Clear Clinics App — Privacy Policy

Clear Clinics Limited ("Clear Clinics", "we", "us", or "our") is committed to protecting your privacy and personal data.

This Privacy Policy explains how we collect, use, store, and protect personal and patient data when you use the Clear Clinics mobile application ("App").

This policy applies only to the Clear Clinics App.

This policy applies to:

• Registered healthcare professionals and contractors using the App
• Authorised practice users
• Patients whose data is processed within the App

For the purposes of data protection law:

• You (or your organisation) are the Data Controller for patient data
• Clear Clinics Limited acts as a Data Processor, unless otherwise agreed in writing

Clear Clinics is the Data Controller for user account and operational data.

4.1 User Information

• Name
• Email address
• Phone number
• Professional role and organisation
• Account credentials (encrypted)
• App usage logs and activity records

4.2 Patient Data (Uploaded by Users)

• Patient name or identifier
• Date of birth or age
• Consent records
• Images and videos captured via endoscope camera
• Clinical notes and treatment records
• Hearing screening results (where applicable)

Clear Clinics does not collect patient data directly — it is uploaded by authorised users.

4.3 Device & Technical Data

• Device type and operating system
• App version
• Crash logs and error diagnostics
• IP address (for security and audit purposes)

We process data under the following lawful bases:

• Contractual necessity — to provide the App
• Legal obligation — compliance with healthcare and data laws
• Legitimate interests — app security, service improvement
• Explicit consent — for patient data processed within the App

Users are responsible for obtaining valid patient consent.

We use data to:

• Provide and operate the App
• Enable secure storage of clinical records
• Support consent capture and audit trails
• Maintain app security and integrity
• Improve functionality and performance
• Provide customer support

We do not sell or monetise personal or patient data.

Clear Clinics implements appropriate technical and organisational safeguards, including:

• Encryption at rest and in transit
• Secure cloud infrastructure
• Role-based access controls
• Audit logging
• Regular security reviews

While we take strong measures, no system can be guaranteed 100% secure.

Data is stored on secure servers located within the UK and/or EEA, unless otherwise required for technical reasons.

Any international transfers comply with UK GDPR safeguards.

• User account data is retained while the account remains active
• Patient data retention is controlled by the user or organisation
• Data may be retained longer where legally required

Users are responsible for ensuring retention aligns with clinical and regulatory obligations.

We may share limited data with:

• Cloud hosting and infrastructure providers
• Analytics and crash-reporting services (non-clinical)
• Regulatory or legal authorities where required by law

All third parties are contractually bound to data protection standards.

We never share patient data for marketing purposes.

You agree that you:

• Obtain valid patient consent
• Upload only data you are authorised to process
• Use the App in compliance with data protection law
• Keep login credentials secure

Under UK GDPR, individuals may have rights including:

• Access to personal data
• Correction of inaccurate data
• Erasure (where applicable)
• Restriction or objection to processing
• Data portability

Requests should be directed to the data controller (you or your organisation). Clear Clinics will assist where required as a data processor.

The App is intended for professional use only.

Where patient data relates to minors, users must ensure:

• Appropriate legal consent is obtained
• Safeguarding obligations are met

The App does not use advertising cookies.

Limited analytics and diagnostics tools may be used to:

• Monitor performance
• Identify bugs or crashes

No patient data is used for analytics.

We may update this Privacy Policy from time to time.

• Material changes will be communicated via the App or email
• Continued use of the App constitutes acceptance

For privacy or data protection queries:

Clear Clinics Limited
📧 admin@clearclinics.co.uk
🌐 www.clearclinics.co.uk