Merchant Privacy Policy

Clearpay Merchant Privacy Policy

Effective Date: 11 November, 2025

We appreciate that you trust us with your personal information. Here we provide an overview of what personal information we collect from you and why, how we handle it, and your rights and choices.

This Privacy Policy describes how Clearpay and affiliates (“Clearpay,” “we,” “us”, and "our") collect, use, disclose, transfer, store, retain or otherwise process your personal information ("your", “you”, and "Merchant") when you visit our website, apply for and use our Merchant product and related services, or otherwise interact and engage with us in relation to our Merchant products, features, and services, including as outlined in our Terms of Service ("agreement") (collectively, "Services"). The Clearpay entity you are interacting with will be based on your country of residence.

Partners, merchants, online market places, and suppliers that Clearpay interacts with are independent of Clearpay and responsible for their own privacy policies and practices. This includes, content on their websites or app, and products or services provided. Please refer to their Privacy Policy or reach out directly to those third parties for further information.

Our Privacy Policy explains:

1. Personal information we collect about you and why

2. When and with whom we share your personal information

3. How we secure your personal information

4. How we use cookies and similar technologies

5. How long we keep your personal information

6. Your rights and choices

7. Rights of California Residents and Federal Privacy Notice

8. International Data Transfers

9 Children's Personal Information

10. Changes to this privacy policy

11. How to contact us

1. PERSONAL INFORMATION WE COLLECT ABOUT YOU AND WHY

Personal information reasonably identifies you and is about you, directly or indirectly, as described in applicable data privacy laws.

We collect and process personal information about you in three ways:

(i) when you provide it to us directly;

(ii) when we gather personal information while you are using any of our Services, including through cookies and similar technologies(see 4. How We Use Cookies and Similar Technologies below); and

(iii) when we collect personal information from other third party sources.

We explain in the table below what types of personal information we collect and process, how and why we do so, and the lawful bases that apply in particular as prescribed under applicable data privacy laws. We may use a variety of tools to support our processing of your information, including artificial intelligence technologies. We may collect or process personal information in other ways than as described below. We will let you know at that time, unless otherwise inappropriate or unlawful to do so.

If you do not provide us with personal information we request from you directly, including to gather personal information while you are using our Services or from third party sources, we may not be able to proceed with entering into or fulfilling some of our Services. Consequently, we will not be able to provide or continue to provide those Services to you. This includes, but without limitation, setting up your Clearpay account, or responding to a support request or complaint.

Purpose of processing	Categories of personal information we collect and how	Why we collect and process personal information, and lawful bases where applicable
To reach out and understand whether you may be interested in applying to be a Merchant with us, including when you have completed our online business sign up and inquiry pages, or when we have received your personal information from other sources.	From you - Contact information, such as your name, address, location, phone number, and email From other sources - Contact information, such as your name, address, location, phone number, and email. We collect these from third parties (such as a Merchant who has referred you under our Merchant Referral Program), publicly available sources (e.g. your website or social media sites), and other third party sources	With your consent Our legitimate interests to promote our Services, and yours, where otherwise permitted and consistent with applicable law, so that we can explore opportunities and benefits of the use of our Services
To create (and assess whether to create) a Clearpay account, including to carry out our identity and account verification process and to enable you to authenticate into your account once created.	From you - Contact information, such as your name, address (and location), phone number, and email Financial and business-related information, such as bank account details Identity information, such as your date of birth, driver's licence, passport, and other requested identification information documents From other sources - Confirmation of your identity through verification processes from identity verification and fraud prevention providers, and credit reference agencies, who may validate the information you provide us with other information from publicly or commercially available sources. Your personal information may also be screened against relevant sanctions watchlists We may search online for any publicly available information about you, such as adverse media, through our onboarding process, and ongoing review of your suitability to provide our Services	To comply with our legal obligations relating to applicable anti-money laundering and counter terrorism financing and sanctions laws To take steps to enter into and for the performance of our agreement with you For our legitimate interests to protect our business, and to confirm your identity, to detect, prevent and investigate suspected or actual money laundering, fraud, or other crimes or illegal activities
To provide our Clearpay account Services, including setting up your business's Service account to interact with you and deliver our Services, such as sending you communications as necessary about our Services, invoices, and agreement updates.	From you - Contact information, such as your name, address, phone number, and email Communications between us	For the performance of our agreement with you
To send you direct marketing and other promotional communications, before or after you apply to become a Merchant, including to offer new partnerships and promotion opportunities. Where permitted, we may opt you in to marketing communications, but you can opt out at any time by clicking the unsubscribe link at the bottom of these messages. Refer also to 6. Your Rights and Choices below.	From you - Your contact details, such as your email address	With your consent, or for our legitimate interests to promote our Services, where otherwise permitted and consistent with applicable law.
To provide you support, including to resolve disputes, collect fees and troubleshoot problems.	From you - Identity verification information requested from you to discuss your account with you Information about the subject of your support request or complaint From other sources - Identity verification information requested from an agent you have authorised to discuss your account on your behalf Information relevant to the subject of the support request or complaint from merchants or other relevant sources	For the performance of our agreement with you For our legitimate interests, such as to investigate or respond to a support request or complaint
To detect, investigate and prevent suspected or actual fraud, money laundering, or other crimes or illegal activities on an ongoing basis, including credit card rules, and to protect Clearpay's legal rights and claims.	From your use of our Services - Information about your use of our Services From other sources - Information from third parties about you as consistent with applicable law, including from our affiliates	For our legitimate interests, in establishing any risks in providing our Services to you and to prevent, detect and prosecute fraud and other crimes
To monitor postings relating to Clearpay Services and financial promotions.	From your public postings on social media - Details and financial promotions you make about Clearpay's offering, to ensure these are compliant with regulations relating to, but not limited to, financial promotions We may use a variety of tools for this monitoring, including artificial intelligence	For our legitimate interests in ensuring Merchants are acting fairly, lawfully and ethically when representing Clearpay Services
To learn more about your level of satisfaction, your expectations of us and our Partners, and how we can meet them, so that we can customise, measure, and improve our Services including its content, layout and operations. We may send you survey requests to do so. We may use this information to produce statistics and reports about our Services and operations. We will typically use this information to create aggregated or anonymised information and only use personal information where necessary.	From you - Feedback you provide us about our Services and interactions with us and our partners From your use of our Services - Information from you, your use of our Services, and other sources, as detailed in this section of our Privacy Policy	For our legitimate interests to understand our Merchants so that we can provide a better experience for you and everyone, and to maintain and improve our Services
To make our app or site work as you'd expect it to, such as to prevent and respond to suspected or actual malicious software or activity, for secure identity verification and login, fraud prevention, and remembering your cookies choices. This includes personal information collected and processed by the use of cookies and similar technologies. Refer to 4. How We Use Cookies and Similar Technologies below.	From your use of our Services - Technical information, such as date and time you visited a site or took an action, IP address, login details, your location, device or browser settings Cookies consent preference	To enter into and for the performance of our agreement with you Our legitimate interests, to provide a secure and functioning delivery of our Services
To provide by the use of cookies and similar technologies on our website and app better functionality, to assess our performance, for advertising by us and our digital partners, and to provide a personalised experience. Refer also to 4. How We Use Cookies and Similar Technologies below.	From your use of our Services - Technical information, such as date and time you visited a site or took an action, IP address, contact details such as your email address, your geolocation, device or browser settings	With your consent or where otherwise lawful and consistent with applicable law
For other purposes.	From you, from the use of our Services, or other sources. For instance, if we collect and process personal information categorised as "sensitive" or "special" under applicable laws, such as your health information, to deliver our Services. Other information from you, from the use of our Services, or other sources as explained to you at the time we seek your consent.	With your consent (where required) Where required or permitted by applicable laws or regulation
As required or permitted by applicable laws and regulations, including to satisfy our bookkeeping, taxation, auditing, and accounting requirements, and to carry out business, operational, and legal functions.	All of the above information, including from use of our Services, or other sources.	As required or permitted by applicable laws and regulations For our legitimate interests to uphold our rights, protect our business, and carry out business, operational and legal functions

2. WHEN AND WITH WHOM WE SHARE YOUR PERSONAL INFORMATION

We may share personal information described in 1. Personal information we collect and why section with the following categories of service providers and other third parties.

Categories of third parties	When and why we may share your personal information
Affiliates within our group of companies Such as, Cash App, Square, Tidal, Afterpay entities or other wholly-owned subsidiaries of Block Inc.	We may share your personal information for the following purposes for our legitimate interests or as otherwise required or consistent with applicable law. To provide (or assess to provide), maintain or improve our Services To understand how you engage with our Services to help make them better for you and for everyone To help us manage our relationship with you across our group of companies and for customer support issues and to enforce our agreement with you, including in cases of debt recovery For us and our affiliates to prevent, detect, and prosecute money laundering, fraud and other crimes or illegal activities For marketing purposes where legally permitted As instructed by you and choices available to you As required or permitted by applicable law
Service providers, partners and sub-contractors.	We share your personal information with the following service providers or partners to provide, maintain and improve our Services. Technology and IT infrastructure providers to store information and to provide software or programs that help us provide our Services Marketing or event providers that help us run our advertising campaigns, contests, special offers, or other events or activities Identity verification and fraud prevention providers and credit reference agencies to help us confirm your identity and prevent fraud, to assist us in meeting our obligations under anti-money laundering / counter terrorism financing and sanctions laws, and other compliance requirements. These companies process your personal information in accordance with their own privacy policies Financial partners, like financial institutions, payment networks, payment card associations, and credit bureaus that help us provide our joint Services Outbound phone and text messaging services. Our service provider may need to access and intercept messages between us and your from time to time or disclose your personal information to a government body or telecommunications network provider to comply with applicable telecommunications laws, or a court or tribunal order Customer service agencies, to support manage our relationship with you Analytics providers, to understand how you engage with our Services to help make them better for you and for everyone. For example, we partner with third-party analytics providers, whose cookies we use to help us understand how you use our Services so that we can improve our customer experience
Financial institutions that we may partner with to jointly create and offer a product, including banking partners as may be required by credit card association rules for inclusion on their list of terminated merchants.	We share your personal information for the following purposes with your consent, to fulfill our agreement with you, or for our legitimate interests. To provide Clearpay Services and partner products and services To maintain funding lines so that our business remains commercially viable and to provide (or assess to provide) our Services to you
Your customers.	We share your personal information with customers that you engage and transact with using our Services for the following purposes to fulfil our agreement with you. To assist you to manage an order, including dealing with any refunds, disputes, or claims, or in regards to an inquiry or complaint made by a customer
Online trackers, advertising partners, social media platforms and external affiliate networks.	We share your personal information for the following purposes with your consent, for our legitimate interests, or as otherwise consistent with applicable law. We share your personal information with advertising partners through the use of cookies and similar technologies for interest-based advertising or "targeted" advertising campaigns, and with advertising partners that help analyse our site, run contests, special offers, or other events or activities, and track metrics on our behalf or in connection with our Services We may share certain personal information (such as name, email address, telephone number) with social media sites to serve advertising to you on these sites, the information is used to check whether there is a match in their database Clearpay shares the information that you have clicked on a sponsored retailer link from our web or app with our external affiliate network partner who may track you through that retailer's website, (including connecting our hyperlink with you) in order to calculate a potential commission due to us in line with their own privacy policies and practices Refer to 4. How We Use Cookies and Similar Technologies for more information.
Companies that we plan to merge with or be acquired by or who may invest in us.	We share your personal information for the following purposes for our legitimate interests. For business transfers and corporate changes to enable the assessment or completion of the relevant merger, restructuring, financing, acquisition, divestiture, dissolution or other corporate change. If we do or try to do a corporate merger, consolidation, or restructuring (including during due diligence and negotiation of these); the sale of substantially all of our stock and/or assets; the financing, acquisition, divestiture, or dissolution of all or a portion of our business; or other corporate change To ensure that we or our business remains commercially viable To a subsequent owner, co-owner, or operator of one or more of the Services to enable them to continue to run the Services after the change of owner or operator
Law enforcement agencies, government agencies, officials, or other authorities or third parties pursuant to a subpoena, court order, or other legal process, requirement, or legitimate interest.	We share personal information for the following purposes for our legitimate interests, to protect our business and enforce our agreement with you, or where required or authorised by law. To detect, investigate and prevent suspected or actual fraud, money laundering, or other crimes or illegal activities, including credit card rules To comply with any applicable law, regulation, legal process or governmental request (e.g., from creditors, tax authorities, law enforcement agencies, in response to a garnishment, levy, or lien notice, etc.) To establish, exercise or defend our legal rights, including to enforce our agreement with you To protect ours or our customers' rights or property, including from harm, fraud, or potentially prohibited or illegal activities, and for the security or integrity of our Services
With your consent.	Other third parties with your consent or direction to do so, such as to provide, or assess to provide, our Services or to discuss your account with an authorised agent
Other third parties where required by law, or our legitimate interests as permitted by law.	To comply with any applicable law, regulation, legal process or governmental request (e.g., from creditors, tax authorities, law enforcement agencies, in response to a garnishment, levy, or lien notice, etc.) Other purposes as permitted by applicable laws

3. HOW WE SECURE YOUR PERSONAL INFORMATION

We take appropriate measures, including administrative, technical, and physical safeguards, to protect your personal information from loss, theft, and misuse, and unauthorised access, disclosure, alteration, and destruction. The internet is not a 100% secure environment, so we cannot guarantee absolute security of the transmission or storage of your information. We are an ISO 27001 compliant company, and require our third parties to meet appropriate privacy and security standards when handling data on our behalf. Your personal information will be accessible by our employees, contractors and service providers who require access for the purposes described in this Privacy Policy.

For more information about our security practices, please visit https://www.afterpay.com/en-AU/security or refer to 11. How to Contact Us below.

4. HOW WE USE COOKIES AND SIMILAR TECHNOLOGIES

Our websites and apps may use cookies and other similar technologies, such as tracking pixels or browser local storage (together “cookies”).

Our Cookies Notice explains what types of cookies we use, for which purposes, which third parties are associated with these cookies, the choices you have with respect to optional cookies, how to revoke your cookie consent and manage your previous cookie choices.

5. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

The retention periods for personal information we collect and process about you are determined on a case-by-case basis that depends on the following factors below.

- The nature of the personal information, and why it is collected and processed, as described in this Privacy Policy. This includes to provide our Services, to comply with legal obligations, to enforce and prevent violations of our agreement with you, and to protect us against fraudulent activity.

- To manage and enforce our agreement with you. Your use of our Services is subject to the agreement between us. So if, for example, you close your Clearpay account, we retain personal information about you for a period of time so as to collect any debt or fees owed, resolve disputes, troubleshoot problems, assist with any investigations or complaints, and to prevent fraud or risk.

- To establish, exercise, or defend our legal claims or rights. For example, we preserve your personal information related to a legal claim or complaint, such as where we are subject to a regulatory investigation, or we need to defend ourselves in legal proceedings involving your personal information, or respond to a government authority or body in relation to a legal or regulatory complaint made by you or someone else.

- As required or otherwise permitted by applicable law. For example, retention periods may be imposed under law or regulation for a prescribed period of time.

Personal information collected and processed to enter into and for the performance of our agreement with you will be generally retained for up to 10 years after your application is made or the termination of our agreement with you (where applicable), and as otherwise we have a lawful basis to do so. Our reasons include, but without limitation, to deliver our Services for the duration that your Clearpay account exists so we can maintain your account, and to comply with applicable anti-money laundering/counter terrorism financing and sanctions laws.

6. YOUR RIGHTS AND CHOICES

You can see or change personal information you gave us, ask us to close your account, control your device location tracking settings, or tell us to stop sending marketing to you at any time. Head to our Help Centre by clicking "Help" on our website or app for detailed instructions. We also respect other privacy rights and choices you make consistent with applicable law.

We may ask you to verify your identity in accordance with our standard procedures, including any authorised agent who would like to act on your behalf, or clarify your request, before taking further action on your privacy right or choice request. We endeavour to respond and address all privacy rights and choices requests within the applicable statutory time frame. We will let you know if we need more time, and why and whether we are unable to fulfil your request as there is a legitimate basis to refuse it. For example, if you seek to erase your personal data in a way that would mean we are not able to comply with our obligations under law.

If you would like to make a privacy right or choice request, please refer to 11. How To Contact Us below.

Rights and choices that may be available to you

Right to	Description
Withdraw your consent	You have the right to withdraw your consent where we have relied on it to process your personal information. If you withdraw your consent, we may not be able to provide you with certain Services. It will not affect our lawful basis for processing based on consent before your withdrawal.
Access	You have the right to request a copy of your personal information held by us.
Further information	You have the right to enquire further about the personal information we hold about you and our privacy practices, including how we transfer personal information internationally and onward disclosures of personal information.
Correction	You have the right to ask us to correct your personal information held by us, including where you believe it is not accurate, complete, up to date, or relevant.
Erasure	You have the right to ask us to erase your personal information, and where this is made public, to inform other controllers of your personal information erasure request, subject to exceptions the law provides.
Restrict Processing	You have the right to ask us to restrict processing of your personal information.
Object to processing	You have the right to object to us processing your personal information where we process it based on our legitimate interests, including for direct marketing purposes and other profiling activities. You can also opt out of direct marketing at any time as described above.
Data Portability	You have the right to ask us to access or transfer on your behalf personal information we hold about you to a third party in a structured, commonly used and machine-readable format.
Make an enquiry or complaint	You have the right to make an enquiry or complaint to us, including to lodge a complaint with your local privacy authority. To make a privacy complaint to us, please see 11. How to Contact Us below for details.
Object to automated decision making	We use systems to make decisions about you through automated means, including behavioural profiling, without our staff being involved. You have the right to object to these solely automated decisions that we may have made about you where those are significant, and ask for more information about the decision and have a person review it, unless we are prohibited or exempt from doing so under law. More information We complete the following decision making by automated means, with legal or similarly significant effects on you, to enter into and perform our Services you request from us, or to comply with laws that apply to us: Verify your identity to assess your application, prevent fraud, money laundering, terrorism financing, and allow us to check against sanction lists in relevant cases. These decisions rely on personal information we collect or hold about you from your applications and your interactions and experiences with us, such as transactions attempted to be made or made to your company. We may also use information about you we collect from third party credit reference and fraud prevention agencies. Automated decisions can affect the Services we may offer you. As a result of the above decisions, you may be declined access or have limited access to our Services. We perform regular checks of our automated decision models to ensure they are operating correctly.

7. RIGHTS OF CALIFORNIA RESIDENTS AND FEDERAL PRIVACY NOTICE

If you live in California, and to read the Notice applicable to non-public information collected under and in accordance with the US Federal Gramm-Leach-Bliley Act, please review our US Afterpay privacy policy available here.

8. INTERNATIONAL DATA TRANSFERS

Personal information we collect and handle about you may be transferred to or stored outside the UK. We may do so, for example without limitation, when sharing personal information with our affiliates, partners and service providers to help us provide (or assess to provide) our Services or other third parties that we partner with. Your personal information may be transferred to or stored in Australia, New Zealand, the United States, Canada, United Kingdom, the European Union, China, and Singapore. We may transfer your personal information to other countries, but we will always take steps to ensure your personal information is afforded equivalent levels of protection and rights as are required under your country of residence and where Clearpay operates. For more information please reach out using the details in 11. How to Contact Us below.

Where we transfer your personal information outside the United Kingdom, we take steps to ensure your personal information is afforded equivalent levels of protection. For transfers to countries that are not covered by an adequacy decision of the UK government (as applicable), we use appropriate safeguards that include Standard Contractual Clauses approved by the UK's Information Commissioner's Office as appropriate, or other applicable measures, including transfers to a third party that has implemented Binding Corporate Rules, or specific situations outlined under applicable data privacy laws. You can access a copy of the Standard Contractual Clauses approved by the UK Information Commissioner's Office here. Clearpay is bound by an Intercompany Personal Data Transfer Agreement that contains Standard Contractual Clauses.

For further information about our policies and practices with respect to international data transfers, please refer to 11. How To Contact Us below.

9. CHILDREN'S PERSONAL INFORMATION

Our Services are not directed at children under the age of 18. If we learn that any personal information we collect has been provided by a child under the age of 18, we will promptly close the relevant account and delete that personal information as consistent with applicable law.

10. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy from time to time, as may be required. We will provide you with reasonable prior notice of any material changes in how we use your personal information, including by email if you have provided one. If you disagree with these changes, you may cancel your Clearpay account at any time. Any amendments will be published by posting a revised version of the Privacy Policy and updating the “Effective Date” above. The revised version will be effective on the “Effective Date” listed.

11. HOW TO CONTACT US

If you have any questions or concerns regarding this Privacy Policy, or would like to exercise your rights and choices, you can do so by using the details and links below. If you are dissatisfied with our response, you have a right to make a complaint to your local privacy authority, the Information Commissioner’s Office, via the link to their contact page below.

Country	Contact Details	Local Authority
United Kingdom	Submit a privacy request or complaint here [email protected] Clearpay Finance Limited 101 New Cavendish Street, London, W1W 6XH If you would like to contact Clearpay's UK Data Protection Officer, please address your communication for the attention of the Data Protection Officer. Clearpay Finance Limited is the Data Controller for the purposes of the applicable data privacy laws and is notified with the Information Commissioner's Office under registration number: ZA285684.	Information Commissioner's Office

Country

Contact Details

Local Authority

United Kingdom

Submit a privacy request or complaint here

[email protected]

Clearpay Finance Limited

101 New Cavendish Street, London, W1W 6XH

If you would like to contact Clearpay's UK Data Protection Officer, please address your communication for the attention of the Data Protection Officer.

Clearpay Finance Limited is the Data Controller for the purposes of the applicable data privacy laws and is notified with the Information Commissioner's Office under registration number: ZA285684.

Information Commissioner's Office

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