Fertility, Genetic & Wearables · Period & fertility tracking app · Structural / no discrete incident
Clue (BioWink GmbH)
Headline
Clue says the cycle and symptom data you log is never sold or given to advertisers, but its own policy describes two exceptions to watch…
Not independently verified. Verification status: Unverified - heuristic first draft. Publish state: draft unverified.
Clue says the cycle and symptom data you log is never sold or given to advertisers, but its own policy describes two exceptions to watch: a messaging vendor (Braze) processes some tracked health data in pseudonymized form, and ordinary app events (installs, subscriptions, device advertising IDs) go to ad networks including Meta and TikTok. No breach or regulator action was found this pass. Because Clue is a German company storing data on EU servers, U.S. users get German law and Berlin courts, not U.S. arbitration.
- Severity
- Evidence tierUnassigned
- Claims confirmed
- Last verified2026-10-16
Primary source. helloclue.com/privacy — Unverified - heuristic first draft.
Terms
Arbitration
No arbitration clause and no class action waiver in the Terms. German law governs (Sec. 11.3); disputes go to Berlin courts to the extent permitted by law (Sec. 11.4). BioWink states it is 'neither obliged nor willing' to take part in consumer arbitration-body proceedings (Sec. 11.5). U.S. Supplemental Notice not reviewed.
Data sharing
Health data: policy says it is never sold or shared with advertisers (Secs. 3.6, 3.8, 7). Non-health data: app events, ad IDs and IP addresses shared with ad networks (Meta, TikTok) via Adjust (Sec. 3.7); on iOS with activity tracking on, device IDs and usage data go to advertisers (Sec. 3.8). Service-provider exception: Braze processes 'certain tracked health data' pseudonymized (Sec. 3.1.1). De-identified health data shared with research partners only after opt-in (Secs. 3.3-3.4). AI features process health data only if the user turns them on (Sec. 3.1.7). Data stored on EU servers (Sec. 2).
Fees and billing
Clue Plus subscriptions auto-renew indefinitely until cancelled; cancellation needs at least 24 hours' notice before the end of the subscription month (Terms Secs. 6.5, 10.2). App Store / Google Play subscriptions must be cancelled through the store; web subscriptions through Paddle (Sec. 10.2-10.3). Doctor's Report is a one-time purchase, no refund after delivery (Secs. 6.10, 10.5).
Contacts
Privacy contact. trust@helloclue.com (Privacy Secs. 1, 5, 10)
Legal notice. BioWink GmbH, Adalbertstrasse 7-8, 10999 Berlin, Germany (Terms Sec. 1.1; Privacy Sec. 10)
Mailing address. Not recorded.
Evidence
No claims have been itemized for this row yet.
Sources
| Source | Claim | Tier | Status | Quote |
|---|---|---|---|---|
| Company privacy policy · 2026-09-29 helloclue.com/privacy | whole row | Unassigned | confirmed | “Clue is made by BioWink GmbH, Adalbertstraße 7-8, 10999 Berlin” Quote basis: not recorded. |
| Company terms · 2026-06-25 helloclue.com/terms | whole row | Unassigned | confirmed | “neither obliged nor willing to participate in dispute resolution proceedings before a consumer arbitration body” Quote basis: not recorded. |
Source vault
Link status: Candidate - not yet fetched
| Document | Last fetch | |
|---|---|---|
| Privacy policy https://helloclue.com/privacy | Not fetched yet | NOT CONFIRMED |
| Terms of service https://helloclue.com/terms | Not fetched yet | NOT CONFIRMED |
| Website https://helloclue.com | Not fetched yet | — |
| Primary source https://helloclue.com/privacy Verification: Unverified - heuristic first draft | Not fetched yet | — |
Enforcement
No enforcement actions are linked to this row.
State statute
No comprehensive state privacy statute on file for Germany