Privacy Policy
Personal Data Processing and Privacy Settings
This document (hereinafter "Privacy Settings") describes the principles of personal data processing for clients of the Claspal application and website (hereinafter "Application") by Claspal OÜ and its subsidiaries and affiliates (hereinafter "Claspal").
General Principles
A client, within the meaning of these Privacy Settings, is any person who visits the Claspal App website or uses the Claspal App and the services provided through it.
When you contact Claspal app (e.g., via email, letter, or phone), we process the personal data you provide (e.g., name, contact information, communication details). We do this based on our legitimate interest in responding to and/or resolving your inquiry, including offering support.
When you visit the Application's website, we may obtain personal data about you through cookies used on our website.
Legal Basis and Purposes for Personal Data Processing
Claspal processes personal data as necessary to fulfill the services, including delivering personalized mental wellbeing support and maintaining app functionality. This processing is essential to perform our contract with the Client.
For registration purposes, the following data is collected directly from the Client:
• Email address
This personal data, provided by the Client during registration, is processed to support the personalized functionalities within the app.
Claspal also processes the following types of data
• Client activity within the app and website - including chats, session history, summaries, preferences, settings, and interaction patterns. This data is used to personalize the experience, support the Client's self-reflection process, and help us improve technical performance.
Please note: Chats, messages, summaries and analytics are stored. Avoid sharing personal or sensitive information you do not wish to be stored.
Analytics
Our Application may collect some usage data to understand the Clients' needs and to improve our services. These usage data are for example, app launches, taps, screen visits, session duration and other information about how the Client interacts with the Application. The Application may also collect crashes and performance reports so we can improve the stability and performance of our Application.
Retention of Personal Data
Claspal documents and retains personal and health data collected during service provision according to applicable legal requirements for the duration necessary to achieve the processing purpose and as long as required by law.
• Client feedback collected to assess customer satisfaction is retained for 5 years from the date of receipt.
• Accounting documents are retained for 7 years in accordance with the Accounting Act.
• Data collected according to Client consent during beta versions of the application will be deleted at no later than 3 months after the data has been collected.
Protection of Personal Data
Personal data is stored in a secure cloud that meets the security requirements for processing highly sensitive data with appropriate security settings and monitoring in place.
The identification and authentication of all Clients are carried out according to the Client's chosen option. Secure industry-standard software is used to verify and manage Clients' identity and access control.
Client Rights Regarding Personal Data
Clients have all the rights of a data subject under applicable law regarding the processing of personal data.
Clients have the following rights regarding the processing of personal data, among others:
Right of access: The right to ask at any time whether Claspal holds personal data about the client and to receive information on which personal data Claspal processes about them;
Right to rectification: The right to request Claspal to correct or update personal data if it is inadequate, incomplete, or incorrect;
Right to object: The right to object to the processing of personal data by Claspal;
Right to erasure: The right to request the deletion of personal data, such as when processing is based on the client's consent and the client has withdrawn their consent;
Right to restrict processing: The right to request Claspal to restrict the processing of personal data, for instance, if Claspal no longer needs the data for processing purposes, or if the client has objected to the processing;
Right to withdraw consent: The right to withdraw consent for personal data processing at any time;
Right to data portability: The right to receive personal data provided by the client and processed based on consent or a contract in a structured, commonly used format.
Right to lodge a complaint: If the client believes their personal data rights have been violated, they have the right to file a complaint with the Data Protection Inspectorate or a court.
Contact
For questions or concerns regarding this Privacy Policy, contact us via email: contact@claspal.com
Last updated: September 5, 2025