Introduction

Clea Inc. (US) and Clea Technology Limited (Nigeria) (“Clea,” “we,” “us,” or “our”) value your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use Clea, our platform that facilitates cross-border payments and related financial services for individuals and businesses, including the Clea Card.

By using Clea, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, please do not use our services.

Information We Collect

We may collect the following types of information:

Personal Information

• Name
• Email address
• Phone number
• Residential or business address
• Bank Verification Number (BVN)
• Government-issued identification
• Date of birth and other information required for identity verification

Business and Transactional Information

• Company name and registration details
• Bank account details
• Transaction history and payment data
• Currency conversion requests
• Beneficiary and recipient information
• Information relating to purchases, merchants and payment instructions

Card Information

Where you apply for, receive or use a Clea Card, we may collect and process information relating to:

• Cardholder identity and business information
• Card identifiers and the last four digits of your card number
• Card status, activation and provisioning information
• Card transaction, merchant and authorization information
• Refund, reversal and dispute information
• Card controls, limits and security events
• Digital-wallet provisioning and tokenisation information

We do not display or store sensitive card credentials except where necessary and permitted for the provision of the Clea Card service and in accordance with applicable security requirements.

Device & Technical Data

• IP address
• Device type and operating system
• Browser type
• Date and time of access
• Device identifiers
• Application version
• Login and authentication information
• Security and fraud-prevention information

Where you use a supported digital wallet, additional technical information relating to your device and wallet provisioning may also be processed.

How We Use Your Information

We use your information to:

• Provide, operate and maintain Clea services
• Process payments, transfers and currency conversions
• Issue, provision and manage Clea Cards
• Process and authenticate card transactions
• Enable supported digital-wallet functionality
• Verify your identity and business information
• Detect, investigate and prevent fraud or unauthorized activity
• Conduct sanctions, anti-money laundering and other compliance checks
• Communicate with you about your account, transactions and services
• Provide customer support
• Handle refunds, disputes and card-related inquiries
• Comply with legal and regulatory requirements
• Improve our platform, products and user experience

How We Share Your Information

We do not sell your personal information.

However, where necessary to provide our services, we may share information with:

• Payment processors and banking partners
• Card issuers, card-program managers and processing partners
• Card networks, including Visa®
• Digital-wallet providers, including Google where you choose to use Google Pay
• Identity verification, fraud-prevention and compliance providers
• Technology, infrastructure, analytics and customer-support providers
• Regulatory bodies, courts and law-enforcement authorities where required by law
• Clea affiliates and subsidiaries where necessary for the operation of our services

We only share information that is reasonably necessary for the relevant service, transaction, regulatory requirement or legitimate business purpose.

Third parties receiving your information may also process information in accordance with their own legal obligations and privacy policies.

Clea Card and Digital Wallets

If you apply for, receive or use a Clea Card, we may collect, use and share information necessary to issue, operate and manage your Card and process transactions made with it.

This information may include Cardholder information, card identifiers, merchant information, transaction amounts, currencies, authorization information, refunds, reversals, disputes, security events and other information relating to your use of the Clea Card.

Where you add your Clea Card to a supported digital wallet such as Google Pay, information may also be exchanged between Clea, the Card issuer, our card-program and processing partners, Visa®, Google and other service providers involved in providing the digital-wallet service.

This may include information relating to:

• Your eligible Clea Card
• Your device
• Card tokenisation and wallet provisioning
• Authentication and verification
• Transaction activity
• Fraud and security monitoring

We process this information to enable your Card to be added to and used through supported digital wallets, authenticate transactions, protect your Card and Account, prevent fraud, provide customer support and comply with applicable legal and regulatory requirements.

Google Pay and other digital-wallet services are provided by third parties. Information you provide directly to a digital-wallet provider, or information processed independently by that provider, will also be subject to that provider’s own privacy policy and terms.

Using a supported digital wallet is optional. You may continue to use your Clea Card through other supported methods where available.

International Data Transfers

Clea provides cross-border financial services and works with payment networks, card issuers, processors, technology providers and other service providers operating in multiple jurisdictions.

As a result, your personal information may be processed, stored or transferred outside the country in which you reside.

Where required, we take appropriate measures to protect personal information transferred internationally in accordance with applicable data-protection laws.

Data Retention

We retain your information only for as long as reasonably necessary to provide our services, fulfil the purposes described in this Privacy Policy, resolve disputes, prevent fraud, enforce our agreements and comply with applicable legal and regulatory requirements.

Certain financial, transaction, compliance and card-related records may be retained for longer periods where required by law or regulatory obligations.

Security

We implement appropriate technical and organizational measures designed to protect your personal information from unauthorized access, alteration, disclosure, loss or destruction.

We also apply security measures appropriate to payment, Card and transaction information.

However, no electronic transmission or storage method is completely secure, and we cannot guarantee absolute security.

You are responsible for maintaining the security of your Clea Account, Card, devices, passwords, PINs and other authentication credentials.

Your Rights

Depending on your location and applicable law, you may have the right to:

• Access or request a copy of your personal information
• Request correction of inaccurate or incomplete information
• Request deletion of your personal information where legally permitted
• Object to or restrict certain processing
• Withdraw consent where processing is based on consent
• Request information about how your personal information is used
• Lodge a complaint with an applicable data-protection authority

Some information may need to be retained despite a deletion request where Clea is required to retain it for regulatory, compliance, fraud-prevention, contractual or legal purposes.

To exercise any of these rights, please contact us.

Cookies and Tracking Technologies

We may use cookies and similar technologies to provide functionality, personalize your experience, maintain security and analyze use of our platform.

You may be able to disable cookies through your browser settings. However, some Clea services may not function properly if certain cookies are disabled.

Third-Party Services

Clea may integrate with or provide access to third-party services, including payment providers, banking partners, Card networks, digital-wallet providers and other technology services.

Where a third party independently collects or processes your information, its own privacy policy and terms may apply.

Clea is not responsible for the independent privacy practices of third parties. We encourage you to review their privacy policies where appropriate.

Children’s Privacy

Clea is not intended for individuals under the age of 18.

We do not knowingly collect personal information from children under 18.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes to our services, legal requirements, Card Program, technology or data-processing practices.

Where changes are material, we may notify you through email, the Clea platform or another appropriate communication channel.

The “Last Updated” date at the top of this Privacy Policy indicates when it was most recently revised.

Contact Us

If you have questions, concerns or requests relating to this Privacy Policy, the Clea Card, digital-wallet privacy or our data practices, please contact Clea Support.