Privacy Policy

3. Data We Collect

3.1. Information You Provide

When you submit an enquiry, complete a contact form, or engage with our service, we may collect:

•  Your name and job title
•  Business name and registered address
•  Email address and telephone number
•  Jurisdiction of incorporation and nature of business activities
•  Details of the services you are seeking
•  Any additional information you choose to provide

3.2. KYC and Due Dilligence Information

In the course of assessing your suitability for introduction to a regulated provider, we may request or receive documentation relating to your identity, business structure, ownership, source of funds, or regulatory status. This may include identity documents, corporate documentation, and information about beneficial owners and directors.

3.3. Automatically Collected Data

When you visit the Site, we may automatically collect technical data including your IP address, browser type, device identifiers, referring URLs, and pages visited, through cookies and similar technologies.

Please see our Cookie Policy for further information.

3.4. Data from Third Parties

We may receive information about you from publicly available sources (such as company registries and regulatory databases) or from regulated providers and professional intermediaries in the course of conducting due diligence or facilitating introductions.

4. Lawful Basis for Processing

We process personal data on the following lawful bases:

•  Legitimate interests — to assess your suitability for an introduction, to manage our business operations, and to maintain records of introductory activities. We have conducted a legitimate interests assessment and are satisfied that our interests do not override your fundamental rights and freedoms.

•  Pre-contractual steps / performance of a contract — where processing is necessary to respond to your enquiry or take steps prior to formalising an engagement.

•  Legal obligation — where we are required to process data to comply with applicable anti-money laundering, sanctions screening, or other regulatory obligations.

•  Consent — where we rely on your consent (e.g. for marketing communications), which you may withdraw at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. How We Use Your Data

We use personal data to:
•  Respond to your enquiry and assess your requirements
•  Identify and approach suitable regulated third-party providers on your behalf
•  Facilitate introductions and communicate progress
•  Manage our relationship with you and maintain engagement records
•  Send you relevant updates or information about our services — where you have consented or where we have a legitimate interest in doing so
•  Improve and maintain the performance and security of this Site

6. Sharing Your Data

6.1. Regulated Providers

To facilitate an introduction, we will share relevant information about you and your business with one or more regulated providers. We will inform you before making any such introduction. Once shared, those providers will process your data under their own privacy policies and as independent data controllers.

6.2. Service Providers

We may share data with trusted third-party suppliers who support our operations (e.g. CRM systems, email platforms, compliance screening tools). These parties act as data processors under written agreements and are not permitted to use your data for their own purposes.

6.3. Business Transfers

In the event of a merger, acquisition, or sale of assets, personal data may be transferred as part of that transaction. We will notify you of any such change and ensure appropriate protections remain in place.

7. International Transfers

Our service involves introducing clients to regulated providers across multiple jurisdictions, which may include territories outside the UK and European Economic Area (EEA). Where personal data is transferred internationally, we ensure that appropriate safeguards are in place, such as:

•  Transfers to countries with an adequacy decision; or
•  Use of the UK International Data Transfer Agreement (IDTA) or EU Standard Contractual Clauses (SCCs), as applicable.

8. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, taking into account:
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•  Any ongoing legal obligations or disputes
•  Our legitimate interests in maintaining records of introductory activity

Enquiries that do not progress to engagement will be retained for a shorter period and securely deleted thereafter.

9. Your Rights

Under UK GDPR and applicable data protection law, you have the following rights in relation to your personal data:

•  Right of access — to request a copy of the personal data we hold about you
•  Right to rectification — to request correction of inaccurate or incomplete data
•  Right to erasure — to request deletion of your data in certain circumstances
•  Right to restrict processing — to request that we limit how we use your data
•  Right to data portability — to receive your data in a structured, machine-readable format where technically feasible
•  Right to object — to object to processing based on legitimate interests or for direct marketing
•  Rights related to automated decision-making — we do not make decisions about you solely by automated means

Please note that some rights are subject to exemptions — for example, data we are legally required to retain for AML purposes cannot be deleted on request.

To exercise any of your rights, please contact us at privacy@clear.broker. We will respond within 30 days. We may need to verify your identity before processing a request.

10. Marketing Communications

Where you have indicated an interest in our services and we have a legitimate basis to do so, we may contact you with relevant updates or information about our introductory services. You may opt out at any time by contacting us or using the unsubscribe link included in any email communication.

11. Cookies

This site uses cookies and similar technologies to support functionality and improve performance. For detailed information about the cookies we use and your choices, please refer to our Cookie Policy.

12. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These include access controls, encryption in transit, and regular review of our information security practices.

Notwithstanding these measures, no method of transmission over the internet is completely secure. If you become aware of any security issue relating to data you have shared with us, please notify us promptly at privacy@clear.broker.

13. Complaints

If you have concerns about how we have handled your personal data, please contact us in the first instance so we can attempt to resolve the matter.

You also have the right to lodge a complaint with the relevant supervisory authority:
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•  UK: Information Commissioner's Office (ICO) — ico.org.uk
•  Isle of Man: Information Commissioner — inforights.im

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational circumstances. The date of the most recent update is shown at the top of this page. We encourage you to review this Policy periodically. Continued use of the Site following any update constitutes acceptance of the revised Policy.

15. Contact

For any questions about this Privacy Policy or to exercise your rights:If you have any questions about these Terms, please contact us:

Email: