Privacy Policy

Last updated: April 15, 2025

1. Introduction

This Privacy Policy explains how your personal data is collected, used, and disclosed by Cleera (referred to in this policy as "Cleera", "we", "us", or "our"). This Privacy Policy applies to personal data collected through our website, mobile applications, and related online services (collectively referred to as the "Service").

Cleera is currently operated by the creator(s) of Cleera, who act as the data controller for the purposes of the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018.

By using our Service, you agree to the collection, use, and disclosure of your personal data as described in this Privacy Policy.

2. Personal Data We Collect

We collect the following categories of personal data:

  • Identity and Contact Information: First name, last name, email address, phone number.
  • Account Information: Password (stored securely), user role (e.g., adviser, client, administrator), organisation ID.
  • Financial Information: Payment method details (processed securely via Stripe), subscription information.
  • Professional Information: Mortgage type, reference numbers, case information.
  • Documents and Forms: Information contained in documents you upload to the Service (such as bank statements, identification documents).
  • Property Information: Property addresses and related details for mortgage applications.
  • Technical Information: IP address, browser type, device information, and other technical identifiers when you use our Service.
  • Usage Information: Information about how you use our Service, collected through cookies and similar technologies.

3. How We Collect Your Personal Data

We collect personal data in the following ways:

  • Direct Interactions: Information you provide when creating an account, submitting forms, uploading documents, or communicating with us.
  • Automated Technologies: We use cookies and similar technologies to collect information about your use of our Service.
  • Google Analytics: We use Google Analytics to understand how visitors interact with our Service.
  • Third-Party Services: We may receive information from payment processors (Stripe) and other service providers.

4. How We Use Your Personal Data

We use your personal data for the following purposes:

  • To provide and maintain our Service, including processing transactions and managing your account.
  • To process and manage mortgage applications and related documentation.
  • To communicate with you about our Service, updates, and customer support.
  • To personalize your experience and deliver content relevant to your interests.
  • To improve our Service through analysis of usage patterns and technical issues.
  • To protect the security and integrity of our Service.
  • To comply with legal obligations and enforce our terms of service.

5. Lawful Basis for Processing

Under the UK GDPR, we must have a lawful basis for processing your personal data. Our lawful bases for processing include:

  • Contractual Necessity: Processing necessary for the performance of our contract with you (e.g., providing our Service).
  • Legitimate Interests: Processing necessary for our legitimate interests, provided these interests don't override your rights (e.g., improving our Service).
  • Legal Obligation: Processing necessary to comply with legal obligations (e.g., financial regulations, anti-money laundering requirements).
  • Consent: Where you have provided consent for specific processing activities.

6. Cookies and Similar Technologies

We use cookies and similar technologies to collect information about your use of our Service. These technologies help us analyze usage patterns, remember your preferences, and provide enhanced functionality.

You can control cookies through your browser settings. However, disabling cookies may limit your ability to use some features of our Service.

7. Data Sharing and Disclosure

We do not sell your personal data to third parties. We may share your personal data in the following circumstances:

  • Service Providers: We share data with trusted service providers who perform services on our behalf, such as payment processing, data analysis, email delivery, and hosting services.
  • Business Transfers: If Cleera is involved in a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction.
  • Legal Requirements: We may disclose your personal data if required by law, legal process, or government request.
  • Protection of Rights: We may disclose personal data to protect the rights, property, or safety of Cleera, our users, or others.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

9. Data Retention

We retain your personal data for as long as necessary to provide our Service and fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When determining retention periods, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, and applicable legal requirements.

10. Your Data Protection Rights

Under the UK GDPR, you have the following rights regarding your personal data:

  • Right to Access: You have the right to request a copy of the personal data we hold about you.
  • Right to Rectification: You have the right to request correction of inaccurate personal data or completion of incomplete personal data.
  • Right to Erasure: You have the right to request deletion of your personal data in certain circumstances.
  • Right to Restrict Processing: You have the right to request restriction of processing of your personal data in certain circumstances.
  • Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
  • Right to Object: You have the right to object to processing of your personal data in certain circumstances.
  • Rights Related to Automated Decision-Making: You have rights related to automated decision-making, including profiling.

To exercise your rights, please contact us at contact@cleera.co.uk. We will respond to your request within one month. This period may be extended by up to two additional months if necessary, taking into account the complexity and number of requests.

11. International Data Transfers

We process and store your personal data within the United Kingdom and European Economic Area (EEA). We do not transfer your personal data outside the UK/EEA.

12. Children's Privacy

Our Service is not directed to individuals under the age of 16, and we do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without verifiable parental consent, we will take steps to delete that information.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email or through a notice on our Service prior to the change becoming effective. We encourage you to review this Privacy Policy periodically.

14. Complaints

If you have concerns about our processing of your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

We would appreciate the opportunity to address your concerns before you approach the ICO, so please contact us in the first instance.

15. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at:

Email: contact@cleera.co.uk