Handling personal data

Clear.bio processes your personal data carefully and in accordance with the law. We would like to provide the following information about this. The person responsible for the processing of personal data is Clear Health B.V., established in Amsterdam and registered in the trade register with number 87729563 in Amsterdam. Clear Health B.V. is a subsidiary of holding company Clear B.V. (registered in the trade register with number 75846136, located in Amsterdam). Clear Health B.V. uses the trade name “Clear.bio”.

Last update: 12 July 2023

Your privacy

At Clear.bio we take your privacy seriously – we believe that your data is yours and you should have full control and visibility over it at all times. We will never sell your data to third parties. All personal data remains within Clear.bio and is stored encrypted in Amazon Web Services (AWS).

Below we describe our procedures to guarantee your privacy for our website, (web) application and treatments (‘services’). If you have any questions about this privacy policy, please contact us at: privacy@clear.bio.

Clear.bio complies with the General Data Protection Regulation (GDPR) and has appointed a Data Protection Officer (DPO) and Security Officer. Also, a Quality Manager has been appointed. You can reach them as follows:

Data Protection Officer: privacy@clear.bio

Security Officer: securityofficer@clear.bio

Quality: quality@clear.bio

At all times you have the right to access, correct, erase or restrict your information. If necessary, please contact the DPO via the above e-mail address.

Purpose and legal basis for our processing

Clear.bio processes personal data in the context of its services to enable participation in a Clear.bio treatment, as well as for communication and invoicing. In addition, Clear.bio processes personal data in the context of its business operations, including recruiting and selecting personnel, processing administration, managing ICT systems, compliance with legal obligations, archiving and handling requests, complaints and disputes. It also processes personal data for marketing and communication purposes, including managing this website and sending email newsletters. Legal bases for the processing are entering into and executing agreements that Clear.bio concludes with you and complying with legal obligations. Clear.bio asks for your explicit written permission for the processing of personal data with regard to health (such as medical history, blood values and medication use). You can withdraw your consent at any time. Clear.bio also asks for your permission to send the email newsletter, send app access by email and/or any events and place cookies. You can withdraw your consent at any time.

In addition, your data may be used for scientific purposes. The aim is to study the impact of the use of Clear.bio treatments on health. There is no risk to your privacy, as information security is in accordance with GDPR regulations. When analyzing this data, only anonymized data will be used.

What personal data and origin we collect and process

Information collected automatically

We automatically collect technical information and information about your visit to our website to understand how people access our information (services) and to improve it over time.

Technical information includes data such as IP addresses, domain names, your browser type and version, time zone setting, the country from which you visit us, files requested, types and versions of browser plug-ins, operating system and platform.

Information about your visit may include the full URL clickstream to, through and from our website (including date and time), length of visits to certain pages and app screens, page and app interaction information (such as scrolling, clicks, mouse-overs) or how to exit the page or app. We keep this information anonymous to protect your privacy. We use analytics partners (such as Google Analytics) to help analyze usage and traffic on the website.

Read our Cookie Policy for more information.

If you sign up for the newsletter

Clear.bio processes your first name and email address to send the newsletter. Clear.bio obtains your personal data because you disclose it to it yourself. We keep your data until you unsubscribe from the newsletter and can use this data for a personal follow-up by email. We never share your data with third parties.

When you sign up for the waiting list

Clear.bio processes your first name and contact details so that we can email or call you. We also store medical data and health insurance data that you enter yourself in the waiting list form. Clear.bio obtains your personal data because you disclose it to it yourself. We never share your data with third parties.

If you become a participant

Clear.bio processes your name and address and contact details so that we can register you for the application, send you associated information and send you the start kit. When registering via insurance, we also process citizen service number (‘BSN’) and insurance policy number. In some cases, we will contact your primary care provider (GP/internist) to discuss your health insofar as it relates to your possible participation in a Clear.bio treatment. When registering for a treatment, we will also automatically register you for the newsletter. We keep your data until you unsubscribe from the newsletter and can use this data for a personal follow-up by email.

By participating, you provide personal and health data in our application: date of birth, gender, surname, duration of diabetes, weight, height. We use this data to provide you with our services, such as personalized nutritional information based on analysis of the data you provide.

During participation, we process your blood sugar data. Only employees within the dietician and support team have access to this data. This data is generated by the Sensor (separate terms apply when using the FreeStyle LibreLink app) and is automatically forwarded to Clear.bio via a third party (Vital). With this data processor, as with any partner, we have a signed processing agreement. After participating you can disconnect the connection for the blood sugar data. Your logged meals, activities (including exercise), drinks, supplements are logged by you in the Clear.bio application and are also visible to employees within the dietician and support team. Files are created in our Electronic Patient File (EPD). We use this data to provide you with our services, such as personalized nutritional information based on analysis of the data you provide.

Communication between the user and Clear.bio mainly takes place via chat. We use Intercom technology.  Only employees within the dietician and support team have access to this data.

After completion of a treatment, we store your data digitally for another 20 years in accordance with the legal retention period for medical records. We do not store other data for longer than is necessary to comply with legal requirements. We periodically assess whether there is a valid reason for storing data. If this is missing, our retention obligation ends and we destroy the data.

Your biomedical data will be anonymized and aggregated and used in reports with the aim of providing insight into the effectiveness of our treatment. Data is also used pseudonymously for the purpose of maintaining and developing algorithms and conducting scientific research.

We will keep your contact details for the purpose of informing you about any developments within Clear.bio outside the newsletters. If you do not appreciate this, you can unsubscribe via your contact person within Clear.bio or by sending an email to privacy@clear.bio.

If you install the Clear.bio app

Installing the Clear.bio app is required to participate in the treatment. Access is only possible if Clear.bio has been prescribed or purchased. We use a database and CRM system with the aim of tracking your treatment and making all information visible in the application.

If you apply for a job at Clear

Clear.bio collects and processes data from applicants directly or by means of forms and/or attached resumes via the Homerun tool. Clear.bio also collects and processes data from applicants through personal contacts, telephone conversations and/or email. Some examples of applicant data are: contact details of the applicant (such as name, address), education of the applicant (such as education, courses) employment history (such as former employers, references).

Clear.bio stores applicant data during the recruitment and selection process. Pursuant to the General Data Protection Regulation (GDPR), we remove applicant data and all identified characteristics from its database, no later than 4 weeks after terminating and/or completing the application procedure. If this term is deviated from, for example if we may have a suitable other position in the future, this will be discussed with the applicant. We keep your data for one year in consultation.

No third parties for healthcare data

We do not share your personal information and will never share it with third parties. Your personal data, including glucose sensor data, nutritional and physical activity data, and any relevant medical information you have chosen to share with us, always remains within Clear.bio and is stored encrypted on Amazon Web Services (AWS).

Technical data and data about your visit to our website and the use of our app may be shared with our analytics partners to help analyze and improve the use of our services, as described above.

Transfer of personal data outside the European Union

In principle, your personal data will not be transferred by Clear.bio to countries outside the European Union. Clear.bio engages ActiveCampaign as the processor for taking care of mailings. ActiveCampaign is based in the United States. For more information about the processing of personal data by ActiveCampaign, we refer you to the privacy policy of ActiveCampaign. Clear.bio uses the CRM system Airtable as a processor for the processing of (special) personal data. Airtable is located in the United States, but the data stored by Clear.bio is stored on a European server (located in Ireland). For more information about the processing of personal data by Airtable, please refer to Airtable’s privacy policy. Clear.bio uses the chat system Intercom as a processor to process chats. Intercom is located in the United States, but Clear.bio is in the process of saving the stored data on a European server (located in Ireland).

Links to other websites

Our website contains links to other websites. On websites over which we have no control, we cannot be held responsible for the protection and privacy of any information you provide while visiting those sites.

Disclaimer

The conditions of this disclaimer apply to the website www.clear.bio, whose domain name is held by the company Clear Health B.V. with limited liability under Dutch law, registered with the Chamber of Commerce under number 75846136. Clear Health B.V. trades under the name Clear.bio.

The following terms and conditions apply to this website (www.clear.bio). By viewing this site and using the information provided on it, you agree to these terms and conditions:

• The information on this website is intended for general information. This information is subject to change without further notice. Clear.bio has exercised due care in compiling and maintaining the website, making use of sources that are considered reliable. However, Clear.bio does not guarantee the correctness, completeness and topicality of the information provided. Clear.bio assumes no obligation and expressly disclaims any liability in this regard. You cannot derive any rights from the information provided. Clear.bio also does not guarantee that the Clear.bio website will function without error or interruption.
• On www.clear.bio reference is made, whether or not by means of hyperlinks, to information provided by third parties. Such information has not been further assessed by Clear.bio for reasonableness, correctness, completeness or topicality. Clear.bio expressly disclaims any liability in this regard.
• The information provided is not intended to be a substitute for expert medical advice. If you use the information provided without verification or further advice, you do so at your own expense and risk. The information available on this website is therefore purely intended as information for people with type 2 diabetes who want to participate in the Clear.bio treatments. It is emphatically not intended as a guideline for making diagnoses. The information is also not intended as a guideline to start, change or end treatments. Diagnoses should always be made by your doctor and treatment of any condition should always be guided by your doctor. Clear.bio is not set up as an online consultation service. We will not answer specific questions about type 2 diabetes or the treatment prescribed for you. You will need to make an appointment with your GP or specialist for this.
• The results of the treatment are based on the results of 215 participants after three months.
• Clear.bio, respectively the owner, retains all rights (including copyrights) with regard to the information presented on www.clear.bio. The contents of www.clear.bio may not be published in whole or in part on any other website or in any other type of media, without the explicit permission of the rightholder.
• The personal use of printouts of the information texts is encouraged. Physicians are also allowed to provide printouts of the information texts to patients. The source of the information, in this case www.clear.bio, must then be displayed.
• The exclusions and limitations of liability also benefit directors and employees of www.clear.bio.
• Dutch law applies to www.clear.bio and to this Privacy Statement and Disclaimer.

Email disclaimer

An email message from Clear.bio is intended solely for the addressee(s). Use of this information by anyone other than the addressee is prohibited. Disclosure, duplication, distribution and/or provision of this information to third parties is not permitted. Clear.bio does not guarantee the correct and/or complete receipt of the content of this email message, nor for the timely receipt. Non-business views, opinions, opinions and expressions contained in this email are solely those of the author of this message and are not attributable to Clear.bio. We draw your attention to the fact that the confidentiality and integrity of information sent by email is not guaranteed. It is possible that email messages have been viewed or modified by third parties. If you have accidentally received this email message, please contact the sender of this message at Clear.bio. We recommend that you always use up-to-date anti-virus software.

Disclaimer FreeStyle Libre

Clear.bio uses Abbott’s FreeStyle Libre flash glucose monitoring system (FSL). The FreeStyle Libre is a medical device and is registered as such by Abbott. The Clear.bio treatment, as a non-medical application, is not included in this registration. Abbott assumes no liability for the safety, longevity and performance of this unregistered application. Clear.bio results should not take the place of your doctor’s advice. For professional medical assistance, please contact your doctor.

Coordinated Vulnerability Disclosure

At Clear.bio we work hard to maintain and improve the security of our (medical) devices, systems and services. No matter how much effort we put into system security, there might be vulnerabilities present. If you discover a vulnerability you can report it safely via our Coordinated Vulnerability Disclosure, so Clear.bio can take safety measures.

Reporting a vulnerability

If you have found a vulnerability, we would like to hear about it so that we can take appropriate measures as quickly as possible. Clear.bio is keen to cooperate with you to protect our clients and systems better.
Read here more about reporting a vulnerability.

Copyright

All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or made public in any form or by any means, electronic, mechanical, by printouts, copies, or by any other means, without the prior written permission of the publisher.

Contact

Suggestions for improving the website can be sent to Clear.bio by email (info@clear.bio).