Privacy Policy

1. Introduction

This Privacy Policy explains how Splintara OÜ ("we", "us", "our") collects, uses, stores, and protects personal data when you use Cleare (cleare.app) — an educational entertainment platform ("Service"). We are established in Estonia, a member state of the European Union, and process personal data in compliance with the General Data Protection Regulation (GDPR) (EU) 2016/679.

2. Data We Collect

2.1 Account and Registration Data

• Full name and email address (required for account creation)
• Date, time, and place of birth (used to generate synastry profiles)
• Partner birth details if voluntarily provided

2.2 Payment Data

We do not store payment card numbers or banking details. Payments are processed by a third-party payment processor. We receive only a transaction confirmation and subscription status.

2.3 Usage Data

• Log data: IP address, browser type, pages visited, time and date of access
• Device information: device type, operating system, browser version
• Interaction data: features used, content viewed, preferences saved

2.4 Communication Data

If you contact us via our support form or email, we store your name, email, and the content of your message to enable us to respond.

2.5 Cookies and Tracking

We use cookies and similar technologies. See our Cookie Policy for full details.

3. Legal Basis for Processing

• Contract performance (Art. 6(1)(b) GDPR): processing your account and birth data to provide the Service you subscribed to.
• Legitimate interests (Art. 6(1)(f) GDPR): fraud prevention, security, analytics to improve the Service.
• Consent (Art. 6(1)(a) GDPR): marketing communications and non-essential cookies, where applicable.
• Legal obligation (Art. 6(1)(c) GDPR): compliance with applicable law (e.g., tax records).

4. How We Use Your Data

• Provide, operate, and improve the Service
• Generate your personalised synastry profile and daily content
• Process payments and manage your subscription
• Respond to support requests
• Send transactional emails (e.g., subscription confirmations)
• Send marketing emails (only with your consent; you may unsubscribe at any time)
• Prevent fraud and ensure platform security
• Comply with legal obligations

5. Data Sharing

We do not sell your personal data. We may share data with:

• Payment processors: to handle subscription billing.
• Hosting and infrastructure providers: who store data on servers within the EU/EEA or with adequate safeguards.
• Analytics providers: for anonymised or aggregated usage analysis.
• Legal authorities: if required by law or court order.

All third-party processors are bound by data processing agreements that comply with GDPR requirements.

6. International Transfers

If personal data is transferred outside the EEA, we ensure adequate safeguards are in place — such as Standard Contractual Clauses (SCCs) approved by the European Commission — in accordance with Chapter V of the GDPR.

7. Data Retention

We retain your personal data for as long as your account is active or as required to provide the Service. After account deletion we delete personal data within 30 days, unless we are required to retain it longer by law (e.g., financial records for 7 years per Estonian accounting law).

8. Your Rights (GDPR)

As a data subject under the GDPR, you have the following rights:

• Access (Art. 15): obtain a copy of the personal data we hold about you.
• Rectification (Art. 16): correct inaccurate personal data.
• Erasure (Art. 17): request deletion of your personal data ("right to be forgotten").
• Restriction (Art. 18): restrict how we process your data.
• Portability (Art. 20): receive your data in a structured, machine-readable format.
• Objection (Art. 21): object to processing based on legitimate interests.
• Withdraw consent: if processing is based on consent, you may withdraw it at any time without affecting prior lawful processing.

To exercise any of these rights, contact us at support@cleare.app. We will respond within 30 days. You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee) or the supervisory authority in your country of residence.

9. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, or destruction. These include encrypted connections (HTTPS/TLS), access controls, and regular security reviews.

10. Children

The Service is not directed to persons under 18 years of age. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us immediately at support@cleare.app.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or by posting a notice on the Service. The "Last updated" date at the top will always reflect the most recent revision. Continued use of the Service after changes constitutes acceptance.

12. Contact

For any questions about this Privacy Policy or how we handle your data, contact:
support@cleare.app
Splintara OÜ, Harju maakond, Tallinn, Lasnamäe linnaosa, Peterburi tee 53, 11415, Estonia