ClariTrack Privacy Policy

1. Scope and Eligibility

This Privacy Policy applies to:

• visitors to claritrack.app;
• people who join the ClariTrack waitlist;
• registered users of the mobile application;
• Early Access and beta participants;
• people who contact customer support or otherwise communicate with us; and
• users of related ClariTrack features that link to this Privacy Policy.

The Services are intended only for individuals who are 18 years of age or older. People under 18 may not register for or use the Services.

ClariTrack is a health and wellness tracking service. It is not a medical device and does not provide medical advice or diagnose, treat, cure, prevent, monitor, or predict any medical condition. Information about health-related processing appears below because the Services allow users to record sensitive Health and Wellness Data.

2. Definitions

For this Privacy Policy:

• Account Data means information used to create, authenticate, administer, or secure a ClariTrack account.
• Application means the ClariTrack mobile application.
• Health and Wellness Data means health-related, lifestyle, and self-tracking information that a user chooses to enter or generate through the Services.
• Personal Data or Personal Information means information relating to an identified or reasonably identifiable person. The terms are used interchangeably unless a particular law uses a specific term.
• Processing means any operation performed on Personal Data, such as collecting, storing, using, analysing, transmitting, disclosing, or deleting it.
• Service Provider means a third party that processes Personal Data for us or provides infrastructure or functionality used by the Services.
• Usage Data means technical and activity information generated when a person interacts with the Services.
• Website means https://claritrack.app (https://claritrack.app).

Health and Wellness Data may be treated as sensitive personal data, special-category data, consumer health data, or sensitive personal information under applicable law.

3. Personal Data We Collect

We collect only the categories reasonably needed for the purposes described below. The exact information depends on how you interact with the Services and which features you use.

3.1 Account and profile information

When you create or manage an account, we may collect:

• first and last name;
• email address;
• account and user identifiers;
• authentication information, such as hashed credentials or tokens;
• profile information and preferences;
• condition or tracking-focus selections, including fibroids, Polyendocrine Metabolic Ovarian Syndrome (PMOS), or another concern selected by you;
• notification and communication preferences; and
• account creation, login, verification, and security records.

If you use Google Sign-In or Sign in with Apple, we receive only the information made available through the authorisation you approve, typically an account identifier, name, and email address. We do not receive your Google or Apple password. We do not request your social-media contacts, private messages, or general account activity through these sign-in services.

3.2 Health and Wellness Data

When you use the tracking features, you may choose to record:

• symptoms and symptom severity;
• menstrual or cycle information;
• condition selections and health-related tracking preferences;
• meals, individual foods, drinks, snacks, water, and herbal teas;
• medications and supplements;
• mood, energy, sleep, movement, exercise, and routines;
• quick check-in responses;
• personal notes and other information entered in free-text fields;
• dates, times, frequency, and changes associated with entries;
• saved or reused tracking items; and
• information included in summaries, charts, alerts, insights, Pattern Discovery Reports, Doctor Prep materials, and other reports generated from your entries.

You decide what to enter. Do not enter another person’s Personal Data unless you are legally authorised to do so and have obtained any required permission.

We use Health and Wellness Data to provide the tracking features you request, organise your records, generate summaries and reports, and surface possible associations or changes in your entries. These outputs do not establish medical causation and are not medical advice.

3.3 Waitlist information

When you join the Website waitlist, we may collect:

• name;
• email address; and
• the date, source, and status of your waitlist submission and communication preferences.

Waitlist information is maintained separately from Health and Wellness Data. Do not submit symptoms, diagnoses, medications, or other health information through the waitlist form.

We use waitlist information to confirm your submission, send launch and Early Access updates, and manage the waitlist. Joining the waitlist does not create an Application account or a paid subscription.

3.4 Usage, device, and diagnostic information

When you access the Services, we and our Service Providers may automatically receive:

• IP address;
• browser type and version;
• device type, operating system, and application version;
• language, time zone, and general location inferred from IP address;
• pages, screens, features, buttons, and links used;
• date, time, duration, and referring page information;
• unique application, installation, session, or device identifiers where used;
• crash reports, error logs, performance information, and diagnostic data; and
• security and fraud-prevention events.

We do not collect precise GPS location unless we introduce a feature that clearly requests it and obtain any permission required by law and the operating system.

3.5 Communications and support information

If you contact us, we collect the information contained in your message, your contact details, attachments you choose to send, and records of our response. Do not send unnecessary Health and Wellness Data through ordinary email because email may not be an appropriate channel for sensitive information.

3.6 Cookies and similar technologies

The Website may use cookies, local storage, pixels, or similar technologies for purposes such as:

• keeping the Website and account features secure;
• maintaining sessions and remembering preferences;
• recording cookie choices;
• understanding Website performance and usage; and
• supporting delivery and management of service or waitlist emails.

Necessary technologies operate because they are required to provide requested features or secure the Services. Where applicable law requires consent for analytics, marketing, or other non-essential technologies, we will request consent before activating them. You can adjust available cookie controls, browser settings, or email-client settings. Blocking necessary technologies may prevent parts of the Services from functioning.

Our current policy does not permit the use of Health and Wellness Data for cross-context behavioural advertising.

3.7 Information we do not currently collect

Unless you voluntarily include it in a support communication or free-text entry, ClariTrack does not currently request:

• a telephone number for account creation or marketing;
• SMS or text-message consent;
• government identification numbers;
• contact lists or address books;
• precise GPS location;
• biometric identifiers used to identify you; or
• payment-card information.

The Services do not currently provide public user profiles, community posts, or social feeds through which your private health entries are made visible to other users.

4. How We Use Personal Data

We use Personal Data for the following purposes:

4.1 Providing the Services

• creating, authenticating, and administering accounts;
• storing and displaying entries and preferences;
• enabling quick check-ins, history, saved items, and tracking tools;
• generating requested insights, observations, alerts, summaries, charts, and reports;
• enabling downloads, exports, and user-directed sharing;
• providing Early Access and beta features; and
• responding to support requests.

4.2 Safety, security, and integrity

• authenticating users and securing accounts;
• detecting, investigating, and preventing fraud, abuse, security incidents, and unlawful activity;
• diagnosing errors and maintaining availability;
• enforcing our Terms and protecting users, the Services, and our rights; and
• maintaining records needed to demonstrate consent and compliance.

4.3 Communications

• sending security, account, service, legal, and administrative notices;
• confirming waitlist or account activity;
• sending launch, Early Access, product, or marketing communications where permitted; and
• recording and honouring communication preferences and unsubscribe requests.

We do not currently collect phone numbers or send marketing SMS messages.

4.4 Analytics and improvement

• understanding feature usage and Website performance;
• investigating crashes, errors, and user experience problems;
• evaluating and improving the Services; and
• creating aggregated or de-identified statistics that do not reasonably identify an individual.

We do not use Health and Wellness Data to target third-party advertising. We will not use identifiable Health and Wellness Data to train a general-purpose AI model without providing additional notice and obtaining any consent required by law.

4.5 Legal and business purposes

• complying with legal obligations and valid governmental requests;
• establishing, exercising, or defending legal claims;
• conducting audits, risk assessments, and corporate transactions; and
• protecting vital interests where permitted by law.

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5. Legal Bases for Processing

The legal basis depends on the information, purpose, feature, and law that applies.

Where the European Union General Data Protection Regulation (GDPR), UK GDPR, Nigeria Data Protection Act 2023 (NDPA), or another law requiring a legal basis applies, we rely on one or more of the following:

• Contract: processing needed to create your account and provide features you request under our Terms and Conditions.
• Consent: processing based on your freely given permission, including marketing or non-essential cookies where consent is required.
• Explicit consent for sensitive data: where required, we rely on your explicit consent to process Health and Wellness Data. ClariTrack presents core Health and Wellness Data processing separately from optional AI-assisted processing. The consent choices are unticked by default, recorded with a timestamp and policy or consent-text version, and may be withdrawn. Under the GDPR and UK GDPR, this includes Article 9(2)(a) in addition to an Article 6 basis.
• Legitimate interests: securing, maintaining, analysing, and improving the Services; preventing fraud and abuse; sending non-marketing service communications; enforcing our agreements; and managing business operations, after balancing those interests against your rights.
• Legal obligation: complying with laws, court orders, accounting requirements, and valid regulatory requests.
• Vital interests: protecting someone’s life or physical safety where the law permits and the person cannot provide consent.

You may withdraw consent at any time. Withdrawal does not affect processing already lawfully completed. Withdrawing optional AI consent stops future AI processing while allowing basic manual tracking to remain available. Withdrawing consent for core Health and Wellness Data processing prevents ClariTrack from continuing to provide features that require that data and may require deletion of the related data, subject to your choices and applicable law.

We do not rely on a medical-care or public-health legal basis to present ClariTrack as a healthcare provider. ClariTrack is not a healthcare professional or medical service.

6. AI-Assisted Processing

ClariTrack uses artificial intelligence to help organise and analyse information users choose to record and to generate requested insights, observations, summaries, alerts, and Pattern Discovery Reports.

Our current AI Service Provider is:

• Anthropic — Anthropic Privacy Policy (https://www.anthropic.com/legal/privacy)

AI-assisted features remain disabled unless you separately grant optional AI-processing consent. After consent is granted, we may transmit relevant Health and Wellness Data, instructions, and contextual information needed to generate the requested output. We seek to limit the information sent to what is reasonably necessary for the feature. Direct account identifiers are not intentionally included when they are not needed for the request.

Anthropic processes this information for us under the applicable service arrangements. We do not authorise Anthropic to use identifiable ClariTrack Health and Wellness Data for unrelated advertising. Any provider use for model training or other independent purposes must be consistent with our agreement, this Privacy Policy, and applicable law.

You may withdraw AI-processing consent through the Application’s Privacy and Data controls. Withdrawal stops future Anthropic requests and disables AI insights, AI trigger alerts, AI-generated summaries, and AI-generated Pattern Discovery Reports. Basic manual tracking remains available where core Health and Wellness Data consent remains active.

AI outputs can be inaccurate, incomplete, or misleading. They do not establish causation and are not medical advice, diagnosis, treatment, or emergency guidance. ClariTrack does not make solely automated decisions that produce legal or similarly significant effects concerning users.

7. When and With Whom We Disclose Personal Data

We do not sell Personal Data. We do not share Personal Data for cross-context behavioural advertising as those terms are defined by California law.

We may disclose Personal Data in the following circumstances.

7.1 Service Providers

Service Providers process information only for the services they provide to us, subject to contractual or other applicable safeguards. Current providers may include:

• Lovable, for application platform and Website-related services — Privacy Policy (https://lovable.dev/privacy);
• Supabase, including database, authentication, storage, and backend infrastructure hosted through Lovable Cloud in the Asia-Pacific region in Singapore — Privacy Policy (https://supabase.com/privacy);
• Anthropic, for AI-assisted features — Privacy Policy (https://www.anthropic.com/legal/privacy);
• Google, for Google Sign-In, Android distribution or testing, and related services — Privacy Policy (https://policies.google.com/privacy);
• Apple, for Sign in with Apple, TestFlight, iOS distribution or testing, and related services — Privacy Policy (https://www.apple.com/legal/privacy/); and

The information disclosed to each provider depends on the feature used. TestFlight and Google Play testing may independently collect device, account, diagnostic, and distribution information under Apple’s or Google’s own terms and privacy practices.

7.2 Your instructions and sharing choices

We disclose information when you direct us to export, download, email, print, or otherwise share a report or record. Once information leaves ClariTrack at your direction, the recipient or third-party service may process it under its own terms and privacy policy.

7.3 Legal, safety, and compliance disclosures

We may disclose information where reasonably necessary to:

• comply with applicable law, legal process, or a valid request from a competent authority;
• investigate or prevent fraud, abuse, security incidents, or unlawful activity;
• protect the rights, property, safety, or security of users, the public, the Company, or the Services;
• enforce our agreements; or
• establish, exercise, or defend legal claims.

We assess legal requests and disclose only information reasonably necessary where permitted to do so.

7.4 Corporate transactions

Personal Data may be disclosed in connection with a proposed or completed merger, financing, reorganisation, acquisition, insolvency, or sale of all or part of the business. Where required, we will provide notice before Personal Data becomes subject to a materially different privacy policy.

7.5 Affiliates and professional advisers

We may disclose information to controlled affiliates and professional advisers such as lawyers, auditors, accountants, insurers, or security consultants where reasonably necessary and subject to confidentiality and legal obligations.

8. International Data Transfers

Sapphire Mace Limited is registered in Nigeria. ClariTrack’s primary database and backend infrastructure are currently hosted in Singapore through Supabase and Lovable Cloud. Some Service Providers operate or process information in the United States and other countries.

Accordingly, Personal Data, including Health and Wellness Data where necessary for a requested feature, may be processed outside the country where you live. Privacy laws in those countries may differ from those in your jurisdiction.

Where applicable law restricts an international transfer, we use an available lawful transfer mechanism, which may include:

• an adequacy decision;
• contractual safeguards such as the European Commission’s Standard Contractual Clauses;
• the UK International Data Transfer Agreement or UK Addendum;
• contractual and organisational safeguards required under the NDPA;
• consent where legally valid and appropriate; and
• supplementary technical and organisational measures based on the transfer risk.

Those measures may include data minimisation, encryption in transit, access controls, contractual restrictions, vendor review, and separation of direct identifiers where appropriate. You may contact privacy@claritrack.app for more information about an applicable transfer mechanism, subject to appropriate redaction of confidential terms.

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9. Data Retention

We retain Personal Data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including providing the Services, maintaining security, complying with law, resolving disputes, and enforcing agreements.

Our general retention approach is:

• Account Data: while the account remains active and for a limited period after closure where needed for security, fraud prevention, support, legal claims, or compliance.
• Health and Wellness Data: while your account is active or until you delete the data or account, subject to limited infrastructure-log, backup, security, and legal-retention exceptions.
• Waitlist and marketing information: until you unsubscribe, withdraw consent, the waitlist purpose ends, or the information is no longer needed. We may retain a minimal suppression record to honour an unsubscribe request.
• Support communications: generally for up to 24 months after the matter is closed, unless a longer period is needed for a legal claim, security investigation, or legal obligation.
• Usage and diagnostic data: generally for up to 24 months, although shorter or longer periods may apply depending on security, aggregation, provider configuration, and legal requirements.
• Consent and legal records: for as long as needed to demonstrate compliance, resolve disputes, or meet limitation and recordkeeping periods.
• Future transaction records: if paid services are introduced, transaction, invoice, tax, and accounting records will be retained for the period required by applicable law. We do not currently collect payment-card information.

When you complete the in-app account-deletion process, ClariTrack immediately and permanently deletes the user-scoped records in its active application database and then deletes the authentication user record. If any required deletion step fails, the request returns an error instead of intentionally completing only part of the deletion. Standard infrastructure, security, and diagnostic logs may remain for the limited period set by the relevant provider’s retention schedule. Protected platform backups, if applicable, are not used for ordinary business purposes and age out under the provider’s backup-retention process.

We may retain aggregated or de-identified information that can no longer reasonably identify you. We will not attempt to re-identify properly de-identified information except to test whether de-identification controls are effective or where otherwise permitted by law.

10. Account Deletion and Privacy Requests

You may permanently request deletion of your account and associated Personal Data, including Health and Wellness Data, by:

• using Profile → Delete account within the Application, then confirming the request by typing DELETE; or
• emailing privacy@claritrack.app from the email address associated with your account if you cannot access the Application.

Deletion is permanent and may prevent recovery of entries, reports, and other account information. Export information you wish to keep before deleting your account.

The in-app deletion function verifies your authenticated session so that users can delete only their own accounts. It deletes user-scoped records from the active application database, deletes the authentication record, signs you out, and returns you to the welcome screen. If you submit an email request because you cannot access the Application, we may take reasonable steps to verify your identity and authority and will process the verified request within the period required by applicable law.

Deleting your account does not delete copies you previously exported or shared with another person or third-party service.

At the date of this Privacy Policy, ClariTrack has no paid subscriptions. If app-store subscriptions are introduced later, deleting a ClariTrack account may not cancel the subscription; cancellation would also need to be completed through the applicable Application Store.

11. Security

We use reasonable administrative, technical, and organisational safeguards designed to protect Personal Data, taking account of its sensitivity and the nature of the Services. Current measures include:

• Row Level Security policies restricting user-table operations to the authenticated user’s own records;
• platform-level JWT verification and server-side session and authorisation validation for protected backend functions;
• HTTPS/TLS encryption in transit;
• platform encryption for database storage and backups at rest;
• provider and infrastructure security controls;
• logging, monitoring, and incident investigation;
• data minimisation and restricted access;
• backup and recovery measures; and
• policies and procedures for handling Personal Data.

No internet transmission or electronic storage system is completely secure. We cannot guarantee absolute security. You are responsible for protecting your device, login methods, and account access. Notify us promptly at privacy@claritrack.app if you suspect unauthorised access to your account or Personal Data.

12. Marketing and Communication Choices

We may send waitlist, launch, Early Access, or product communications where permitted by law. Where consent is required, we send marketing only after obtaining that consent.

You may opt out of optional marketing by using the unsubscribe link in an email or contacting privacy@claritrack.app. Opting out of marketing does not prevent necessary account, security, legal, or service communications.

You may unsubscribe from optional marketing using the link provided in an applicable email or by contacting us.

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13. Future Payments

All ClariTrack plans are currently free during Early Access. We do not currently collect payment-card information or process paid ClariTrack subscriptions.

If paid services are introduced, we will update this Privacy Policy and provide relevant notice before payment processing begins. Payments may be processed by Apple, Google, Stripe, or another disclosed payment provider. Payment-card details would be provided directly to the payment provider and would not ordinarily be stored by ClariTrack. The provider’s privacy policy would govern its independent processing.

We will not use the introduction of future payments as a reason to use Health and Wellness Data for advertising or unrelated profiling.

14. Your Privacy Rights and Choices

Depending on where you live and the law that applies, you may have rights to:

• receive information about our processing;
• access Personal Data we hold about you;
• correct inaccurate or incomplete Personal Data;
• delete Personal Data;
• restrict or object to certain processing;
• withdraw consent;
• receive certain Personal Data in a portable format;
• opt out of direct marketing;
• opt out of the sale or legally defined sharing of Personal Data;
• limit certain uses of sensitive Personal Data;
• appeal or challenge a refusal where applicable; and
• complain to a privacy or data-protection authority.

To exercise a right, email privacy@claritrack.app and describe your request. We may request information reasonably necessary to verify your identity, protect your account, and confirm an authorised representative’s authority.

We will respond within the period required by applicable law. For example, GDPR and UK GDPR requests are generally answered within one month, subject to a permitted extension, and verified California requests are generally answered within 45 days, subject to a permitted extension. We will not discriminate against you for exercising a privacy right.

Some rights are subject to exceptions. If we deny or limit a request, we will explain the reason where required and provide information about any available appeal or complaint mechanism.

15. Nigeria Privacy Rights

Sapphire Mace Limited is subject to the Nigeria Data Protection Act 2023 and applicable guidance issued by the Nigeria Data Protection Commission (NDPC).

Where the NDPA applies, you may have rights including access, correction, deletion, objection, restriction, withdrawal of consent, data portability, and protection from certain solely automated decisions. Health and Wellness Data is sensitive personal data and is processed only where an applicable condition for sensitive processing is satisfied, including explicit consent where appropriate.

You may submit a request to privacy@claritrack.app. You may also lodge a complaint with the NDPC. Information about the NDPC is available at https://ndpc.gov.ng (https://ndpc.gov.ng).

We use appropriate safeguards for international transfers as required by the NDPA. Depending on the scale and nature of ClariTrack’s processing, Sapphire Mace Limited may also be required to complete regulatory registration, impact assessments, audit filings, or Data Protection Officer arrangements. Those organisational obligations are addressed through our compliance programme and do not limit your rights under this Privacy Policy.

16. Japan Privacy Rights

Where Japan’s Act on the Protection of Personal Information (APPI) applies, you may request notification of the purpose of use, disclosure of retained personal data or certain third-party transfer records, correction, addition, deletion, suspension of use, erasure, or suspension of third-party provision, subject to the conditions and exceptions in the APPI.

You may submit an APPI request to privacy@claritrack.app. Information about Japan’s Personal Information Protection Commission (PPC) is available at https://www.ppc.go.jp/en/ (https://www.ppc.go.jp/en/).

We take reasonable steps to understand and supervise the foreign environments in which Personal Data is processed, as required by applicable APPI cross-border and security-control rules.

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17. European Economic Area and United Kingdom

Where the GDPR or UK GDPR applies, Sapphire Mace Limited is the controller of the Personal Data described in this Privacy Policy.

In addition to the rights listed in Section 14, you may have the right to object to processing based on legitimate interests and an absolute right to object to direct marketing. The right to data portability applies to certain automated processing based on consent or contract.

Health and Wellness Data is special-category data. Where required, we ask for explicit consent before processing it for the relevant tracking and AI-assisted features. You may withdraw that consent, but doing so may prevent us from providing features that require the data.

ClariTrack does not use solely automated processing to make decisions producing legal or similarly significant effects concerning you.

You may complain to the data-protection authority in the EEA country where you live or work or where you believe an infringement occurred. In the United Kingdom, you may complain to the Information Commissioner’s Office at https://ico.org.uk (https://ico.org.uk).

If applicable law requires Sapphire Mace Limited to appoint an EU representative, UK representative, or Data Protection Officer, the relevant contact information will be published in this Privacy Policy before the affected processing or market availability requires it.

18. California Privacy Notice

This section applies to California residents to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), applies to ClariTrack’s processing.

18.1 Categories collected

During the preceding 12 months, we may have collected the following statutory categories:

• Identifiers: name, email address, account identifiers, IP address, and authentication identifiers.
• California Customer Records information: name and health or medical information entered by the user.
• Protected-classification information: health or medical-condition selections, sex-related or menstrual information, and age-related eligibility information where provided or reasonably implied by user entries.
• Internet or network activity: interactions with the Website or Application, logs, device information, and diagnostics.
• Geolocation: general location inferred from IP address; we do not currently request a location through the waitlist or collect precise GPS location.
• Inferences: AI-assisted observations, patterns, or preferences derived from information a user asks ClariTrack to analyse.
• Sensitive Personal Information: account login information and Health and Wellness Data.

ClariTrack does not currently collect payment-card details, biometric identifiers used for identification, professional or employment records, or non-public education records through its ordinary features.

We collect these categories from you, your device or browser, Google or Apple when you use social sign-in, and Service Providers supporting the Services.

18.2 Purposes and recipients

We use these categories for the business purposes described in Sections 4 and 6. We disclose them for business purposes to the categories of recipients described in Section 7, including hosting, authentication, AI, email, testing, security, and professional-service providers. Health and Wellness Data may be disclosed to Supabase and Lovable for infrastructure and to Anthropic when needed to provide an AI-assisted feature requested by the user.

18.3 No sale or sharing

We have not sold Personal Information or shared it for cross-context behavioural advertising in the preceding 12 months. We do not knowingly sell or share the Personal Information of anyone under 16. Because the Services are restricted to adults, people under 18 may not use them.

If our practices change, we will provide required notice and opt-out methods and will recognise legally required opt-out preference signals, such as Global Privacy Control, where applicable.

18.4 Sensitive Personal Information

We use sensitive Personal Information to provide and secure the Services, including the tracking, insights, and reports requested by the user. We do not use sensitive Personal Information to infer characteristics for unrelated advertising or other purposes that would require a separate right to limit under the CCPA/CPRA without providing that right.

18.5 California requests

Subject to applicable law, California residents may request access to categories and specific pieces of Personal Information, correction, deletion, portability, information about sources, purposes and recipients, and opt-out or limitation rights where applicable.

Email privacy@claritrack.app to submit a request. We may verify your identity and an authorised agent’s authority as permitted by law. We generally acknowledge verified requests within 10 business days and respond within 45 calendar days, subject to a permitted extension.

California’s “Shine the Light” law may allow eligible residents to request information about disclosure for third parties’ own direct-marketing purposes. We do not disclose Personal Information to third parties for their own direct marketing.

The Services do not currently respond to the legacy browser “Do Not Track” signal. This does not affect legally recognised opt-out preference signals where applicable.

19. Children’s Privacy

The Services are intended solely for adults aged 18 or older. We do not knowingly collect Personal Data from anyone under 18.

If you believe a person under 18 has provided Personal Data, contact privacy@claritrack.app. We will investigate and take reasonable steps to delete the information and deactivate any associated account where appropriate.

We do not sell or share Personal Data of minors for behavioural advertising.

20. Third-Party Links and Services

The Services may link to third-party websites or services that we do not operate. Their privacy practices are governed by their own policies. Review those policies before providing Personal Data. We are not responsible for an independent third party’s privacy practices, except to the extent applicable law provides otherwise.

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21. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to the Services, providers, laws, or processing practices. We will post the revised policy and change the “Last updated” date.

Where required by law or where a change materially affects your rights or the processing of sensitive information, we will provide additional notice and obtain new consent where necessary. We will not use a policy update alone to obtain permission for a materially incompatible new use of Health and Wellness Data.

22. Contact Us

For privacy questions, requests, complaints, or concerns, contact:

Sapphire Mace Limited

Operator of ClariTrack

14, Jimoh Ibrahim, Gbagada

Lagos 100234, Nigeria

Email: privacy@claritrack.app

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