ClaraWell Inc. is a Delaware, United States corporation, incorporated February 14, 2025.

ClaraWell Health platforms are publicly accessible via the internet. Public accessibility does not constitute targeted marketing, regulatory submission, or establishment of operations within any specific jurisdiction.

ClaraWell does not currently operate production systems collecting identifiable personal data. No intentional collection or storage of regulated personal health data is occurring at this time.

Regulatory Scope

The General Data Protection Regulation (EU) 2016/679 (GDPR) governs the processing of personal data of individuals located within the European Union under specific territorial conditions.

ClaraWell does not actively direct services toward residents of the European Union. Where GDPR applicability arises under Article 3, ClaraWell systems are architected to support alignment with principles of lawfulness, transparency, purpose limitation, data minimization, integrity, confidentiality, and accountability.

Lawful Basis & Data Processing Principles

• Lawful Basis: Future regulated processing would rely on explicit consent or other legally recognized bases where applicable.
• Purpose Limitation: Data processing limited to clearly defined purposes.
• Data Minimization: Collection limited to information necessary for stated functionality.
• Integrity & Confidentiality: Role-based access controls and encrypted transmission standards.
• Accountability: Structured governance documentation and review prior to deployment.

Data Subject Rights (If Applicable)

Where GDPR applies, individuals may have rights including access, rectification, erasure, restriction of processing, data portability, and objection to processing, subject to statutory limitations.

Cross-Border Data Considerations

ClaraWell Inc. is a United States–incorporated entity. Should regulated personal data processing involving EU residents occur in the future, cross-border transfer mechanisms consistent with applicable legal requirements would be implemented prior to deployment.

Automated Decision-Making

ClaraWell systems do not currently engage in regulated automated decision-making involving personal data under GDPR Article 22. Any future regulated deployment involving such processing would undergo legal and governance review prior to operational launch.

Pre-Deployment Regulatory Review

Prior to any operational deployment involving personal data subject to GDPR, ClaraWell Inc. will conduct formal regulatory assessment and safeguard validation consistent with applicable European data protection requirements.

Jurisdiction & Applicability

Regulatory applicability is determined based on the nature of services offered, data collected, user location, and applicable statutory thresholds.

ClaraWell Inc. reserves the right to restrict or limit access in jurisdictions where regulatory requirements materially change or where continued availability would require formal authorization, registration, or licensure.