Privacy Policy
Effective date: January 27, 2026
This Privacy Policy explains how Kyle Williams (trading as ClearLedger) (“we”, “us”, “our”) collects, uses, and protects personal data when you visit https://www.clearledger.finance or use our products and services (“Services”).
1. Who we are and how to contact us
The data controller responsible for your personal data is Kyle Williams.
- Email: me@clearledger.finance
- Jurisdiction: Hong Kong
2. What personal data we collect
We collect only the personal data that is reasonably necessary to operate the Services, fulfil purchases, comply with legal obligations, and protect against fraud or misuse.
2.1 Data you provide to us
- Identity and contact details (such as name and email address).
- Booking and communication details (such as scheduled sessions, messages, and preferences).
- Payment-related information (such as payment status, billing email, customer name, invoice references, and limited card identifiers like the last four digits or card brand).
- Support and correspondence (messages you send to us and our responses).
- Program inputs (information you voluntarily share as part of participating in the program, such as goals or progress notes).
We do not intentionally collect or store sensitive personal data such as full payment card numbers, CVV codes, bank account credentials, or government-issued identification. Please do not send this information to us.
Payments
Payments are processed securely by our third-party payment processor, Stripe. Stripe acts as an independent data controller for payment information and processes personal data in accordance with its own privacy policy.
We do not receive or store full payment card details. We receive only limited payment-related information necessary to confirm transactions, provide access to the Services, issue refunds, handle disputes, and meet legal and accounting obligations.
2.2 Data we collect automatically
- Usage data (pages viewed, interactions, referring URLs, and approximate location based on IP address).
- Device and technical data (browser type, device type, operating system, and language settings).
- Cookies and similar technologies used for essential functionality, analytics, and security.
3. How we use your personal data
- To provide, operate, and deliver the Services.
- To process payments, confirm transactions, and manage access.
- To communicate with you regarding the Services.
- To improve performance, security, and user experience.
- To comply with legal, tax, and regulatory obligations.
We do not sell personal data and do not use it for advertising profiles or automated decision-making.
4. Legal bases for processing
- Contract: to deliver purchased Services and manage bookings and payments.
- Legal obligation: to retain transaction and accounting records.
- Legitimate interests: to operate, secure, and improve the Services.
- Consent: where required for non-essential cookies or communications.
5. International transfers
Some service providers, including Stripe, may process personal data outside your country of residence. Where required, we rely on appropriate safeguards such as standard contractual clauses to protect international data transfers.
6. Data retention
We retain personal data only for as long as necessary to fulfil the purposes described in this policy, including legal, accounting, and dispute-resolution requirements.
7. Your rights
Depending on your location, you may have rights to access, correct, delete, or restrict the processing of your personal data, and to object to certain processing. You may also have the right to data portability and to withdraw consent where applicable.
To exercise your rights, contact us at me@clearledger.finance.