Cleared · operated by Synergy Enterprises Limited
Privacy Policy
This Privacy Policy explains how Synergy Enterprises Limited (“we”, “us”, “our”), operating the Cleared product (including websites such as cleardeal.si / clrd.si and related apps), collects, uses, stores, and shares personal data. We handle personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”) and other applicable law.
1. Who we are
Controller: Synergy Enterprises Limited.
Product: Cleared (AI-assisted agent commerce and authentication facilitation for luxury goods, starting with watches).
Contact for privacy requests: privacy@cleardeal.si (or the privacy contact we publish on Cleared).
2. What we collect
Depending on how you use Cleared, we may collect:
- Identity & contact — name, email, phone, waitlist details, account credentials, admin/access identifiers.
- Deal & item data — watch/model references, photos and media you upload, box/papers status, location/shipping details, preferred price or offers, negotiation messages with our agent.
- Transaction data — payment status, amounts held or released, fee amounts, payout details (as needed to complete a deal), authentication outcome.
- Technical data — IP address, device/browser type, approximate location derived from IP, logs, cookies or similar technologies, referral URLs.
- Support & communications — messages you send us, feedback, and related metadata.
We do not require dealers and end users to reveal their identities to each other. Counterparty contact details are used by us (and our agents/processors) to run the deal, not to introduce parties directly unless you instruct otherwise in writing.
3. How we use personal data
- Provide, operate, and improve Cleared (including waitlist, sign-in, sell/buy flows, guided demos, and bona fide AI-agent discovery/use of published machine-readable materials).
- Identify items, gather deal details, negotiate with counterparties through our agent, arrange shipping for authentication, and coordinate payment release.
- Facilitate professional authentication (including via Hong Kong authentication partners such as WAV / related Watch God Group operations) and related logistics.
- Prevent fraud, abuse, and scams; enforce our Terms; secure accounts and funds holds.
- Comply with law, respond to lawful requests, and protect our rights.
- Send service messages; with consent or as permitted, send product updates or marketing (you may opt out of marketing).
4. Legal bases / PDPO principles
We collect personal data for lawful purposes related to Cleared, only to the extent necessary, and take practicable steps to keep it accurate and secure. Where consent is required (for example certain marketing or optional cookies), we will ask for it. You may refuse to provide data, but some features may then be unavailable.
5. Sharing
We may share personal data with:
- Service providers — hosting, analytics, email, payments, KYC/AML (if enabled), customer support, and IT security vendors under confidentiality obligations.
- Authentication & logistics partners — including Hong Kong authentication and related operational partners needed to inspect, hold, or ship items.
- Deal counterparties (limited) — only information required to perform the anonymized deal (for example shipping label details to a carrier). We do not publish your identity to the other side as a directory or open marketplace contact.
- Professional advisers & authorities — lawyers, auditors, insurers; regulators or law enforcement when required by law.
- Corporate transactions — in connection with a merger, financing, or sale of assets, subject to appropriate safeguards.
We do not sell your personal data.
6. International transfers
Cleared is operated with a Hong Kong operational focus. Data may be processed or stored in Hong Kong and in other jurisdictions where our vendors operate. Where we transfer personal data outside Hong Kong, we take practicable steps consistent with the PDPO to protect it.
7. Retention
We keep personal data only as long as needed for the purposes above, including deal completion, dispute handling, legal retention, security, and accounting. Waitlist emails may be kept until you ask to be removed or we close the list. Authentication media and deal records may be retained longer where needed for fraud prevention or legal claims.
8. Security
We use administrative, technical, and organizational measures appropriate to the risk (access controls, encryption in transit where standard, least-privilege access). No method of transmission or storage is completely secure; please use strong credentials and protect your devices.
9. Your rights
Subject to the PDPO, you may request access to and correction of your personal data held by us. You may also ask us to stop using your data for direct marketing. To exercise rights, email privacy@cleardeal.si. We may need to verify your identity. You may complain to the Privacy Commissioner for Personal Data, Hong Kong.
10. Cookies and similar technologies
We may use essential cookies to run the site/app and, where enabled, analytics or preference cookies. You can control cookies via your browser. Blocking essential cookies may break sign-in or waitlist flows.
11. Children
Cleared is aimed at adults engaging in luxury-goods transactions. We do not knowingly collect personal data from anyone under 18. If you believe we have, contact us and we will delete it where required.
12. Third-party links
Cleared may link to third-party sites or payment pages. Their privacy practices are their own; review their policies before providing data.
13. Changes
We may update this Policy. We will post the new version with an updated effective date and, where changes are material, provide additional notice on Cleared or by email where appropriate. Continued use after the effective date means you acknowledge the updated Policy.
14. Contact
Synergy Enterprises Limited — Privacy
Email: privacy@cleardeal.si
Product: Cleared (cleardeal.si / clrd.si)