Privacy Policy
Last updated: 12 October 2026
Clairly is a rental trust and payment-reliability platform for France and the EU. This policy explains what data we process, why, and the rights you have.
1. Who we are
The data controller is Clairly, a SAS with share capital of 100 euros, Lyon RCS 952 573 053, registered office 11 rue Émile Zola, 69002 Lyon.
- Privacy contact: privacy@clairly.co
- Data Protection Officer (DPO): dpo@clairly.co
2. What Clairly is not
Clairly is not a guarantee, an insurance product, a replacement for the rental dossier, a full dossier verification service, a legal authority, a public-sector decision tool, a blacklist, a debt collection product, a surveillance product, or a credit score.
Clairly verifies and reports rental payment history. It does not give tenants a score or a rating, and it does not recommend whether to rent to anyone. Clairly does not decide whether a person is offered a tenancy, refused one, kept in one or asked to leave one (see section 10).
3. What data we process
| Category | Examples |
|---|---|
| Identity and contact | name, email, phone, preferred language |
| Tenancy relationship | tenant to property link, declared rent, relevant lease |
| Payment history | monthly status and per-entry verification level |
| Bank data (open banking) | transactions from selected accounts, processed transiently to identify rent payments |
| Dispute evidence | supporting documents submitted in a dispute |
| Billing | plan, subscription and purchase payment history |
| Security and audit | access logs, IP addresses, consent ledger, hashed share tokens |
| Waitlist | email address and whether you are a tenant, a landlord or an agency |
Bank transactions unrelated to rent are neither retained nor analysed. Clairly does not analyse spending habits, overall financial health, or any behaviour unrelated to rent.
4. Why, and on what legal basis
Each purpose rests on its own lawful basis. No single basis covers all processing.
| Purpose | Lawful basis |
|---|---|
| Tenant-controlled sharing of the Clairly Report | Consent (Art. 6(1)(a)) |
| Open banking connection (rent verification, Boost import) | Consent, collected separately before each connection |
| Retroactive attachment of pre-consent history (landlord monitoring) | Tenant consent |
| Account creation, delivery and management of the Service | Performance of a contract (Art. 6(1)(b)) |
| Security, fraud prevention, account integrity | Legitimate interest (Art. 6(1)(f)) |
| Accounting and billing obligations | Legal obligation (Art. 6(1)(c)) |
| Waitlist: telling you when you can create your account | Consent (Art. 6(1)(a)), given when you join the list; withdraw at any time by writing to privacy@clairly.co |
Consent can be withdrawn at any time, without justification; withdrawal does not affect the lawfulness of prior processing. Data is processed for rental payment reliability only, not for credit scoring, unrelated profiling, spending analysis, or marketing reuse.
5. Open banking
- Bank connections run through Powens, an account information service provider (AISP) authorised under PSD2 and supervised by the ACPR, after a Clairly consent screen that is separate from account signup and bank authentication.
- You choose which account(s) are covered. Clairly looks for rental transactions only.
- Boost can import up to 24 months of eligible past rent payment history.
- Under PSD2, bank consent must be renewed every 180 days.
- Raw transaction data is retained only temporarily, to convert identified rent payments into structured entries.
- Landlord-side monitoring reads only the landlord’s own account and matches the declared rent amount; non-matching transactions are not retained.
6. Who can see what
- When you share a report, the recipient sees only what that share covers: depending on the level you choose, your rent receipts, or your full rental payment history with dates, amounts, the source of each record and any disputes.
- They cannot see unshared tenancies, bank account details, unrelated transactions, or identity/supporting documents (unless separately and explicitly shared through another valid flow).
- Every share is a deliberate tenant action, never public, never automatic. Share links expire after 30 days unless re-authorised.
- Access is revocable at any time; revocation removes the report from the third party’s dashboard and blocks future access through Clairly. It cannot remove a copy the recipient has already saved outside Clairly.
7. Recipients and processors
Clairly uses the following processors under GDPR Art. 28 agreements:
| Processor | Role | Location / transfer |
|---|---|---|
| Clerk | Account authentication | USA (SCC / DPF) |
| Supabase (AWS, EU region) | Database and storage | European Union |
| Powens (Powens SAS, ACPR-supervised AISP, CIB 16948) | Open banking (account aggregation) | European Union |
| Stripe | Subscription and purchase payments | USA (SCC / DPF) |
| Brevo (Sendinblue SAS, Paris, RCS 498 019 298) | Transactional email delivery, and carrying contact form and waitlist messages to Clairly’s mailbox | European Union |
| Microsoft 365 | Clairly’s mailboxes (contact form and waitlist messages are read there) | European Union |
| Google Analytics | Site audience measurement | USA (SCC / DPF) |
| Vercel | Site hosting | USA (SCC / DPF) |
| Support & monitoring providers | Customer support and error monitoring | EU / USA |
Where data is transferred outside the EU/EEA, Clairly relies on an adequacy decision, Standard Contractual Clauses (SCC), or the EU-US Data Privacy Framework (DPF) where the provider is certified. No data is sold, and no data is passed to third parties for marketing.
8. Retention
- Account data, structured payment history, and records needed for the Clairly Report are kept for the life of the account, then archived for up to 10 years for evidence, dispute handling, defence of our rights, audit, and accounting and legal obligations.
- Raw open banking transactions are processed transiently and deleted once rent payments are converted into structured entries. Transactions unrelated to rent are not retained.
- After account deletion, Clairly keeps a pseudonymised marker (e.g. a hash of the email address) to prevent fraud, in particular deleting and recreating an account to erase a payment history. This marker alone cannot reconstruct your profile.
- Billing data is kept 10 years under accounting obligations.
- Waitlist entries (your email and your chosen role) are kept until we invite you to create your account, then deleted within 30 days, or deleted 12 months after you joined, whichever comes first. You can ask for deletion earlier at privacy@clairly.co.
9. Your rights
You can exercise the following rights via privacy@clairly.co:
- Access and copy of your data; export of your Clairly Report and payment history.
- Rectification; the dispute flow also lets you challenge an inaccurate payment record with evidence.
- Erasure, subject to lawfully grounded retention.
- Restriction of processing and objection under GDPR conditions.
- Portability of data you provided.
- Withdrawal of consent at any time (sharing, open banking).
- Post-mortem directives about your data (Art. 85 French Data Protection Act).
- Complaint to the CNIL: www.cnil.fr.
We respond within one month, extendable under GDPR Art. 12(3).
10. Payment history, corrections and decisions
Rent payments are recorded against the month of rent they pay, whether a landlord or agency records them or they are matched from a bank connection. Each record shows its source and any dispute still open on it. Clairly does not give tenants a score, a risk category or a recommendation about whether to rent to them. A shared payment history may inform the assessment of a rental application, but:
- it is one element of information among others, not a decision;
- the landlord or agency remains responsible for its own decision, must not base it on the shared history alone, and must consider other supporting materials (employment situation, income, guarantor, complete dossier);
- no decision producing legal effects or significantly affecting you is based solely on automated processing: the decision to rent rests with the landlord or agency, who are human;
- any disputed record remains clearly flagged until resolved, through a dispute flow with human review, and is never shown as a settled fact while the dispute is open;
- every dispute resolves to a definite outcome: Amended (the record is corrected) or Confirmed (the record stands).
11. Security
Encryption at rest with our providers, role-scoped access controls, share tokens stored as hashes, access logging, and a consent ledger. In the event of a data breach, the CNIL is notified within 72 hours where legally required, and affected individuals are informed under GDPR Art. 34.
12. Minors
The service is for adults (18+) and is not directed at minors.
13. Changes
Any material change to this policy will be notified with an effective date shown at the top of this page.