Privacy Policy

1. Definitions

• Account means a unique account created to access the Service.
• Application means Clarté, the software provided by the Company.
• Company (also “we”, “our”) means Lorelingo, a French SAS (985 186 907 R.C.S. Paris), with its registered office at 78 Avenue des Champs-Élysées, Bureau 326, 75008 Paris, France.
• Country means France.
• Device means any equipment that can access the Service (smartphone, tablet, computer).
• Personal Data means any information relating to an identified or identifiable natural person, within the meaning of article 4(1) of the GDPR.
• Service means the Clarté application and the clarteapp.com website.
• Processor means a third-party provider that processes personal data on our behalf.
• Usage Data means data collected automatically when using the Service.

2. Information we collect

Personal data

When creating your account or using Clarté, we may ask you for:

• Your email address
• Your first name (optional)

Usage data

Some data is collected automatically when using the Service, in particular:

• Your device’s IP address
• Device type and operating system version
• Pages and features visited within the app
• Date and time of your visits
• Time spent on screens
• Device identifiers and diagnostic data

This data is collected via the following analytics services:

• Sentry (Functional Software, Inc.) — used to diagnose technical errors and ensure app stability.
• Statsig (Statsig, Inc.) — used to measure feature usage, run product (A/B) tests, and improve the app.
• Google Analytics (Google LLC) — used on clarteapp.com to analyze traffic.

User content

Clarté records the data you create in the app: your audio recordings, their transcripts, and the generated analyses. Audio recordings are sent to the OpenAI API for automatic transcription (audio → text), then stored encrypted in Supabase Storage so you can listen back to them. The transcripts and analyses are linked to your account and used only to provide and improve the Service.

Third-party authentication

You can sign in to Clarté using email and an OTP code. No third-party authentication (Google, Apple, etc.) is used at this time.

3. Use of your information

We use your personal data for the following purposes:

• Provide and maintain the Service, including usage and performance monitoring.
• Manage your account, including sign-up and access to features.
• Handle subscriptions, including purchases and payments.
• Contact you about updates, notifications, and Service-related information.
• Provide personalized analyses, via our AI models (Structure/Clarity/Impact scores, rephrasings, suggestions).
• Improve the Service, through usage analysis and the development of new features.
• Respond to your requests and provide customer support.

4. Legal basis for processing

Under article 6 of the GDPR, we process your personal data on the following legal bases:

Where we rely on legitimate interest, our interest is to understand how users interact with the Service in order to improve how it works. You may object to such processing at any time (see section 10).

5. Sharing of your information

We do not sell your personal data. We may share your information with the following processors and in the circumstances described below:

Processors

Other circumstances

• Legal obligations: we may disclose your information if required by law or in response to a valid judicial request.
• Protection of rights and safety: we may share information to protect the rights, property, or safety of the Company, its users, or a third party.
• With your consent: we may share your information for any other purpose with your explicit consent.

6. International transfers

Your personal data may be transferred to and processed in the United States by the processors listed in section 5. These transfers are governed by:

• The EU-U.S. Data Privacy Framework (DPF): for certified providers (OpenAI), recognized by the European Commission as offering an adequate level of protection.
• Standard Contractual Clauses (SCCs): for other providers, in accordance with the standard clauses adopted by the European Commission.

You may request a copy of these safeguards by contacting us (see section 14).

7. Tracking technologies

Mobile app

• Sentry SDK: collects anonymized error logs and technical context. Does not use cookies.
• Statsig SDK: logs pseudonymized usage events and evaluates feature flags. Does not use cookies.
• RevenueCat SDK: communicates with Apple or Google to verify your subscription status. No payment data is collected by Clarté.

Website (clarteapp.com)

• Google Analytics: uses cookies to analyze traffic. You can opt out via the Google Analytics Opt-out or by adjusting your browser settings.

8. Data retention

We retain your personal data only for as long as necessary for the purposes described. In particular:

• Account deletion: when you request deletion of your account from the app, it is scheduled with a grace period of 14 days. During this period, you can cancel the request by signing back in; once the period has elapsed, your account and all associated data (audio, transcripts, analyses, email, first name) are irreversibly deleted.
• User content (audio, transcripts, analyses): retained as long as your account is active, then deleted at the end of the 14-day grace period.
• Account data (email, first name): deleted at the end of the same 14-day grace period.
• Analytics data: retained in identifiable form for up to 24 months, then anonymized or deleted.
• OpenAI processing: OpenAI does not retain any data from our API requests. The audio and text transmitted are not stored by OpenAI.
• Invoices and accounting records: retained for up to 10 years after the transaction, in accordance with the French Commercial Code (art. L123-22).

9. Data security

The security of your personal data matters to us. We implement reasonable measures: encryption in transit (HTTPS/TLS), encryption at rest (Supabase Storage), access control (Row Level Security), and OTP authentication. However, no storage or transmission system is 100 % secure.

10. Your rights

Under the GDPR, you have the following rights:

• Access — obtain confirmation that your data is being processed and receive a copy.
• Rectification — request the correction of inaccurate or incomplete data.
• Erasure — request the deletion of your data (“right to be forgotten”).
• Restriction — object to certain forms of processing.
• Portability — receive your data in a structured, machine-readable format.
• Objection — object to processing based on legitimate interest or for marketing purposes.
• Withdrawal of consent at any time, without retroactive effect on processing already carried out.

You can exercise these rights from the app settings or by contacting us (see section 14). We respond within 30 days.

Right to lodge a complaint: if you believe that the processing of your data infringes the GDPR, you may lodge a complaint with the:

Commission Nationale de l’Informatique et des Libertés (CNIL) — the French data protection authority
3 Place de Fontenoy, TSA 80715
75334 Paris Cedex 07, France
Website: www.cnil.fr

11. AI and automated processing

Clarté uses artificial intelligence to deliver its core features:

• Automatic audio transcription
• Speech analysis (structure, clarity, impact)
• Rephrasing suggestions and areas for improvement
• Generation of personalized follow-up topics

This processing is carried out by the OpenAI API on our behalf. The following safeguards apply:

• No automated decisions with legal effect: we do not use AI to make decisions producing legal effects concerning you (art. 22 of the GDPR).
• No training on your data: your content is not used to train any AI model — neither by Lorelingo nor by OpenAI. The OpenAI API operates under a zero-retention policy for our usage.
• Accuracy of AI content: generated analyses may contain inaccuracies. They are provided as a tool to support your growth, not as absolute truth.

AI transparency (EU Regulation 2024/1689): we inform you that the features above are generated by AI. Clarté uses general-purpose AI models provided by OpenAI. You retain the right to review, edit, or delete any generated content.

Report AI content: every analysis includes a “Report” button that lets you flag inappropriate, inaccurate, or problematic content. Reports reach us immediately and are processed to improve the quality of the AI and to filter out unsuitable content.

12. Protection of minors

Clarté is not intended for children. We do not knowingly collect personal data from anyone under 15 (the digital age of consent in France, art. 7-1 of the French Data Protection Act). Users between 15 and 18 must use the app under the supervision of a parent or legal guardian (see our Terms of Service).

If we become aware that we have collected personal data from a child under 15, we will take steps to delete it promptly. If you are a parent or guardian, please do not hesitate to contact us.

13. Changes to this policy

We may update this privacy policy from time to time. Any changes will be posted on this page with a new last-updated date. For significant changes, we will notify you by email or through the app.

14. Contact us

For any question relating to this policy or to exercise your rights:

• Online: via our contact page or from the app settings.
• By mail: Lorelingo — Data Protection, 78 Avenue des Champs-Élysées, Bureau 326, 75008 Paris, France.