Clex Privacy Policy

Effective date: 21 August 2026

This policy covers the Clex products and services listed in section 2, including this website. Details specific to website visits (access logs, the contact form) are also described in the website privacy policy. Previous versions of this policy are archived: 20 August 2026, 18 August 2026, 11 August 2026 and 4 August 2026.

1. Who We Are

This Privacy Policy is issued by Clex A/S, a Danish corporation (CVR 37750840) with registered address at Ewaldsgade 9, 1., 2200 Copenhagen N, Denmark.

Clex develops language-technology writing support for the care sector. This policy describes how we handle information when you use our products and services.

2. Scope

This policy covers all Clex products and the Clex website:

The products are designed for professional care workers who document care activities within their organization’s electronic health record (EHR/EOJ) systems.

Each product has its own, more detailed privacy policy, describing it field by field: Privacy Policy, Clex Keyboard for Android, Privacy Policy, Clex Keyboard for iOS, and Privacy Policy, Clex Web. Where this policy and a platform policy describe that platform’s behaviour differently, the platform policy is the accurate one.

3. Our Approach to Privacy

Clex products are built on a local-first, privacy-by-design architecture:

• The free text you write stays on your device or in your browser. It is not sent to Clex, and no product endpoint accepts free text.
• Word prediction, sentence suggestions, sentence correction, translation, speech to text, and read-aloud all run locally, using language models stored on the device or in the browser.
• What does leave the device is a licence check, a daily count of feature use, and requests for model files. Section 4 lists each of them.
• No keystrokes are logged, monitored, or transmitted at any point.

About the keyboard access warning. When you enable Clex Keyboard on Android or iOS, your operating system displays a standard warning that the keyboard may be able to collect everything you type, including passwords and credit card numbers. This warning is shown for all third-party keyboards and is not specific to Clex. We want to be clear: Clex Keyboard does not collect, store, or transmit any text you type. All text processing happens locally on your device. No keystrokes, passwords, or typed content ever leave your device through Clex.

4. What Data Is Processed

4.1 Licensing and Activation

The organisation’s licence key or activation code and the app version are sent to the Clex licence service when the product is activated and when the licence is validated. The service returns an access token that carries the organisation identifier and no personal data about end users. Clex keeps a licence record for the duration of the customer contract.

4.2 Usage Statistics

To keep the products reliable and to know which features are used, each app and browser extension sends one report per day of use. A report contains: the calendar day it describes, the app or extension version shortened to its first two numbers, the keyboard or writing language (Danish, Swedish, English or German; every other language is reported as “none”), three fixed labels naming the report format, the product and the platform, a random report number, and a set of counters, each recording how many times a feature was used or failed that day.

A report never contains what you typed, which app or website you were writing in, any time of day, or any character count. Response times are reported as counts within fixed ranges, never as individual measurements. When a report arrives, its numbers are added into a running daily total for your organisation and the report itself is not stored.

A usage report contains no identifier for a person, user, device, installation or session. It contains a random report number created for that one report and used only to discard duplicates, and it is sent with your organisation’s access token so that Clex can tell which organisation the counts belong to. The report number cannot link reports from different days or devices; it is deleted at most 15 days after the report arrives. Clex’s service uses the access token only to read the organisation identifier it carries; the token itself is not stored or logged.

Usage statistics are aggregated: they are counted per organisation and calendar day and carry no identifier for a person, device or installation. Clex reads them only as organisation totals, only internally and only with an internal credential; the language and app-version breakdowns are never returned by the read interface. An organisation can ask for its own totals; Clex then delivers organisation totals only. Clex does not use usage statistics to monitor, evaluate or discipline individual employees, to train models, or to market to individuals, and does not combine them with support cases, access logs or any other data. Clex keeps organisation totals for 24 months. The in-app statistics switch is available to every user on Android, iOS and in Clex Web.

The platform policies describe the reports field by field. You can switch usage statistics off at any time in the app’s settings on Android and iOS and on the extension’s settings page in Clex Web; pending reports are deleted when you do.

4.3 Model and Language Downloads

The language models that make on-device processing possible are delivered through the edge network from Clex’s servers, on first use of a language or feature and when models are updated. These requests carry no account and no licence; like any network connection they carry the device’s IP address for the duration of the connection (see section 4.6).

4.4 Local Features (No User Text Transmitted)

The following features run locally on your device or in your browser. No user text is sent to Clex or any third party for these features:

• Word prediction – runs locally on all platforms.
• Sentence suggestions and sentence correction – run locally on all platforms, using language models stored on the device or in the browser.
• Translation – runs locally on all platforms. Language resources are downloaded once on first use and cached on the device.
• Read-aloud – runs locally on all platforms using offline speech engines.
• Speech to text – runs locally on all platforms. What you say is transcribed by a speech model stored on the device or in the browser and inserted as text where you are writing. The audio is held in memory during transcription only: it is never stored, never uploaded, and never sent to the platform’s own speech service. The microphone permission is optional, and each product works fully without it.

About the microphone. On Android and in Clex Web the microphone is used only while you record. On iOS, while dictation is switched on in the Clex app, the app keeps the microphone session open between your recordings so that the keyboard can start a recording while you are in another app; sound that arrives while you are not recording is discarded as it arrives and is neither analysed, stored nor sent. You can switch dictation off in the Clex app at any time. Details are in the iOS privacy policy.

No user text is included in any download or network request related to these features.

The models are static: they never learn from what is typed, dictated or read, and they are updated only as versioned files from Clex. Machine-generated text can contain errors. A suggestion enters the text only when the care worker accepts it, and checking it professionally before the note is saved remains the care worker’s responsibility; the record is the care worker’s, not the model’s.

4.5 Clex Website (clex.ai)

The Clex website is designed with the same privacy-first approach as our products:

• One cookie, strictly necessary. The website sets a single first-party cookie that stores your language preference, as described in the cookie policy. No consent banner is shown because strictly necessary cookies require none, and there are no other cookies.
• No tracking or analytics. The website does not use Google Analytics, Facebook Pixel, or any other tracking or analytics service. No visitor behavior is recorded or profiled.
• No external scripts. All JavaScript is self-hosted. No third-party scripts are loaded in your browser.
• No external fonts. All fonts are self-hosted. No requests are made to Google Fonts or other external font services.
• No local storage. The website does not use browser localStorage or sessionStorage.

Contact form. The website includes a voluntary contact form. When you submit the form, the information you provide (name, email, and message) is delivered by email to the relevant Clex market contact and used only to respond to your inquiry. This data is not used for marketing, profiling, or any other purpose. The bot check (proof-of-work) runs in your browser and sets no cookies. Contact form data is subject to the legal basis described in section 6.

4.6 IP Addresses and Network Logs

Every network connection necessarily carries the device’s IP address for as long as the connection lasts. Clex’s licence and usage-statistics services do not read or store it, and they do not store browser or device signatures. The edge network that delivers model files and fronts Clex’s services writes its access logs with the last part of the address removed (the last octet of an IPv4 address, the host part of an IPv6 address); those logs are kept for 72 hours on a rolling basis by the edge provider and are not forwarded or archived. The usage-statistics endpoint has edge logging switched off. Clex’s own servers keep no per-request access log.

5. What We Do Not Collect

Through the products (apps and extension), Clex does not collect:

• Text you type or dictate into EHR/EOJ systems or any other application
• The name of the app or website you are writing in
• Keystrokes, keystroke timing, or input patterns
• Personal data such as names, addresses, phone numbers, or health records of any individual
• Voice recordings, photographs, or other user-generated media
• Information from the EHR/EOJ systems where text is entered
• Device contacts, call logs, or browsing history
• Individual-level usage events or crash stack traces
• Any identifier for a person, user, device, installation or session in a usage report (section 4.2)

6. Roles and Legal Basis

Who is responsible for what. Roles are assigned per processing activity.

• The notes, messages and other text that care workers write, dictate or have read aloud are processed on the organisation’s own devices and browsers and are never received by Clex. For that processing the organisation is the controller, exactly as for any other text its staff write, and Clex is the supplier of the software, neither a controller nor a processor.
• For licence validation and activation, the connection data that those requests carry, and the daily usage statistics, Clex A/S decides the purpose and the means and is therefore an independent controller. Hetzner Online GmbH and BunnyWay d.o.o. process that data for Clex A/S as processors. On the Swedish market Clex Sweden AB is the contracting party; Clex A/S remains the controller.
• Where Clex processes personal data on an organisation’s documented instructions, for example if the organisation grants Clex diagnostic access during a support case, Clex acts as a processor for that activity, and a data processing agreement under Article 28 is in place before that processing begins. Clex provides a per-activity overview on request; when an organisation’s data protection officer requests a data processing agreement for any other activity, Clex concludes one.

Because Clex products are designed to avoid processing personal data on the server side, the scope of data processing that requires a legal basis is limited:

Clex’s legitimate-interest assessment for these activities is available from Clex. The care workers who use Clex are normally not party to the agreement between their organisation and Clex, which is why Clex does not rely on Article 6(1)(b) for them. The organisation’s own legal basis for the documentation work Clex assists with is the one it already has for that work; Clex adds no new purpose.

You may object to the processing of your contact-form data and ask us to delete it at any time by contacting us.

Clex does not carry out any automated decision-making or profiling as defined in Article 22 of the GDPR. Our products propose draft sentences and corrections, generated on the device, and the care worker reads and decides whether to use each one. No automated decisions are made about individuals, and no personal profiles are created.

7. Data Sharing and Processors

We do not sell, rent, or trade personal data. The following providers are involved in delivering the service:

The apps are distributed through Google Play, the Apple App Store and the Chrome Web Store (Clex Web also runs in Microsoft Edge). Google, Apple and Microsoft process account, device and download data for their own store and browser services under their own terms; that processing is not part of Clex’s service and Clex receives none of it.

Apart from the processors and the distributors named above, no other service receives data from Clex products in normal operation. On-device components process data locally and do not transmit data to any external party.

8. Infrastructure and Data Residency

Clex’s services run on servers operated by Hetzner Online GmbH in Germany. In front of them sits an edge network operated by BunnyWay d.o.o. (Slovenia) that delivers model and language files, protects the services against attack and answers DNS queries; it is configured to route traffic within the EU only. Both companies process data for Clex as processors under written agreements. Everything Clex manages is processed within the EU.

Key points:

• No data Clex manages is transferred outside the EU for processing; Google, Apple and Microsoft process their own store and browser data under their own terms.
• Edge traffic is routed only through European edge locations, and the edge network writes its access logs with the last part of the visitor’s IP address removed; section 4.6 describes network logging in full.
• The architecture is designed to minimize external service dependencies and to maintain EU-only data residency for all server-side operations.

9. Data Security

All communications between Clex products and Clex-managed servers are encrypted in transit. Server infrastructure is protected using industry-standard security controls.

While we apply commercially reasonable security measures, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security, but we design our systems to minimize the data that is exposed in the first place.

10. Data Retention

• Text you write, dictate or have read aloud is held in device or browser memory only and is discarded when the field or session ends. It is never held on Clex servers, because it is never sent there.
• An unsent daily report stays on the device or in the browser until it is uploaded, at most 14 days, and is deleted immediately if you switch statistics off.
• A received daily report is validated and added to the organisation’s totals on arrival; the individual report is not kept.
• The report number used to discard duplicates is kept at most 15 days after the report arrives.
• Organisation daily totals carry no identifier for any person and are deleted 24 months after the day they describe, and sooner if the organisation asks or its contract ends.
• Licence validation records are retained for the duration of the customer contract.
• Edge access logs are kept for 72 hours on a rolling basis, with the last part of the IP address removed, and are not forwarded or archived.
• Server backups of licence and statistics data are encrypted, held in the EU and under Clex’s control. A deleted record leaves the most recent backups within 48 hours and every backup within 72 days.
• Contact form submissions are retained for as long as needed to respond to and follow up on the inquiry, after which they are deleted.

11. Your Rights Under the GDPR

Where the conditions in the GDPR are met you have the right to access, rectify, erase and restrict the processing of personal data about you, and to object to processing based on Article 6(1)(f); the simplest way to object to the usage statistics is to switch them off in the settings. The right to data portability applies only to processing based on consent or contract; of Clex’s own processing, only the website contact form rests on contract, and you can ask us for a copy of what you sent through it. Because usage statistics are counted per organisation and carry no identifier for a person, Clex cannot look up data about an individual in them (Article 11); your organisation can ask Clex to delete all totals belonging to it. Contact: Email us. You can also complain to Datatilsynet (or, in Sweden, Integritetsskyddsmyndigheten).

You also have the right to lodge a complaint with your supervisory authority:

11.1 Special Categories of Personal Data (Article 9)

Clex is developed as reading and writing support, and it is rolled out to whole teams and used by people with and without reading or writing difficulties. Clex does not ask for, record or infer a diagnosis, and the usage statistics are never linked to a person, device or installation, so Clex cannot derive anything about an individual from them. If your organisation itself links the use of Clex to a named employee, for example as an agreed workplace accommodation, that is your organisation’s own processing and your organisation assesses its legal basis under Article 6 and, where relevant, Article 9. Counting per organisation, reading only organisation totals and the short life of the report number are safeguards, not a legal basis.

12. Children’s Privacy

Clex products are designed for use by professional care workers in an organizational context. They are not intended for use by children. We do not knowingly collect information from children under the age of 16.

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the effective date at the top of this document and post the revised version on our website. Superseded versions remain available: the version effective 20 August 2026 is archived here, the version effective 18 August 2026 here, the version effective 11 August 2026 here, and the version effective 4 August 2026 here. We encourage you to review this policy periodically.

14. Contact

If you have any questions about this Privacy Policy or how we handle data, please contact us: