We, CFT Clear Finance Technology Corp., its affiliates, subsidiaries,
assigns and successors (collectively, “Clearco”, “we”, “us” or “our”)
are committed to protecting your privacy and your personal data. This
Privacy Policy (“Policy”) will provide you transparency on the personal
data we collect, how we secure it and your rights available under law.
Personal data means any information relating to an identified or
identifiable natural person (“Personal Data”). If your information is
aggregated, de-identified or anonymized, and it is no longer reasonably
associated with an identified or identifiable natural person, we may use
such information for any business, research, or statistical purposes.
This Policy applies to all websites, devices, and applications that we
operate (including mobile applications), pages within or associated with
each such websites, devices, and applications, and any equivalent,
mirror, replacement, substitute or backup to such websites, devices, and
applications (“Sites”). This Policy further applies when you access or
use our Sites, or our products, services, tools, and functions offered
or made available by us, whether online (including via the Site or a
mobile application) or in-person, or when you sign up to our
newsletters, or when you otherwise interact with us (“Services”).
If you have any additional business agreements with us, to the extent
there is a conflict between this Policy and such business agreement,
then the terms of such business agreement will prevail over this Policy
with respect to such specific Services.
It is important you read and understand this Policy along with our
Terms of Service. If you do not agree to or do not
have the authority to agree to this Policy or Terms of Service, you may
not access or use our Sites or our Services.
To enable you to better understand how we handle your Personal Data,
this Policy details:
When you access or use our Service, we collect information including
Personal Data from you, through automatic methods or from third
parties. We only collect the minimum necessary Personal Data to
provide our Services.
Information you provide:
Your Identity and Contact information include full name, email
address, mailing address, phone number, password, date of birth,
social security/social insurance number/national identification/
taxpayer identification number, citizenship, job title and if you
are an authorized signatory to enable us to identify and register
you for our Services.
Your Business Information such as type of business, registered and
business addresses, financial statements, organizational
documents, organizational information, beneficial ownership
information, director and employee information, sales volumes, to
better understand your business and your business needs.
Your Banking Information such as bank statements, banking and
payment history, credit card information to evaluate your revenue
and financial position.
Your preferred third-party vendors, websites, or internet services
(“Third Party Sites”) to enable us to register, set up vendor
accounts or provide specific Services.
Your Profile Information and User Preferences such as preferred
Services, your interests, feedback, survey responses to customize
your preferences.
Your Marketing and Communication Preferences such as subscription
to our newsletters and blogs to provide you information about
Clearco and our Services.
Your employment application including your resume, contact
details, employment history, and education to evaluate your job
application.
Your personal testimonials including your name as a customer of
our Services.
Information we automatically collect:
We use cookies, web beacons and other similar technology to
collect information to support the integrity of our registration
process, retain your preferences and account settings, count
visits, and help evaluate and compile aggregated statistics about
user activity.
We may collect your computer browser type, geolocation, Internet
protocol address, pages visited, and average time spent on our
Sites. This information may be used, for example, to alert you to
software compatibility issues, or it may be analyzed to improve
our web and mobile application design and functionality.
When you use the mobile versions of our Sites, we may collect the
unique device identifier assigned to that device by phone makers,
carriers, or makers of the operating system (the “Device ID”) to
uniquely identify your device for purposes of storing application
preferences, user activities and other data.
Information we receive from third parties:
We may collect, on your behalf, your account and other Personal
Data from Third Party Sites that you register under your account
via the Services including providers of payment and delivery
services.
We may use third parties to gather your Personal Data, Business
Information and Banking Information from financial institutions or
registered agents to provide Services.
We may collect information from our business partners, referral
service providers, analytics providers and search information
providers about your interests and preferences.
We may also collect information about you from mailing list
providers, publicly available sources, and other third parties,
including to process and manage your application and transactions.
We may allow third party service providers to use cookies (as
noted above) or other tracking technologies to collect information
about your browsing activities over time and across different
websites following your use of our Sites.
We may obtain Personal Data from recruiters or other entities as
part of background checks for an employment opportunity with
Clearco.
Our legal basis to process your Personal Data are:
Contract: to enable us to enter into a contract with you or to
perform and fulfill our contractual obligations
Legitimate Interest: as detailed in “How we use your information”,
Legal or regulatory obligations: to comply with our legal and
regulatory obligations.
Except in relation to your marketing or cookie preferences, we do
not rely on consent as a legal basis for processing your Personal
Data.
We will not reuse your Personal Data for a new purpose other than
the aforesaid original one(s) for which it was collected, unless one
or more of the following apply:
the new use is compatible with the original use such that you
would reasonably expect such a similar use.
we have notified you of the new use and given you an opportunity
to authorize it; or
the new use is otherwise permitted or required by law.
We may share your Personal Data with the parties set out below:
Internal Third Parties: These third parties include our
subsidiaries and affiliates
External Third Parties: These third parties include our service
providers, agents, subcontractors, consultants, insurance
providers, financial institutions, funders, payment processors,
business partners, referral partners, recruiters, governmental
entities (to respond to a request, subpoenas, registrations, or
legal processes) or other third parties (as required by law, to
comply with our legal and regulatory obligations, or to protect
and secure our interests, rights, and our assets)
Third parties to whom we may choose to sell, transfer or merge
parts of our business or our assets.
We require all third parties to respect the security of your
Personal Data and to treat it in accordance with the law in your
jurisdiction. We do not allow our third-party service providers to
use your Personal Data for their own purposes and only permit them
to process your Personal Data for specified purposes and in
accordance with our instructions.
We may transfer your Personal Data from your current location to the
offices and servers of Clearco and to our authorized third parties
located in the United States and Canada.
Whenever we transfer your Personal Data out of Australia, United
Kingdom (“UK”), Switzerland or European Union (“EU”), we ensure a
similar degree of protection is afforded to it by ensuring at least
one of the following safeguards is implemented:
We will only transfer your Personal Data to countries that have
been deemed to provide an adequate level of protection for
personal information.
Where we use certain service providers, we may use specific
contracts approved for use in Australia, UK, Switzerland, or EU
(as applicable) which give personal information the same
protection it has in Australia, UK, Switzerland, or EU (as
applicable).
Please contact us if you want further information on the specific
mechanism used by us when transferring your Personal Data out of
Australia, UK, Switzerland, or the EU.
We will only retain your Personal Data for as long as reasonably
necessary to fulfil the purposes we collected it for, including for
the purposes of satisfying any legal, regulatory, administrative,
security, compliance, contractual, tax, accounting, or reporting
requirements. We may retain your Personal Data for a longer period
in the event of a complaint or if we reasonably believe there is a
prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for Personal Data, we
consider the amount, nature and sensitivity of the Personal Data,
the potential risk of harm from unauthorised use or disclosure of
your Personal Data, the purposes for which we process your Personal
Data and whether we can achieve those purposes through other means,
and the applicable legal, regulatory, tax, accounting, or other
requirements.
We will continue to retain certain information about our customers
for seven (7) years after they cease being customers in accordance
with applicable laws. In some circumstances you can ask us to delete
your Personal Data: see
Request to erase your Personal Data
below for further information.
We take reasonable measures, including firewall barriers, SSL/TLS
encryption techniques, and authentication procedures, to help
protect your Personal Data from accidental loss, theft, misuse, and
unauthorized access, disclosure, alteration, and destruction. In
addition, we limit access to your Personal Data to those employees,
agents, contractors and other third parties who have a business need
to know. They will only process your personal data on our
instructions, and they are subject to a duty of confidentiality. We
have put in place procedures to deal with any suspected personal
data breach and will notify you and any applicable regulator of a
breach where we are legally required to do so.
As the internet or email transmission is not fully secure or error
free, email sent to or from the Services may not be secure.
Therefore, you should take special care in deciding what information
you send us via email. Please keep this in mind when disclosing your
Personal Data to Clearco via the internet. We encourage you to
disclose any suspected security vulnerabilities or bugs to our
security team at [email protected].
Under certain circumstances, you have rights under data protection
laws in relation to your Personal Data. Your rights may provide:
This enables you to receive a copy of your Personal Data we hold.
This enables you to correct any incomplete or inaccurate data we
hold about you, though we may need to verify the accuracy of the
new data you provide to us.
This enables you to ask us to delete or remove Personal Data where
we are no longer required to hold it. You also have the right to
ask us to delete or remove your Personal Data where you have
successfully exercised your right to
. Note, however, that we may not always be able to comply with
your request of erasure for specific legal reasons which will be
notified to you, if applicable, at the time of your request.
This enables you to object to processing of your Personal Data
when it is based on our legitimate interest or those of a third
party. You also have the right to object where we are processing
your Personal Data for direct marketing purposes.
This enables you to ask us to suspend the processing of your
Personal Data in certain circumstances such as establishing the
accuracy of your Personal Data, but you do not want to erase it,
where you require us to hold the Personal Data to establish,
exercise or defend legal claims etc.
This enables you to request transfer of your Personal Data to you
or (if technically feasible) any third party in a commonly used
machine-readable format. Note that these rights only apply to
Personal Data which you initially provided us. Certain Personal
Data will need to be retained for administrative, legal, security
or other legitimate business purposes.
This enables you to withdraw consent at any time where we are
relying on consent to process your Personal Data. However, this
will not affect the lawfulness of any processing carried out
before you withdraw your consent. If you withdraw your consent, we
may not be able to provide certain Services to you.
What we may need from you
We will handle your requests and rights in accordance with
applicable law. This means there may be legal reasons why we cannot
fulfil all requests. We may need to request specific information
from you to help us confirm your identity and ensure your right to
access your Personal Data (or to exercise any of your other rights).
This is a security measure to ensure that Personal Data is not
disclosed to any person who has no right to receive it. We may also
contact you to ask you for further information in relation to your
request to speed up our response.
No fee required
You will not have to pay a fee to access your Personal Data (or to
exercise any of the other rights). However, we may charge a
reasonable fee if your request is clearly unfounded, repetitive, or
excessive. Alternatively, we could refuse to comply with your
request in these circumstances.
Time limit to respond
We try to respond to all legitimate requests within one month.
Occasionally it could take us longer than a month if your request is
particularly complex or you have made a number of requests. In this
case, we will notify you and keep you updated.
This Policy applies to residents of California as required under the
California Consumer Privacy Act (“CCPA”). The below provides
California residents the right to know the categories of Personal
Data collected and whether Clearco disclosed your Personal Data for
business purposes in the preceding twelve (12) months:
CATEGORIES OF PERSONAL DATA COLLECTED
CATEGORIES OF THIRD PARTIES THAT PERSONAL DATA IS DISCLOSED TO FOR A BUSINESS PURPOSE
- Your Identity and Contact Information
- Your Profile Information and User Preferences
- Your Marketing and Communication Preferences
Internal and External Third parties
- Business and Banking Information
Internal and External Third parties
- Internet activity or other electronic network activity information
Internal and External Third parties
- Geolocation data
Internal and External Third parties
- Employment or recruiting related information
Internal and External Third parties
The categories of sources from which we collect Personal Data, our
purposes for using your Personal Data as well as your rights to
access,
rectify
and
erase
your Personal Data are set forth above in this Policy.
Clearco does not “sell” your Personal Data, nor do we have actual
knowledge of any sale of personal information of minors under 18
years of age. Clearco will not discriminate against any individual
for exercising their rights under the CCPA. In the event you require
an authorized agent to act on your behalf to make a verifiable
request related to your Personal Data, please contact us at
[email protected]. We request that sufficient detail be provided to
reasonably verify you or your authorized agent. If you would like to
exercise any of your rights under the CCPA, please contact us at
[email protected].
Marketing, Communications & Cookies
We may provide our registered customers with summaries of their
account information, SMS/text messages and email alerts. We may also
allow you to subscribe to email newsletters and from time to time
may transmit SMS/text messages and emails promoting Clearco or
third-party goods or services. You will receive marketing
communications from us if you have requested information from us or
received Services from us and you have not opted out of receiving
that marketing communication.
You can also set your browser to refuse all or some browser cookies,
or to alert you when our Sites set or access cookies. If you disable
or refuse cookies, please note that some parts of our Sites may
become inaccessible or not function properly. Learn more about our
Cookie Policy.
Opting Out
You can opt out of receiving our newsletters and marketing SMS/text
messages and emails and to terminate our newsletter subscriptions by
following the instructions in the emails or by contacting us by
email at [email protected]. Opting out in this manner will not end
transmission of service-related SMS/text messages or emails, such as
email alerts. You can also change your cookie preferences on our
Sites.
DNT Signals
Our Site currently does not respond to “Do Not Track” (DNT) signals
and operates as described in this Policy whether or not a DNT signal
is received. If we do so in the future, we will describe how we do
so in this Policy.
Unsolicited Information
This Policy shall not apply to any unsolicited information you
provide to Clearco through the Services or through any other means.
This includes, but is not limited to, information posted to any
public areas of the Services, such as forums, any ideas for new
products or modifications to existing products, and other
unsolicited submissions (collectively, “Unsolicited Information”).
All Unsolicited Information shall be deemed to be non-confidential
and not Personal Data and Clearco shall be free to reproduce, use,
disclose, and distribute such Unsolicited Information to others
without limitation or attribution.
Third Party Sites
The Services may contain links to other web sites and services not
operated or controlled by Clearco (the “Linked Sites”). This Policy
does not apply to Third Party Sites or Linked Sites. The links from
the Services do not imply that the Clearco endorses or has reviewed
the Third-Party Sites or Linked Sites, we are not responsible for
actions of these Third-Party Sites or Linked Sites. We suggest
contacting those sites directly for information on their privacy
policies.
By using our Services, you grant our third-party providers including
Third Party Sites or Linked Sites, the right, power, and authority
to act on your behalf to access and transmit your personal and
financial information from the relevant financial institution.
We may use GoCardless to process your Direct Debit payments. More
information on how GoCardless processes your Personal Data, and your
data protection rights, including your right to object, is available
at gocardless.com/legal/privacy/
Some of our pages utilize framing or private-labelling techniques to
serve content from our partners while preserving the look and feel
of our Sites. Please be aware that in these instances you may be
providing your Personal Data to these third parties and not to
Clearco.
Children and Consumers
Clearco does not knowingly collect Personal Data from persons under
the age of 18. If you are under the age of 18, please do not submit
any Personal Data through the Services. Our Sites and our Services
are not intended for consumers.
Controller
CFT Clear Finance Technology Corp. is the controller and responsible for
your Personal Data and is located at 33 Yonge Street, Suite 1200,
Toronto, Ontario, Canada M5E 1G4. We are registered with the Information
Commissioner’s Office in the UK with registration number ZB245411.
Complaints
You have the right to make a complaint at any time to your applicable
data privacy supervisory authority or however we appreciate the chance
to address your concerns before you approach the supervisory authority
and therefore request you to contact us in the first instance.
Federal Trade Commission or your applicable state government agency
Changes to this Policy
We reserve the right, at our discretion, to make changes to this Policy
from time to time without notice, so please review it frequently.
Changes take effect immediately upon posting. Your continued use of the
Services after any changes or revisions to this Policy shall indicate
your agreement with the terms of such revised Policy.
Contact us
If you have any questions about this Policy or our privacy practices including any request to exercise your rights available under law, please email [email protected] or by mail addressed to “Clearco”, Attention: Privacy & Compliance Department, 33 Yonge Street, Suite 1200, Toronto, Ontario, Canada M5E 1G4.
