Privacy Policy
Effective Date: [EFFECTIVE_DATE]
Last Updated: [EFFECTIVE_DATE]
1. Definitions and Interpretation
1.1 In this Policy:
- "Account" means the account a Customer creates in order to use Clearmint;
- "APPs" means the Australian Privacy Principles set out in Schedule 1 to the Privacy Act;
- "Clearmint" means the Clearmint personal finance web application, together with any related services supplied by the Company;
- "Company" means [ENTITY_NAME] (ABN [ABN]);
- "Customer" means a person who creates an Account or otherwise uses Clearmint;
- "Customer Data" means the figures and other information a Customer enters into Clearmint;
- "Meta" means Meta Platforms, Inc. and its affiliates;
- "Privacy Act" means the Privacy Act 1988 (Cth);
- "Support Email" means [SUPPORT_EMAIL];
- "Terms" means the Company's Terms of Service;
- "Visitor" means a person who visits the Website; and
- "Website" means the Company's public website at clearmint.app, excluding Clearmint.
- “Waitlist” means the list of email addresses collected on the Website before Clearmint is publicly launched;
1.2 Headings are for convenience only and do not affect the interpretation of this Policy. The word "including" is not a word of limitation.
2. About This Policy
2.1 Clearmint is operated by the Company, a business registered in Australia.
2.2 This Policy explains what personal information the Company collects, why it is collected, to whom it is disclosed, and the choices available to Customers and Visitors. It applies to the Website, Clearmint and any email the Company sends.
2.3 The Company handles personal information in accordance with the Privacy Act and the APPs. Clearmint is available worldwide, and clause 12 addresses rights that may apply depending on a person's country of residence.
3. Overview
3.1 This clause 3 is a summary only. If there is any inconsistency between this clause and the remainder of this Policy, the remainder of this Policy prevails.
3.2 Clearmint does not connect to any bank. It has no bank feeds or open banking integration, and no access to banking credentials.
3.3 The Company does not receive or store payment card numbers. Payments are processed by Stripe.
3.4 Customer Data is stored in Australia, in a database hosted in Sydney.
3.5 The Company does not sell Customer Data.
3.6 Clearmint contains no advertising, analytics or tracking. The Website uses Cloudflare Web Analytics and the Meta Pixel, as described in clauses 4 and 11.
4. Information Collected
4.1 Account information. When a Customer creates an Account, the Company collects the Customer’s name, email address, password and country of residence, and where the Customer’s country is one for which the Company offers a state or region list, their state or region. Passwords are stored in hashed form. Where a Customer chooses to create an Account or log in using Google, Google provides the Company with the Customer's name and email address, and no password is created.
4.2 Customer Data. Customer Data is the information a Customer enters into Clearmint, including income, expenses, assets, debts, savings goals and investment projections. The Customer chooses what to enter. Clearmint does not require a bank account number and has no field requesting one.
4.3 Payment information. When a Customer purchases Clearmint, Stripe processes the payment and sends the Company a confirmation containing the Customer's email address, the amount paid, the currency and a transaction reference. The Company does not receive the Customer's card number, security code or expiry date, which are provided directly to Stripe.
4.4 Technical information. The Company's hosting provider records standard web server information, including IP address, browser type and version, device type, the pages requested, and the date and time of access. This information is used for security, fraud prevention and fault diagnosis.
4.5 Website analytics. The Company uses Cloudflare Web Analytics on the Website to understand visits to the Website. Cloudflare Web Analytics is cookieless. It is not used within Clearmint, and Customer Data is never sent to any analytics service.
4.6 Meta Pixel. The Company uses the Meta Pixel, a tool provided by Meta, on the Website. The Meta Pixel uses cookies to collect information about Visitors' activity on the Website, such as pages viewed, and sends that information to Meta for advertising purposes. The Meta Pixel is not used within Clearmint, and Customer Data is never sent to Meta.
4.7 Contact correspondence. Where a person contacts the Company through the contact form on the Website or by email, the Company collects their name, email address, the subject category they select and the content of their message. The Company retains that correspondence and its reply in order to assist the person and to refer to it if they make further contact.
4.8 Waitlist. Before Clearmint is publicly launched, a person may join the Waitlist by providing their email address on the Website. The Company collects the email address and the date it was provided. No other information is collected, and joining the Waitlist does not create an Account.
4.9 Spam prevention. The contact form on the Website is protected by Cloudflare Turnstile. Turnstile collects technical information about the browser and device submitting the form, including IP address, in order to distinguish genuine submissions from automated ones. Turnstile does not receive the content of the message.
5. Information Not Collected
5.1 Clearmint does not use open banking, screen scraping or any account aggregation service. The Company will never request a Customer's internet banking login details, and a Customer must not provide them to the Company or to any person claiming to represent the Company.
5.2 The Company does not receive payment card numbers (see clause 4.3).
5.3 The Company does not request government identifiers, including tax file numbers, driver licence numbers, passport numbers or Medicare numbers, or their equivalent in any country. A Customer who has entered such an identifier into a free-text field should remove it.
5.4 The Company does not sell personal information.
6. Purposes of Collection
6.1 The Company collects personal information only where it is reasonably necessary for the Company's functions, and uses it for the following purposes:
| Purpose | Information used |
|---|---|
| Creating and securing Accounts | Name, email address, hashed password |
| Storing and synchronising Customer Data across devices | Customer Data |
| Processing purchases and confirming access | Email address, Stripe transaction reference |
| Sending transactional email, including receipts, password resets and service notices | Email address |
| Responding to support requests | Email address, correspondence, limited Account details |
| Maintaining security and diagnosing faults | Technical information |
| Understanding visits to the Website | Cloudflare Web Analytics data |
| Advertising | Information collected by the Meta Pixel on the Website |
| Sending product news to Customers who have opted in | Email address |
| Responding to contact form submissions | Name, email address, subject category, message content |
| Notifying Waitlist subscribers of launch, and sending news and partner offers | Email address |
| Preventing automated abuse of the contact form | Technical information collected by Cloudflare Turnstile |
7. Storage of Customer Data
7.1 Customer Data is stored in the Company's database and synchronised to each device on which the Customer is signed in, so that it is available on any device at any time.
7.2 Customer Data is encrypted in transit using TLS, and encrypted at rest by the Company's database provider.
7.3 Customer Data is associated with the Customer's Account and is not visible to other Customers.
7.4 Clearmint may keep a copy of Customer Data in the browser's local storage so that it remains responsive, including where Clearmint has been added to a home screen. Clearing browser data removes that local copy; the Customer Data held in the Customer's Account is unaffected.
7.5 Backups. The Customer may generate a PDF report from Clearmint at any time. Although the Company takes reasonable steps to protect Customer Data, the Customer should not rely on any single service as the only copy of information that is important to them.
8. Disclosure of Personal Information
8.1 The Company discloses personal information to the following service providers, to the extent set out below:
| Provider | Service | Information received |
|---|---|---|
| Stripe | Payment processing | Email address and payment details (card details are provided directly to Stripe and do not pass through the Company) |
| Supabase | Account authentication and database | Name, email address, hashed password, country and state or region, Customer Data, contact form submissions and Waitlist email addresses |
| Optional sign-in | Name and email address, where the Customer chooses to sign in with Google | |
| Cloudflare | Website hosting, content delivery, security, cookieless Website analytics and contact form spam prevention | Technical information, including IP address, and Website analytics data |
| Resend | Transactional email | Email address and message content |
| Meta | Advertising | Information collected by the Meta Pixel about Visitors' activity on the Website |
8.2 Other than as set out in clause 8.1, the Company discloses personal information only where:
(a) the individual requests or consents to the disclosure;
(b) the disclosure is required or authorised by Australian law, a court or a regulator; or
(c) the disclosure is necessary to investigate suspected fraud or a serious threat to a person's safety.
9. Overseas Processing
9.1 Account information and Customer Data are stored in Australia, in a database hosted in Sydney, New South Wales.
9.2 Certain of the Company's service providers operate globally, and some of the information described in clause 8.1 is processed outside Australia. Stripe, Cloudflare, Resend, Google and Meta may process information in the United States, the European Union and other countries in the course of processing payments, serving the Website, delivering email, providing sign-in and providing advertising services.
9.3 By using the Website or Clearmint, a person acknowledges that some of their information may be processed outside their country of residence.
10. Marketing
10.1 When creating an Account, a Customer may choose to receive product news from the Company. Marketing email is sent only to Customers who have opted in.
10.2 Every marketing email includes an unsubscribe link, and unsubscribing takes effect promptly. A Customer may also withdraw consent at any time by writing to the Support Email.
10.3 Unsubscribing does not stop transactional email. Receipts, password resets and service notices form part of the supply of Clearmint and cannot be opted out of while the Customer holds an Account.
10.4 Waitlist. A person who joins the Waitlist consents to receive an email when Clearmint launches, and occasional news and partner offers after that. Every such email includes an unsubscribe link, and unsubscribing takes effect promptly. A person may also unsubscribe at any time by writing to the Support Email. Joining the Waitlist does not create an Account and does not entitle a person to use Clearmint.
11. Cookies and Similar Technologies
11.1 Clearmint uses browser storage to keep Customers signed in and to hold a working copy of Customer Data so that Clearmint operates smoothly. This storage is strictly functional.
11.2 Clearmint does not use advertising or tracking cookies.
11.3 On the Website, Cloudflare Web Analytics is cookieless. The Meta Pixel uses cookies to collect information about Visitors' activity on the Website for advertising purposes, as described in clause 4.6.
11.4 Browser storage and cookies may be cleared at any time through the browser's settings. Clearing the browser storage used by Clearmint signs the Customer out and removes the local working copy of Customer Data.
12. Access, Correction and Deletion
12.1 A person may request a copy of the personal information the Company holds about them, or request that it be corrected if it is inaccurate, by writing to the Support Email. The Company will respond within a reasonable time and may need to verify the person's identity first. If the Company refuses a request, it will provide its reasons in writing.
12.2 A Customer may also, from within Clearmint, clear all Customer Data from their Account while keeping the Account open, or delete their Account entirely. Deleting an Account permanently removes the Account and its associated data and ends the Customer's access to Clearmint. Neither action can be reversed and no refund is given. A Customer may instead request deletion by writing to the Support Email.
12.3 Customers in the European Economic Area or the United Kingdom may have additional rights under the data protection laws of their region.
12.4 Where the law of a person's country of residence provides stronger rights than this Policy, those rights apply.
13. Security
13.1 The Company takes reasonable steps to protect personal information from misuse, loss and unauthorised access. These include encryption in transit, encryption at rest through the Company's database provider, hashed password storage and access controls.
13.2 No method of transmission or storage is completely secure, and the Company cannot guarantee absolute security. Customers should use a strong, unique password and keep it confidential.
14. Retention
14.1 The Company retains Account information and Customer Data for as long as the Account remains open. When a Customer deletes their Account, whether from within Clearmint or by writing to the Support Email, the Company will delete the Account and its associated data.
14.2 The Company retains transaction records for the period required by Australian tax and corporations law, currently five (5) years. Those records contain the Customer's email address, the amount paid and the date of payment, and do not contain Customer Data.
14.3 Where a Customer’s access is withdrawn following a refund or chargeback, the Company retains the Account and Customer Data for thirty (30) days from the date access is withdrawn so that the Customer may re-activate without loss of their information, after which the Account and Customer Data are deleted. Clause 14.2 continues to apply to transaction records.
14.4 The Company retains contact form submissions and email correspondence for two (2) years from the date of the last message in the exchange, after which they are deleted.
14.5 The Company retains a Waitlist email address until the person unsubscribes or asks to be removed. Where a person unsubscribes, the Company retains their email address only for the purpose of ensuring they are not added to the Waitlist again.
15. Children
15.1 Clearmint is not directed at children. A person must be at least sixteen (16) years of age to create an Account, as set out in the Terms.
16. Amendments
16.1 The Company may amend this Policy from time to time, in which case the "Last Updated" date will be revised.
17. Contact and Complaints
17.1 Questions, requests and complaints regarding this Policy may be directed to:
[ENTITY_NAME] (ABN [ABN])
Email: [SUPPORT_EMAIL]
17.2 A person who is not satisfied with the Company's response to a privacy complaint may contact the Office of the Australian Information Commissioner:
Website: oaic.gov.au
Phone: 1300 363 992