1. Overview of Privacy Policy:
ScopeAt Clearer Limited your privacy is important to us, and so is being transparent about our privacy practices.
This Privacy Policy (Policy) applies to individuals and corporate clients that use our products and services and our Online Channels (defined below). This Policy describes the information we collect and how that information is used and shared by us. It also includes details about the choices we offer you in relation to that information. If you are a customer of Clearer Limited, this Policy should be read with the customer agreement you enter into with us (Customer Agreement).
DefinitionWe, us and our refers to Clearer Limited
Personal Information refers to any information or opinion relating to or about an individual or an individual who is reasonably identifiable.
Online Channels means:
Website operated by us (Website)
Software applications made available by us for use on or through computers and mobile devices (Apps);
Our social media pages and apps that we control (collectively, our Social Media Pages);
HTML-formatted email messages that we send to you that link to this Policy or other communications with you.
Device notifications and other channels or activities described in this Statement that we use that are not Website, Apps or Social Media Pages.
2. Compliance with the Data Protection Laws and Regulations:
Clearer Limited is committed to complying with the Nigerian Data Protection Regulations (NDPR), Nigerian Data Protection Act (NDPA), General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and other applicable data protection laws. This commitment applies to all personal data collected, processed, and stored by Clearerpay, from users in any location worldwide.
For any inquiries or requests related to data protection compliance, please contact us at
hello@clearerpay.com.
3. Information We Collect:
Identification Information
We may collect some or all of the following information: your name, date of birth, title, gender, e-mail address, phone number, email address, nationality, occupation and social security number or other tax identification number. To comply with applicable laws and regulations (including anti-money laundering and counter-terrorism financing laws), we may collect identity verification information such as copies of your government-issued identification (including passport, driver’s license, social security card, government health benefits card or national ID card) or other authentication information, all of which may include photographs of you.
Financial Information
In order to comply with laws, assess creditworthiness, process payments and transactions we may collect financial information such as bank account details (account number, routing number), credit or debit card numbers, credit information or reports or tax information, such as withholding allowances and filing status.
Transaction Information
When you place a payment order with us, we may collect information about the parties to the transaction, the source of the funds, the reason for the transaction, and the devices and payment methods used to complete transactions. If you choose to pay someone else, we will ask you for the designated recipient’s name, e-mail address, email address and bank account information. This is necessary for us to make a payment to them and you confirm that you know they agree or that you are otherwise allowed to give us this information and will inform them of the contents of this Policy.
Business Information
If you are using our services on behalf of a business entity, we may collect information about the business and individuals involved in the business. We also may collect entity formation documents or other corporate records. Such information may include the Beneficial Owner’s name, date of birth, title, gender, phone number, email address, nationality, occupation and social security number or other tax identification number. You confirm that the Beneficial Owners agree or that you are otherwise allowed to give us this information and will inform the Beneficial Owners of the contents of this Policy.
Background Information
To the extent permitted by applicable law, we may obtain, in the course of providing you with the services you request, background check reports from public records of criminal convictions and arrest records. Some jurisdictions require us to obtain your consent. Where you refuse to provide consent, we may be unable to provide services to you.
Log Data
When you access our Online Channels, we collect server logs, which may include information such as IP address, access times and dates, pages viewed and other system activity, including the third-party site you were using before and after accessing our services.
Device Information
We may obtain information about the devices you use to access our Online Channels including: the device type, operating systems and versions, the device manufacturer and model, preferred languages, unique identifiers (including identifiers used for advertising purposes), and plugins.
Usage and Preference Information
We collect information about how you interact with the Online Channels and how you use our Online Channels, including your user preferences and other settings selected by you. In some cases we do this by using cookies and other tracking technologies.
Geolocation Information
When you use certain features of our Online Channels, we may collect information about your approximate location as determined by data such as your IP address.
Aggregated, Anonymised and Deidentified Data
We may also collect or create aggregated, anonymised, or deidentified data about our users. This data is used for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
Other Information
We may collect any other Personal Information you may provide to us when you update your account information, respond to surveys, post to community forums, or use any other feature of our Online Channels or services.
4. How We Collect Information:
We collect information about you in a variety of different ways, including the following:
Information You Provide
We collect Personal Information and other information from you when you complete an application or form, register for a CLEARERPAY user account, submit to our verification procedures, apply for additional account features or services, conduct transactions, respond to our emails, messages or surveys, communicate with us by telephone, email and online, provide feedback, participate in promotions or contests, provide referrals, or upload content. We make and store recordings of our telephone communications with you.
Information from Your Use of Services
When you use our services, we collect Personal Information and other information about you and the devices you use to access the Online Channels. If you connect your social media account to your CLEARERPAY account, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your CLEARERPAY account.
Information from Third Parties
We also collect Personal Information about you from third parties and other sources, including government agencies, identity verification and fraud detection service providers and databases, credit bureaus, credit reporting bodies, credit reference agencies, community forums used to post ratings or reviews, social media platforms, advertising, advertising technology and market research companies, contact list, demographic & profile data brokers including companies that publish CLEARERPAY marketing and advertising materials that you interact with, CLEARERPAY business partners and associates through which you access our services, or other sources of public records. For corporate clients, we may collect Personal Information about the Beneficial Owners of the business from any person that has represented to us that they have authority to act on behalf of the business entity and provide that information.
5. How We Use Your Information:
We use Personal Information we collect from or about you (including credit information) for several purposes, including:
To provide or improve our services
To process payments or money transfers.
To provide customer support.
To evaluate your application to use our services.
To develop new products or enhance existing products and services.
To monitor and analyse trends, usage, preferences and other user activities on our Online Channels to optimise user experience and to enhance the effectiveness of our promotional campaigns.
For quality control and staff training.
To ensure safety and security
To verify your identity or authenticate your right to access an account or other information.
To conduct manual or automated monitoring to protect against fraud, money laundering and other crimes and harmful activities.
To comply with legal obligations
To comply with laws, regulations, codes of conduct, stock exchange rules, binding determinations or to respond to legal process or government authorities.
To address disputes or resolve claims related to use of our services.
To enforce our terms and conditions and collect fees.
To communicate with you
To respond to your inquiries and support requests.
To send you technical notices, updates, security alerts and other administrative messages.
To provide information related to your transactions, including confirmations, receipts, and tracking notices.
To market and advertise our services
To deliver promotional offers, incentives, and targeted or personalised marketing in a variety of ways including via email, SMS, push messages, telephone, social media or online.
To provide invitations and information about events held by us or our partners.
To facilitate promotional contests or sweepstakes.
For analytics and insights with any Personal Information that we collect or obtain about you, including combining your Personal Information with other personal information and data to use in advertising and marketing that may influence your behaviour or decisions or provide insights and measurement to us in relation to any advertising initiatives that we may run.
You can opt-out of receiving marketing at any time through the unsubscribe function available in each marketing communication we send. Alternatively, you can update your preferences by logging in to your CLEARERPAY account on the Website or contact us at hello@clearerpay.com or using the 'Contact Us' information below.
Other purposes
6. Information Sharing and Disclosure:
We may disclose or otherwise provide anonymised/aggregated, or deidentified data to third parties without restriction. We may also share information about you, including Personal Information, with the following third parties if you ask us to, if we consider it necessary to provide our services to you, if we have a duty to disclose it or an applicable law allows us to do so for legitimate interests or business reasons:
Our Corporate Affiliates
To facilitate or support us in providing our services to you, we may share your Personal Information with other companies in the Clearer Limited group.
Our Service Providers
We engage a variety of service providers to enable us to provide our services to you. For example, service providers may be used to support technology or infrastructure, analytics and insights generation, collect debts, determine who we should market and advertise to, distribute marketing materials, conduct market research, perform audits, provide professional advice or other functions.
Payment Processors
To payment processing service providers, intermediary banks and financial institutions to process your transactions.
Credit Reference and Identity Verification Agencies
To credit bureaus, credit reporting bodies, credit reference agencies, identity verification agencies and other companies and organisations (Verification Agencies) to check your details, verify your identity and protect against fraud, money laundering and other crimes and harmful activities. In some cases Verification Agencies may need to access third party databases (including without limitation databases of government issuers of identification documents). You provide your authority for Verification Agencies to act as your agent in accessing these databases. Verification Agencies may disclose to third parties any information provided to them for identity verification purposes.
Our Partners, Business Associates or Contractors
To any of our partners, business associates, or contractors or your agents that you have authorised to have access to your CLEARERPAY account or your Personal Information in connection with the provision of our services. A partner’s, business associate’s or contractor’s access to and use of any transactional data provided by CLEARERPAY will be treated in accordance with that third party’s terms of use. Xero’s access to and use of any transactional data provided to Xero by CLEARERPAY will be treated in accordance with Xero’s Terms of Use. If you are an online seller receiving funds from a marketplace, we may be required to share your Personal Information and CLEARERPAY account information with the marketplace to assist with minimising fraudulent and illegal activity or as required by applicable laws.
Other Authorised Third Parties
If you provide your consent, we may share your information including your Personal Information with other authorised third parties. Such disclosure will only be carried out in the manner described to you at the time you agreed to the sharing. Authorising a third-party application or website to access your CLEARERPAY account or participating in certain promotional activities constitutes such consent to share your information.
Government Authorities
If we believe it is necessary or appropriate, we may share your Personal Information with law enforcement officials, government authorities, regulatory bodies or other third parties, including for purposes of: (i) enforcing our Customer Agreement or other applicable agreements or policies; (ii) protecting our rights, property, privacy, or security, or that of others; or (iii) complying with applicable law, legal process, or government orders.
Third-Party Acquirers
If we are the subject of or are involved in any corporate merger, acquisition, consolidation, reorganisation, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in connection with bankruptcy or similar proceedings), we may disclose or transfer data, including Personal Information, with third parties in connection with such events.
Professional Advisors
We may share your information with professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they provide to us.
7. International Transfers:
We collect information globally and may transfer, process and store your information outside of your country of residence, to wherever we, our third party service providers or any recipients referred to in section 5. Whenever we transfer your information, we take steps to protect it.
8. Choices and Transparency:
You have choices regarding how to manage your Personal Information and how we use and disclose your Personal Information.
How Your Information may be Accessed, Updated or Corrected
To ensure the information we hold is accurate, you should tell us as soon as possible if any of the information you have provided us has changed. You may request that we correct or update the Personal Information you provided to us at any time by logging into your CLEARERPAY account or by contacting us using the 'Contact Us' information below. If you want to access a copy of the Personal Information we hold about you, you can contact us at
hello@clearerpay.com or using the 'Contact Us' information below. We will respond to any such request consistent with applicable law. Prior to changing or correcting your information or providing your information to you, we may be required to verify your identity. There may be situations where we cannot action your request including where the information may impact the privacy of other individuals, the information is subject to legal privilege, the disclosure could threaten the safety, physical or mental health or life of an individual or CLEARERPAY is prohibited by applicable law from providing you with access. If this is the case, we will set out in writing to you any reasons for our refusal to provide access to such information. We will take reasonable steps in the circumstances to ensure that your Personal Information is accurate, complete and up-to-date to minimise the possibility that inappropriate information may be used to make a decision about you. We will not routinely update your Personal Information unless such a process is necessary to fulfil the purposes for which the information was collected.
Device Permissions
Most mobile devices allow you to disable the use of location services, or revoke consent to applications to access your camera and photo library or send you push notifications. Some devices allow you to activate a 'do not track' function, reset your device-specific advertising identifier. Please refer to your device settings to restrict collection of certain information.
Marketing Opt-Out
You can opt out of receiving our marketing at any time through the unsubscribe function in each marketing communication. Please note that if you opt out of marketing-related emails from us, we will continue to send you non-promotional messages that are required to provide our services, such as transactional receipts and messages about your account or our relationship with you.
Testimonials
We display personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at hello@clearerpay.com or using the 'Contact Us' information below.
Declining to Provide Information
We need to collect Personal Information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
9. Security:
We employ technical, physical, and organisational measures designed to safeguard your Personal Information against loss, misuse, or unauthorised access.Unfortunately, the transmission of information over the Internet or the telephone is never 100% secure and no data storage system can be guaranteed safe.We cannot warrant the security of data transmitted to us and any transmission is at your own risk.We encourage you to understand the integral role you play in keeping your own Personal Information secure and confidential, always keep your log-in details secure. You should also take care not to give any security credentials we provide you or you choose(such as a password) to someone who is not an CLEARERPAY representative. We will never ask you for your full security credentials.If you are unsure, please end the session.If you suspect any unauthorised use or access to your account or information, please contact us immediately, using the “Contact Us” information below.
10. Advertising, Profiling, non-advertising issues and analytics:
We may partner with third parties to display and personalise CLEARERPAY advertisements to you and to track and report on the performance of those advertisements.These third- party partners use cookies and other technologies to gather information about your activities on our Online Channels, as well as information from third parties and your activities on other sites or online services on any of your devices, in order to serve you advertising based upon your online behaviours including browsing history and interests.They also use these technologies, along with information they collect about your online use, to recognise you across the devices you use.
11. Social Media Features:
Our Website may include social media features, such as the Facebook Like button, and widgets, such as the Share This button or interactive mini-programs that run on our Website. These features may collect information about you and your online activities and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy statement of the company providing it.
12. Third Party website and services:
This Policy does not apply to third party website, applications, products or services, even if they are linked to our services or Online Channels, and we are not responsible for the privacy, information, or other practices of third parties. The inclusion of a link on the Online Channels does not imply endorsement. You should review the privacy policies of any third party website you visit.
13. Children:
Our services are not intended for or directed at individuals under the age of 18. If you are a parent or guardian of a child from whom you believe we have collected Personal Information in a manner prohibited by law, please contact us using the “Contact Us” information below. If we learn that we have collected Personal Information through the Online Channels from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
14. Complaints:
CLEARERPAY will investigate all complaints. For more information on how we manage complaints contact Customer Service at
hello@clearerpay.com.
15. Updates to This Policy:
We may change this Policy from time to time. If we make any material changes we will notify you by means of a notice on our Website. Any changes will become effective on the date specified in the revised Policy posted on our Website.
16. Contact Us:
If you have questions or concerns about this Policy, need it in an alternative format, have a specific request related to your Personal Information or any complaints about our privacy practices, please contact us at
hello@clearerpay.com.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using our services.
Your Data Protection Rights
Your right of access - You have the right to ask us for copies of your personal information.
Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate or is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.