Privacy notice
Version 0.1 · Effective date: [to be set on approval]
Qlear keeps records of money you lent and money you owe. This notice explains what we keep, why, who helps us run it, and what you — and the people in your records — can ask of us under the Data Privacy Act of 2012 (RA 10173).
Who we are
Qlear is run by Over-Biz [legal name, registered address and SEC/DTI registration to be confirmed]. For anything about your data, including reaching our data protection officer, email hello@over-biz.com [dedicated privacy address to be confirmed].
Two kinds of data, two roles
- About you — your account and how you use Qlear. Over-Biz decides how this is used, so we are its personal information controller.
- About the people in your records — the people you lent to or borrowed from, and, in a Business workspace, your collectors. You decide what to record about them, so you are their controller and Over-Biz processes it on your behalf. You need a lawful reason to keep it (usually the loan itself), and they should know you use Qlear to track it.
What we keep
- Your account: your name, email address and sign-in details (through Clerk), your household, and your role in it.
- People you record: name, and whatever else you add — email, mobile number, photo, address and landmark, notes.
- Loans and payments: amounts, schedules, interest and fees, payments, settlements, and attachments you upload, such as a GCash screenshot or a signed IOU.
- Cards and debts: the bank, the last 4 digits, the limit, the cut-off and due dates, and the balances you enter or import. Never the full card number, expiry date or CVV. Qlear has nowhere to store them, and removes a full number from an imported statement before anything is saved.
- Messages we send for you: each reminder, receipt and statement as it was sent, and whether it was delivered. If someone unsubscribes, or an address bounces or complains, we keep that too, so they stop getting messages.
- The coach: your questions, the answers, which of your records it looked up, and how much it was used.
- Shared links: a scrambled (hashed) form of each borrower-page link, never the link itself.
- An activity history: who created or changed each record, and when.
- This website: page visits counted in aggregate by Plausible, with no cookies and no personal profile.
Why we use it
- To run Qlear for you: calculate schedules and balances, and send the reminders and receipts you set up.
- To keep it secure, and to know who changed what.
- To answer you when you contact us.
- To understand, only in aggregate, how Qlear is used, so we can improve it.
We don’t sell personal data, and we don’t use it for advertising.
Who helps us run Qlear
These providers process data for us, only to provide their part of the service:
- Clerk: sign-in and accounts.
- Railway: hosting and the database.
- [Object storage provider to be confirmed]: uploaded attachments. These are private and only reachable through short-lived links.
- Resend: sending email.
- Semaphore: sending SMS reminders.
- Anthropic: the AI behind the coach. Your question and the figures the coach looks up are sent to answer it.
- Plausible: cookie-free website statistics.
Some of these providers store data outside the Philippines. [Countries and transfer safeguards to be confirmed.]
How long we keep it
We keep your records while your household exists. When you ask us to delete your household, we delete everything in it: people, loans, payments, attachments, message history, coach conversations and the activity history. Borrower-page links expire after 90 days unless you renew them, and you can revoke one at any time. [Backup retention period to be confirmed.]
Your rights
Under RA 10173 you have the right to be informed, to access your data, to object to its processing, to have it corrected, to have it erased or blocked, to data portability, and to damages. You can also file a complaint with the National Privacy Commission. To use any of these rights, email us.
If you’re someone a Qlear user recorded, such as a borrower, please contact that person first: they control your record. If you can’t reach them, email us and we’ll help. Every reminder has a link to unsubscribe from reminders and statements.
Security
How we protect your data, and what we never store, is on our security page.
Children
Qlear is for adults. Don’t create an account if you are under 18.
Changes
When this notice changes, we’ll update the version and date above, and tell you in the app before a significant change takes effect.