1. Who we are
Clearyx operates a software platform that helps Nigerian organizations manage administrators, members, dues, fines, payment receipts, and settlement bank details.
Contact for privacy matters:
cetrakeep@gmail.com
2. Scope
This Policy applies to:
- Organization Admins (OrgReps) — including primary and co-admins.
- Members — individuals who register and may join organizations via Reference Code.
- Visitors who use public pages (e.g. home, forgot password, terms).
Organizations may process member data for their own purposes. Clearyx provides tools; each Organization remains responsible for how it uses member information under its own rules and applicable law.
3. Information we collect
3.1 Account and profile data
- Admins: full name, email, phone number, organization name and type, position held, password (stored as a hash), and settlement bank details (bank name, account number, account name).
- Members: full name, email, phone number, local government, state of origin, residential address, profile photograph, and password (stored as a hash).
3.2 Organization and membership data
- Organization Reference Code (e.g. CLX-XXXXXX).
- Membership records linking members to organizations (join date, status).
- Admin invites (name, email, phone, position, token, status).
- Primary-admin designation and transfers between co-admins.
3.3 Financial and payment data
- Dues and fines (titles, amounts, descriptions, status).
- Payment records: amounts, service fees, Paystack references, unique Clearyx receipt IDs, timestamps, and payment status.
- Settlement account change requests, including purpose text and uploaded proof documents (images/PDFs).
- Bank account lookup results obtained via payment/banking APIs (e.g. resolved account name).
3.4 Communications
- Support messages from members to organization admins (subject, body, status, timestamps).
- Emails we send (invites, payment notices, password resets, admin replies) and related delivery metadata.
3.5 Technical and security data
- Session identifiers and login state (e.g. admin or member session).
- Password-reset tokens (time-limited, single-use).
- Server logs needed for security, debugging, and abuse prevention (which may include IP address, timestamps, and error traces).
3.6 Information we do not intentionally collect
We do not ask for full payment card numbers to be stored on Clearyx servers; card entry is handled by the payment provider (e.g. Paystack) under their own terms and policies.
4. How we use information
We use personal and organization data to:
- Create and operate admin and member accounts.
- Issue Reference Codes and manage multi-admin teams (invites, primary transfer).
- Verify and store settlement bank details (including NUBAN resolution).
- Publish dues/fines, process payments, generate receipts, and support receipt verification.
- Process settlement account change requests with dual-admin consent and documentation.
- Route member support messages to organization admins and enable email replies.
- Send transactional emails (welcome, invites, payment receipts, password reset, security notices).
- Protect the Service (fraud prevention, abuse detection, security investigations).
- Comply with legal obligations and enforce our Terms.
- Improve reliability and user experience (e.g. diagnosing failures from logs).
We do not sell your personal information to third parties for their independent marketing.
5. Legal bases (Nigeria)
Where the Nigeria Data Protection Act (NDPA) and related regulations apply, we process personal data on bases that may include:
- Contract — to provide the Service you request (accounts, payments, receipts, admin tools).
- Consent — where required (e.g. optional communications or certain uploads), which you may withdraw where applicable.
- Legitimate interests — security, service improvement, and preventing abuse, balanced against your rights.
- Legal obligation — where we must retain or disclose information under law.
7. Retention
We retain information for as long as needed to:
- Provide the Service and maintain account history (including receipts and payment audit trails).
- Meet legal, tax, accounting, or dispute-resolution requirements.
- Secure the platform and investigate abuse.
Password-reset tokens expire (typically within hours) and are invalidated after use. When accounts or organizations are closed, we may delete or anonymize data within a reasonable period, except where retention is required or permitted by law.
8. Security
We implement reasonable technical and organizational measures, including:
- Hashed passwords (not stored in plain text).
- Session-based authentication for admins and members.
- Time-limited, single-use reset tokens.
- Access controls so organization data is scoped by Reference Code / membership.
- Secure upload handling for allowed document types (e.g. PNG, JPG, PDF) used in settlement change proofs.
No system is perfectly secure. You must protect your login credentials and devices. Notify us promptly at cetrakeep@gmail.com if you suspect unauthorized access.
9. International processing
Infrastructure or subprocessors (email, payments, hosting) may process data outside Nigeria. Where that occurs, we take steps appropriate under applicable law so that personal data continues to receive a suitable level of protection.
10. Your rights
Subject to the Nigeria Data Protection Act and other applicable law, you may have rights to:
- Access personal data we hold about you.
- Request correction of inaccurate data.
- Request deletion, in certain circumstances.
- Object to or request restriction of certain processing.
- Withdraw consent where processing is consent-based (without affecting prior lawful processing).
- Lodge a complaint with the relevant data protection authority in Nigeria.
To exercise rights, email cetrakeep@gmail.com with enough detail to verify your identity and the account involved (registered email and, if relevant, Organization Reference Code). We may need to retain some records (e.g. payment receipts) even after a deletion request, where the law requires it.
11. Children
The Service is directed at organizations and adults capable of forming binding accounts. We do not knowingly collect personal data from children under 18 for the purpose of creating admin or member accounts. If you believe a child has provided data inappropriately, contact us and we will take reasonable steps to delete it.
13. Third-party links and services
Payment pages, bank resolution, and email delivery are provided in whole or in part by third parties. Their privacy practices are governed by their own policies. We encourage you to review Paystack’s and other providers’ privacy notices.
14. Changes to this Policy
We may update this Privacy Policy from time to time. The “Last updated” date at the top will change when we do. Material updates may also be communicated through the Service or by email. Continued use after an update constitutes acknowledgment of the revised Policy.
15. Contact
Questions, requests, or complaints about privacy:
cetrakeep@gmail.com
Please include your registered email and, where relevant, your role (Admin or Member) and Organization Reference Code so we can respond efficiently.