ClearAccount

Privacy Policy

This Privacy Policy has been prepared by ClearAccount International Limited, trading as ClearAccount (also referred in this Privacy Policy by the words “Company”, “ClearAccount”, “we”, “us” and “our”), to meet the requirements of the UK's Data Protection Act 1998, (the "Act") and it only relates to the collection, protection, disclosure and use of personal data belonging to living individuals.

It does not relate to data which emanates from companies or other entities, although the general principles regarding our collection and use of data is broadly the same irrespective of whoever is the user of our website or our customer.

ClearAccount is registered under the Act with registration number: ZA234482 and will act as the Data Controller.

This privacy policy (together with our Website Terms and Conditions of Use, available at https://www.clearaccount.com/Content/policies/TermsUK.html and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data.

1 INFORMATION WE MAY COLLECT FROM YOU

1.1 As part of our ClearAccount service, you enter your internet banking details into our ClearAccount Site, including your personal identification numbers (PIN) and security passwords ( Internet Banking Credentials). Your Internet Banking Credentials are encrypted in transit and stored securely for a short period on our servers before being transferred to our agent and supplier Yodlee, Inc. ( Yodlee). Your encrypted Internet Banking Credentials are then stored by Yodlee upon their servers in a secure environment.

1.2 You have designated and provided the details of your internet banking account (Bank Account), including your Internet Banking Credentials within ClearAccount because you wish to enable ClearAccount to report on your transaction history from your nominated internet banking account (Transaction Data ) to you both at the time of your application to ClearAccount and on a continuing basis thereafter and to monitor the balance on your Bank Account on a daily basis.

1.3 To provide the ClearAccount Service to you, as your agent and nominated representative, you agree that ClearAccount and its supplier Yodlee may and instruct us and Yodlee to access, retrieve, view, represent and use your Transaction Data for the purposes specified. The purposes include:

  • Yodlee distributing the Transaction Data to ClearAccount;

· ClearAccount modifying, displaying and representing information (including but not limited to via a dashboard on the ClearAccount website) based on the Transaction Data to you including via your ClearAccount dashboard;

· ClearAccount periodically viewing and monitoring your Bank Accounts and the balances on your Bank Accounts;

· ClearAccount periodically copying Transaction Data from your Bank Accounts; and

· ClearAccount storing copied Transaction Data upon its servers and Yodlee storing the Transaction Data on its servers.

Save as provided above your raw Transaction Data is treated as confidential and will not be passed to any third parties other than members of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries in each case as defined in section 1159 of the UK Companies Act 2006), or our business partners, suppliers and sub-contractors for the performance of services under any contract we enter into with them or you. Aggregated and/or anonymised Transaction Data will be used by us to enhance our product and service offerings, and will be shared with third parties.

1.4 For the avoidance of doubt, we will not pass your Internet Banking Credentials to any third parties other than to Yodlee in encrypted format.

1.5 In this Privacy Policy, where we refer to sharing information with third parties, we are not referring to sharing your Internet Banking Credentials or raw Transaction Data.

1.6 We may collect and process the following data about you:

1.6.1 Information that you may provide by filling in forms on www.ClearAccount.com (our "Site"). This includes your name, address, email address and telephone numbers along with any other information provided. It will also include your date of birth, residential status, time at address, employment details and financial information. We may also ask you for information when you report a problem with our Site.

1.6.2 Correspondence, or a record of it, if you should contact us or we contact you.

1.6.3 Surveys that we use for research purposes, which we have asked you to complete, although you do not have to respond to them.

1.6.4 Financial transactions seen in your Transaction Data.

1.6.5 Transaction history from your nominated internet banking account.

1.6.6 Details of your visits to our Site (including, but not limited to, traffic data, location data, weblogs and other communication data) and the resources that you access.

1.6.7 any other information you voluntarily provide.

1.7 For the avoidance of doubt, we will not, and cannot; control your Bank Account, make payments or transfer funds to third parties or otherwise operate any other functionality on your Bank Account.

1.8 You acknowledge and accept that your internet banking provider may not endorse or sponsor ClearAccount or Yodlee or any associates or business partners.

2 IP ADDRESSES AND COOKIES

2.1 We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and may report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

2.2 A "cookie" is a small electronic file that collects information when someone visits a website. A cookie can identify the pages that are being viewed, and this can assist us to select the pages that the viewer sees. Some cookies only exist whilst viewers are online, but "persistent" cookies - which are not session-based - remain on the viewer's computer, so that he or she can be recognised as a previous visitor when he or she next visits our website. We may use persistent cookies to allow us to collect information about a viewer's browsing habits whilst on our site, so that we can monitor and improve our services.

2.3 Under the Privacy and Electronic Communications (EU Directive) Regulations 2003 (as amended) we are required to get the consent of everyone who uses our Site to the use of cookies. By continuing to use our Site you agree to the use of cookies by us in the manner outlined in this Policy and a pop up will appear on the screen when you first access the Site to remind you of this.

2.4 We do not store sensitive information such as account numbers or passwords in "persistent" cookies, and cookies in themselves do not contain enough information to identify you. We will only acquire a personal identity in relation to your browsing habits after you have formally provided us with your personal data for the purposes outlined at section 4 below.

2.5 In addition to using cookies, we might also use web tools to collect information about your browsing activities whilst on our Site. In this respect the information that is provided is similar to the information supplied by cookies, and we use it for the same purposes.

2.6 Any information that we acquire about you using cookies or web tools is subject to the same restrictions and conditions as any other information we collect about you.

2.7 Some of our advertisers may also use cookies or web tools that are set by other people such as advertising agencies, or the businesses to which the advertisements in question relate. We do not have access to any information that might be collected in this way, and, if you are concerned, you should contact the advertiser for more information.

2.8 List Of Cookies

Cookie

Summary

Persistent/Session

Description

__utma

Google Analytics

Persistent

This cookie is part of Google Analytics and helps us improve our customer experience by anonymously tracking how users interact our website. It is specifically used to track the number of visits to our website.

__utmc

Google Analytics

Persistent

This cookie is part of Google Analytics and helps us improve our customer experience by anonymously tracking how users interact our website. It is specifically used to check approximately how long you stay on our website.

__utmz

Google Analytics

Persistent

This cookie is part of Google Analytics and helps us improve our customer experience by anonymously tracking how users interact our website. It is used specifically to track how you arrived at our website.

_vis_opt_exp*

Visual Website Optimizer

Persistent

This cookie is used to run content experiments so we can improve the effectiveness of our website.

cookieAccepted

Whether to display cookie message

Persistent

This cookie tells us whether this is your first visit to our website and if so to display our cookie policy banner.

ASP.NET_SessionId

ASP.NET Session ID

Session

This cookie is required to make our website work by setting an anonymous ID which is used when you navigate the website.

cookieLocale

Region

Persistent

This cookie remembers the region based version of the site you are viewing (eg. UK or US site).

2.9 Most browsers automatically accept cookies. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site and we cannot guarantee that your experience with our Site will be as quick or responsive. Unless you have adjusted your browser setting so that it will refuse cookies, our system will automatically issue cookies when you log on to our Site.

2.10 You can find and control your cookie settings via your browser; your browser help function will tell you how. Please note, it is not possible for ClearAccount to allow you to carry your settings with you between your browsers and devices so you will need to change these settings for each browser you use.

3 WHERE WE STORE YOUR PERSONAL DATA

3.1 All information you provide to us is, as far as reasonably practicable, stored on our secure servers. Any payment transactions will be encrypted using industry standard 256-bit bank level encryption.

3.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

3.3 We will retain your information securely stored for a reasonable period or for as long as the law requires.

4 HOW WE USE YOUR INFORMATION

4.1 We use information held about you in the following ways:

4.1.1 to report on your Transaction Data to you;

4.1.2 to carry out our obligations to you including categorising and presenting your Transaction Data;

4.1.3 to ensure that content from our Site is presented in the most effective manner for you and for your computer;

4.1.4 for statistical analysis and trend monitoring; and

4.1.5 to notify you about changes to our service.

4.2 We may transfer your data outside of the EEA, but only to countries that have an adequate level of protection in line with the protection afforded to the data in the UK.

4.3 We may telephone you, if you discontinue an application part way through, to offer assistance in the application process.

4.4 Any information or statistics relating to our business that we disclose to others shall not identify you personally. We may, for example, perform statistical analyses of the behaviour of the users of our Site in order to measure interest in the various areas of our site and to inform advertisers as to how many consumers have seen or "clicked" their advertising banners. This information, and any other general information about our users that we share with advertisers and other partners, will not disclose personal information about you.

4.5 In addition to using the Transaction Data and other data you provide to undertake the analysis necessary to enable us to provide the ClearAccount Service, ClearAccount will use the information it holds about you to add it to its database to enhance and develop and further increase the value and usefulness of the databases it holds, in connection with the provision of the ClearAccount Service and other services it provides.

5 DISCLOSURE OF YOUR INFORMATION

5.1 We may disclose your personal information to third parties:

5.1.1 Who provide a service to us or are acting as our agents, to prepare or send any communications to you, or to assist us in connection with any of our administrative or business functions, or in the provision of any of our services to you, subject to contractual or other legal obligations to keep the information confidential, and to use your personal data only for the purpose of providing the service to us. If they are located in another country we will seek to ensure that they agree to apply equivalent levels of protection to those we are required to apply to information held in the UK.

5.1.2 If ClearAccount International Ltd or substantially all of its assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.

5.1.3 If we transfer or may transfer our rights and duties to them.

5.1.4 If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions of Use https://www.clearaccount.com/Content/policies/TermsUK.html and other agreements; or to protect the rights, property, or safety of ClearAccount International Ltd, our customers, or others, or if the law allows us to do so. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

5.2 We may share your personal information with members of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries in each case as defined in section 1159 of the UK Companies Act 2006) to enable them to develop and enhance their service offerings.

6 YOUR RIGHTS

6.1 Our site may, from time to time, contain links to and from the websites of our advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

6.2 We will store and process your information on our computers and in any other way we consider appropriate. By "your information" we mean personal and financial information we (a) obtain from you or from third parties, such as credit reference agencies (who may search the Electoral Register), fraud prevention agencies or other organisations when you apply for an account or any other product or service or which you or they give to us at any other time or (b) learn from the way you use and manage your account(s), from your transactions and from the payments made to your account.

6.3 We will use your information to manage your account(s), give you statements and provide our services, for research, assessment and analysis (including credit and/or behaviour scoring, market and product analysis) and to develop and improve our services to you and other customers and protect our interests.

6.4 Section 7 of the Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act by sending us an email to enquiries@clearaccount.com or writing to us at ClearAccount International Ltd t/a ClearAccount, Floor 33, Euston Tower, 286 Euston Road, London, UK, NW1 3DP

Company Registration Number: 10332236. Any access request may be subject to a small statutory fee to meet our costs in providing you with details of the information we hold about you.

6.5 Calls between us may be recorded and/or monitored for customer service, training and general auditing purposes.

6.6 We may give information about you and how you manage your account to the following:

7 CHANGES TO OUR PRIVACY POLICY

7.1 Our privacy policy will be reviewed and amended from time to time and you should check this page to see our most up to date version of the privacy policy. Any changes we may make to our privacy policy in the future will be posted on this page.

8 CONTACT

8.1 Questions, comments and requests regarding this privacy policy are welcomed at enquiries@clearaccount.com or ClearAccount International Ltd t/a ClearAccount, Floor 33, Euston Tower, 286 Euston Road, London, UK, NW1 3DP. If you have any concerns about the information we hold you should contact the Data Protection Officer at ClearAccount International Ltd stating what you think the problem is and you will get a response within 15 working days. If you still feel dissatisfied, you can appeal to the Managing Director of ClearAccount International Limited or you can contact the Information Commissioner's Office Customer Services Team, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.