Legal

Privacy Policy

Effective date: 23 March 2026 · ClearPulse Limited (RC: [INSERT RC NUMBER])

Plain-language summary: ClearPulse connects to your bank accounts to help you understand where your money goes. We only collect what we need, we never sell your data, and you can delete your account and all associated data at any time. This policy explains exactly what we collect, why, and how we protect it.

Who We Are

ClearPulse Limited is a company incorporated in Nigeria (RC: [INSERT RC NUMBER]) with its registered address at 26, AF Street, Federal Low Cost Housing Estate, Ikorodu, Lagos State. We operate the ClearPulse personal finance platform accessible at clearpulse.ng.

For the purposes of the Nigeria Data Protection Regulation (NDPR) 2019 and the Nigeria Data Protection Act (NDPA) 2023, ClearPulse Limited is the data controller of your personal information.

You can contact our data protection officer at: privacy@clearpulse.ng

What Data We Collect

We collect only the data necessary to provide you with financial clarity. This includes:

Account and identity data:

Full name and email address (collected at registration)
Password (stored as a one-way cryptographic hash — we cannot read it)
Profile photo (optional)

Financial data (collected only with your explicit consent):

Bank account balances and transaction history, retrieved via Mono Technologies (our licensed Open Finance partner)
Manually entered income and expense records that you add yourself
Categorisation data and spending labels you create or confirm

Technical and usage data:

IP address, browser type, and device information (collected automatically when you use the platform)
Log data including pages visited, features used, and timestamps
Cookies and session tokens necessary for authentication and security

We do not collect your bank login credentials. Bank account connections are handled entirely by Mono Technologies using secure, regulated Open Finance infrastructure. ClearPulse receives only read-only transaction data — we cannot initiate transfers or payments on your behalf.

How We Use Your Data

We use your data solely to provide and improve the ClearPulse service. Specifically:

To authenticate you and maintain your account securely
To retrieve and display your bank transactions via Mono's Open Finance API
To automatically categorise transactions and generate spending insights
To calculate your financial runway, net worth, and other dashboard metrics
To send you notifications, digests, and alerts you have opted into
To respond to your support requests
To detect and prevent fraud, abuse, or security incidents
To comply with our legal obligations under Nigerian law

We do not use your financial data for advertising. We do not sell, rent, or share your personal data with third parties for their own commercial purposes.

Legal Basis for Processing

Under the NDPA 2023, we process your personal data on the following legal bases:

Consent — for connecting your bank accounts via Mono. You provide explicit, informed consent at the point of bank account connection, and you may withdraw this consent at any time by disconnecting your account within the app.
Contract performance — for processing data necessary to deliver the ClearPulse service you have signed up for.
Legitimate interests — for fraud prevention, security monitoring, and product improvement, where these do not override your rights.
Legal obligation — where processing is required to comply with applicable Nigerian law.

Bank Account Connection and Mono Technologies

ClearPulse uses Mono Technologies Limited, a licensed Open Finance provider regulated under the Central Bank of Nigeria (CBN) Open Banking Framework, to facilitate secure bank account connections.

When you connect a bank account:

You are redirected to Mono's secure consent interface, which is operated entirely by Mono
Your bank login credentials are entered directly with Mono and are never transmitted to or stored by ClearPulse
Mono provides ClearPulse with read-only access to your account balance and transaction history
This access is governed by Mono's own Privacy Policy, available at mono.co/privacy

You may disconnect any linked bank account at any time from your ClearPulse settings. Upon disconnection, ClearPulse will cease fetching new data from that account. Historical transaction data already imported may be retained in your account history unless you request full deletion.

Data Storage and Security

Your data is stored on secure cloud infrastructure. We implement the following security measures:

All data is encrypted in transit using TLS 1.2 or higher
Passwords are hashed using industry-standard algorithms (bcrypt) — we cannot recover or read your password
Access to production databases is restricted to authorised personnel only
Two-factor authentication is available and encouraged for all accounts
Security incidents are logged and reviewed on an ongoing basis

While we take security seriously, no system is completely immune to risk. In the event of a data breach that is likely to affect your rights, we will notify affected users within 72 hours of becoming aware of the incident, in accordance with NDPA requirements.

Data Retention

We retain your data for as long as your account is active or as needed to provide you with the service. Specifically:

Account and transaction data is retained for the duration of your account
Upon account deletion, your personal data is permanently deleted within 30 days
Anonymised, aggregated data that cannot be used to identify you may be retained for analytical purposes after account deletion
We may retain certain records for up to 7 years where required by Nigerian tax or financial regulation

Sharing Your Data

We do not sell your personal data. We share your data only in the following limited circumstances:

Mono Technologies — as our Open Finance infrastructure provider, solely to facilitate bank account connections you have consented to
Supabase — our database and authentication infrastructure provider, acting as a data processor under our instructions
Paystack — for processing subscription payments. Paystack processes only the payment data necessary to complete transactions
Legal compliance — where required by Nigerian law, court order, or regulatory authority

All third-party processors are contractually bound to process your data only as instructed by ClearPulse and to maintain appropriate security standards.

Your Rights Under the NDPA 2023

As a data subject under Nigerian law, you have the following rights:

Right of access — you may request a copy of all personal data we hold about you
Right to rectification — you may correct inaccurate data held about you
Right to erasure — you may request deletion of your account and all associated data
Right to restrict processing — you may ask us to limit how we use your data in certain circumstances
Right to data portability — you may request your transaction data in a machine-readable format (CSV or JSON)
Right to withdraw consent — you may disconnect bank accounts or delete your account at any time without penalty
Right to object — you may object to processing based on legitimate interests

To exercise any of these rights, contact us at privacy@clearpulse.ng. We will respond within 30 days.

Cookies

ClearPulse uses only essential cookies necessary for the platform to function. These include session tokens for authentication and security preferences. We do not use advertising, tracking, or analytics cookies from third parties.

Children's Privacy

ClearPulse is intended for users aged 18 and above. We do not knowingly collect personal data from individuals under 18. If you believe a minor has created an account, please contact us at privacy@clearpulse.ng and we will delete the account promptly.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make material changes, we will notify you by email and display a notice within the app at least 14 days before the changes take effect. Your continued use of ClearPulse after that date constitutes acceptance of the updated policy.

The current version is always available at clearpulse.ng/privacy.

Contact our Data Protection Officer

Email: privacy@clearpulse.ng

Company: ClearPulse Limited

Address: 26, AF Street, Federal Low Cost Housing Estate, Ikorodu, Lagos State

RC Number: [INSERT RC NUMBER AFTER CAC REGISTRATION]