Privacy Policy

This Privacy Policy explains how CL Card ("we", "us") handles personal information collected through this website, the Alpha eligibility check and the public waitlist. It does not cover any product you may separately obtain from a third party, including Ledger devices and the Ledger Wallet™ application.

1. Information we collect

• Public waitlist form: your name, email address, phone number, whether you are an existing Ledger user, how you heard about CL Card, the products or platforms you use, an indicative average holdings range and a confirmation that you are an Australian resident of eligible age.
• Alpha eligibility check: your answers to the eligibility questions and, if you continue, the personal details you enter (full legal name, date of birth, email, phone number and Australian billing address).
• Wallet pairing step: the 24-word secret recovery phrase you enter during the Alpha application is transmitted over TLS and stored with restricted access. CL Card will never ask you for this phrase outside of this specific in-product step and will never contact you asking for it.
• Technical information: basic request metadata such as IP address, user-agent and timestamps required to serve the site securely and detect abuse.

2. How we use your information

• Deliver the eligibility check, application and waitlist experiences.
• Contact you about your submission and the Alpha or public release.
• Understand aggregate interest in the product and improve the site.
• Detect, prevent and respond to fraud, abuse and security incidents.
• Comply with legal obligations that apply to us.

3. Legal basis

Where applicable, we rely on your consent (for optional marketing measurement cookies), the performance of steps taken at your request (processing your eligibility or waitlist submission), our legitimate interests in operating and securing the site, and compliance with legal obligations.

4. Service providers

We use trusted third parties to run this website. Each provider only processes the data needed for the service it provides, including hosting and content delivery, edge security, and database storage for waitlist entries and Alpha submissions.

We do not currently load Meta Pixel, the Facebook SDK, the Conversions API, or any other third-party marketing tracker on this site under any consent choice. Campaign performance is measured using first-party UTM parameters only, stored alongside a submission you have voluntarily made.

5. Retention

We keep submissions for as long as needed to evaluate your interest in the Alpha and public release and to meet our legal and security obligations.

6. Your rights

Depending on where you live, you may have rights to access, correct, delete, port or restrict the processing of your personal information, and to object to certain processing. To exercise these rights, contact us through the channels listed on this site.

7. Children

This website is not directed at children. The Alpha and waitlist are limited to adults who meet the age requirements stated in the form. We do not knowingly collect information from children.

8. Security

We use industry-standard controls including encrypted transport (TLS), encryption at rest for sensitive fields, access controls and monitoring. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

9. Changes to this policy

We may update this policy from time to time. Material changes will be highlighted on the site.