Privacy Policy — Homöopathie Ratgeber (United States)
Last updated: March 2026
1. Data Controller
Clesk Digital GmbH
Am Biehl 5, 57234 Wilnsdorf, Germany
Managing Directors: Enzo Frenker-Hackfort, Tobias Kajetan Roesner
Commercial Register: HRB 13012 (Amtsgericht Siegen)
VAT ID: DE351357159
Email: info@clesk.de
Phone: +49 (0) 271 33885017
2. Overview
The app "Homöopathie Ratgeber" (also published as "Globuli App" and "Globuli Ratgeber", App ID: de.clesk.globuli, hereinafter "App") is a homeopathic remedy finder for iOS and Android. The App works without registration or login. Most features are available offline. This privacy policy informs you about what data we collect, how we process it, and what rights you have under applicable US privacy laws.
3. What Data Do We Collect?
3.1 Automatically Collected Data
When you use the App, the following data is automatically collected:
Firebase Analytics (Google Ireland Ltd., EU): Anonymized usage statistics such as screen views, search terms, and feature usage. An anonymous Firebase Installation ID is generated on your device that cannot be linked to any individual. Legal basis for accessing your device: user consent. Legal basis for subsequent data processing: consent. You may withdraw your consent at any time (see Section 13).
Firebase Crashlytics (Google Ireland Ltd., EU): In the event of crashes or technical errors, crash reports are automatically transmitted. These contain stack traces, device information (model, operating system, app version), and the anonymous Installation ID. Legal basis: strictly necessary for service provision in conjunction with legitimate interest.
Network Status: The App checks whether an internet connection is available to provide offline functionality. This information is not transmitted.
IP Address: When using online features (AI recommendations, scanner, database updates), your IP address is technically transmitted to our servers. It is used exclusively and transiently for rate limiting (abuse protection) and is not stored. Legal basis: legitimate interest.
3.2 Data Collected Through User Action
AI Symptom Analysis (Premium): When you use the AI feature, your symptom description is transmitted to our server and forwarded to Mistral AI (Paris, France). Processing takes place within the EU. See Section 4 for details.
OCR Scanner (Premium): When you use the scanner feature, camera or gallery images are transmitted to our server and processed by Mistral AI (EU) via OCR. Images are processed exclusively transiently and are not stored. See Section 5 for details.
Error Reports: If you report an error through the App, your description is stored in our database (Google Cloud Firestore, EU) and forwarded to our team by email. This is voluntary. Legal basis: legitimate interest.
Disclaimer Acceptance: On first launch, you must accept a medical disclaimer. The timestamp of this acceptance is stored as an audit trail in our database. Legal basis: legitimate interest.
3.3 Data Stored Locally on Your Device
The following data is stored exclusively on your device and is never transmitted to our servers:
- Favorites (saved remedies)
- Personal notes on remedies
- Onboarding status
- App launch counter
- Offline cache of the remedy database (automatically refreshed every 7 days)
This data is deleted when you uninstall the App.
4. AI Recommendations (Mistral AI)
Our App offers AI-based recommendations for homeopathic remedies. This feature is exclusively available to Supporters (Premium) and is only executed upon your explicit action.
What is transmitted: Your symptom description (free text) and a list of available remedy names and indications from our database.
What is NOT transmitted: No name, no email address, no device ID, no location data, and no health history. Only the current input is processed.
Recipient: Mistral AI SAS, Paris, France. Data processing takes place on EU servers.
Storage: Neither we nor Mistral AI store your symptom description permanently. Data is processed exclusively transiently to generate the recommendation and then discarded.
Legal basis: consent. As symptom descriptions may qualify as health data under applicable health data laws, processing is based on your explicit consent pursuant to explicit consent for health data.
Note: AI recommendations do not replace medical advice, diagnosis, or treatment. For serious health concerns, please consult a doctor.
5. OCR Scanner (Mistral AI)
The scanner feature allows you to photograph homeopathic remedy bottles and have the label automatically recognized. This feature is exclusively available to Supporters (Premium).
What is transmitted: The image you captured or selected.
Recipient: Mistral AI SAS, Paris, France. Processing takes place on EU servers.
Storage: The image is processed exclusively transiently. No permanent storage occurs on our servers or at Mistral AI.
Legal basis: consent.
6. App Permissions
The App requests the following permissions, each only when the corresponding feature is used:
Camera (iOS and Android): To photograph remedy bottles for the scanner feature (Premium). The permission is requested by the operating system and can be revoked at any time in your device settings.
Photo Library (iOS): To select an existing image for the scanner feature.
Internet Access (Android): For all online features of the App.
7. Payment Processing
Supporter subscriptions (3.99 USD/month or 29.99 USD/year) are processed exclusively through the Apple App Store or Google Play Store. The App itself does not process any payment data.
To manage subscription status, we use RevenueCat (RevenueCat Inc., USA). RevenueCat receives the subscription status (active/expired), purchase events, and an anonymous, app-internal device identifier. No payment data is transmitted to RevenueCat. Legal basis: contractual necessity.
For data transfers to the USA, we rely on EU Standard Contractual Clauses and supplementary technical and organizational measures.
8. Affiliate Links
The App contains affiliate links to the following providers:
- Amazon (Amazon EU S.à r.l., Luxembourg) via Amazon PartnerNet (affiliate tag: clesk-21)
- Shop-Apotheke and DocMorris via AWIN AG (Berlin, Germany)
When you tap an affiliate link, you are redirected to the external shop. An affiliate tracking parameter is transmitted so we can receive a commission. The privacy policies of the respective provider apply on the destination site. Legal basis: legitimate interest.
9. Retention Periods
| Data |
Storage Location |
Retention Period |
| Analytics events |
Google Analytics |
90 days |
| Crash reports |
Google Crashlytics |
90 days |
| Symptom texts (AI) |
Nowhere (transient) |
Immediately discarded |
| Scanner images |
Nowhere (transient) |
Immediately discarded |
| Error reports |
Google Cloud Firestore (EU) |
3 years, then deleted |
| Disclaimer acceptance |
Google Cloud Firestore (EU) |
Duration of App operation |
| Favorites and notes |
Locally on your device |
Until deletion or uninstallation |
| Offline cache |
Local storage |
7 days |
| Subscription status |
RAM only |
Until app restart |
10. Security Measures
We implement the following technical and organizational measures to protect your data:
- All data transmissions are encrypted via HTTPS/TLS.
- Inputs are checked server-side for malicious content (input sanitization and prompt injection protection).
- All server endpoints are protected by rate limiting.
- Database access is restricted by security rules (no access to other users' data).
- API keys are managed exclusively server-side in a secured key store.
11. Cookies and Tracking
The App does not use cookies. No third-party trackers are used (no Google Ads, no Facebook Pixel, etc.). The App contains no advertising.
12. Recipients and Data Processors
We have concluded data processing agreements pursuant to applicable data processing requirements with the following service providers:
- Google Ireland Ltd. (Firebase Analytics, Crashlytics, Cloud Firestore, Cloud Functions)
- Mistral AI SAS (AI recommendations and OCR scanner)
- RevenueCat Inc. (subscription management)
13. Your Rights
Under applicable US privacy laws, you have the following rights, among others: access, rectification, erasure, restriction of processing, data portability, and objection.
To exercise your rights, please contact: info@clesk.de
You also have the right to lodge a complaint with a data protection authority. The competent authority for United States is: California Attorney General (for CA residents) at oag.ca.gov; for other states, your state attorney general.
Withdrawal of Consent
You may withdraw any consent given at any time with effect for the future. Withdrawal does not affect the lawfulness of processing carried out prior to the withdrawal.
AI Recommendations and Scanner: Consent is given through active use of the respective feature. You can withdraw consent by simply not using these features.
Firebase Analytics: You can withdraw consent to the collection of usage statistics by sending us an email at info@clesk.de.
Additional Information for California Residents (CCPA/CPRA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):
- Right to Know: You may request information about the categories and specific pieces of personal information we have collected about you in the preceding 12 months.
- Right to Delete: You may request deletion of your personal information that we hold.
- Right to Correct: You may request correction of inaccurate personal information.
- Right to Data Portability: You may request a copy of your personal information in a portable format.
- Right to Limit Use of Sensitive Personal Information: You may request that we limit the use and disclosure of your sensitive personal information.
- Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.
Do Not Sell or Share My Personal Information
We do not sell your personal information, and we do not share your personal information for cross-context behavioral advertising. The App does not serve ads and does not pass user data to ad networks or data brokers.
Personal information is processed only for the purposes listed in this policy (providing the App, AI recommendations, scanner, error reports, and — if you explicitly consent — Firebase Analytics for usage statistics). Analytics consent can be withdrawn at any time in the App settings.
Notice at Collection
At the point of collection (when you install the App or use any feature), we collect the categories of personal information described in Section 3 of this policy (device data, user input for AI features, OCR images, crash reports, anonymous analytics if consented to). We retain these categories only as long as needed for the purposes described.
How to Exercise Your Rights
To exercise any of the rights above, contact us at: info@clesk.de. We will verify your request by asking you to confirm the email address or device-identifier information you used in the App. We will respond within 45 days (extendable by another 45 days if necessary, with notice).
You may also designate an authorized agent to make a request on your behalf, subject to verification.
Shine the Light Law
California Civil Code § 1798.83 permits California residents to request information regarding the disclosure of personal information to third parties for direct marketing purposes. As stated above, we do not disclose personal information for such purposes.
14. Automated Decision-Making
The AI recommendations in the App constitute non-binding suggestions for homeopathic remedies. No automated decision-making within the meaning of applicable automated decision-making laws takes place that produces legal effects concerning you or similarly significantly affects you.
15. Use by Minors
The App is aimed at a general audience. Minors under the age of 13 require parental or guardian consent to use consent-based features (AI recommendations, scanner) under applicable laws. We do not knowingly collect personal data from children under 13 without parental consent.
16. Changes to This Privacy Policy
We reserve the right to update this privacy policy as needed. The current version is always available in the App under Settings.
End of Privacy Policy
