Effective date: 19 June 2025

Welcome to The Clarity Wallet (“we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, store, and share your personal data when you use our website, tools, and services (collectively, the “Service”).

By using our Service, you agree to the practices described in this Privacy Policy.

1. Who We Are

The Clarity Wallet is operated by Damola Oguntayo, a UK-based sole trader.

If you have any questions or concerns, you can contact us at:

• Email: info@theclaritywallet.com
• Address: 128 City Road, London, EC1V 2NX

2. What Data We Collect

We may collect and process the following types of personal data:

• Identity Data: Name, email address, phone number
• Financial Data: Payment details (processed via Stripe or PayPal)
• Usage Data: Interactions with our site, apps, and tools (including the Money Clarity Score, Quiz and Clarity Wallet™ app)
• Technical Data: IP address, browser type, device identifiers, and cookies
• Marketing Data: Preferences for receiving newsletters, offers, and coaching promotions

3. How We Collect Your Data

We collect data through:

• Direct interactions (e.g. when you complete a quiz, sign up for emails, or purchase a product)
• Automated technologies (e.g. cookies, analytics tools)
• Third-party integrations (e.g. Stripe, PayPal, Twilio, Google Analytics)

4. How We Use Your Data

We use your data to:

• Provide and personalise our Service
• Process payments and send receipts
• Send quiz results, coaching insights, and app updates
• Deliver marketing emails (with your consent)
• Monitor usage for analytics and service improvement
• Comply with legal obligations

5. Lawful Basis for Processing

Under the UK GDPR, we rely on the following lawful bases:

• Consent: For sending marketing emails and optional WhatsApp messages
• Contract: To fulfil our obligations when you use paid services
• Legal Obligation: For compliance with tax and regulatory laws
• Legitimate Interests: To improve our tools and provide relevant insights

6. Sharing Your Data

We do not sell your data. We only share your data with trusted third parties that help us deliver the Service, including:

• Stripe and PayPal (payment processing)
• Twilio (automated WhatsApp reminders)
• Google (analytics and web performance)
• Hosting and CRM platforms (e.g. email and app management)

Some of these providers may store data outside the UK. Where this occurs, we ensure appropriate safeguards (e.g. standard contractual clauses) are in place.

7. Data Retention

We retain personal data only as long as necessary to:

• Provide the Service
• Meet legal, tax, and reporting requirements
• Respect unsubscribe or deletion requests

8. Your Rights

Under UK data protection law, you have rights to:

• Access your personal data
• Correct inaccurate or incomplete data
• Request deletion (“right to be forgotten”)
• Object to or restrict processing
• Withdraw consent for marketing at any time
• Lodge a complaint with the Information Commissioner’s Office (ICO)

To exercise your rights, contact us at info@theclaritywallet.com.

9. Cookies

We use cookies to enhance user experience and monitor site performance. You can control cookie settings via your browser.

For more detail, see our Cookie Policy.

10. Marketing & Communication

You will receive marketing communications if you have opted in (e.g. by downloading a lead magnet, free downloads or quiz result). You can unsubscribe at any time by clicking the link in the footer of our emails or contacting us directly.

11. Data Security

We take appropriate technical and organisational measures to secure your data, including encryption, secure access controls, and monitoring.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Any significant changes will be posted on this page with a revised effective date.

13. Contact

If you have questions about this Privacy Policy or your data, contact:

Data Controller
Damola Oguntayo
Email: info@theclaritywallet.com
Address: 128 City Road, London, EC1V 2NX

Thank you for trusting The Clarity Wallet to support your financial journey.