Privacy Policy

1. Data Controller

The entity responsible for the processing of personal data ("Data Controller") is the operator of the Clearfinal website.

For any questions related to this Privacy Policy or the processing of personal data, users may contact the Data Controller via the contact details made available on the Website.

2. Scope of This Policy

This Privacy Policy applies exclusively to data collected through the Website during its pre-launch phase.

It does not govern the processing of data within the Clearfinal platform itself, which is not yet publicly available.

3. Categories of Personal Data Collected

At this stage, the Website collects only limited personal data, primarily through a waitlist form.

3.1 Data Provided Directly by the User

The following information may be collected voluntarily:

• Professional email address
• Company name (optional)
• Areas of interest related to the Clearfinal product (optional), such as instant settlement, global treasury management, stablecoin payments, and on-ramps and off-ramps

Users are not required to provide sensitive personal data.

3.2 Automatically Collected Data

When users visit the Website, limited technical information may be collected automatically, such as IP address (anonymized where possible), browser type and version, device and operating system information, and approximate geographic location at country or region level.

This data is collected for technical and statistical purposes only.

4. Purposes of Data Processing

Personal data is processed strictly for the following purposes:

• Managing and maintaining the waitlist
• Sending informational communications related to the Clearfinal launch
• Understanding aggregated interest in different product areas
• Improving the Website's performance, usability, and content

Personal data is not used for advertising, behavioral profiling, automated decision-making, or data resale.

5. Legal Basis for Processing

The processing of personal data is based on one or more of the following legal grounds:

• User consent, provided when submitting the waitlist form
• Legitimate interest, limited to operating, securing, and improving the Website

Where consent is required, users may withdraw it at any time.

6. Data Retention

Personal data is retained only for as long as necessary to fulfill the purposes described in this Privacy Policy or until the user requests its deletion.

Once the data is no longer needed, it is securely deleted or anonymized.

7. Data Sharing and Third Parties

Personal data is not sold or disclosed to third parties for marketing purposes.

However, data may be processed by trusted third-party service providers acting on behalf of the Data Controller, such as website hosting providers, email communication tools, and analytics providers.

These providers process data solely under documented instructions and appropriate confidentiality and security obligations.

8. International Data Transfers

Some service providers may be located in jurisdictions outside the user's country. In such cases, appropriate safeguards are implemented to ensure an adequate level of data protection in line with international data protection standards.

9. Data Security

Appropriate technical and organizational measures are implemented to protect personal data against unauthorized access, loss, alteration, disclosure, or accidental or unlawful destruction.

While no system can guarantee absolute security, reasonable safeguards consistent with industry standards are applied.

10. User Rights

Users may exercise the following rights, subject to applicable data protection standards:

• Access to their personal data
• Correction or updating of inaccurate data
• Deletion of personal data
• Restriction of or objection to certain processing activities
• Withdrawal of consent at any time

Requests can be submitted using the contact details provided on the Website.

11. No Contractual Relationship

Submitting information through the Website or joining the waitlist does not create a contractual or customer relationship, does not imply any obligation to use future services, and does not constitute an offer or commitment by Clearfinal.

12. Changes to This Privacy Policy

This Privacy Policy may be updated periodically to reflect changes in the Website, regulatory requirements, or operational practices.

Any material changes will be published on this page with an updated revision date.