1. About the policy

This policy express our commitment to protect your privacy and what we need from you in relation to your personal data. References to "Klearing", "we", "us", "our" refer to our group companies acting as Data Controller of your information.

2. What data (personal information) do we collect

You may give us personal details like your name, address, e-mail and phone number. In other situations you might also provide social security number, geographic location, personal description and photographs or videos.
When you are using our services we may collect IP address, login information, browser type and version, time zone setting, operating system and platform. We may also automatically collect information on products you viewed, lengths of visit and page interaction (scrolling, clicks or mouse-over).

3. How we collect personal information

3.1 Information you provide

You may provide personal information when you fill in any forms or sign up for a service or open an account. We may also need additional information from you for high-value transactions or where we need to comply with AML regulations. You may also provide us with information through other types of correspondence with us including support or contact for other reasons.
If you provide us with personal data about other people you confirm that their attention has been brought to this policy.

3.2 Information we collect

We collect technical information from you and other information about your visit and how you interact with our website. We also collect information regarding transaction details when you are using our platform.

3.3 Information from others

We collect personal data from third parties such as banks, official registers and databases. We also collect information from public sources for customer due diligence purposes as part of our KYC process.

4. Sensitive data & children's data

We process a limited amount of sensitive data when we verify ID-documents that contain biometric data. We rely on the substantial public interest condition in GDPR Article 9(2)(g) and DPA (2018) Condition 14, Part 2 of Schedule 1.
Our products and services are directed at adults aged 18 years and over. We do not knowingly collect data from people under 18 years. If any data of children would be collected by mistake it will be deleted.

5. Cookies

We use cookies to analyse how you use our website. Please read the Cookies Policy for more information regarding cookies.

6. Purpose and legal basis

Our legal basis for processing your data will be one of the following:
(1) When it necessary to keep our contracts and agreements with you
(2) When we have a legal obligation to comply (AML regulations for example)
(3) Legitimate interest when reasonable and balanced against your right to privacy
(4) When you have left your consent

7. Sharing & disclosure

We may disclose or share your personal data to the following third parties:
(a) Our group companies when we have a legitimate interest in order to provide you with the best service
(b) Our payment provider to help us provide our service to you
(c) Beneficiaries and third party payers due to regulatory requirements
(d) Law enforcement or other organisations when obliged due to legal reasons assisting in financial-crime investigations

8. International sharing

Due to our international service we may need to disclose your personal data outside of EEA. When this happens we will take measures to protect your data and ensure that the level of data protection is equivalent to the one within EEA.

9. How we store and protect your information

We are committed to protect your personal information from loss and take all reasonable precautions to safeguard the confidentiality it contains. We use a variety of physical and technical measures to keep your data safe. Electronic data is stored on secure computer systems with control over access to information. We restrict access to your information to those employees of Klearing who have a business reason to know such information. We have have security and data protection policies in place which our staff receives training and are required to follow when handling your data.
We take all reasonable measures to keep your personal data secure but cannot guarantee it will be secure during transmission by you to our website. We use HTTP Secure with encrypted protocol through Transport Layer Security for secure communication over networks.

10. How long do you store my personal data

We do not keep your personal information longer than necessary for the purpose for which the information is processed. The length of time we retain information depends on the purpose as required with applicable laws. Fraud prevention agencies can hold your data for different periods of time if you pose a risk for money laundering.

11. Retention

Klearing may be required to store some of your personal and transactional data beyond the closure of your account. Your data is only accessed on on a need to know basis and if absolutely necessary. We will always delete data that is no longer required by a relevant law or jurisdiction we operate in.

12. Automatic decisions

As part of being a technical and innovative company we may use automatic decision making to improve your experience or to prevent financial crime. This mean we may use technology to evaluate your personal circumstances or other factors to prevent risks or outcomes. When we make an automated decision about you, you have the right to ask for a manual review.

13. Your rights

You have the following rights:
(a) You have the right to access to any personal information we hold about you and ask for a copy of your personal information. If and how your information is used and which safeguards we use if we transfer your information outside EEA.
(b) You have the right to update your information if it's out of date or incorrect.
(c) You have the right to delete your information in certain circumstances for which you can ask for more information regarding.
(d) You have the right to restrict the use of your information in certain circumstances for which you can ask for more information regarding.
(e) You have the right to ask us to stop using your information for direct-marketing.
(f) You have the right to ask us to provide your personal information to a third party provider.
(g) You have the right to ask us to consider any valid objections to use your information where we process that information on the basis of another person's legitimate interest.

14. Changes to this policy

All changes to our privacy policy will be posted on this page and when appropriate, notified to you by e-mail. Please check this page from time to time for any possible updates och changes in the policy.

15. Contacting Klearing

Questions and requests regarding this policy are welcome to be addressed to privacy@klearing.com