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Privacy Policy

Last Updated: January 2025

1. Introduction

Arch Ridgeline Technologies Limited ("Cleared," "Company," "we," "us," or "our"), a company incorporated in Ireland, is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Cleared protocol, application, website, APIs, and related services (collectively, the "Services").

This Privacy Policy complies with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and other applicable data protection laws.

By using the Services, you consent to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Services.

2. Data Controller

The data controller responsible for your personal data is:

Arch Ridgeline Technologies Limited

Dublin, Ireland

Data Protection Contact: [email protected]

For EU residents, you have the right to lodge a complaint with the Irish Data Protection Commission (DPC) or your local supervisory authority.

3. Information We Collect

3.1 Information You Provide

Data TypeExamplesPurpose
Account InformationEmail address, name, business nameAccount creation and communication
Business InformationCompany name, business type, invoice detailsProviding invoicing services
CommunicationsSupport requests, feedbackCustomer support and service improvement

3.2 Information Collected Automatically

Data TypeExamplesPurpose
Blockchain DataWallet addresses, transaction hashes, invoice NFT dataCore service functionality
Device InformationIP address, browser type, operating systemSecurity and service optimization
Usage DataPages visited, features used, timestampsService improvement and analytics

3.3 Special Note on Blockchain Data

Blockchain transactions are public and permanent.

When you use the Services, certain information is recorded on public blockchain networks, including your wallet address, invoice creation and payment transactions, and NFT ownership and transfers. This on-chain data is publicly accessible, immutable, and cannot be deleted by Cleared or anyone else.

4. How We Use Your Information

4.1 Legal Bases for Processing (GDPR Article 6)

PurposeLegal Basis
Providing the ServicesPerformance of contract (Art. 6(1)(b))
Account managementPerformance of contract (Art. 6(1)(b))
Customer supportPerformance of contract (Art. 6(1)(b))
Security and fraud preventionLegitimate interests (Art. 6(1)(f))
Service improvement and analyticsLegitimate interests (Art. 6(1)(f))
Legal complianceLegal obligation (Art. 6(1)(c))
Marketing communicationsConsent (Art. 6(1)(a))

4.2 What We Do NOT Do

  • We do NOT sell your personal data
  • We do NOT use your data for targeted advertising
  • We do NOT perform KYC/identity verification (you are responsible for your own compliance)
  • We do NOT monitor your transactions for regulatory purposes

5. How We Share Your Information

5.1 Service Providers

We share data with third-party service providers who assist in operating the Services:

ProviderPurposeData Shared
PrivyEmbedded wallet infrastructureAuthentication data, wallet identifiers
SafeSmart contract walletWallet addresses, transaction data
Blockchain Networks (Base, Ethereum)Transaction processingPublic transaction data
Cloud InfrastructureHosting and storageAll service data (encrypted)

All service providers are bound by data processing agreements and are required to protect your data in accordance with GDPR.

6. International Data Transfers

Your information may be transferred to and processed in countries outside the European Economic Area (EEA), including the United States, where our service providers operate.

For transfers outside the EEA, we ensure appropriate safeguards are in place:

  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Adequacy decisions where applicable
  • Binding Corporate Rules where applicable

You may request a copy of the safeguards we use by contacting [email protected].

7. Data Retention

We retain your personal data only as long as necessary for the purposes described in this Privacy Policy:

Data TypeRetention PeriodReason
Account informationDuration of account + 3 yearsLegal and contractual obligations
Support communications3 yearsService improvement, legal claims
Usage analytics2 years (anonymized)Service improvement
Marketing preferencesUntil consent withdrawnCompliance with consent

Blockchain data is permanent and serves as the authoritative record. Off-chain data associated with your account will be deleted or anonymized upon request, subject to legal retention requirements.

8. Your Rights (GDPR)

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

RightDescription
AccessRequest a copy of your personal data
RectificationRequest correction of inaccurate data
Erasure ("Right to be Forgotten")Request deletion of your data (subject to legal limitations)
RestrictionRequest limited processing of your data
PortabilityReceive your data in a structured, machine-readable format
ObjectObject to processing based on legitimate interests
Withdraw ConsentWithdraw consent for consent-based processing

How to Exercise Your Rights

To exercise any of these rights, contact us at: [email protected]

We will respond to your request within 30 days. We may request verification of your identity before processing your request.

Limitations

  • Blockchain data cannot be deleted as it exists on public, immutable networks outside our control
  • Certain data may be retained for legal compliance, even after a deletion request
  • Deletion may result in inability to use certain Services

9. Cookies and Tracking Technologies

Cookies are small text files stored on your device when you visit our website. We use cookies and similar technologies to operate and improve the Services.

Types of Cookies We Use

TypePurposeDuration
Essential CookiesRequired for basic functionality (authentication, security)Session
Functional CookiesRemember your preferences and settings1 year
Analytics CookiesUnderstand how users interact with the Services2 years

We do NOT use:

  • Advertising or tracking cookies
  • Third-party marketing cookies
  • Cross-site tracking

10. Security

We implement appropriate technical and organizational measures to protect your personal data, including:

  • Encryption: Data encrypted in transit (TLS) and at rest
  • Access Controls: Role-based access, multi-factor authentication
  • Infrastructure Security: Secure cloud hosting with regular security audits
  • Monitoring: Continuous monitoring for security threats

However, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your data.

Security Incident Response

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and notify affected individuals without undue delay (where required).

11. Children's Privacy

The Services are not intended for individuals under the age of 18 (or the age of legal majority in your jurisdiction). We do not knowingly collect personal data from children. If we become aware that we have collected data from a child, we will delete it promptly.

12. Third-Party Links

The Services may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal data.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last Updated" date.

For material changes, we will:

  • Notify you via email (if you have an account)
  • Display a prominent notice in the Services

Your continued use of the Services after changes constitutes acceptance of the updated Privacy Policy.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Arch Ridgeline Technologies Limited

Dublin, Ireland

Email: [email protected]

15. Supervisory Authority

If you are not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with:

Irish Data Protection Commission

21 Fitzwilliam Square South

Dublin 2, D02 RD28

Ireland

Website: www.dataprotection.ie

Or your local supervisory authority if you reside in another EU/EEA member state.