Privacy Policy

Last updated: June 11, 2026

1. Overview

ClearKYC ("Company", "we", "us") is committed to protecting the privacy of our users. This Privacy Policy explains how we collect, use, and protect information in connection with our KYC compliance platform. We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable Canadian privacy law.

2. Our Zero Data Retention Commitment

ClearKYC is designed to minimize data retention. Specifically:

  • We do not store client identity documents. Passport scans, driver's licences, and selfie photographs are processed in-memory and permanently deleted after report generation.
  • We do not store biometric data. Facial recognition is performed in real-time and results are not retained.
  • We do not store client financial information. Income, net worth, and suitability data submitted in the KYC form are not retained after PDF generation.
  • All processing occurs on servers located in Canada (AWS ca-central-1, Montreal).

3. Information We Collect

3a. Dealer Account Information

When you register as a dealer, we collect:

  • Business email address
  • Company name
  • CIRO registration number (optional)

3b. Submission Metadata

For each KYC submission, we store only:

  • Client name (as entered by the dealer)
  • Submission status (Pending / Completed / Failed)
  • Submission date
  • Associated dealer identifier

3c. What We Do NOT Store

  • Passport photos or scans
  • Selfie photographs
  • Date of birth, address, or phone number
  • Financial information (income, net worth)
  • KYC questionnaire responses
  • PDF compliance reports

4. How We Use Information

  • Account management: Dealer email is used for authentication and service communications.
  • Report delivery: The compliance report PDF is emailed to the dealer and immediately deleted from our servers.
  • Dashboard display: Client names and submission status are displayed in the dealer dashboard.
  • Service improvement: Aggregated, anonymized usage data may be used to improve the Service.

5. Third-Party Services

We use the following third-party services to process data:

  • AWS (Amazon Web Services) — Canada (ca-central-1): Cloud infrastructure, document OCR (Textract), facial recognition (Rekognition), and email delivery (SES). AWS processes data under our instructions per the AWS Data Processing Addendum.
  • Google Gemini AI: Risk assessment generation. Only anonymized extracted data (no photos) is transmitted.
  • OpenSanctions: AML and sanctions screening. Client names are queried against global sanctions databases.

6. Data Residency

All data is stored and processed in Canada (AWS ca-central-1, Montreal). We do not transfer personal information outside of Canada except as required to operate the Service (e.g., OpenSanctions API queries for sanctions screening).

7. Data Retention

  • Dealer accounts: Retained for the duration of the subscription plus 90 days after termination.
  • Submission metadata (client name + status): Retained for 24 months to support dashboard functionality.
  • Client identity documents and photos: Not retained. Deleted immediately after processing.
  • Compliance report PDFs: Not retained. Delivered by email and deleted from our servers.

8. Security

We implement industry-standard security measures including:

  • TLS encryption for all data in transit
  • AWS-managed encryption at rest for all stored data
  • Access controls limiting data access to authorized systems only
  • No storage of sensitive personal or biometric data on our servers

9. Your Rights

Under PIPEDA, you have the right to:

  • Access the personal information we hold about you
  • Request correction of inaccurate information
  • Withdraw consent and request deletion of your account data

To exercise these rights, contact us at info@clearkyc.ca.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify registered dealers of material changes by email. Continued use of the Service after notification constitutes acceptance of the updated policy.

11. Contact Us

For privacy-related inquiries or to exercise your rights under PIPEDA:

ClearKYC Privacy Officer
Email: info@clearkyc.ca
Website: www.clearkyc.ca