Last updated: 16 October 2026

1. Who we are

Pure Clear Minds Limited, trading as Clear Minds (“Clear Minds”, “we”, “us” or “our”), operates clearminds.com and the Clear Minds app.

We are registered in Gibraltar under company number 121214, with our registered office at 5/9 Main Street, Gibraltar, GX11 1AA.

Clear Minds is the controller of the personal information described in this policy.

This policy explains how we handle personal information when you visit our website, use our app, purchase our products, manage a membership or contact us. We handle personal information in accordance with applicable data protection law, including the UK GDPR, the Data Protection Act 2018 and, where applicable, the EU GDPR.

Contact: info@clearminds.com

2. Health and medical data: no collection, processing, storage or tracking

Clear Minds does not collect, process, store, track or use personal health or medical data through our website, app, analytics or advertising technologies.

This includes information about an individual’s:

• Physical or mental health.
• Health status.
• Medical conditions.
• Health or wellness conditions.
• Symptoms or diagnoses.
• Treatment or medication.
• Medical history.

We do not use browsing activity, purchases, content viewed, session choices or interactions with health and wellness topics to infer an individual’s medical conditions or physical or mental health status.

We do not sell, share, disclose or transmit personal health or medical data to Meta, Google, OpenAI or any other third party. We do not use this information for advertising, retargeting, profiling, audience creation, personalisation or automated decision-making.

These restrictions apply to cookies, pixels, analytics tools, advertising technologies, server-side tracking and other data-sharing methods.

Clear Minds provides general wellbeing content. We do not assign a condition, diagnosis or health status to someone because they view, select or purchase particular content. This does not change the legal classification of information that actually reveals someone’s health status.

The ordinary personal information described below does not authorise the collection or use of health or medical data. Consent to marketing, analytics or advertising cookies does not override this restriction.

3. Personal information we collect

We collect ordinary personal information needed to operate our business and provide our services. Depending on your interaction with us, this may include:

• Identity and contact information, such as your name, email address, telephone number and billing address.
• Account information, such as login credentials, membership status and account preferences.
• Transaction information, such as orders, purchases, subscription details, payment status and billing records.
• Payment-related information handled by our payment providers.
• Technical information, such as your IP address, browser, device, operating system and approximate location.
• Operational usage information needed to provide, secure and improve our website and app, subject to the health-data restrictions in section 2.
• Marketing preferences and records of consent.
• Non-health-related correspondence, feedback and service enquiries.

We collect information directly when you create an account, place an order, subscribe, manage your preferences, contact us or provide feedback.

We may also receive information from payment providers, service providers and technologies used on our website or app, as explained in our Cookie Policy.

Please do not submit medical records, diagnoses, treatment information or other personal health information through our website, app or routine customer-service channels.

4. How and why we use personal information

We use ordinary personal information to:

• Create and manage your account.
• Process orders, payments and subscriptions.
• Provide access to purchased content and membership services.
• Answer service enquiries and resolve technical or billing issues.
• Send order confirmations, service notices and account updates.
• Maintain financial records and meet legal obligations.
• Prevent fraud, protect accounts and maintain security.
• Understand general service performance and improve usability.
• Send marketing communications where permitted.
• Measure advertising performance where permitted and subject to your preferences.

None of these purposes permits the processing of health or medical data described in section 2.

Our legal basis depends on the purpose. It may be:

• Performance of a contract with you.
• Compliance with a legal obligation.
• Our legitimate interests, where those interests are not overridden by your rights.
• Your consent, where required.

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing lawfully carried out before withdrawal.

5. Marketing and service communications

We may contact you about orders, subscriptions, account security, access to services or important changes.

Where permitted by law, we may also send marketing communications about Clear Minds products and services. You can unsubscribe using the link in our marketing emails or contact info@clearminds.com.

Unsubscribing from marketing does not prevent essential account or service communications.

We do not select marketing recipients or personalise advertising using medical conditions, health status or inferred health information.

6. Cookies, analytics and advertising

Our website uses cookies and similar technologies for essential functions and, where permitted by your choices and applicable law, functionality, analytics and advertising.

These technologies may process ordinary technical, interaction and transaction information. They must not collect, transmit or use information that reveals an individual’s health or medical status.

We do not use health-related browsing, purchases or session choices to create health profiles or advertising audiences.

See our Cookie Policy for information about cookie categories and managing your preferences.

7. Sharing ordinary personal information

We do not sell your personal data.

Where necessary for the purposes described in this policy, we may share ordinary personal information with:

• Website, app, hosting and technology providers.
• Payment providers and financial institutions.
• Subscription, account-management and customer-service providers.
• Communication, analytics and advertising providers, where permitted.
• Accountants, legal advisers and other professional advisers.
• Regulators, courts, law enforcement or other authorities where legally required.

Depending on the service used, providers may include Shopify, Stripe, Apple, Google, Meta and YouTube.

We limit disclosures to information appropriate to the relevant purpose and use contractual or other safeguards where required.

This section does not authorise sharing personal health or medical data. The restrictions in section 2 apply to all providers and disclosures.

8. International transfers

Some service providers process ordinary personal information outside your country, including in Canada or the United States.

Where applicable law requires safeguards for international transfers, we use an appropriate transfer mechanism, such as an adequacy decision, approved contractual clauses or another legally recognised safeguard.

You can contact us for information about the safeguards relevant to your personal information.

9. Retention

We retain ordinary personal information only for as long as necessary for the purpose for which it was collected, including applicable legal, accounting and reporting requirements.

Retention periods depend on the record and purpose. Financial and transaction records may generally be retained for up to six years, or longer where legally required. Other information may be deleted sooner.

When information is no longer required, we delete it securely or anonymise it.

These retention provisions do not authorise the storage of health or medical data.

10. Security

We use appropriate technical and organisational measures to protect personal information against unauthorised access, loss, alteration or disclosure.

Access is limited to people and providers who need it for authorised purposes.

No online service can guarantee absolute security. Where a personal data breach occurs, we assess it and notify affected individuals and relevant authorities where legally required.

11. Your rights

Depending on your location and applicable law, you may have the right to:

• Access your personal information.
• Correct inaccurate or incomplete information.
• Request deletion.
• Restrict processing.
• Receive or transfer certain information in a portable format.
• Object to processing, including direct marketing.
• Withdraw consent.
• Receive applicable protections relating to solely automated decisions with legal or similarly significant effects.

These rights are subject to legal conditions and exceptions.

To make a request, email info@clearminds.com. We may need to verify your identity. We normally respond within one month, subject to any lawful extension.

12. Complaints

Please contact info@clearminds.com if you have concerns about how we handle personal information.

You may also complain to the data protection authority relevant to your location. In the UK, this is the Information Commissioner’s Office: https://ico.org.uk.

If you are in the EEA, you may contact your local supervisory authority.

13. Changes and contact

We may update this policy to reflect changes to our services, practices or legal obligations. The publication date above identifies the latest version.

For privacy questions, rights requests or an accessible version of this policy, contact:

info@clearminds.com