withClaro Privacy Notice

Effective date: 13 August 2026

This Privacy Notice explains how we collect, use and share your personal data when you use the withClaro mobile application and withclaro.com (together, the "Service"), and what choices and rights you have. It is issued by Pink Elephant, Unipessoal Lda, the company that operates withClaro.

1. Who we are

withClaro is provided by Pink Elephant, Unipessoal Lda (NIPC 519056582), registered in Portugal, with its registered office at Edifício Amoreiras Square, Rua Carlos Alberto da Mota Pinto, no. 17, second floor, 1070-313 Lisboa, Portugal. We are the "controller" of your personal data under the GDPR.

You can reach us, including with any privacy question or request, at [email protected].

Because we are established in Portugal, the GDPR applies to our processing of your personal data, and our supervisory authority is Portugal's data protection authority, the Comissão Nacional de Proteção de Dados (CNPD).

2. What this notice covers

This Notice covers personal data we process through the withClaro mobile app, and through the tools on withclaro.com that do not require an account.

withClaro is designed for adult users (18 and over) and is a wellness-support tool, not a medical service. It does not diagnose, treat, or provide medical advice, does not replace a doctor or clinician, and is not equipped to respond to a medical or psychiatric emergency. If you are in crisis, please contact your local emergency services or a crisis helpline.

3. Information we collect and how we use it

We collect different categories of personal data depending on which parts of withClaro you use.

Account and authentication

When you create a withClaro account, we collect your email address, authentication details, and sign-in and session information, to set up and secure your account and keep you signed in. This is necessary to provide the Service (Article 6(1)(b) GDPR).

Your profile and wellness journey

Setting up your profile involves your time zone, preferences, and onboarding answers about your health, medication history and mental health, which we need to personalize your wellness journey. Because this is health information, we ask for your explicit, separate consent before these features become available to you (see "Special category data and your consent," below). That consent also covers the check-in, medication and recommendation features described next, which build on the same profile. An avatar or profile photo, if you add one, is optional and based on your consent.

Check-ins, medication and personalized recommendations

As you use withClaro, we process the check-ins, questionnaires, mood and symptom entries, and medication and dosage information you record, to maintain your check-in history, provide medication tracking and reminders, and generate personalized wellness recommendations and schedules based on this information and, if connected, your Apple Health data. This is necessary to provide the features you have chosen to use (Article 6(1)(b) GDPR), building on the consent described above. These recommendations are suggestions only, see "Automated decision-making," below.

Apple Health / HealthKit (optional)

If you choose to connect Apple Health, we read the health categories you authorize, such as activity, sleep, heart rate, mindfulness and, where enabled, assessment scores, to support the wellness features that use this data, and, where you enable it, write selected results back to Apple Health. This exchange happens on your own device under Apple's controls. We only store the resulting record on our servers if syncing it is needed for a feature you have enabled, and we do not keep raw HealthKit samples beyond that sync. This feature is entirely optional and based on your explicit consent.

AI companion and AI safety features (optional)

If you choose to use withClaro's AI companion or other AI-powered features, your messages and relevant context, which may include check-in, medication or HealthKit data needed for that feature, are sent to OpenAI to generate a response. This is optional and based on your explicit consent. AI responses are wellness-support content, not medical advice or a diagnosis.

We also use automated safety checks, including through OpenAI, on chat, check-in and related activity, to help prevent abuse and keep the Service reliable. These checks are necessary to operate the features you use (Article 6(1)(b) GDPR) and do not include crisis or self-harm detection. withClaro is not designed to identify or respond to a crisis.

Notes (optional)

If you create standalone notes, we store their content, which may include health information you choose to include. This feature is optional and based on your explicit consent.

Wellness and doctor reports (optional)

If you request one, we can generate a wellness report from your profile, check-in, medication, HealthKit and AI-companion data, for your own use or to share with a clinician. This is not medical advice or a diagnosis. It is optional and based on your explicit consent, and we do not keep a copy of the report once you have exported or downloaded it.

Notifications

If you turn on notifications, we register your device's notification token and keep the delivery logs needed to send the reminders you have enabled, through Apple's push notification service. Notification content is generic and never includes medication names, symptoms, or other health details. This is necessary to provide the feature you have enabled (Article 6(1)(b) GDPR).

Analytics and product improvement

We collect pseudonymous analytics about how the app and website are used, such as which screens and features you interact with, to understand usage and improve the product, using PostHog for the app, hosted in the EU with screen recording turned off, and Google Tag Manager for the website. This is based on your consent, given through the app or our cookie settings.

Bug reports and diagnostics

When you report a bug, or when the app crashes, we collect the report and related diagnostic and device information to fix the issue and keep the Service stable and secure. We rely on our legitimate interest in keeping withClaro reliable and secure for this (Article 6(1)(f) GDPR). You can object to this at any time. See "Your rights" below.

Billing and payment

If you subscribe to a paid feature, we process your subscription status and transaction records to administer billing and to meet our tax and accounting obligations. We do not store your full card details ourselves. RevenueCat and the Apple App Store handle that directly.

Research program (optional)

If you separately opt in, we remove your name and account identifiers from agreed wellness data and assign it a distinct research pseudonym, which we use to compile comparative statistics about the withClaro program and, once fully anonymized, may publish. This is entirely optional, separate from using the core app, and is never used to make a decision about you individually. You can opt out at any time, which stops any new data being added.

Public website tools

withclaro.com also offers several tools that do not require a withClaro account, each based on your consent to use it. None of them require an account, and each is illustrative or educational only, not medical advice.

• Taper calculator - generates an illustrative dose-reduction schedule from the medication, dose and preferences you enter. This information stays in your browser and the page URL unless you ask us to email you the full protocol, in which case we also collect your email address.
• Withdrawal symptom checker - gives an illustrative common-versus-red-flag classification of the symptoms you report.
• "Ask a Psychiatrist" - lets you submit a tapering-related question and your email address, which a reviewing psychiatrist answers by email for educational purposes. This is not a doctor-patient relationship, and email is not a secure channel.
• Helpline finder - helps you locate crisis and mental-health helplines by country and topic.
• Healthcare-professional access - professionals can apply for free access by providing their name, contact details and profession, which we use to verify the application and issue an access code.

4. Special category data and your consent

Much of what withClaro processes is special category data under Article 9 GDPR, which receives extra protection under data protection law. We only process it with your explicit consent under Article 9(2)(a) GDPR.

We ask for this consent once, when you set up your profile and wellness journey, and it covers the core features built around it: check-ins, medication tracking and recommendations. For features that are separately optional such as Apple Health, the AI companion, notes, wellness reports, the research program, and the public website tools, we ask for your specific consent before turning each one on individually.

You can withdraw your consent at any time (see "Your rights" below). Withdrawing consent to one feature will not affect the rest of the Service but will mean that specific feature is no longer available to you.

5. Automated decision-making

withClaro does not make any decision about you using a fully automated process that has a legal or similarly significant effect on you. The personalized recommendations and AI companion responses are wellness-support suggestions, and our automated safety checks are internal classifications. None of them determine your access to the Service or any other significant outcome, and none of them are designed to detect or respond to a crisis.

6. Who we share your information with

We share personal data only with our own staff who need it to do their jobs, and with the service providers below, each of which is only permitted to use your data to provide their service to us, under a data processing agreement.

• OpenAI Ireland Ltd powers our AI companion, AI-powered features and safety checks, and, where used, report generation. This may involve processing outside the EU/EEA, under the safeguards in our agreement with OpenAI.
• PostHog Cloud provides our in-app analytics and is hosted in the EU. This data does not leave the EU/EEA.
• Klaviyo delivers account emails and, where relevant, taper protocols and Ask a Psychiatrist responses, and may involve processing outside the EU/EEA.
• DigitalOcean hosts our backend database and storage, within the EU/EEA.
• Google provides Google sign-in and website analytics (Google Tag Manager), which may involve processing outside the EU/EEA.
• Apple provides Apple sign-in and push-notification delivery, which may involve processing outside the EU/EEA. Notification content itself is generic and excludes health details.
• RevenueCat and the Apple App Store handle card payments directly and do not pass full card details to us.

Where any of the above involves sending data outside the EU/EEA, we rely on an appropriate safeguard under the GDPR, such as the European Commission's Standard Contractual Clauses or an adequacy decision. You can ask us for details of the specific safeguard that applies at [email protected].

We may also disclose personal data where required by law, to protect our rights, or as part of a merger, acquisition or sale of assets, in which case we will notify you of any change this brings.

7. How long we keep your information

We keep personal data only as long as we need it for the purposes described in this Notice.

Most account and activity data, i.e., your profile, check-ins, medication records, recommendations, AI companion history, notes and reports, is kept for as long as your account is active, and deleted within 30 days of a confirmed deletion request. A few things are kept for shorter, specific periods: session and login logs for 12 months; OTP codes are invalidated as soon as they are used; recommendation and AI-safety metadata for 90 days; notification delivery logs for 90 days; and analytics data for 24 months, after which it is deleted or fully anonymized. Bug and crash reports are kept for 12 months.

Billing records are kept for 7 years to meet our tax and accounting obligations under Portuguese law, and other subscription information for the life of your account plus 30 days.

8. Data security

We use encryption in transit (TLS 1.2 or higher) and at rest (AES-256) to protect withClaro's systems and data, store your authentication tokens securely on your device, and back up our database daily. No system is completely secure and we cannot guarantee absolute security, but we work to protect your information appropriately.

9. Your rights

Subject to the conditions in the GDPR, you have the right to:

• access the personal data we hold about you;
• correct inaccurate data;
• delete your data;
• restrict or object to certain processing;
• receive your data in a portable format, where applicable; and
• withdraw consent at any time, without affecting anything we did before you withdrew it.

If we process your data based on our legitimate interest (this applies only to bug reports and diagnostics, described above) you can object to that processing at any time on grounds relating to your situation, and we will stop unless we have compelling grounds to continue or need the data for legal claims.

To exercise any of these rights, contact us at [email protected]. We may need to verify your identity first, and we will respond within one month, extendable by two months for complex requests, in which case we will let you know within the first month.

You also have the right to complain to the CNPD, Portugal's data protection authority (www.cnpd.pt), or to the supervisory authority where you live or work.

10. Children

withClaro is intended for adults (18 and over) and is not directed at children. We do not knowingly collect personal data from children. If you believe a child has given us personal data, please contact us at [email protected] so we can take appropriate action.

11. Cookies

Our website uses cookies and similar technologies, including for the website analytics described above. Our separate Cookie Policy explains what we use, why, and how you can manage your preferences.

12. Changes to this notice

We may update this Notice from time to time. If we make a material change, we will let you know in an appropriate way, and we will always update the effective date above.

13. Contact us

If you have any questions about this Notice or how we handle your personal data, contact us at [email protected], or by post at Pink Elephant, Unipessoal Lda, Edifício Amoreiras Square, Rua Carlos Alberto da Mota Pinto, no. 17, second floor, 1070-313 Lisboa, Portugal.