Privacy Policy

1. How it works

• When you tap “Try now” before joining a video session, you give explicit consent for transcription.
  
• The encrypted audio stream is sent to Azure OpenAI Whisper running in EU data centres for speech‑to‑text.
  
• The text is summarised by an EU‑hosted instance of Azure OpenAI to create bullet‑point insights (“Session Notes”).
  
• Your therapist then reviews the draft and can edit or approve it before it becomes visible in both your profiles.

2. Human review & quality controls

We apply prompt testing, regression testing and continuous user‑feedback monitoring to catch mistakes.

3. Storage & deletion

• Raw video is never stored.
  
• Transcripts are retained for 30 days and then deleted automatically.
  
• Session Notes live in our encrypted EU data‑centre and stay until you delete them or 5 years after your last session, whichever comes first.

4. Opt‑out

Disable the feature any time under Profile privacy settings. Future sessions will not be transcribed; you can also delete existing transcripts and notes.

5. No model‑training use

 Transcripts and summaries are not reused to train any model.

6. Automated decision‑making

AI Session Notes are informational only and do not make clinical or legal decisions about you.

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4. Cookies

We set only essential cookies until you choose otherwise. View the full list and durations in our Cookie Policy. You can change preferences anytime through the banner or browser settings.

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5. International transfers

All personal data are stored and processed within the European Economic Area (EEA). We do not transfer your personal data outside the EEA.

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6. Security measures

We apply industry‑standard controls including TLS 1.3 in transit, AES‑256 encryption at rest, role‑based access, MFA for staff log‑ins, and tamper‑proof audit logs. Security is audited at least annually.

If a personal‑data breach occurs, the DPO (dpo@clearly.help) will notify the Agencia Española de Protección de Datos (AEPD) within 72 hours and affected users without undue delay.

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7. Who receives your data

Therapists on Clearly – Processors acting under our Data‑Processing Addendum; access limited to sessions you book.

Azure Whisper & GPT (EU) – Sub‑processors for transcription & summarisation; SCCs applied.

Cloud hosting (EU) – Infrastructure provider; ISO 27001, encryption at rest.

Payment processor (Stripe Payments Europe Ltd.)  – Handles card data; PCI‑DSS Level 1.

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8. Your rights

You may access, correct, erase, restrict, object, withdraw consent, or export (port) your personal data at any time. Email dpo@clearly.help or use in‑app tools. 

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9. Children

Our services target users 14 years and older. We do not knowingly process data of children under 14 without verified parental consent.

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10. Changes

Material changes will be announced by email and a banner 15 days before they take effect. Check “Last updated” at the top for the current version.

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11. Contact

General privacy queries – dpo@clearly.help
DPO – dpo@clearly.helpPostal: Therapy Space Inc., 8 The Green St., Suite #13997, Dover, DE 19901, USA