Privacy Policy — Cleera

Cleera is a trading name of Seringa Ltd (“we”, “us”, or “our”). We are committed to protecting personal data. This Privacy Policy explains how we collect, use, share, and protect information when you use our platform at cleera.co.uk, related subdomains, and embedded services. It is written in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This policy should be read alongside our Terms of Service and Cookie Policy.

1. Who We Are and Our Roles

Seringa Ltd (trading as Cleera) operates the Cleera platform. Depending on the activity, we act in different roles:

Data controller: for personal data about people who register for Cleera accounts, visit our marketing website, contact us, or otherwise interact with Cleera directly as a customer or prospect of Cleera.
Data processor: for personal data about your clients, leads, and introducers that you or your organisation enter into Cleera, or that is submitted through features you configure (for example client portals, introducer portals, website lead capture forms, and document ingestion). In those cases, your firm is the data controller and we process data on your instructions to provide the service.

If you submit an enquiry through a mortgage adviser's public intake form, that adviser's firm is usually the data controller for your enquiry. The form should link to their privacy policy. You may contact them first about how your enquiry is used. You may also contact us using the details at the end of this policy if you need help reaching the correct firm or have a question about Cleera's processing.

Questions about how we handle data can be sent via our contact page.

2. Who This Policy Applies To

Advisers, org admins, and other staff who use Cleera on behalf of a firm
Clients who use a firm's branded client portal
Introducers who use a firm's introducer portal
Members of the public who complete a firm's website lead capture form (hosted by Cleera or embedded on the firm's site)
Visitors to cleera.co.uk and our marketing pages

3. Data We Collect

Information you provide directly

Name, email address, and password when you register an account
Company name, role, and organisation settings when setting up your firm
Case, client, and introducer information you enter into the platform
Documents and files you upload (including PDFs submitted for AI-assisted ingestion)
Messages sent via our contact form or in-app messaging features
Payment information processed via our payment processor (we do not store full card numbers)
OAuth connection details when you connect a supported third-party practice management integration, including tokens stored in encrypted form

Website lead capture (public enquiry forms)

When someone completes a lead capture form configured by a firm, we may collect:

Contact and enquiry details entered in the form (for example name, email, phone, and other fields the firm chose)
Consent selections shown on the form (including acknowledgement of the firm's privacy policy and optional marketing consent)
A hashed IP address and submission metadata used for rate limiting and abuse prevention
Technical data needed to operate embeds (for example referrer or origin information)

Submissions are held in a pending state until the applicant confirms their email address. Unconfirmed submissions expire automatically after 48 hours.

Information collected automatically

Log data (IP address, browser type, pages visited, timestamps)
Usage data collected via Google Analytics 4 and our infrastructure provider's analytics tools when enabled (see our Cookie Policy for when analytics load)
Performance data via our infrastructure provider's performance monitoring tools (anonymised)
Authentication tokens stored as secure, HTTP-only cookies
Bot-challenge signals when bot-protection challenges are enabled on public intake forms

Property and open-data lookups

When a firm views a property report for a case, we may send property identifiers (for example postcode and address elements) to UK public and open-data services to retrieve property information such as energy performance, flood risk, broadband, past sale prices, and local crime statistics. These lookups are performed to display information to authorised users of the firm and are not used for unrelated marketing.

Address lookup

When you enter a postcode into an address field anywhere on the platform (including public website lead capture forms, the client portal, and internal case and client records), we send that postcode to our address lookup provider to retrieve matching addresses for autocomplete. This lookup happens on our server; your browser does not contact that provider directly.

Identity verification (optional)

Some firms enable an optional identity verification feature for their own clients. Where enabled, and only for a client asked to verify their identity as part of a case, we redirect that client to a hosted verification session operated by our identity verification partner, Didit. We do not transmit your document or biometric data to Didit ourselves. You provide it to Didit directly during that session, after being shown and giving explicit consent. Once the check is complete, we receive back and store in our own systems: images of the identity document you provided (front and back), a photograph taken to confirm you match that document (a portrait or “selfie” image), the verification outcome, and a compliance report. See Section 7 for how long each of these is kept.

Call recording and meeting notes (optional)

Firms can use Cleera to record a call or meeting with a client and turn it into a draft case note. This only happens when an adviser starts it, after confirming that the people on the call have been told it is being recorded. There are two ways to do this:

Phone call recording: the adviser records the call in their browser. Who said what is worked out from what is said and the names of the people on the call; voices are not used to identify anyone.
Meeting bot: for a video meeting (for example Google Meet, Microsoft Teams, or Zoom), the adviser can send an automated participant called “Cleera Notetaker”, operated by our meeting recording provider. It joins the meeting visibly under that name, records audio only (never video), and leaves when the meeting ends. The names participants display in the meeting are used to label who said what. So that names and terms are transcribed accurately, the provider is also given limited case details, such as the names of the clients on the case.

The audio is converted to text (transcribed), and the transcript is used to draft a case note and to suggest updates to case and client records, for the adviser to review. Depending on how the firm uses the feature, the transcript may also be used to draft fact-find answers. Nothing is saved to the case or client record until the adviser approves it. See Section 5 for the AI processing involved and Section 7 for how long each part is kept.

4. How We Use Your Data

We use personal data for the following purposes, relying on the legal bases indicated:

To provide and manage the service: performance of a contract (for Cleera account holders) or processing on our customers' instructions (for client, lead, and introducer data)
To process payments and manage subscriptions: performance of a contract
To send transactional emails (account notifications, form reminders, document alerts, lead confirmation emails): performance of a contract or our customers' instructions
To send firm-initiated marketing emails to clients (mailshots and simple newsletters that a firm composes and sends to its own client backbook via Cleera, delivered by our email delivery provider): our customers' legitimate interests as controller, with PECR unsubscribe controls; Cleera acts as processor
To run AI-assisted features (see Section 5): performance of a contract or our customers' instructions; outputs are generated for review by authorised users
To record and transcribe calls and meetings (where an adviser uses this optional feature): our customers' instructions; the firm is responsible for telling participants and for its lawful basis
To verify a client's identity (where a firm has enabled this optional feature): performance of a contract and your explicit consent, given before the check begins
To push data to integrations you connect (for example a practice management system): performance of a contract and your explicit action when you choose to send data
To protect public forms from abuse: legitimate interests (rate limiting, honeypot, timing checks, and bot-protection challenges where enabled)
To respond to enquiries submitted via the contact form: legitimate interests
To improve and maintain the platform: legitimate interests
To comply with legal obligations: legal obligation
To send marketing communications about Cleera (if you have opted in): consent

5. AI-Assisted Features

Cleera offers a set of AI-assisted features powered by large language models: a case chat assistant, an FCA-suitability-note drafting tool, a document checklist generator, a document analyser, a fact-find data extractor, form-answer review, a case-readiness assistant that reviews a case and proposes follow-up actions (such as requesting a document, drafting a client message, creating a task, flagging a risk, or suggesting a case-stage update), and, for recorded calls and meetings, transcription, case-note drafting and suggested updates to case and client records. These features are only available where a firm's plan includes them.

Most of these features run when an authorised user of the firm triggers them. Two run automatically as part of a feature the firm uses:

Recorded calls and meetings are transcribed and processed (note drafting and suggested updates) automatically after the adviser starts the recording.
Case message summaries: messages exchanged between a firm and its client on a case are summarised by AI once a conversation has been quiet for a while, so the adviser can see a short daily summary.

We have assessed this processing in a Data Protection Impact Assessment and put the following safeguards in place:

Zero data retention. Every request to our AI model providers, including transcription of phone-call recordings, is made with data retention disabled (“zero-data-retention”, or ZDR), enforced at the point the request is made. The providers do not retain prompts, audio, or outputs beyond the time needed to generate a response, and do not use them to train their models.
Meeting recordings. Meeting-bot recordings are transcribed by our meeting recording provider, which does not use them to train AI models and deletes them as described in Section 7.
Data minimisation. Only the data a feature needs is included. Structured case summaries are reduced before use (for example, ages rather than dates of birth, and no National Insurance numbers). Features that work on a specific item, such as a document, a set of form answers, a call transcript, or a message thread, use that item in full, because they need it to work.
Special category data. Some fact-finds, particularly for protection insurance, ask about health, medical history, and smoking status. Where a firm collects this information and uses an AI feature on it (for example form review, suitability-note drafting, fact-find extraction, or a recorded call in which health is discussed), that information is processed by the AI providers on the zero-data-retention basis described above, or, for meeting-bot recordings, by our meeting recording provider. The firm, as data controller, is responsible for having a lawful condition for processing it.
Human review. AI outputs are assistive drafts only. Advisers and other authorised users remain responsible for reviewing AI-generated content for accuracy before relying on it, sharing it with a client, or filing it as part of a regulatory record.
No autonomous actions. Where an AI feature proposes an action on a case, nothing is created, sent, or changed until an authorised user of the firm explicitly reviews and approves it. Every approved action is carried out through the same process a person taking that action manually would use. There is no separate automated pathway.
International transfer. Our AI providers process data under data-processing terms with Seringa Ltd, using the UK International Data Transfer Agreement and Standard Contractual Clauses as the transfer mechanism for data leaving the UK.

AI conversation history is deleted from Cleera's own systems after 90 days, and AI-generated extraction drafts are deleted after 30 days, automatically, by a daily scheduled process (see Section 7, Data Retention).

6. Sharing Your Data

We do not sell personal data. We require every processor we work with to be bound by a data processing agreement or equivalent contractual data protection terms before we share personal data with them. We may share data with the following categories of recipients:

Cloud infrastructure providers (global): hosting, file storage, log drains, and bot management
Database hosting providers (UK): hosting for our primary database
AI model providers (United States and other jurisdictions, operating on a zero-data-retention basis): power the AI-assisted features described in Section 5, including transcription of phone-call recordings
Meeting recording providers (EU processing region): the Cleera Notetaker meeting bot, when an adviser sends it to a meeting
Error monitoring providers (EU): diagnosing faults in the platform, with personal data removed from error reports where possible
Payment processors (global, PCI-DSS compliant): payment processing and subscription billing
Email delivery providers (EU): transactional email delivery
Electronic signature providers (EU): e-signature services for case documents and client consent
Bot protection providers (global): protection against automated abuse on public intake forms, when enabled
Address lookup providers (UK): address lookup and autocomplete when a postcode is entered into an address field
Practice management integration providers (UK): when an authorised user connects a supported third-party practice management system and chooses to send case data or documents
Identity verification providers (EU processing region by default): optional identity document and biometric verification, only where a firm enables this feature and a client actively completes a check
Public and third-party data providers: for property reports (UK public and open-data services)
Your firm's clients and introducers: where the service requires sharing between parties you have invited to a case or portal

Where we act as processor for customer firms, we share data only to deliver the service on their instructions or as required by law. We maintain an internal register of our processors, their locations, and the status of our data protection arrangements with each of them, and review it at least annually.

7. Data Retention

We keep personal data only for as long as needed for the purpose it was collected, or as required by law. Retention periods vary by the type of data and, for customer-firm data, by our customers' own instructions and regulatory obligations:

Mortgage and advisory casework (client and case records): up to 7 years from case close, in line with FCA record-keeping rules (SYSC 9)
AI chat conversation history: 90 days, then automatically deleted
AI-generated extraction drafts: 30 days, then automatically deleted
Call and meeting audio: phone-call recordings are deleted automatically within 3 days of being transcribed (or of the recording failing or being cancelled). If transcription is paused because a firm has reached its monthly AI allowance, the audio is kept until the call can be transcribed. Meeting-bot recordings are held by our meeting recording provider only until the transcript has been saved in Cleera, and in any case for no more than 24 hours
Call and meeting transcripts, draft call notes, and AI-suggested updates: kept as part of the case record, for the same period as the case (see above), unless deleted earlier on request. If the adviser discards the draft call note, the transcript and any remaining audio are deleted at that point
Uploaded case and identity documents: for the duration of the case, plus up to 7 years in line with FCA record-keeping rules
Identity document images and verification outcome (Didit, where enabled): 5 years from the end of your relationship with the firm, in line with the Money Laundering Regulations 2017 record-keeping duty (regulation 40)
Selfie/portrait image captured during identity verification (Didit, where enabled): the standalone copy of this image is automatically deleted around 90 days after the check completes, as it is used only to confirm you matched your ID document at the time of the check and is not itself a record we are required to keep. A copy remains visible within the compliance report generated for that check, which we do retain for 5 years alongside the ID document images (see above)
Website lead capture submissions: unconfirmed submissions expire after 48 hours; confirmed submissions are retained as part of the relevant firm's records
Transactional email content and delivery logs (our email delivery provider): deleted or anonymised within 100 days of our contract with that provider ending; day-to-day delivery logs are retained indefinitely at low sending volumes, or on a rolling basis once an account exceeds high-volume thresholds
Billing records (our payment processor): for as long as required for accounting, tax, and dispute-resolution purposes
Integration tokens (for example practice management integration credentials): until you disconnect the integration or your account is closed
Audit logs (who did what, and when, within the platform): 12 months
Data submitted to a connected practice management system via our outbound sync: not retained by Cleera after the sync completes; retention is governed by your own account with that provider

When you close your Cleera account, we will delete or anonymise personal data we control within 90 days, except where we are required to retain it for longer: most commonly, case-related records kept for up to 7 years under FCA SYSC 9, or financial records kept for up to 6 years under UK tax law.

8. International Transfers

Some of our third-party providers operate outside the UK. Where we transfer personal data internationally, we ensure appropriate safeguards are in place, such as the UK International Data Transfer Agreement (IDTA) or adequacy decisions.

9. Your Rights

Under UK GDPR, you may have the following rights in relation to personal data we control:

Right of access: to request a copy of the personal data we hold about you
Right to rectification: to ask us to correct inaccurate or incomplete data
Right to erasure: to ask us to delete your personal data in certain circumstances
Right to restriction: to ask us to restrict processing of your data
Right to data portability: to receive your data in a structured, machine-readable format
Right to object: to object to processing based on legitimate interests
Right to withdraw consent: where we rely on consent, you may withdraw it at any time

If your data was submitted to a firm through Cleera (for example as a client, introducer, or website lead), contact that firm first to exercise rights against the data controller. We will assist our customer firms with requests that relate to data we process on their behalf, within the scope of our agreement with them.

To exercise rights against Cleera as controller, please use our contact page. We will respond within 30 days. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

10. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or destruction. These include encryption in transit (TLS), hashed passwords, encrypted storage of sensitive integration tokens, access controls, and regular security reviews. However, no method of transmission over the internet is 100% secure.

11. Cookies

We use cookies and similar technologies. For full details, please see our Cookie Policy.

12. Children

Our platform is not directed at children under 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify account holders of material changes by email or by displaying a prominent notice on our platform. Continued use after changes take effect constitutes acceptance where applicable.

14. Contact

For any privacy-related questions or to exercise your rights against Cleera as controller, please contact:
Cleera (trading name of Seringa Ltd)
Company number: 15449830
ICO registration number: ZC184688
Registered office: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Email: our contact page