Consumer Data Right (CDR) Information

Operative policy

Fiskil's CDR Policy applies

Read Fiskil's CDR Policy here: fiskil.com/legal/cdr-policy.

Fiskil's CDR Policy sets out your rights as a CDR consumer, how to make an access or correction request, how CDR complaints are handled and escalated, and the applicable timeframes and contact pathways. This page does not create separate processes, rights or commitments in relation to CDR data. If anything on this page differs from Fiskil's CDR Policy, Fiskil's CDR Policy prevails.

Cleer Money is operated by Cleer Co Pty Ltd (ACN 699 655 948), a company registered in Australia, with its registered office in Maroochydore, Queensland, Australia. Our Privacy Policy covers personal information that is not CDR data.

Arrangement

How the arrangement works

Cleer Money is not itself an accredited data recipient. We access CDR data as a CDR Representative of Fiskil Pty Ltd, an accredited data recipient under the Competition and Consumer Act 2010 (Cth) and the Consumer Data Right rules.

• When you connect a bank, you give consent through Fiskil's CDR consent flow, and your bank authenticates you directly, so we never see your banking credentials.
• Fiskil retrieves your data from your bank and passes it to Cleer Money strictly in accordance with the consent you gave and Fiskil's CDR Policy.
• Access is read-only. Cleer Money can never move money or initiate payments.

Use in the App

What Cleer Money uses CDR data for

Within the consent you give through Fiskil, the App uses CDR data as follows:

CDR data is used for categorisation and insights only. It is not used for marketing, advertising, profiling or credit assessment, and it is not sold or disclosed to third parties for their own purposes. CDR data is stored on our cloud infrastructure (Supabase) with encryption in transit, row-level security, and access limited to authorised systems.

Deletion

Deletion when consent ends

This applies whenever consent ends, including where you:

• withdraw consent in the App (Profile → your connected bank → Remove bank), through Fiskil's consent dashboard, or through your bank's data-sharing dashboard;
• have a consent revoked or expire, or do not renew it;
• disconnect a bank, or the connection is otherwise terminated;
• let a subscription lapse or delete your Cleer Money account.

No new CDR data is collected from the moment consent ends. Withdrawing CDR consent does not by itself delete your Cleer Money account: you can keep using the App with CSV import, or reconnect a bank later, which requires a new consent.

Rights & complaints

Your CDR rights, requests and complaints

Your rights in relation to CDR data — including access and correction requests, complaint handling, escalation, response timeframes and external dispute resolution — are set out in Fiskil's CDR Policy, which applies to CDR data handled under this arrangement.

If you contact Cleer Money about a CDR matter at support@cleermoney.com.au, we will handle it in accordance with Fiskil's CDR Policy and, where that policy requires, refer it to Fiskil.