CLĀR

The short version. If you never give us an email address, nothing you type into the consultation ever reaches us — it stays in your browser. If you do give us an email, your answers and your daily logs are backed up to your account so you can pick up on another device. Your photographs never leave your phone under any circumstances. We do not sell anything to anyone, we run no advertising trackers, and we take no commission on any medicine.

Who we are

CLĀR is operated by Andrew Gray, a sole trader trading as CLĀR ("we", "us"). We are the data controller for the information described here.

14/13 Hawkhill Close
Edinburgh
EH7 6AL
United Kingdom

For any privacy question, or to exercise any of your rights, email [email protected].

What CLĀR does

CLĀR asks about your skin and your general health, and uses your answers together with the NICE guideline on acne vulgaris (NG198) to tell you which first-line treatment your answers point at and how to ask your GP for it. It then runs a twelve-week tracker alongside that treatment. We are not a healthcare provider, we do not diagnose, and we do not prescribe or supply medicine. What CLĀR is for and what it cannot do is set out in full in our Terms of Sale and Use.

What we collect, where it lives, and why

Data	Where it lives	Why
Your consultation answers — age band, where you have acne, how severe, how long, what you have tried, relevant health and medication information, distress rating, nation	Your browser. Also our servers, but only once you give us an email address	To work out which treatment the guideline points at for you, and to show you why
Your daily logs — spot counts, which steps you completed, dates, and how you rated the outcome	Your browser. Also our servers once you have an account	To run the twelve weeks and to settle the guarantee if you claim it
Your progress photographs	Your device only. Never uploaded, never backed up, never transmitted	So you can compare your own week one against your week twelve
Your email address, and a password if you set one	Our servers. Passwords are stored only as a slow one-way hash — we cannot read yours	So you can get your account back on a new device
Your payment — name, email, card	Stripe. We never see or store your card number; we can see your email and the last four digits	To take the £79 and to issue a refund if you ask for one
Anonymous usage counts — that a consultation was started, finished, or paid for, tagged with a random identifier that is not linked to your name, email or answers. If you arrived from one of our advertisements, the campaign tag in that link is recorded too, so we can tell which advertisement brought people who found CLĀR useful	Our servers	To see which parts of CLĀR work and which lose people
Your checkout reference, and a count of how many devices it has been used on	Our servers	To match payments to unlocks, and to spot a purchase being shared
Anything you type into a feedback or waiting-list form	Netlify Forms	To answer you and to fix what you tell us is wrong

Your photographs

If you take progress photographs, they are saved into your browser's own private storage on the device that took them. They are never uploaded to us, never included in any backup, never used to train any model, and never seen by any person other than you. We could not produce your photographs if we were asked to, because we have never had them.

The practical consequence is that they do not follow you to a new device, and clearing your browser data deletes them. That is the trade we have chosen deliberately.

Health data

Your answers about your skin, your medication, your mental health and your photographs are special category health data under UK GDPR, which carries extra protection.

We process it on the basis of your explicit consent, given when you choose to answer. You can withdraw that consent at any time — email us and we will delete your account and everything in it, or simply clear the app's data on your device if you never created an account.

Our legal bases

Explicit consent — for your health information, and for backing it up to an account when you give us an email address.
Contract — to deliver the twelve-week programme you have paid for, and to run your account.
Legitimate interests — for anonymous usage counts, and for checking that a purchase is not being shared. We keep those unlinked to your identity, which is what makes the balance fair.
Legal obligation — we have to keep records of payments for tax purposes.

What we never do

We never sell your data, and we never share it with advertisers
We run no advertising pixels, no third-party analytics and no cross-site trackers
We do not track your location
We do not upload your photographs anywhere
We do not require an account — the free consultation works without giving us anything
We do not sell medicine and take no commission on any treatment we name

What CLĀR stores on your device

CLĀR stores information in your browser rather than on our servers wherever it can. That falls into two groups:

Necessary for the service you asked for — your answers, your result, your daily logs, your photographs, whether you have paid, and your sign-in token if you have an account. Without these CLĀR cannot work at all.
Usage measurement — a random identifier used to count how many people get through each step, and, if you arrived from an advertisement, which one. It is first-party and it is never shared with the advertising platform or anyone else. We measure our own advertising; we do not let advertisers measure you. Nothing here is used to target you, follow you to other sites, or build a profile — there is no advertising pixel on CLĀR, by choice. You can stop it by clearing the app’s data or by using private browsing.

We do not use cookies for advertising, and no third party sets anything through CLĀR.

Who else touches your data

Only the infrastructure that makes CLĀR work, each acting on our instructions:

Netlify — hosting, our account storage, and form submissions.
Stripe — payment processing. Stripe is the controller of your card data in its own right and has its own privacy policy.

Both process some data outside the United Kingdom. Where that happens, transfers are covered by UK adequacy regulations or the UK International Data Transfer Addendum. CLĀR loads its typeface from Google Fonts, which means your browser makes a request to Google carrying your IP address; nothing else is sent.

How long we keep it

On your device — until you delete it, clear your browser data, or uninstall.
Your account — while it exists. We delete it, and everything in it, within 30 days of you asking.
Payment records — six years, because HMRC requires it. This is the one thing we cannot delete on request.
Anonymous usage counts — up to 24 months.

Security

Data on your device is protected by your own device and browser. Data in transit is encrypted with TLS. Account records are stored under a key derived from your email address and are reachable only with your sign-in token. Passwords, where set, are stored as a PBKDF2 hash with 150,000 iterations and a unique salt, so we cannot recover yours and neither could anyone who obtained the file.

No system is completely secure. We reduce the risk mainly by collecting as little as possible and by keeping the most sensitive thing you have — your photographs — off our servers entirely.

Your rights

Under UK GDPR and the Data Protection Act 2018 you have the right to access your data, have it corrected, have it erased, restrict or object to its processing, withdraw consent, and receive a portable copy. Because most of your data sits in your own browser, you already hold it directly.

For anything on our servers, email [email protected] and we will respond within one month.

If you think we have handled your data improperly you can complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113. You can complain to them without contacting us first, though we would rather have the chance to fix it.

Age

The free consultation is open to anyone and will tell some people that CLĀR is not right for them. You must be 18 or over to buy. We do not knowingly hold data from anyone under 13. If you believe a child has given us personal data, contact us and we will delete it.

Changes to this policy

We may update this policy. The date at the top shows when it last changed, and we will tell you in the app before any material change takes effect.