. Questions or Comments

If you have any questions or comments relating to our website or this privacy policy, or if you would like to exercise your privacy rights, please send an email to hello@clarosai.co.