Klear Finance S.r.l. continuously adopts and updates internal procedures and policies in accordance with the General Data Protection Regulation (GDPR - EU Regulation 2016/679), to ensure high levels of security and full compliance with the regulations on the protection of Personal Data. This privacy notice describes how Klear Finance S.r.l. processes your Personal Data, who we are, why and how we collect your data, to whom it may be communicated (such as public authorities or consultants) and what your rights are regarding it.

What is meant by Personal Data?

Personal Data is any information that allows the identification of a natural person, for example: name, tax code, address, phone number, online identifiers, personal characteristics such as genetic, economic, financial data (such as account or credit card number), health data, and information related to legal proceedings.

What does it mean to process Personal Data?

The processing of Personal Data includes operations, even automated, that relate to the Personal Data of a natural person, such as collection, recording, organization, storage, modification, extraction, use, communication, interconnection, limitation, deletion, and destruction of data.

Who processes your Personal Data?

Klear Finance S.R.L., based in Milan at Via Val Bregaglia n.3, VAT number 13462040968, acts as the data controller. Personal Data is processed by authorized personnel within the Company as well as by external parties, such as data processors, in compliance with current regulations.

Why do we collect your Data?

Your Personal Data is necessary for specific purposes related to the management of the contractual relationship, including:

I. Main purposes:

• Provision of services offered through the Klear Finance platform;

• Operational management of services, including customer communications, assistance, software updates;

• Maintenance and updating of archives and customer accounts;

• Management of any disputes and other needs related to the requested service.

II. Promotional and marketing purposes:

• Market research, economic and statistical analysis;

• Sending promotional material related to the products and services offered;

• Improvement of user experience.

III. Legal obligations and legitimate interests:

• Prevention of fraud and anti-money laundering activities;

• Protection of the rights of the data controller and users.

The legal basis for processing is based on: contractual obligations (point I), explicit consent of the user (point II), and legal obligations or legitimate interests of the Company (point III). Providing Data for the purposes outlined in point I is mandatory; failure to provide it may hinder the proper execution of services. Providing Data for marketing purposes is optional and does not affect the delivery of primary services.

How do we use your Data?

The Company manages Personal Data securely and transparently, using appropriate measures to ensure confidentiality and protection. Processing occurs through both paper and digital means, with IT and telecommunications tools. Communications related to the services can occur through traditional mail, phone, email, and other automated means.

How long do we keep your Personal Data?

Personal Data will be retained for the time necessary to achieve the purposes described (points I, II, and III), or for the period required by law. For the purposes of point III, Data is retained for a maximum of 10 years from collection, unless revoked.

With whom do we share your Data?

Personal Data may be communicated to external parties for the purposes described above, including:

• Hosting service providers;

• Companies for the maintenance of IT systems and platform services;

• Legal, tax, and accounting consultants;

• Competent public authorities;

• Partners for joint services or promotions;

• Law enforcement and public authorities in cases provided for by law;

• Market research firms;

• Payment services and payment management.

• Partners for banking and/or financial connections (SaltEdge End-user Dashboard).

Can the Company process Data for purposes other than those indicated?

No, the Company is committed to processing Personal Data only for the declared purposes. If new needs arise, we will provide additional information and request the user's consent when necessary.

What are your rights?

At any time, you can exercise the following rights:

• Right of access: confirmation of the existence of processing of your Data and access to the same;

• Right to rectification: updating inaccurate Personal Data;

• Right to portability: requesting Data in a readable format;

• Right to restriction: limiting processing in specific circumstances;

• Right to object: object to processing for personal reasons or for marketing activities;

• Right to erasure: removal of Data when they are no longer necessary or the consent has been withdrawn.

To exercise these rights, send a request to info@klearfinance.com.

Data retention after account deactivation
After you deactivate your account, your personal data will be deleted from our systems permanently within 30 days. 

Can consent be revoked?

Yes, you can revoke consent at any time without affecting the legality of the processing already carried out. Revocation of consent will entail the cessation of services, where the Data is necessary for delivery.

Who can you contact in case of violations?

If you believe your Data has been processed unlawfully or in violation of the regulation, you can file a complaint with the Supervisory Authority (Privacy Guarantor) following the guidelines available at:

https://www.garanteprivacy.it/home/docweb/-/docweb-display/docweb/4535524.

Do you have any other questions?

For further information on privacy or to exercise your rights, contact our team at info@klearfinance.com. This privacy notice supersedes any previous communications in this regard.