Privacy Policy

CliniPearls — operated by Beverley Care Ltd

Effective date: 26 September 2026

Version: 1.2

In short

• CliniPearls is built for anonymised clinical learning content. It is not designed to hold patient-identifiable information, and you must not enter any.
• We never store your voice recordings. Speech is transcribed on your own device by your browser. No audio file is created, sent to us, or saved.
• We never store your photographs. Images are processed in memory to pull out the text, then discarded. The image is not written to our storage or database.
• Identifiers are removed at the point of extraction, before anything is written to our database.
• Your data is hosted in the European Union (Republic of Ireland).
• Where we use AI, your content is processed under paid terms that mean it is not used to train the provider's models. We never train our own models on it.
• We never sell your information. We only measure how our adverts perform (via Meta) if you say yes — see Sections 6 and 8.
• You can access, correct, export, or delete your data at any time.
• Questions: contact@clinipearls.com

1. Who we are

Beverley Care Ltd, trading as CliniPearls ("we", "us", "our"), operates the CliniPearls service at https://clinipearls.com.

• Registered in England and Wales, company number 15459104
• Registered office: 311 Regents Park Road, London N3 1DP
• Privacy contact: contact@clinipearls.com
• ICO registration reference: C2008011

2. Our data-protection role

For your account information — registration, login, subscription, billing, support, and the operation of the Service — Beverley Care Ltd is the data controller.

For the clinical case content you enter, the Service is designed so that identifiers are removed at the point of extraction and no patient-identifiable information is retained by us. Genuinely anonymised information is not personal data under UK data protection law, so the stored content sits outside those rules.

Content may exist in identifiable form for the moment it takes to process it. For that transient step we act only on your instructions and for no other purpose. You, as the healthcare professional entering the information, are responsible for ensuring that no patient-identifiable information is entered at all (see Section 7 and Section 4 of our Terms of Service).

CliniPearls does not store consultation recordings or identifiable patient records. This policy should not be read as us holding or processing identifiable patient data as a matter of routine, because the Service is not built to receive or retain it.

3. What we collect

Account and subscription information

• your name and email address
• your role or grade, and your specialty if you choose to give it
• your login credentials, stored only as a salted cryptographic hash — we cannot see or recover your password
• your subscription plan, billing period, status, and transaction references

Card payments are handled by Stripe. We do not receive or store your card number, expiry date, or security code.

Content you create

• the anonymised case entries, pearls, notes, reflections, and tags you save
• evidence documents, such as PDF certificates, that you choose to upload

Technical information

• browser and device type, IP address, timestamps, and log and error data used to keep the Service secure, reliable, and working

What we do not collect or keep

• Raw audio. Voice capture uses your browser's built-in speech recognition and produces text only. No audio file is created, transmitted to us, or stored.
• Raw photographs. Images you capture are processed transiently to extract text and then discarded. The image is not written to our storage or database.
• Patient-identifiable information. The Service is not designed to receive it and you must not enter it.
• Special category health data about identifiable patients. By design, none is stored.

4. Why we use it, and our lawful basis

Where we rely on legitimate interests, we have assessed that our interest in running a secure, working, improving service does not override your rights. Ask us and we will explain that assessment.

We do not sell your personal information. We do not make decisions about you by solely automated means that have legal or similarly significant effects.

5. Artificial intelligence

Some features use AI to structure and classify what you capture — turning rough notes into portfolio-ready text, suggesting the assessment type, and removing identifiers.

• The relevant content is processed by Google, using the Gemini API.
• We use a paid API tier under terms that prohibit the use of your content to train Google's models.
• Processing is transient: content is sent, processed, and returned. It is not retained by us in unprocessed form beyond completing the operation.
• Identifier removal happens as part of this step, before the structured result is written to our database.
• We do not train any model of our own on your content, and we do not licence, sell, or share your content for anyone else's model development.
• Our API credentials are held as encrypted secrets and are never exposed to your browser.

AI suggestions are suggestions. You can review, override, and correct them, and you should verify all output before using it.

6. Cookies and local storage

We use a small number of essential cookies and browser storage to keep you signed in, maintain your session, and keep the Service secure. If you block these you will not be able to sign in.

We also cache your data locally on your device so the app is fast and works offline. This cache is scoped to your account and cleared when you sign out, so your data cannot persist into another account on a shared device.

In the UK and EEA, if you allow cookies when asked (or later via Cookie settings in the app), we also use the Meta Pixel and Meta's Conversions API to measure whether our adverts bring new users to CliniPearls. This records a page visit and — for a new user who completes setup — that a registration happened. With your consent, Meta may receive your IP address, browser and device information, Meta measurement cookies (_fbp and _fbc where available), and a one-way hashed account identifier. Meta may combine this with its own profile of you, governed by Meta's terms. This happens only with your consent: if you decline (or haven't chosen), none of this tracking runs and no data is sent to Meta for measurement. We never send your email address or your clinical content to Meta. If you withdraw consent, later events are not sent, and events already sent are not recalled.

With the same consent, we also use the Gravity pixel (trygravity.ai) to measure advert performance. It records a page visit and, for a new user who completes setup, that a registration happened; Gravity may receive your IP address and browser and device information. We never send your email address or clinical content to Gravity, and it does not run if you decline.

7. Anonymisation and your responsibilities

CliniPearls is for anonymised professional-development content. As the healthcare professional entering information, you are responsible for ensuring that no patient-identifiable information is entered, and for reviewing content to confirm it is genuinely anonymised before you save or export it.

Our technical measures support anonymisation. They do not guarantee it. This mirrors Section 4 of our Terms of Service and your own professional duty of confidentiality, including GMC guidance.

8. Who we share information with

We share information only where it is necessary to run the Service, with providers acting on our instructions under written contracts that meet UK GDPR Article 28 requirements:

We may also disclose information to our professional advisers where necessary, where the law or a regulator requires it, to protect our rights or the safety and integrity of the Service, or to a buyer or successor if the business is sold or reorganised — in that last case subject to equivalent protections.

We do not sell your personal information to anyone.

9. Where your data is held, and international transfers

Your database, authentication, and stored files are hosted in the European Union (Republic of Ireland). Transfers between the UK and the EU are covered by UK adequacy arrangements.

Some providers, notably Google and Stripe, may process data outside the UK and EEA. Where that happens we rely on one or more of:

• UK adequacy regulations or an EU adequacy decision;
• the UK International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses;
• the EU Standard Contractual Clauses, together with a transfer risk assessment.

Ask us at contact@clinipearls.com for details of the safeguards in place.

10. How long we keep things

Your accumulated case history is the value you build in CliniPearls, so we do not delete it while your account is active. Export anything you need before closing your account.

11. Security

We use technical and organisational measures appropriate to the risk, including encrypted connections, encryption at rest, row-level security so each account can only reach its own records, private storage for uploaded files, and hashed passwords. Our Security Statement sets this out in full.

No system is perfectly secure. Help us by using a strong unique password, keeping your device secure, and signing out on shared computers.

If a personal data breach occurs that is likely to risk your rights and freedoms, we will report it to the ICO within 72 hours of becoming aware and tell you without undue delay where the risk is high.

12. Your rights

You have the right to:

• know how we use your data — this policy;
• access a copy of your personal data;
• correct anything inaccurate or incomplete;
• delete your data, where no overriding legal duty applies;
• restrict or object to certain processing, including direct marketing at any time;
• port your data — receive it in a structured, machine-readable format;
• withdraw consent where consent is our basis.

Email contact@clinipearls.com to exercise any of these. We respond within one month. We may ask you to confirm your identity. There is no charge unless a request is manifestly unfounded or excessive.

If you are unhappy with how we have handled your information, you can complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint or on 0303 123 1113. Please contact us first if you can, so we have a chance to put it right.

13. Improving the Service

We analyse aggregated, non-identifying usage information — such as which features are used and where errors occur — to improve reliability and usability. This does not identify you or anyone else.

We do not use your case content for research, and we do not sell information for research.

14. Children

CliniPearls is for professionals and adults. It is not intended for anyone under 18 and we do not knowingly collect information from children. If you believe a child has given us personal data, tell us and we will delete it.

15. Changes to this policy

We may update this policy to reflect changes to the Service or to our legal obligations. The effective date at the top shows the current version. Where a change materially affects how we use your personal data, we will notify you by email or in-app before it takes effect.

16. Contact

Beverley Care Ltd
311 Regents Park Road
London N3 1DP
contact@clinipearls.com

Use this address for all privacy queries, access requests, and deletion requests.