Privacy Notice

1. Who we are

Clear Path Resolutions (“Clear Path”) is a product operated by Handy Digital Ltd. Handy Digital Ltd is registered in Scotland under company number SC792600. Its registered office is 3e Wallace House, Maxwell Place, Stirling, United Kingdom, FK8 1JU.

This notice applies to Clear Path’s public website, customer portal, company workspace and supporting platform services.

2. Who is responsible for your information

Your case company

The organisation identified in your invitation and portal normally decides why your case, debt and customer information is used. It is therefore normally the data controller for that information. Its own privacy notice should explain its lawful bases, retention periods, regulatory duties and how to exercise rights relating to your case.

Handy Digital Ltd

Handy Digital Ltd normally processes case information on the case company’s documented instructions to host and operate Clear Path. For limited activities where Handy Digital Ltd decides the purpose and essential means—such as company-user administration, platform security, service diagnostics, misuse prevention, supplier management and compliance with its own legal duties—it acts as a separate controller.

3. Information processed through Clear Path

Depending on the features used, this may include:

• names, customer and case references, date of birth and identity-verification results;
• postal address, email address, telephone numbers and communication preferences;
• employment status, bank provider and information about affordability or circumstances;
• support, accessibility, vulnerability, dispute, complaint or contact-restriction information;
• case, account, debt, balance, agreement, settlement, proposal and payment-promise records;
• documents and files supplied by the case company or uploaded to a case;
• messages, letters, email and SMS delivery records, notes and support requests;
• survey invitations, saved answers and submitted responses;
• payment amount, status, date, method, provider reference and masked payment-method details;
• optional voice-call scheduling, audio, transcripts and call outcomes where enabled;
• login, authentication, device, browser, IP address, security and portal-activity records; and
• company-user identity, role, access, audit and account-administration information.

4. Where information comes from

Information may come from:

• the case company and its authorised staff or systems;
• you, when you sign in, send information, make a proposal or payment, or complete a survey;
• communications, payment, identity, hosting and voice-service providers;
• technical and security logs created when the service is used; and
• authorised corrections, imports and records connected with the management of a case.

Where a case company obtains your information from another source, it is responsible for telling you about that source and its use of the information unless a lawful exception applies.

5. How and why information is used

Clear Path may be used to:

• create and administer company and customer access;
• present case information and documents securely;
• support proposals, agreements, payments, disputes, support requests and surveys;
• send and record authorised communications and notifications;
• maintain audit trails and protect the integrity of case records;
• prevent, detect and investigate misuse, fraud and security incidents;
• monitor reliability, diagnose errors and improve platform performance; and
• meet legal, regulatory, contractual and dispute-resolution requirements.

For case information, the case company determines the lawful basis and Handy Digital Ltd processes the information on its instructions. For Handy Digital Ltd’s limited controller activities, processing is generally necessary for legitimate interests in securely operating and protecting the service, performing contracts with company customers, or complying with legal obligations. Consent is used where the law specifically requires it, including for any future non-essential cookies.

6. Sensitive information and support needs

Information about health, vulnerability or support requirements may reveal special-category personal data. The case company is responsible for identifying an appropriate lawful basis and additional condition before recording or using that information. Clear Path restricts access to authorised users and uses it to help the company apply contact restrictions, accessibility requirements, pauses and appropriate support.

7. Automation and optional AI voice calls

Clear Path can automate reminders, communications, schedule calculations, workflow tasks and milestone notifications using rules configured by the case company. The platform is not intended to make final legal or enforcement decisions without the case company’s responsibility.

Where the case company enables AI-assisted voice calls, call scheduling, recordings, transcripts and outcomes may be processed by Vapi and voice or AI providers configured through that service. Calls should identify their purpose and apply the case company’s security and contact rules. The case company’s privacy notice should explain any additional profiling or automated decision-making it undertakes.

8. Payments

Card payments are handled on Acquired.com’s secure hosted payment pages. Clear Path sends limited customer, billing, case and transaction information needed to prepare and reconcile a payment. Clear Path does not receive or store the full card number or security code.

Clear Path may store a provider token, card brand, last four digits, expiry information, payment status, amount and provider references. A reusable payment method is retained only where the relevant payment flow records authority to do so.

9. Who information may be shared with

Information may be shared, as necessary, with:

• the case company and its authorised users;
• Supabase for authentication, database and file-storage services;
• Vercel for application hosting and delivery;
• Twilio and SendGrid for SMS and email communications;
• Acquired.com for payment processing and stored payment methods;
• Vapi and configured voice or AI providers where optional calling is enabled;
• security, malware-scanning, infrastructure and professional-service suppliers; and
• courts, regulators, law-enforcement bodies or advisers where disclosure is lawful and necessary.

Providers may process only the information needed for their service and are subject to contracts, confidentiality and security requirements appropriate to their role.

10. International transfers

Some providers may process information outside the United Kingdom. Where UK personal data is transferred internationally, the responsible organisation must use a lawful transfer mechanism and appropriate safeguards, such as UK adequacy regulations or approved contractual protections, together with any additional security measures required by the circumstances.

11. How long information is kept

Case information is retained according to the case company’s documented instructions and retention obligations. Relevant factors include whether a case remains active, limitation and regulatory periods, legal claims, payment reconciliation, complaints, audit requirements and the need to demonstrate actions taken on an account.

Handy Digital Ltd retains controller information only for as long as reasonably necessary for account administration, security, incident investigation, service records and its own legal obligations. Expired invitations and sessions stop providing access, although limited audit and security records may remain. When data is no longer required, it is deleted, anonymised or securely placed beyond use in accordance with the applicable retention process.

12. Security

Clear Path uses measures designed to protect confidentiality, integrity and availability, including tenant separation, role-based access, multi-factor authentication for company users, secure customer verification, encryption, tokenised payments, malware scanning, audit records and restricted provider credentials. No online service can eliminate every risk, so suspected unauthorised access should be reported promptly.

13. Your data-protection rights

Depending on the circumstances, you may have rights to access, correct, erase or restrict personal information, object to processing, receive portable information, withdraw consent, and challenge qualifying solely automated decisions.

For information about your debt or case, contact the case company shown in your portal because it normally controls that information. Clear Path will assist the company where required. For information controlled by Handy Digital Ltd, write to the address in section 16 marked “Data Protection Enquiry”. We may need to verify identity before responding.

You may also complain to the Information Commissioner’s Office. Visit ico.org.uk/make-a-complaint or call 0303 123 1113. We would appreciate the opportunity to address your concern first.

14. Cookies and local device storage

Clear Path uses strictly necessary cookies and similar storage to maintain authenticated sessions, protect accounts, remember permitted security choices and save interface preferences such as the selected theme. These technologies are required for the requested service or do not track activity for advertising.

Clear Path does not currently use non-essential advertising cookies on the public landing page. If optional analytics or similar technologies are introduced, this notice will be updated and consent will be requested where required before they are used.

15. Changes to this notice

This notice may be updated when the platform, providers or legal requirements change. The latest version and update date will be published here. Material changes may also be brought to users’ attention through the portal or relevant communications.

16. Contact

Contact the case company through the secure portal for case-specific privacy requests. For Handy Digital Ltd’s use of personal information or questions about this notice, write to:

This privacy notice should be read together with the privacy information supplied by the company responsible for your case and our Terms of Use.