Privacy Policy

1. Who we are

Clerk is operated by Faxter Ltd (RC 1677701), a company registered in Nigeria with its registered office at Suite 73 Dumec Plaza, Area 1, Abuja (“Clerk”, “we”, “us”). For the personal data described in this policy, we are the data controlleras defined under the Nigeria Data Protection Act 2023 (the “NDPA”) and the regulations made under it.

Questions about this policy or your data can be sent to our data protection contact at clerk@faxter.com.

2. Scope

This policy applies to the Clerk website, web app, and the channels through which you reach Clerk (such as WhatsApp, email and Slack). Where we process the financial records of your business, much of that data relates to the business itself; where it identifies individuals (you, your team, your customers or suppliers), it is personal data and this policy applies.

3. What we collect

• Account & identity data — name, email, phone number, role, password credentials, and verification information needed to open and secure your account.
• Business & financial data — your chart of accounts, transactions, invoices, bills, payroll inputs, tax registrations (e.g. TIN), and the reports we generate.
• Bank connection data — where you connect a bank account, the account details and transaction history we receive to keep your books (see section 5).
• Documents — statements, receipts, invoices and other files you upload or forward to us, and the data we extract from them.
• Usage & technical data — device, browser, IP address, and how you use the product, collected to operate, secure and improve the service.
• Communications — messages you exchange with Clerk and with your controller across any channel.

4. How we use your data, and our lawful basis

Under the NDPA we rely on the following lawful bases:

• Performance of a contract — to deliver the service: keep your books, close your accounts, prepare and file returns, and answer your questions.
• Legal obligation — to meet record-keeping, tax and anti-money-laundering requirements that apply to us and to the accounting work we perform.
• Legitimate interests — to secure, maintain and improve the product and to prevent fraud and abuse, balanced against your rights.
• Consent — where required, for example before connecting a bank account or sending certain communications. You can withdraw consent at any time.

5. Bank account connections

When you connect a bank account, we use it to read transactions so your books stay current. Bank connections are made through licensed financial-data providers; we request the minimum access needed and, where the connection supports it, that access is read-only. We do not move money on your behalf through these connections. You can disconnect a bank account at any time, after which we stop retrieving new transactions.

6. Automated processing and AI

Clerk uses software, including AI models, to categorise transactions, reconcile accounts, extract data from documents and draft reports. A qualified accountant reviews and signs off the work — material accounting outcomes are not left to automation alone. We do not sell your data and we do not use your books to train third-party AI models.

7. When we share data

We share data only as needed to run the service or to meet the law:

• Service providers (processors) — hosting, infrastructure, financial-data, communications and analytics providers who process data on our instructions under contract.
• Your accountant / controller — the ICAN-qualified professional assigned to your account, who reviews and signs off your books.
• Tax and regulatory authorities — where you instruct us to file on your behalf (for example the Nigeria Revenue Service (NRS) and the relevant state tax authority), or where disclosure is required by law.
• Professional and legal advisers, and parties to a corporate transaction, where lawful and subject to appropriate safeguards.

8. International transfers

Some of our providers process data outside Nigeria. Where data is transferred abroad, we take steps required by the NDPA to ensure it remains adequately protected, including contractual safeguards with the recipients.

9. How long we keep it

We keep your data for as long as your account is active and thereafter as needed to meet legal and accounting obligations. Accounting and tax records are generally retained for at least six years, in line with Nigerian record-keeping requirements. When data is no longer needed we delete or anonymise it.

10. Security

We encrypt data in transit and at rest, restrict access on a need-to-know basis, and keep an immutable audit trail of accounting actions. See our Security page for detail on how we protect your information.

11. Your rights

Under the NDPA you have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• have data deleted, where the law allows;
• object to or restrict certain processing;
• withdraw consent where we rely on it; and
• receive a copy of certain data in a portable format.

To exercise any of these, email clerk@faxter.com. If you are not satisfied with our response, you may lodge a complaint with the Nigeria Data Protection Commission (NDPC).

12. Cookies

We use cookies and similar technologies to keep you signed in, remember preferences, and understand how the product is used. You can control cookies through your browser settings; some features may not work without them.

13. Children

Clerk is a product for businesses and is not directed at children. We do not knowingly collect data from anyone under 18.

14. Changes to this policy

We may update this policy from time to time. When we make material changes we will update the effective date above and, where appropriate, notify you.

15. Contact us

Faxter Ltd
Suite 73 Dumec Plaza, Area 1, Abuja
clerk@faxter.com