Privacy policy

CLARITO Privacy Policy

We understand that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through our services (including the supply of our products) and website Services. In this Privacy Policy we, us or our means CLARO LLC (an Arizona limited liability company).

This Privacy Policy takes into account the requirements of applicable United States federal and state privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), and comparable laws in Virginia, Colorado, Connecticut, Utah and other states. Individuals located in the European Union (EU) or the United Kingdom (UK) may also have rights under the General Data Protection Regulation 2016/679 (GDPR). Appendix 1 outlines the details of the additional rights of individuals located in California. Appendix 2 outlines additional rights for individuals located in the EU and UK.

Personal information

The types of personal information we may collect about you include:

• your contact details, including email address, mailing address, street address and/or telephone number;
• your name and shipping and billing information;
• your payment information (processed by our payment providers, see below);
• voice recordings, speech audio and the text transcriptions produced from them, where you use a CLARITO device or associated application to translate speech;
• the language pairs you select and the date, time and duration of translation sessions;
• device information relating to your CLARITO product, including serial number, firmware version, battery status and diagnostic logs;
• images of you, where you choose to provide them (for example, in a product review or a warranty claim);
• your social media profile details, where you choose to interact with us on social media;
• details of products and services we have provided to you and/or that you have enquired about, and our response to you;
• your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behavior;
• information about your access and use of our online Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
• additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
• any other personal information requested by us and/or provided by you or a third party.

We may collect these types of personal information directly from you or from third parties.

Voice data: how translation works and what happens to your speech

This section is specific to our products and we set it out plainly.

1. What is captured. When you press the microphone button on a CLARITO device, the device captures the audio spoken into it in order to produce a translation. It captures audio only while a translation session is active. It is not a continuously listening device and does not record ambient audio when a session is not running.

2. Where it is processed. Translation may be performed on the device, or by sending the audio or its transcription to a third party translation service provider for processing, depending on the language pair, the mode selected and whether the device is connected to a network. Where cloud processing is used, your speech audio and/or its transcription leaves the device and is transmitted to that provider.

3. Third party translation providers. We use third party speech recognition, machine translation and speech synthesis providers to deliver translations. These providers process your speech under their own terms and privacy policies. A current list of the providers we use is available on request by emailing support@clarito.com.

4. Retention. The CLARITO device does not store your speech audio after a translation has been delivered. Audio is held only for the moments required to produce the translation and is then discarded. We do not maintain a library of your conversations, and we do not keep transcripts of what you say. Where you ask us to delete any translation data associated with you, we will delete it from our systems and instruct our processors to do the same, except where we are required to retain it by law.

Please note that where a translation is processed in the cloud, the third party translation provider handling that request may retain the audio or its transcription for a period governed by their own policies. We have no control over that retention, and we identify those providers on request so that you can review their terms.

5. We do not sell your speech. We do not sell, and have not in the preceding 12 months sold, your voice recordings, transcripts or translation content. We do not share them with advertisers, data brokers or social media platforms.

6. Biometric information. We do not identify you by your voice. The CLARITO device and its associated software do not perform speaker identification, speaker recognition, speaker diarization or voice matching. They do not create, extract, store or transmit a voiceprint, a voice template, a voice embedding, or any other model derived from the physical characteristics of a person's voice. They do not offer voice cloning and do not reproduce your own voice in the translated output. They do not learn, adapt to, or train on an individual user's voice over time.

We do not knowingly collect, capture, purchase, receive through trade, or otherwise obtain biometric identifiers or biometric information within the meaning of the Illinois Biometric Information Privacy Act (740 ILCS 14), the Texas Capture or Use of Biometric Identifier Act (Tex. Bus. & Com. Code §503.001), or the Washington Biometric Privacy Act (RCW 19.375). The device hears words. It does not recognise people.

7. Other people's voices. When you use a CLARITO device to speak with another person, that person's speech is also captured. You are responsible for making that person aware that the device is translating, and for obtaining their consent where the law where you are requires it. Some jurisdictions require the consent of all parties to record a conversation. Do not use CLARITO to record a person who has not agreed to it.

8. Children. Our products and Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has provided us with personal information, contact us and we will delete it.

Collection and use of personal information

We may collect, hold, use and disclose personal information for the following purposes:

• to enable you to access and use our Services, associated applications and associated social media platforms;
• to deliver translations and to operate, maintain and improve the performance and accuracy of our products;
• to contact and communicate with you;
• for internal record keeping, administrative purposes, invoicing and billing purposes;
• to process warranty claims, returns and refunds;
• for analytics, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms;
• to run promotions, competitions and/or offer additional benefits to you;
• for advertising and marketing, including to send you promotional information about our products and services and information that we consider may be of interest to you;
• to comply with our legal obligations and resolve any disputes that we may have; and
• if you have applied for employment with us, to consider your employment application.

Disclosure of personal information to third parties

We may disclose personal information to:

• third party service providers for the purpose of enabling them to provide their services, including (without limitation) speech recognition and translation providers, IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
• our employees, contractors and/or related entities;
• our existing or potential agents or business partners;
• sponsors or promoters of any promotions or competition we run;
• anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
• credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
• courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
• third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you; and
• third parties to collect and process data.

We do not sell your personal information for money. Under some state privacy laws, the use of advertising cookies and similar technologies may be treated as a "sale" or as "sharing" for cross-context behavioral advertising. Where that is the case, you may opt out. See Appendix 1 and the Cookies section below.

International data transfers

Our third party service providers, including translation providers, may store and process data outside the United States. Where the disclosure of your personal information is subject to United States privacy laws, you acknowledge that some third parties may not be regulated by those laws, and if any such third party engages in any act or practice that contravenes them, it would not be accountable under those laws and you will not be able to seek redress under them, except as otherwise provided by applicable law.

Sensitive personal information

Under the CCPA/CPRA and comparable state laws, certain categories of personal information are given a higher level of protection. Sensitive personal information means information relating to your racial or ethnic origin, religious or philosophical beliefs, union membership, precise geolocation, the contents of your mail, email and text messages, genetic data, biometric information processed to uniquely identify you, health information, or information about your sex life or sexual orientation.

The contents of your translated conversations may be sensitive. We treat translation audio and transcripts as confidential. We do not use them to infer characteristics about you, and we do not use them for advertising or profiling. We will not collect sensitive personal information about you without first obtaining your consent, unless required or authorised by law. Provided you consent, your sensitive personal information may only be used and disclosed for purposes relating to the primary purpose for which it was collected.

Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person's consent to provide the personal information to us.

Marketing: If you wish to opt out of our marketing database or opt out of communications (including marketing communications), please contact us using the details below or opt out using the opt-out facilities provided in the communication.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, incomplete, misleading or out of date.

Deletion: You may request that we delete the personal information we hold about you, including your translation history. See Appendix 1 for the process.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. You also have the right to contact the relevant authority in the state or country in which you are based.

Non-discrimination: We will not discriminate against you for exercising any of your privacy rights. We will not deny you goods or services, charge you a different price, or provide you a different level or quality of goods or services because you exercised your rights.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Cookies and tracking

We may use cookies on our online Services from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Meta, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online Services with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our online Services.

We honor the Global Privacy Control (GPC) signal. If your browser sends a GPC signal, we will treat it as a request to opt out of the sale or sharing of your personal information for that browser.

We may use web beacons on our online Services from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor's behaviour and collect data about the visitor's viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

We may use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time.

Links to other websites

Our Services may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy. We will notify you if we amend this Privacy Policy, by contacting you through the contact details you have provided to us. Any amended Privacy Policy is effective once we notify you of the change.

For any questions or notices, please contact our Privacy Officer at:

CLARO LLC
2123 S Priest Dr, Tempe, AZ 85282, USA
Email: support@clarito.com

Last update: 7 September 2026

APPENDIX 1 — ADDITIONAL RIGHTS FOR CALIFORNIA RESIDENTS AND OTHER US STATES

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, or another state with a comprehensive consumer privacy law, you have additional rights which apply to your personal information.

Your rights

• Right to know / access. You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purpose for collecting it, and the categories of third parties with whom we share it.
• Right to delete. You may request that we delete the personal information we have collected from you, including translation audio and transcripts, subject to certain exceptions.
• Right to correct. You may request that we correct inaccurate personal information we hold about you.
• Right to opt out of sale or sharing. You may direct us not to sell or share your personal information for cross-context behavioral advertising.
• Right to limit use of sensitive personal information. You may direct us to limit our use of your sensitive personal information to what is necessary to provide the goods or services you requested.
• Right to non-discrimination. We will not discriminate against you for exercising any of these rights.
• Right to appeal. In some states, if we decline your request, you may appeal that decision by replying to our response.

How to exercise your rights

Email support@clarito.com with the subject line Privacy Request. We will acknowledge your request within 10 business days and respond within 45 days, or tell you if we need a further 45 days.

We will verify your identity before acting on your request, generally by matching the information you provide against the information we hold. If you use an authorised agent, we will require written proof of their authority.

Categories of personal information collected in the last 12 months

Identifiers; customer records; commercial information; internet and network activity; geolocation data; audio and electronic information (voice recordings and transcripts); inferences drawn from the above.

Do we sell or share personal information?

We do not sell personal information for money. We may share certain internet activity information with advertising partners for cross-context behavioral advertising, which some state laws treat as "sharing." You may opt out at any time using the Do Not Sell or Share My Personal Information link in our website footer, or by enabling Global Privacy Control in your browser.

We do not sell or share translation audio, transcripts or conversation content under any circumstances.

APPENDIX 2 — ADDITIONAL RIGHTS FOR INDIVIDUALS LOCATED IN THE EU AND UK

Under the GDPR and UK GDPR, individuals located in the EU and UK have extra rights which apply to their personal information. This Appendix sets out the additional rights we give to individuals located in the EU and UK, including how we process personal information lawfully, transparently and fairly.

How we process personal information

We will process your personal information for our legitimate interest to allow you to access and use our website, to send you marketing content we think may be of interest to you, to contact you if you leave your contact details with us or if you otherwise initiate contact with us.

We will rely on performing a contract to process your personal information where we are preparing to enter into a contract with you or we are carrying out our obligations under a contract with you.

We will rely on a legal obligation to process your personal information where we are subject to a legal obligation.

We rely on your consent to process voice recordings and translation content, and you may withdraw that consent at any time by contacting us. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

If we need to rely on consent, we will ask for consent to process any of your personal information for that specific purpose before we process your personal information for that reason.

Upon written request, we may provide you with a list of the third parties we use to process your personal information.

If you are under 16 years of age, you must have, and warrant to the extent permitted by law to us that you have, your parent or legal guardian's permission to access and use the Services and they (your parents or guardian) have consented to you providing us with your personal information.

Data retention

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see 'access, erasure and data portability' below for further information.

In some circumstances we may anonymise your personal information (so that it can no longer be associated with you) for analytics, research or statistical purposes in which case we may use this anonymised information indefinitely without further notice to you.

Data Transfers

The countries to which we send data for the purposes listed above may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with the Privacy Policy, as supplemented by this Appendix.

Extra rights for EU and UK individuals

Objecting to processing: You have the right to object to the processing of your personal information.

Restricting processing: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.

Access, erasure and data portability: You may have the right to request details of the personal information we hold about you, or to request that we erase the personal information we hold about you, or that we transfer this information to a third party.

Rectification: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, incomplete, misleading or out of date.

Complaint to a supervisory authority: You have the right to lodge a complaint with your local data protection authority.