Privacy Policy

Effective Date: April 11, 2025

Introduction

This Privacy Policy describes how 3NCODE UG ("we", "us", or "our") collects, uses, and protects the information of users ("you") when using the CLARA iOS application ("App"). By using our App, you agree to the practices outlined in this policy.

Explicit Consent

By downloading, installing, and using CLARA, you expressly consent to the collection, use, and disclosure of your information as described in this Privacy Policy. You may withdraw your consent at any time by deleting your account or contacting us directly.

Information We Collect

• User Context Data: Information about family members, interests, and locations you voluntarily provide.
• User Content Data: Chat interactions, images uploaded, and game interactions.
• Analytics Data: Anonymized information about your usage of the App.
• Authentication Data: Username, email address, and encrypted passwords.

How We Use Your Data

• Provide and personalize app services.
• Improve functionality and security.
• Conduct analytics and A/B testing.

Your data is used exclusively for the stated purposes. We do not engage in advertising or automated decision-making.

Data Sharing and Third Parties

We do not share your personal data with third parties except:

• AI service providers (e.g., OpenAI), strictly for generating LLM responses.
• Cloud providers (e.g., Google Firebase and AWS), used for authentication and analytics.

All providers are contractually bound by stringent data privacy obligations.

International Transfers

As an international service provider, your data may be transferred and stored outside your country of residence, including to the EU or the United States, under appropriate safeguards including Standard Contractual Clauses.

Data Security and Retention

Your personal context and content data remain encrypted and stored only locally on your device. Interaction data is temporarily processed through secure connections to provide responses and deleted within 30 days. Analytics data are pseudonymized and retained no longer than 90 days.

We implement industry-standard security measures including AES-256 encryption for stored data, HTTPS/TLS encryption for data in transit, and regular security audits.

Your Rights

• Access, rectify, or delete your data.
• Restrict or object to data processing.
• Withdraw consent anytime.
• Receive a copy of your data.

Requests can be made directly via our contact details provided below.

Governing Law

This Privacy Policy is governed by the laws of Germany and applicable US federal and state laws, including California privacy laws.

Children's Privacy

The App is intended for adults. Users under 18 must have explicit parental consent.

COPPA Compliance

The CLARA app is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we discover we have inadvertently collected data from a child under 13, we will promptly delete it.

Updates

We may update this Privacy Policy periodically and will notify you of significant changes.

How to Contact Us

If you have questions, email us at clara@3ncode.com.

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California Consumer Privacy Act (CCPA) Addendum

Categories of Personal Information Collected

• Identifiers (name, email address, profile context data)
• Customer records (account details)
• Audio, electronic, visual, or similar information (chat content, uploaded images)

Use of Personal Information

Personal information is used for providing and enhancing app services, ensuring security, and performing internal analytics.

Sale of Personal Information

We do not sell your personal information.

Your CCPA Rights

• Request disclosure of the categories and specific pieces of personal information we have collected.
• Request deletion of your personal information.
• Opt-out of any future sale of your personal information (note: we do not sell personal information).

We will not discriminate against you for exercising any of your CCPA rights.

Who We Are

3NCODE UG
An der Lindenhecke 8
30559 Hannover
Germany

Email: clara@3ncode.com

Terms of Use

General Information

These Terms of Use ("Terms") govern the use of the iOS application CLARA ("App"), provided by:

3NCODE UG (limited liability)
An der Lindenhecke 8
30559 Hannover, Germany

(hereinafter referred to as "Provider," "we," "us," or "our").

By registering for and using the App, you ("User," "you," or "your") agree to be bound by these Terms. The App is intended for use by individuals aged 18 or older. Users under 18 must have explicit consent from a parent or legal guardian. We reserve the right to request proof of such consent.

We reserve the right to update and enhance the App, including providing periodic updates.

Description of Services

The CLARA App is a digital assistant specifically designed for individuals experiencing word-finding difficulties. The App provides:

• AI-powered chat functionality generating personalized responses.
• Image upload capabilities with AI-generated descriptions.
• Customizable content based on user-provided context (e.g., family members, interests, and locations).
• Interactive tools to support communication, including engaging activities and games.

The use of the App requires an active internet connection, especially for AI-related functionalities, which rely on connectivity to our servers or those of our service providers.

The App is available strictly for personal, non-commercial use. Commercial use or distribution of App content to third parties is prohibited without explicit prior written permission from the Provider.

We provide the App "as-is" and reserve the right to alter, expand, or discontinue any feature without notice. The App requires an iOS device running at least iOS 18.1.

The App is available as a paid subscription service. Pricing and subscription details are outlined in the section "Pricing and Payment Terms."

Subscription and Account Creation

Use of CLARA requires account registration and a paid subscription, completed through the Apple App Store. By registering, you affirm you are at least 18 years old or have guardian consent. Your contract for paid services becomes active upon completion of registration and subscription purchase within the Apple App Store.

We do not store your contract text. Key contract details are provided within these Terms and the Apple App Store.

Right of Withdrawal

You have the right to withdraw from your subscription under applicable App Store guidelines. However, your right of withdrawal terminates once digital content delivery begins, provided you explicitly consented and acknowledged this forfeiture.

Refunds, if applicable, are governed by Apple's App Store policies.

User Account Responsibilities

Your user account requires a valid email address and secure password or third-party authentication (e.g., Apple ID). You must ensure your account information is accurate, current, and complete.

Your account is personal, non-transferable, and must not be shared. Secure your login details and notify us immediately if unauthorized use is suspected.

We may refuse account creation or suspend/delete existing accounts for reasons including but not limited to inaccurate registration details, misuse, or violation of these Terms.

You may delete your account anytime via App settings or by emailing us directly.

Pricing and Payment Terms

CLARA requires a subscription via the Apple App Store. Current pricing is $4.99 per month (plus applicable taxes). Payments are processed directly by Apple, and subscription management (including cancellations) is handled through Apple's systems.

Subscriptions auto-renew unless canceled at least 24 hours prior to renewal date. Price changes will be communicated in advance; continued use after notification indicates acceptance of new pricing.

We are not responsible for additional fees from Apple, payment providers, or currency conversions.

Subscription Termination

Subscriptions auto-renew monthly unless canceled at least 24 hours before the current subscription period ends. Cancellation must occur via your Apple App Store account settings.

Upon cancellation, paid features remain available until the subscription expires. Refunds are generally not provided except where required by law.

User Obligations

You agree to use the App lawfully, respecting these Terms and applicable laws. Specifically, you must not:

• Use the App for illegal or unauthorized purposes.
• Upload or share content violating laws or third-party rights (e.g., copyrights or privacy).
• Circumvent or manipulate App security features.
• Copy, modify, decompile, or tamper with the App except as expressly permitted by law.
• Share your account details with third parties.

You must safeguard your account credentials and promptly report suspected unauthorized access.

Misuse or violation of these obligations may result in account suspension or termination and further legal action.

Liability and Disclaimer

We are liable under applicable laws for intentional misconduct or gross negligence. For slight negligence, we limit liability to foreseeable damages arising from essential contractual obligations. We assume no liability for losses arising from free features or trial periods unless caused by gross negligence or intentional harm.

Nothing in these Terms excludes our liability for bodily harm, death, or mandatory statutory obligations.

Data Protection

We handle personal data in accordance with our Privacy Policy, available within the App.

Changes to Terms

We reserve the right to update these Terms as necessary, including due to regulatory, technical, or functional changes to the App. Significant changes will be communicated via email or App notifications.

Your continued use after notification constitutes acceptance of revised Terms. If you disagree with changes, you may terminate your subscription.

Applicable Law and Jurisdiction

These Terms are governed by the laws of the State of California, United States, excluding conflict-of-law provisions. Disputes arising from these Terms or App use will be exclusively resolved in competent courts located in California.

These Terms are provided in English, which is the controlling language for all purposes.