Legal
Privacy Policy
Last updated: June 20, 2026
This Privacy Policy is currently under review by legal counsel and may be updated. Operated by Lucas Barrios.
This Privacy Policy explains what personal data Klar collects, why, and how it's protected, in plain language. For the legal terms governing your use of Klar generally, see our Terms of Service.
1.What Data We Collect
When you complete the Germany Readiness Diagnostic, we collect: your name, email, country, age, German and English level, education level, field of study, work experience, your timeline, your financial situation, your current location, and any additional context you choose to share.
If you purchase the Germany Application Kit and generate documents, we additionally process whatever details you choose to add — for example, an employer name, address, or phone number you enter to complete your CV.
We never ask for more than what's needed to assess your readiness or generate your documents.
2.Why We Collect It, and Our Legal Basis
We process your data to deliver the service you've asked for — generating your Diagnostic, matching you to real positions, and drafting your application documents. Under GDPR, this is processed on the basis of performance of a contract (Article 6(1)(b)): you've asked us to provide this assessment, and we need this information to do it.
Where you've explicitly checked a consent box on the intake form, we also rely on your explicit consent (Article 6(1)(a)) for that specific processing.
We keep an internal audit record of key actions (such as a diagnostic being approved) as a legal obligation under the EU AI Act's transparency and record-keeping requirements (Article 6(1)(c)).
3.Human Review — Not a Fully Automated Decision
Your Diagnostic score is generated by AI, but it is always reviewed by a human consultant before it reaches you. This is not a solely automated decision under GDPR Article 22 — a person reviews and approves every result.
4.Who We Share Your Data With
We use a small number of carefully chosen service providers to operate Klar. None of them are permitted to use your data for their own purposes.
| Service | What it does | Where | Data shared |
|---|---|---|---|
| Anthropic | Generates your Diagnostic score and documents | United States | Your profile information, sent for processing only — not stored by Anthropic |
| Supabase | Stores your data | EU (Frankfurt, Germany) | All data you provide |
| Stripe | Processes payment for the Application Kit | United States/Ireland | Payment details only — Klar never sees or stores your card number |
| Resend | Sends you transactional emails (approval notice, payment confirmation) | EU (Ireland) | Your name and email address only |
| LangSmith | Helps us monitor and improve the AI's performance | United States (routed via an EU endpoint) | A version of your request with personal details (name, financial information, address, phone) automatically removed before it's logged |
Where data leaves the EU (Anthropic, Stripe, LangSmith), this is covered by Standard Contractual Clauses, the standard legal mechanism for protecting data transferred outside the EU.
5.How Long We Keep Your Data
We retain your data for 24 months from your last activity with Klar. You can request earlier deletion at any time — see Section 6.
6.Your Rights
You have the right to:
- Access the data we hold about you
- Correct inaccurate data
- Delete your data ("right to erasure")
- Receive a copy of your data in a portable format
- Object to certain processing
To exercise any of these rights, contact us at hello@kairosconsulting.co. We will respond within the timeframe required by GDPR.
7.Security
Your data is protected in transit via HTTPS, stored in an EU-based database with row-level access controls, and accessible only to authorized systems and our reviewing consultant.
8.Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will update the "Last updated" date above.
9.Contact
Questions about this Privacy Policy or your data: hello@kairosconsulting.co