Privacy policy for Clario

LG Consult s.r.o.

Company ID: 22655875

Registered office: Havlíčkova 762, 267 51 Zdice, Czech Republic

Contact: info@lg-consult.cz

This privacy policy explains how the Clario mobile application (the “App”) processes users’ personal data.

Protecting personal data is a priority for us. We act in accordance with:

• Regulation (EU) 2016/679 (GDPR)
• the applicable Czech legal regulations
• Apple App Store rules

We do not sell personal data. We do not sell contract content or account data to third parties. For advertising measurement and optimisation we may (where required consent is obtained) share limited technical and event data with Meta, as described below.

Email address is used for registration, sign-in or password recovery, and communication regarding technical support. We do not use email for marketing newsletters without explicit consent.

For technical account processing and data storage we use standard security measures including encrypted data transfer (HTTPS/TLS) between the App and our services.

Account and sign-in

• email address
• data necessary to verify the account and manage access (only to the extent required for the account to function)
• first name / full name, if the user enters it

Data entered into the App (content)

• data related to contracts and their records (for example provider, contract number, dates, payments, categories, additional fields by contract type)
• links to documents (URLs), if the user saves them

App settings

• user preferences within the App (for example language, theme, onboarding)

Notifications (optional)

• if the user enables system notifications: reminder preferences (for example lead time, quiet hours) and notification content only to the extent necessary for reminders to work

Advertising measurement and Meta SDK (when enabled)

• device identifiers and advertising identifiers (for example IDFA on iOS), where the system and user consent allow it
• technical data about the device and app (for example device type, OS version, App version)
• data about interactions with the App and App Events (for example install, app open, completed registration, in-app purchase, and other events needed to measure campaigns)
• information on whether tracking consent was granted or denied (ATT)

We do not send contract content (texts, contract numbers, notes and similar data) to Meta for advertising purposes.

• providing and operating the App, including storing the user’s data
• managing the user account and authentication
• technical support and communication about the account
• reminders via notifications (if enabled)
• ensuring the security and integrity of the service
• measuring installs and the performance of advertising campaigns (including Meta App Events)
• optimising and delivering ads (to the extent permitted by consent and the platforms)

Processing is carried out mainly on the basis of:

• performance of the contract for providing the App service (running the Clario account and features)
• consent, where relevant (for example system permissions for notifications, advertising tracking / ATT, advertising measurement via Meta SDK)
• legitimate interests in the security of operating the service (to the necessary extent)
• compliance with legal obligations, where required by law

You may withdraw advertising tracking consent at any time as described in the advertising and Meta SDK section. Withdrawal does not affect the lawfulness of processing before withdrawal.

Data may be processed by vendors who technically operate the App (hosting, backend, authentication).

Apple may process data to the extent necessary for distribution via the App Store/TestFlight and for system services (for example notifications via APNs), if the user uses them.

For advertising measurement and optimisation we may share data with Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) and related Meta group companies, to the extent of Meta SDK / App Events and the applicable consent settings.

We do not sell personal data. Sharing with Meta happens only for the advertising and measurement purposes described in this policy.

The App may use the Meta SDK (Facebook SDK) for App Events, install measurement and optimisation of advertising campaigns on Meta platforms (for example Facebook, Instagram).

What Meta SDK may process

• in-app events (App Events), for example install, open, registration or purchase
• device identifiers and advertising identifiers (including IDFA), where available and permitted
• technical information about the device and the App
• tracking consent status

ATT consent on iOS

On iOS we request consent through App Tracking Transparency (ATT) when we want to access the advertising identifier for tracking across apps and websites owned by other companies. If you deny tracking, we will not use IDFA for that purpose. Some aggregated or limited measurement may still occur in line with Apple and Meta rules, without access to IDFA.

How to refuse advertising tracking

• iOS: Settings → Privacy & Security → Tracking → turn off permission for Clario, or deny the system ATT prompt
• in device settings you can limit ad personalisation according to Apple system options
• questions or requests to restrict processing of advertising data: info@lg-consult.cz

For more information on how Meta processes data, see Meta’s Data Policy on Meta’s website.

Some providers (including Meta) may process data outside the EU/EEA. Where that happens, transfers are carried out in accordance with the GDPR, typically using standard contractual clauses and other appropriate safeguards.

We retain data for as long as the user account exists. After the account is deleted we erase or anonymise data without undue delay, unless the law requires otherwise.

Data shared with Meta for advertising measurement may be retained by Meta under its own policies and campaign settings. After you delete your Clario account we stop sending new events from the App associated with that account.

You have the right in particular to access, rectification, erasure, restriction of processing, data portability (where applicable under the GDPR), objection where the GDPR allows, withdrawal of consent (for consent-based processing), and to lodge a complaint with the Czech Office for Personal Data Protection.

Requests are handled at info@lg-consult.cz. Instructions for deleting a Clario account are also available on the Clario data deletion page on this website.

The App is not intended for children under 18 without the consent of a legal guardian.

We may update this policy. The current version will be published on the website.

LG Consult s.r.o.

Company ID: 22655875

Registered office: Havlíčkova 762, 267 51 Zdice, Czech Republic

Email: info@lg-consult.cz