Legal
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:
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 Type | Examples | Purpose |
|---|---|---|
| Account Information | Email address, name, business name | Account creation and communication |
| Business Information | Company name, business type, invoice details | Providing invoicing services |
| Communications | Support requests, feedback | Customer support and service improvement |
3.2 Information Collected Automatically
| Data Type | Examples | Purpose |
|---|---|---|
| Blockchain Data | Wallet addresses, transaction hashes, invoice NFT data | Core service functionality |
| Device Information | IP address, browser type, operating system | Security and service optimization |
| Usage Data | Pages visited, features used, timestamps | Service 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)
| Purpose | Legal Basis |
|---|---|
| Providing the Services | Performance of contract (Art. 6(1)(b)) |
| Account management | Performance of contract (Art. 6(1)(b)) |
| Customer support | Performance of contract (Art. 6(1)(b)) |
| Security and fraud prevention | Legitimate interests (Art. 6(1)(f)) |
| Service improvement and analytics | Legitimate interests (Art. 6(1)(f)) |
| Legal compliance | Legal obligation (Art. 6(1)(c)) |
| Marketing communications | Consent (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:
| Provider | Purpose | Data Shared |
|---|---|---|
| Privy | Embedded wallet infrastructure | Authentication data, wallet identifiers |
| Safe | Smart contract wallet | Wallet addresses, transaction data |
| Blockchain Networks (Base, Ethereum) | Transaction processing | Public transaction data |
| Cloud Infrastructure | Hosting and storage | All 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 Type | Retention Period | Reason |
|---|---|---|
| Account information | Duration of account + 3 years | Legal and contractual obligations |
| Support communications | 3 years | Service improvement, legal claims |
| Usage analytics | 2 years (anonymized) | Service improvement |
| Marketing preferences | Until consent withdrawn | Compliance 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:
| Right | Description |
|---|---|
| Access | Request a copy of your personal data |
| Rectification | Request correction of inaccurate data |
| Erasure ("Right to be Forgotten") | Request deletion of your data (subject to legal limitations) |
| Restriction | Request limited processing of your data |
| Portability | Receive your data in a structured, machine-readable format |
| Object | Object to processing based on legitimate interests |
| Withdraw Consent | Withdraw 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
| Type | Purpose | Duration |
|---|---|---|
| Essential Cookies | Required for basic functionality (authentication, security) | Session |
| Functional Cookies | Remember your preferences and settings | 1 year |
| Analytics Cookies | Understand how users interact with the Services | 2 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:
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.