Privacy Policy
This Privacy Policy explains how ClearStatement ("we", "us", "our"), operated by David Titherington trading as ClearStatement, collects, uses, and protects personal data in connection with the ClearStatement service ("the Service").
We are committed to protecting your privacy and handling all personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Who We Are
Data controller: David Titherington, trading as ClearStatement
Contact: admin@clearstatement.co.uk
Website: clearstatement.co.uk
2. What Data We Collect
Account and billing data: When you subscribe, we collect your name, email address, and payment information (processed by Stripe — we do not store card details).
Usage data: We may collect basic technical information such as your IP address and browser type for security and operational purposes.
Bank statement data: The Service processes your clients' bank statement transaction data for categorisation purposes. This data is processed entirely within your browser and transmitted to our AI provider (Anthropic) solely for categorisation. We do not store, log, or retain any bank statement or transaction data on our servers.
3. How We Use Your Data
- To provide and maintain the Service
- To manage your subscription and send licence keys
- To send important service communications (e.g. billing, updates to these terms)
- To respond to your support requests
- To comply with our legal obligations
4. Legal Basis for Processing
- Contract: Processing necessary to provide the Service you have subscribed to
- Legitimate interests: Security, fraud prevention, and service improvement
- Legal obligation: Where required by law
5. Client Bank Statement Data
You (the subscriber) are the data controller for any personal data belonging to your clients that you process using the Service. ClearStatement acts as a data processor in this context.
Bank statement transaction text is transmitted to Anthropic (our AI provider) over an encrypted connection for the sole purpose of categorisation. No client personal data is stored by ClearStatement. Anthropic's data processing is governed by their Data Processing Agreement, which ClearStatement has signed.
You are responsible for ensuring you have the appropriate basis to process your clients' personal data and for informing clients accordingly under UK GDPR.
6. Third-Party Services
We use the following third-party services:
- Stripe — payment processing. Stripe Privacy Policy
- Anthropic — AI categorisation. Transaction text only; no personal identifiers. Anthropic Privacy Policy
- Cloudflare — hosting and security. Cloudflare Privacy Policy
- Brevo — transactional email (licence key delivery). Brevo Privacy Policy
7. Data Retention
We retain your account and billing data for as long as your subscription is active and for up to 7 years thereafter for legal and accounting purposes. Bank statement data is never retained by us.
8. Your Rights
Under UK GDPR, you have the right to:
- Access the personal data we hold about you
- Correct inaccurate data
- Request deletion of your data (subject to legal obligations)
- Object to or restrict processing
- Data portability
- Lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk
To exercise any of these rights, contact us at admin@clearstatement.co.uk.
9. Cookies
The ClearStatement tool does not use tracking cookies. We use browser localStorage solely to remember your licence key between sessions for your convenience. No data is shared with advertisers or analytics providers.
10. Security
We take appropriate technical and organisational measures to protect your personal data, including encrypted transmission (HTTPS), encrypted storage of licence keys, and restricted access to subscriber data.
11. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated by email. The current version is always available at clearstatement.co.uk/privacy.html.
12. Contact
For any privacy-related queries, please contact us at admin@clearstatement.co.uk.