Clue
Weighted across nine legal categories. Lower is worse.
Executive summary
Clue's Terms present a reasonable framework for a reproductive health tracking app, with transparent pricing and clear medical disclaimers. However, the contract exhibits significant imbalance in account termination rights (company can terminate without notice at its sole discretion), vague authority to modify non-material terms silently, and inconvenient exclusive venue in Berlin for non-German users. Positive elements include the absence of indemnification clauses, preservation of mandatory legal rights, and clear auto-renewal disclosures. Data practices reference a separate privacy policy and comply with German law. Overall, the app is safer than many platforms but includes several provisions that favor the operator.
Category breakdown
Acceptance of Terms & Scope
Contract formation and service boundaries
Clear, prominent terms with appropriate scope definition and plain-language explanations. Age requirement (18 years for paid services) is explicit. Acceptance method is straightforward (agreement by using the service or clicking confirmation). The scope is well-defined: menstrual and reproductive health tracking with free and paid features. Multiple language translations available with English as authoritative version.
Key findings
- Age requirement clearly stated and enforced (18+ for paid services)
- Acceptance mechanism is clear and unambiguous
- Scope limited to specific health tracking domain
- Plain language used throughout with definitions provided
- Medical disclaimer prominently placed
Evidence from the document
These Terms of Service govern the Clue mobile application including all services provided through the Clue App and the Clue website
you must be at least 18 years old to use Clue's Paid Services
By using the Clue Services, you agree to these Terms
Clue is intended to be used as an application on mobile devices
Recommendations
- Review the referenced Privacy Policy (helloclue.com/privacy) to understand full data practices
- Ensure you understand the distinction between medical advice (not provided) and health insights (provided)
- Confirm you are 18+ or have parental consent if using paid services
User Accounts
Registration, suspension, and termination
Account registration is straightforward and secure with multiple options (email/password or social login). However, account termination rights are heavily tilted toward the company with extreme discretion and no notice requirement. Clue reserves the right to terminate 'at our sole discretion and without further notice,' creating significant risk of sudden access loss. No appeal process or clear termination criteria exist beyond vague references to 'good cause.' Payment failures trigger immediate blocking of paid services. While users can export data from free accounts, no explicit data retention guarantees are provided upon termination.
Key findings
- Registration clear and user-friendly (email, Apple, Google, or Facebook login)
- Company termination right is unrestricted and requires no notice
- No appeal process or pre-termination notice period for free accounts
- Payment failure can trigger immediate access blocking
- Limited information on data deletion upon account termination
- Account deletion requires accessing app (no account recovery option described)
Evidence from the document
We too may terminate the contract at our sole discretion and without further notice
If payment cannot be collected, we will be entitled to block access to the relevant Paid Services
The statutory right of both contracting parties to terminate the contract for good cause remains unaffected
you may terminate the contractual relationship with us at any time by deleting your account
Recommendations
- Regularly back up your data by using the app's export feature before account deletion
- Maintain active payment method to avoid service blocking on paid subscriptions
- Document important cycle data externally in case of unexpected account termination
- For paid services, understand the 24-hour cancellation notice requirement and use it appropriately
Intellectual Property & UGC
Content ownership and licensing
The document does not claim ownership of user data, which is positive. Users retain control of their cycle and tracking information stored in the app. However, Clue grants itself broad rights to use 'anonymous information' from user data for research and service improvement without explicit per-use consent. The scope and definition of 'anonymous' are vague. Clue's own content (app software, health articles, educational materials) is strictly copyrighted with no right of modification or redistribution. User liability for personal data security is explicitly placed on users themselves.
Key findings
- Users retain ownership and control of personal cycle and health data
- Clue grants itself broad rights to use anonymous/de-identified data for research and improvement
- Definition of 'anonymous' data is not specified in the T&C (see privacy policy)
- Clue content is protected by copyright with no user modification rights
- Users are solely responsible for data security within the app
- App is non-exclusive, non-transferable license for personal use only
- No revenue sharing for research use of de-identified data
Evidence from the document
We use anonymous information from your usage of the Clue Services to continue to improve them and for scientific research
you are solely responsible for the security of your personal user content
grant us permission to use your anonymous information to improve the Clue Services for all users
The Clue app is a copyright protected software program. You as a user are granted a simple, non-exclusive, non-transferable and revocable right
Recommendations
- Understand that Clue uses your aggregated, anonymized data for research and product improvement
- Do not rely on the app as your only record; maintain external backups of important health data
- Recognize you cannot share, redistribute, or commercially use the app or its content
- Review the Privacy Policy for specifics on what 'anonymous' means and data retention practices
Data Privacy
Data collection, usage, and protection
The document references a comprehensive Privacy Policy and confirms data processing requires consent under applicable laws (GDPR, German law). Sensitive health data collection is explicit and transparent. However, the full privacy framework is relegated to an external document not included in the T&C. Third-party data sharing occurs with payment processors (Paddle for web, app stores, Flex for FSA/HSA), wearable device partners, and benefit program partners. Users must opt in to partnerships but data about activity status is shared with benefit partners. No explicit data deletion guarantee is stated, though German law likely provides protections.
Key findings
- Data collection requires explicit consent under data protection laws
- Sensitive health data including cycles, medications, and pregnancy tracked
- Third parties handle payments and store payment details (Clue does not store)
- Partnership program sharing: activity status shared with partner programs
- Wearable device data synchronized and retained even after subscription ends (30-day grace)
- Anonymous data used for research; definition of anonymous not specified in T&C
- German law applies; GDPR compliance referenced but not detailed in T&C
Evidence from the document
the Privacy Policy details your and our respective rights and obligations in connection with applicable data protection laws, in particular regarding the processing of your sensitive health data
Clue will receive your partnership or benefit program ID; Clue may also share with your Partner whether you have been active in the Clue app
Clue does not store your payment information at any time
if you have any doubt as to whether the information is appropriate for your individual situation, please consult your healthcare provider
Recommendations
- Carefully review the full Privacy Policy at helloclue.com/privacy before using the app
- Understand that payment details are stored by Paddle or Flex, not Clue
- Be aware that wearable device integration shares data with wearable partners
- If using benefits/partnership features, understand your activity status will be shared
- Exercise your right of revocation within 14 days if you wish to cancel (German law)
Payment & Subscriptions
Billing and subscription management
Auto-renewal is clearly disclosed with transparent pricing shown before purchase. Cancellation is straightforward with a 24-hour notice period to end of billing month, matching state auto-renewal law standards. Access continues through the current billing period after cancellation. However, users risk double-billing if subscribing via web while an app subscription is active (company explicitly allows this and requires user to wait for app subscription to expire). Payment blocking on failed collection occurs without notice period. FSA/HSA purchases flow through a different processor (Flex) than regular subscriptions (Paddle), adding complexity. Revocation rights (14 days) are provided under German law.
Key findings
- Auto-renewal clearly stated with indefinite duration after initial term
- 24-hour cancellation notice period (complies with FTC guidance)
- Prices shown before purchase; fees transparent
- Double-subscription risk if signing up via multiple channels simultaneously
- Access continues until subscription expiration after cancellation
- Payment processing by third parties (Paddle, Flex); Clue does not store payment data
- Payment failure triggers immediate access blocking without notice
- 14-day revocation right under German law
- One-time purchases (Doctor's Report) do not auto-renew
Evidence from the document
automatically be renewed for an indefinite time at the end of your initial subscription period, unless we or you have cancelled your subscription
you may cancel your subscription with a notice period of at least 24 hours to the end of each subscription month
you might end up with two active subscriptions at the same time
If you cancel your subscription, remember that you will still have access to all Paid Services features and modes until your subscription runs out
Recommendations
- Cancel subscriptions at least 24 hours before billing date to avoid unintended renewal
- If subscribing via app, cancel app subscription before purchasing web subscription (or vice versa)
- Maintain active payment method to avoid service blocking
- For web subscriptions, manage cancellation through Paddle (help@paddle.com) not through the app
- If eligible, FSA/HSA payments should be managed through Flex support
- Consider using your app store's cancellation features if subscribing via Apple or Google
Limitation of Liability
Risk allocation and legal protection
Liability is limited to actual damages in four specific circumstances: (1) intentional or gross negligent acts by the company, (2) personal injury from breach of duty, (3) product liability or fraud, and (4) breach of fundamental contractual obligations. Liability for these cases is unlimited. For all other claims, liability is excluded. The limitation preserves mandatory rights and makes clear this is general health information, not medical advice. Medical disclaimers are prominent and comprehensive. However, the broad exclusion of liability for service failures and other claims is one-sided. Data breach liability is not explicitly addressed (German law may apply).
Key findings
- Liability limited but carve-outs exist for gross negligence and personal injury
- All company-provided content is general health information, not medical advice
- Health estimates are explicitly described as inherently approximate
- Medical disclaimers are clear and repeated in multiple sections
- Mandatory law rights cannot be excluded
- Liability for most other claims is completely excluded
- No explicit coverage for data breach liability
- Users are responsible for data security within their own devices
Evidence from the document
The Clue Services are not intended to provide medical advice
Clue is no substitute for a consultation with your healthcare provider
These estimates are inherently approximate and may not precisely reflect your individual experience
Our liability for other claims is excluded
Nothing in this section limits or excludes any right that cannot lawfully be excluded
Recommendations
- Do not rely on Clue for medical diagnosis or treatment decisions
- Always consult qualified healthcare providers for specific health concerns
- Understand that cycle predictions and fertile window estimates are approximate
- Do not use Clue as a guaranteed contraception method
- Recognize that Clue cannot be held liable for most service failures
- Maintain backup access to your health information outside the app
Indemnification
Legal responsibility allocation
The document does NOT contain a user indemnification clause. This is a significant positive element, as many digital service agreements require users to defend and indemnify the company against third-party claims. Instead, the document contains usage restrictions (prohibiting sharing access credentials, bypassing access controls, removing copyright notices) but does not shift legal liability back to users through indemnification. This represents a favorable consumer outcome and indicates the company is not attempting to make users liable for its own potential legal claims.
Key findings
- No user indemnification clause present in the document
- No requirement for users to defend the company against third-party claims
- No requirement to pay the company's legal fees or damages
- Usage restrictions exist (access credentials, copyright notices) but these are limitations, not indemnification
- Company bears its own liability for its actions and services
Evidence from the document
You are not permitted to make the access data sent or used for authentication and identification available to third parties
bypass the access control systems of paid services or to take other measures in order to use services without authorization
Recommendations
- This is a positive absence; note that you are NOT required to insure the company against claims
- Comply with the stated usage restrictions (do not share credentials, do not bypass access controls)
- If you violate the usage restrictions, the company may take action but you have no blanket indemnity obligation
Modification of Terms
How agreements can be changed
Material changes to Paid Services require company consent and are defined as changes to service type/scope, duration, or termination. However, the company can make non-material changes 'at any time' without notice or explanation. The distinction between material and non-material is left entirely to the company's discretion, and improvements and new features fall into the non-material category that requires no notice. This creates substantial risk: price changes, feature removals, or privacy policy changes could theoretically occur without notification. No version history is maintained. No retroactivity language is present. No opt-out or exit rights are provided for unfavorable changes.
Key findings
- Material changes to Paid Services require consent (narrowly defined)
- Non-material changes can be made without notice or explanation
- Company unilaterally determines what is material vs. non-material
- Improvements and new features do not require user consent even if material in impact
- No version history, changelog, or dated revisions maintained
- No prospective-only application stated for changes
- No user opt-out or exit rights for rejected changes (except free account deletion)
Evidence from the document
We may make non-material amendments to these Terms at any time. We may implement non-material changes without notice or stating further reasons
this does not prevent us from improving our services or including additional features
We are entitled at any time to change or remove content, services and functionalities
to paywalling all or certain services that were previously free of charge
Recommendations
- Periodically check the terms page (last updated June 25, 2026) for significant changes
- Be aware that service changes, feature removals, or paywalling can occur without notice
- For critical health data, maintain external backups in case the app is discontinued
- If you disagree with non-material changes, your only recourse is to delete your account
- Pay attention to in-app notifications or emails that may hint at upcoming changes
Governing Law & Disputes
Jurisdiction and conflict resolution
Disputes are governed by German law and heard in Berlin courts, with no mandatory arbitration or class action waiver. This is positive for access to justice. However, the exclusive venue in Berlin is highly inconvenient for users outside Germany. The company can also sue users in their home jurisdiction, creating asymmetry. No small claims court carve-out is explicitly mentioned (though German law may provide one). Dispute resolution options are limited; the company explicitly declines to participate in consumer arbitration bodies. French users have access to consumer mediation (AME CONSO). Mandatory law rights are preserved.
Key findings
- German law governs all disputes (GDPR-compliant, consumer-protective)
- Exclusive venue in Berlin, Germany courts
- Company asymmetrically entitled to sue users in their home jurisdiction
- No mandatory arbitration clause
- No class action waiver
- No jury trial waiver
- Company refuses to participate in consumer arbitration bodies
- French users have access to free mediation (AME CONSO)
- Mandatory law rights explicitly preserved
Evidence from the document
all disputes arising under these Terms shall be heard in the courts of our registered place of business in Berlin, Germany
Governing law: German law applies to the exclusion of the UN Convention
We are neither obliged nor willing to participate in dispute resolution proceedings before a consumer arbitration body
Your rights under applicable mandatory law are not affected
Recommendations
- Understand that disputes must be resolved in German courts (unless company sues you locally)
- For significant disputes, consider consulting legal counsel familiar with German law
- If you are a French user, take advantage of free mediation (AME CONSO) before litigation
- Document all interactions with Clue support in writing for dispute evidence
- Preserve emails and in-app messages as evidence of your agreement and claims
Ex-TerCo provides automated analysis of legal documents for informational purposes. This is not legal advice. Terms can change at any time.