Clue is a menstrual-cycle, ovulation, and pregnancy tracking app made by BioWink GmbH, a private company registered in Berlin, Germany (Amtsgericht Berlin-Charlottenburg, HRB 146666 B), with Clue Plus as a paid subscription tier. Clue's Privacy Policy states the sensitive health data users track is 'never shared with or sold to advertisers' and describes data-minimization principles, an appointed data protection officer, and processor vetting intended to limit exposure to non-EU government surveillance powers. Its Apple App Store privacy label nonetheless discloses a broad set of data categories linked to identity by default -- including Health & Fitness, Location, Contact Info, and Sensitive Info -- used partly for the developer's advertising/marketing purposes, and separately discloses that Identifiers may be used to track users across other companies' apps and websites, consistent with the policy's own disclosure that Clue shares device identifiers via Adjust with ad networks including Meta, TikTok, Google Ads, and Apple Search Ads for install-attribution and campaign optimization. No FTC, state-AG, or other regulator action against Clue or BioWink GmbH was found in this research.
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Clue's Apple App Store privacy label lists a broad set of data categories 'Linked to You' by default, including Health & Fitness, Location (coarse), Contact Info (email address, name), Identifiers (device ID), Usage Data, and Sensitive Info, with some of this data used for the developer's own Advertising or Marketing purposes alongside Analytics and Product Personalization.
Clue's Privacy Policy states its products and services are designed to collect only the data necessary to provide its services, and that data is only collected and processed for the purposes outlined in the policy; the same policy's advertising-optimization sections (3.7-3.8) separately disclose that Clue processes usage data and device/technical identifiers (device ID, IP address) specifically to analyze how its advertising performs -- collection beyond the core cycle-tracking feature.
Clue's own Legal Note (imprint) page names BioWink GmbH, registered address Adalbertstraße 7-8, 10999 Berlin, Germany, as the operating company, with Rhiannon White named as Managing Director and a specific German commercial-register citation: Amtsgericht Berlin-Charlottenburg, HRB 146666 B.
Clue's Privacy Policy names BioWink GmbH at the same Berlin address given in the imprint as the company that makes Clue, and states Clue has an appointed data protection officer reachable via a named contact address.
Clue's Privacy Policy states the sensitive health data users track in the app is never shared with or sold to advertisers, with only a minimal amount of technical data shared with advertising networks (e.g. to avoid showing an install ad to an existing user or subscriber); the policy separately discloses that its Standard Contractual Clauses for international transfers do not bind the governmental bodies of a processor's home country, and states Clue avoids processors in countries where it is concerned about the rule of law with respect to privacy.
Clue's Privacy Policy states, as one of its published 'key facts about your privacy,' that the security of its servers is routinely verified by experts to protect data from unauthorized access, and that Clue does not engage in any automated decision-making or profiling activities -- self-reported structural commitments rather than a named third-party audit; no regulator action or breach involving Clue or BioWink GmbH was found in this research.
Clue's Apple App Store privacy label states that Identifiers collected by the app may be used to track users across apps and websites owned by other companies, i.e. cross-app/cross-site tracking is disclosed for default use of the app.
Clue's Privacy Policy names Apple Search Ads, Google Ads, and Adjust as third-party providers used for advertising efforts, and states Adjust uses a user's advertising identifier (Apple IDFA on iOS, Google Play Services ID on Android) and IP address to share standard app events -- such as Clue app installation or Clue Plus subscription -- with advertisement networks including Meta and TikTok, to avoid re-showing install ads to existing users.