Privacy Policy
This policy explains how Clearvett Screening Ltd collects and uses personal information: when you visit clearvett.com, get in touch or book a demo, use Clearvett as a customer, or appear in the information our customers check. We are committed to handling personal information lawfully, fairly and securely, in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Who we are
1.1 Clearvett is provided by Clearvett Screening Ltd, registered in England & Wales, company no. 17540254 (we, us, our). We are registered with the Information Commissioner's Office (ICO), registration no. ZC284505.
1.2 For any question about this policy or your personal information, contact us at support@clearvett.com or on +44 203 432 4771.
2. Our role
2.1 We are the controller of the personal information described in sections 3 to 6: information about visitors to our website, people who contact us, our customers and their users, and the data sets we compile ourselves from public sources.
2.2 When our customers use Clearvett to check a person, the customer decides whom to check and why. For those checks the customer is the controller and we act as its processor, following its instructions under the data processing terms in our Terms and Conditions. Section 7 explains what this means if you have been checked.
3. Visitors to our website
3.1 Our website does not use cookies, advertising trackers or analytics tools, and does not ask you for any personal information.
3.2 Like every website, our hosting provider receives technical information when you visit, such as your IP address, browser type and the pages you request. This is used only to deliver the website and protect it against attacks and misuse, and is kept for short periods. Our lawful basis is our legitimate interest in running a secure website.
3.3 Links on our website to other services, such as our demo booking page, are covered by those services' own privacy policies.
4. People who contact us or book a demo
4.1 When you email, call or book a demo with us, we collect the details you give us, such as your name, organisation, email address, phone number and your message or booking details.
4.2 We use them to reply to you, arrange and hold the demo, and discuss whether Clearvett is right for you. Our lawful basis is our legitimate interest in responding to enquiries and, where you are considering becoming a customer, taking steps at your request before entering into a contract.
4.3 We do not add you to marketing lists without your agreement, and we never sell your information.
5. Our customers and their users
5.1 When an organisation uses Clearvett, we hold information about the organisation and the people who use Clearvett on its behalf:
- Account details: name, work email address, organisation and role;
- Login and security records: when you log in, your IP address, country and browser;
- Records of your acceptance of our Terms and Conditions: which version, when, and from which IP address, country and browser;
- Usage records: the checks run, by whom and when, and your credit balance;
- Payment records: credits and plans bought and invoices. Card payments are handled by our payment provider; we do not see or store your full card details;
- Support records: your emails and calls with us.
5.2 We use this information to provide the Service and your account, keep it secure, prevent misuse, send service messages (such as login notices, Monitoring alerts and receipts), handle billing, provide support and improve Clearvett.
5.3 Our lawful bases are: performing our contract with your organisation; our legal obligations (for example keeping accounting records); and our legitimate interests in keeping the Service secure, preventing fraud and misuse, and improving it.
6. Data sets we compile ourselves
6.1 To help regulated businesses meet their anti-money laundering and counter-terrorist financing duties, Clearvett compiles some data sets itself from information already made public, including official sanctions lists, and its own register of UK politically exposed persons (PEPs) drawn from public sources such as Parliament, government, official gazettes and other official publications.
6.2 For PEPs this can include name, position held and dates, and, where publicly reported, family members and close associates. It is used only to let our customers screen the people they deal with, as required by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
6.3 Our lawful basis is our legitimate interest, and that of the businesses that rely on Clearvett, in preventing money laundering, terrorist financing, fraud and other crime. Where this involves special category or criminal offence information, we rely on the conditions in Schedule 1 of the Data Protection Act 2018, including preventing or detecting unlawful acts and regulatory requirements relating to unlawful acts and dishonesty.
6.4 If you believe information about you in these data sets is wrong or out of date, or you want to object to its use, contact us at support@clearvett.com and we will look into it promptly.
7. If you have been checked by one of our customers
7.1 Businesses that use Clearvett check the people they deal with, for example before taking someone on as a client, to meet legal duties to prevent money laundering, fraud and financial crime. The business that checked you is the controller of that check and should have told you about it in its own privacy notice. Please contact that business first about your information and your rights.
7.2 Checks compare the details provided (such as name, date of birth and nationality) with official sanctions lists, PEP data, insolvency and court records, company registers, law enforcement notices and published media. Crypto wallet checks look up public blockchain records for the wallet address given.
7.3 Remote ID checks. If you are asked to complete a Remote ID check, you will be asked for your consent on our page before your passport and selfie are taken. Comparing your face with your passport photo involves biometric data, which is used only to verify your identity and only with your explicit consent. Passport images and selfies are deleted automatically after 30 days.
7.4 We do not use these checks for any purpose of our own, and we do not sell or share them except as described in section 8. If you contact us, we will help the business that checked you respond to your request.
8. Who we share information with
8.1 We use trusted service providers to run Clearvett, under written contracts that require them to protect your information and use it only on our instructions. They provide: cloud hosting and storage; email delivery; payment processing; AI tools that help write summaries in reports; and the data and verification services behind our checks. A list is available on request.
8.2 We may also share information with our professional advisers, and with law enforcement, regulators or courts where the law requires it.
8.3 If our business is ever sold or reorganised, information may pass to the new owner, who must use it in line with this policy.
8.4 We never sell personal information.
9. International transfers
9.1 We store data in the UK or EU wherever possible. Some of our service providers may process information in other countries, such as the United States. When this happens, we make sure it is protected by a UK adequacy decision or by safeguards approved under UK law, such as the UK International Data Transfer Agreement or Addendum.
10. How long we keep information
| Information | Kept for |
|---|---|
| Website technical logs | Short periods, for security |
| Enquiries and demo bookings | Up to 2 years after we were last in touch, unless you become a customer |
| Customer account details and terms acceptance records | While the account is open, then 6 years |
| Payment and invoice records | 6 years, as the law requires |
| Activity log (who checked whom, and when) | 5 years |
| Remote ID passport images and selfies | 30 days, then deleted automatically |
| Remote ID check results | 5 years from the check |
| AML & Insolvency check records | 3 years |
| Monitoring lists and alerts | Until the person is removed, or the customer's account ends |
| Our compiled data sets (such as PEPs) | While the information remains relevant to anti-money laundering checks |
11. Keeping information secure
11.1 Clearvett is protected by encrypted connections, login controls, access only for people who need it, and records of who used the Service and when. Our staff are bound by confidentiality. No system is completely secure, but we work to protect your information and will tell you and the ICO about a serious breach where the law requires it.
12. Automated decisions
12.1 Clearvett highlights possible matches and risks for our customers to review. We do not make decisions about you with legal or similarly significant effects based solely on automated processing.
13. Your rights
13.1 You have the right to:
- ask for a copy of your personal information;
- ask us to correct information that is wrong or incomplete;
- ask us to delete your information, or to limit how we use it;
- object to our use of your information where we rely on legitimate interests;
- ask for information you gave us to be transferred to you or another organisation, where this applies;
- withdraw your consent at any time, where we rely on it.
13.2 Some rights do not apply in every case, for example where information must be kept to prevent crime or meet legal duties. To use your rights, contact us at support@clearvett.com. We will reply within one month, and there is normally no charge.
14. Complaints
14.1 If you have a concern, please contact us first so we can try to put it right. You also have the right to complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint or on 0303 123 1113.
15. Children
15.1 Clearvett is a business service and is not intended for children.
16. Changes to this policy
16.1 We may update this policy from time to time. The latest version will always be on this page, with the date it was last updated.