Welcome to Clenz

Nelsonin Research LLC. built the Clenz. app as a Premium app. This SERVICE is provided by Nelsonin Research LLC. and is intended for use as is.

This Privacy Policy explains how Nelsonin Research LLC and its affiliated entities (“Clenz” or “we” or “us”) complies with the provisions of the General Data Protection Regulation (“GDPR”) and any other applicable data protection laws and regulations. This Privacy Policy explains how Clenz collects, stores, uses, transfers, and shares personal data from our users (“you”) in connection with the Clenz mobile application, Clenz Routine Tracker application (the “App”),* and the clenz.ai website, including all subdomains, products, and services related to it (the “Website”) (all collectively, the “Services”).

We may change this Privacy Policy from time to time. If the changes are material, we will notify you by email or through the App. If permitted by law, your continued use of the Services after this policy has been updated indicates your acceptance of changes made. In some cases, you will be given a choice to accept changes to this policy. If you do not accept the terms of the updated Privacy Policy, please do not use the Services.

The latest updates to this policy are available on our Website and in the App.

Information we collect from you

For a better experience, while using our Service, we may require you to provide us with certain personally identifiable information, including but not limited to Name and e-mail. The information that is requested will be retained on your device and is not collected by us in any way.

The app does use third-party services that may collect information used to identify you.

Personal data you provide to us directly:

General Information:

When you sign up to use the Services, we may collect personal data such as your name, email address, year and month of birth, password, place of residence, and location information including time zone and language. We may be able to infer your sex and/or gender by your use of the Services.

You may also choose to input information such as your first name or the name you would like us to call you. This is led by you and it will not affect your use of the Services should you choose not to enter this information.

Well-being & Personal Care Routine Information:

When you use the Services, you can choose to input personal data about yourself, such as your skin condition; routines you follow; height; weight; body mass index (BMI); body temperature; menstrual cycle dates; general well-being and health; symptoms, which may include information relating to your daily life; or other information, like your physical and mental well-being, water intake, and sleep duration.

Personal data we collect automatically:

When you access or use the Services, we may automatically collect the following information:

Device information:

Device model; information about the operating system and its version; unique device identifiers; enabled device accessibility features (e.g., display features, hearing features, and physical and motor features); mobile operator and network information; device storage information or version of your device system.

Location information:

IP address for an approximate location (not precise location); time zone or information about your mobile service provider.

Data about your use of the Services, including:

Frequency of use; areas and features of the Services that you access or use; payment transaction information (excluding full payment card details) or engagement with particular features.

To collect this and other information, we may use cookies and other similar technologies. See more in our Cookie Policy.

Data from external sources:

We may receive personal data about you from third parties. For example, we may obtain information from third parties to enhance or supplement your existing information, including to customize your experience and for statistical purposes and analytics.

How do we intend to use your personal data

Depending on which features of the Services you use, we will process your personal data based on one or more of the following legal bases (we have included some examples):

Your consent:

You can give us permission to process your skin & health data to provide the Services.

To fulfill our contractual obligations to you in order to provide the Services to you:

We may process your personal data to fulfill our contractual obligation to you for activities such as management of your Clenz account and other administrative purposes.

Legitimate interest:

We may process your personal data based on our legitimate interests in order to manage our Services better. For example, we may use your personal data in order to:

• Identify and fix bugs;
• Determine genuine user interaction with the Services (rather than bots);
• Monitor the App and analyze its performance and reliability;
• Inform you of matters concerning your subscriptions;
• Conduct vulnerability scanning to protect the security of the Services; and
• Review aggregated App usage trends.

Further examples of our legitimate interests are outlined in the table below. When relying on this legal basis, we first determine that we have a legitimate interest in conducting and managing our business. We then consider and balance potential impacts to you and your rights, to ensure that our interests do not override them.

Legal obligation:

We may be obligated to process some of your personal data to comply with applicable laws and regulations.

Data minimization and purpose limitation:

We will not process personal data in a way that is incompatible with the purposes for which it has been collected or authorized by you or collect any personal data that is not needed for the mentioned purposes.

No sale of personal data:

We will not sell or rent your personal data for monetary gain. We will not disclose your personal data except as otherwise described in this Privacy Policy. We will share your personal data with our service providers who support our Services as described in this Privacy Policy. We will also not use information received through your use of any third-party service providers for advertising or similar services, or sell it to advertising platforms, data brokers, or information resellers.

Privacy Rights

It does not matter what country, state, or region you come from; we are committed to providing you with individual privacy rights in accordance with the GDPR in relation to your personal data.

• Only you or a person legally authorized to act on your behalf may make a verifiable request related to your personal data. We reserve the right to perform reasonable checks to confirm a person’s authorization.
• If you believe that your personal data is inaccurate, you have the right to contact us and ask us to correct such personal data.
• You have the right to request that the processing of your personal data be restricted in some circumstances. For example, you have the right to request the restriction of your personal data if you contest the accuracy of your personal data and we need some time to verify such accuracy.
• You have the right to request information about what personal data we process about you, to access all your personal data, and to receive a copy of it, including a structured and portable form (.json).
• You have the right to request your personal data in a portable form which enables you to, for instance, reuse your data for your individual purposes or different services. In other words, it may allow you to move, copy or transfer personal data from Clenz in a safe and secure way.
• You have the right to request that we erase your personal data at any time. Please be aware that erasing some personal data may affect your experience using certain features of the Services, and other statistics.

Retention of personal data

Except as set forth below, we will retain your personal data for as long as needed to provide you with the Services or otherwise fulfill the purposes for which it was collected.

Impact of account deactivation/requests to erase personal data:

At any time, you can deactivate your account by following the steps detailed above at ‘How to exercise your privacy rights’. We will address your deletion request within one-month after receipt. It will take us up to 60 days in some cases to complete full erasure of your personal data stored in our backup systems. If you choose to deactivate your account, Clenz will generally delete all your personal data after a 30-day period of time, and it will not be recoverable should you later create another account.

Impact of App deletion or inactivity:

If you choose to delete the App from your device or your account becomes inactive, we will retain your personal data for a period of 30 days in case you decide to reactivate the Services or reinstall the App. After 30 days of inactivity, we will delete your personal information. While this is the Clenz data retention standard, you can still ask for your data to be deleted at an earlier date by contacting us.

Limitations:

You should be aware that although we will delete, anonymize, or otherwise de-identify your data where possible, we may retain certain personal data and other information after your account has been terminated or deleted. This is as required and permitted by applicable law, like the GDPR, and will include the following circumstances:

• As necessary to comply with legal obligations;
• Establishment, exercise, or defense of legal claims; and
• For archiving purposes in the public interest, scientific or historical research, or statistical purposes.

Security Measures

We implement technical and organizational measures in an effort to protect personal data from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the nature of the personal data that we process and risks associated with special categories of personal data we collect. This includes:

• Encryption of your personal data in transit and in rest;
• Systematic vulnerability scanning and penetration testing;
• Protection of data integrity;
• Organizational and legal measures: For example, our employees have different levels of access to your personal data and only access your personal data for limited and necessary purposes required for the operation of the Services. We impose strict responsibility on our employees for any disclosure, unauthorized access, alteration, destruction, or misuse of your personal data; and
• Conducting periodical data protection impact assessments in order to ensure that the Services fully adhere to the principles of privacy by design, privacy by default, and others. We also commit to undertaking a privacy audit in the event of Clenz’s merger or takeover.

Please protect your password. Do not share it with others or allow anyone to use your mobile device. You may also wish to add a passcode or enable face ID to access the App for an added layer of protection.

No security system is perfect. Therefore, we cannot guarantee the absolute security of the Services or that your information will not be intercepted while being transmitted to us.

If we learn of a security systems breach, we may either post a notice or attempt to notify you by email and will take reasonable steps to remedy the breach as specified in applicable law and this Privacy Policy. If we learn of a potential personal data breach, together with other actions referred to in the Privacy Policy, we will take actions to remedy the breach as appropriate under the circumstances, which may include logging you out from all the devices, resetting a password (sending a temporary password for you to apply), and performing other reasonably necessary activities.

If you want to report a security incident related to the Services, please email us at support@clenz.ai

Children's policy

General age limitation: The Services are not intended for children, and we do not knowingly collect personal information from children under 16 years old through the Services. If you are aware of anyone under 16 years old using the Services, please email us at support@clenz.ai and we will take the required steps to delete such information and/or delete the child’s account.

Some App functions are only available to users over the age of 18 years.

Contact Us

If you have any questions or concerns about your privacy, you may contact us or our data protection officer by writing to us at:

Nelsonin Research LLC, # 20136, 5900 Balcones Drive, Austin, Texas - 78731, US

Or by emailing us at support@clenz.ai