Last updated: 01/07/2026
Clear-State Personal Data Processing Policy
This Policy explains how LLC "KHMARKA" ("Operator", "we", "us") processes personal data of users of the Clear-State AI product.
Clear-State is an AI tool for structured self-reflection in non-crisis situations of emotional tension. Clear-State is not psychotherapy, medical, psychiatric, crisis, or emergency assistance and does not replace consultation with a qualified specialist.
Clear-State is not intended for use in situations of immediate danger, acute psychological crisis, risk of self-harm, suicidal thoughts, violence, threats to the life or health of the user or other persons. In such cases, the user should immediately contact emergency services, crisis services, a doctor, psychotherapist, psychiatrist, or another qualified specialist.
This Policy applies specifically to the use of the Clear-State product. Data processed when visiting the website may be governed by a separate Website Privacy Policy.
1. Who is responsible for data processing
Operator of the Clear-State product: LLC "KHMARKA"
Registration code: 39514910
Address: 4B Verkhnii Val Street, LITERA A, Kyiv, Ukraine 04071
Email for personal data questions: info@khmarka.com.ua
2. What data may be technically processed
When using Clear-State, the user may independently enter:
- text describing the situation;
- answers to clarifying questions from Clear-State;
- thoughts, emotions, assumptions, expectations, or other details that the user decides to describe.
Clear-State does not ask the user to enter their full name, residential address, document numbers, financial data, exact place of work, medical documents, or data of third parties.
For the technical operation of the product, technical data necessary to support the session, security, and proper functioning of the service may also be temporarily processed.
3. Sensitive data
Please do not enter into Clear-State:
- full name, address, document numbers, or bank details;
- medical documents, diagnoses, prescriptions, or detailed medical data;
- information about an acute crisis, risk of self-harm, violence, or an immediate threat to life or health;
- personal data of other people without a proper legal basis.
If the user voluntarily enters such information, they do so at their own risk and understand that Clear-State is not intended for processing crisis-related, medical, or excessively sensitive data.
4. What data is processed for
Data entered by the user into Clear-State is technically processed in order to:
- ensure the operation of the AI interaction;
- generate a response within the active session;
- support the dialogue logic during the current interaction;
- ensure the technical stability and security of the product.
We do not use users' personal data for targeted advertising and do not sell personal data to third parties.
5. Legal bases for processing
Depending on the specific situation, personal data may be processed on the following bases:
- the user's consent;
- the need to provide the user with access to Clear-State in accordance with the Terms of Use;
- the Operator's legitimate interest in ensuring the operation, security, and stability of the product;
- compliance with a legal obligation, if such an obligation applies.
If processing is carried out on the basis of consent, the user may withdraw it at any time. This does not affect the lawfulness of processing carried out before consent was withdrawn.
6. AI processing and automated responses
Clear-State uses artificial intelligence technologies to generate responses based on the information entered by the user.
Clear-State does not make decisions that have legal consequences for the user or similarly significantly affect them. Clear-State responses are informational and reflective in nature and are not medical, psychological, legal, or other professional conclusions.
The user independently decides how to interpret Clear-State responses and whether to take any actions after interacting with the product.
7. Research
Ordinary use of Clear-State does not mean automatic participation by the user in research.
If the user is offered participation in research, such participation must be governed by separate participant information, an informed consent form, and/or a separate research data processing policy.
8. Third-party technology services
Third-party technology services may be used for the operation of Clear-State, including AI/LLM services, cloud infrastructure, security services, or other technical providers.
Such services may technically process data only to the extent necessary for the operation of Clear-State.
9. International data transfers
Since Clear-State may use cloud, AI, and other technology services, technical data processing may take place in countries other than the user's country of residence.
If required by applicable law, we use appropriate safeguards for international data transfers.
10. Data storage
At the current stage, Clear-State does not store users' personal data.
In particular, the Operator does not store:
- texts of dialogues with Clear-State;
- user responses;
- interaction history;
- user profiles;
- a database of personal data of product users.
Data entered by the user into Clear-State is technically processed during the active session to generate a response and is not stored by the Operator after the interaction is completed.
If the operating model of Clear-State changes in the future and the product begins to store any personal data, this Policy will be updated before or simultaneously with the implementation of such change.
11. User rights
Depending on applicable law, the user may have the right to:
- know what personal data is processed and for what purpose;
- access their personal data;
- request correction or deletion of personal data;
- object to certain processing;
- withdraw consent if processing is based on consent;
- lodge a complaint with the competent personal data protection authority.
Since Clear-State at the current stage does not store users' personal data after the session ends, in some cases the Operator may not have the technical ability to identify a specific interaction or provide a copy of the data after the session ends.
For requests regarding personal data, write to us at: info@khmarka.com.ua
12. Data security
We apply reasonable technical and organizational measures to protect data while Clear-State is being used.
At the same time, no online service or method of data transmission over the Internet can be guaranteed to be completely secure.
13. Children's data
Clear-State is intended only for users aged 18 and over.
We do not knowingly collect children's personal data and do not intend Clear-State for use by minors.
If a child or minor, contrary to this Policy and the Terms of Use, independently used Clear-State or entered personal data, the Operator, to the extent permitted by applicable law, is not responsible for such use, data entry, or the consequences of such use.
If you believe that a child has used Clear-State or provided personal data, please contact us.
14. Data of third parties
The user must not enter personal data of other persons into Clear-State without a proper legal basis or their consent.
If the user enters personal data of other persons into Clear-State, the user is independently responsible for having a proper legal basis for such entry and processing.
The Operator, to the extent permitted by applicable law, is not responsible for the user's entry of personal data of third parties without a proper legal basis, consent, or other lawful permission.
15. Changes to this Policy
We may update this Policy from time to time.
The current version will be published on the website with the date of the last update indicated.
16. Contacts
For questions about this Policy or the processing of personal data, please contact:
Email: info@khmarka.com.ua