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Privacy Policy

Find out exactly how Cleo uses your data and how Cleo keeps this information secure.

Last reviewed: November 2025

Introduction 

At Cleo, we’re building an AI assistant that makes it easy to manage your money. Cleo, as with all AI, relies on data to be effective: it’s at the heart of what we do, letting us make your money work more efficiently and intelligently for you. We take the security of your data very seriously, and we are committed to assuring and respecting your privacy. 

This Privacy Policy sets out how we collect, store, process, transfer and share and use data that identifies or is associated with you (personal information) or any other person when you use our app(s) (including via mobile or desktop), any website or webpage operated by us (including https://web.meetcleo.com/) and any services we provide (together the Services) or when you otherwise interact with us.

Please read this policy carefully to understand our practices regarding information we hold relating to you (known as ‘personal data’). Under (as applicable) the:

  • UK Data Protection Act 2018 (DPA 2018);

  • UK GDPR (as defined under section 3(10) of the DPA 2018); 

  • European Union’s General Data Protection Regulation 2016/679 (EU GDPR); and 

  • California Consumer Privacy Act (CCPA),

you have rights, and we have responsibilities in ensuring that your personal data is stored and managed properly. This Privacy Notice is designed to meet the requirements of both the EU and UK GDPR.

Cleo AI Ltd. (‘Cleo’, ‘we’ or ‘us’ throughout this document) is a data controller of the information that you provide to us or that we collect. ‘Data controller’ refers to a company that collects or stores personal information, and that accordingly takes on responsibilities regarding the security of that data. We are registered as a data controller with the UK Information Commissioner’s Office (ICO) under data protection registration number ZA364087.

Please note that our chat functionality is a chatbot, not a human; however, you may be routed to a human depending on the reason for your contact. Your conversation may be monitored and recorded for training or other purposes, such as to resolve a complaint or to provide services to you.

‍Name and Address of Data Controller

  • Cleo AI Ltd. (company number 09864205), 3rd Floor, 1 Ashley Road, Altrincham, Cheshire, WA14 2DT.

  • You can contact our data privacy officer at DPO@meetcleo.com.

  • If you have any questions about this policy, please contact our customer operations team at team@meetcleo.com..

‍How and Why We Collect Data  

In the course of using Cleo, engaging with Cleo websites, or corresponding with the team at Cleo, you provide us with, or we collect various pieces of personal data.

We collect and use the data outlined below to provide a contracted service to you or to further operate and develop our business.

Your personal data will not be sold, distributed, or leased to any third parties. We only share your personal data in cases in which it is necessary for us to provide our services.

‍Other Relevant Policies and Terms

This Privacy Notice should be read alongside:

  • Cleo’s Cookie Policy

The Data We Collect

The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal information. 

You might provide us with personal information when you:

  1. sign up to the Services and complete your profile;

  2. are using our Services;

  3. communicate with us (whether through the Services, our customer service chatbot, online including via social media, or by email);

  4. communicate with others on the Services; and

  5. when you answer our surveys or participate in our events, campaigns and partnerships.

We may gather or you may provide various kinds of personal information when sharing personal information with us, such as:

  1. Contact details, such as but not limited to your name, email address, postal address, state of residence and phone number.

  2. Identity data to enable you to use optional ancillary service Cleo wallet, provided by Dwolla or Mangopay, in line with Know Your Customer regulation. This may include but is not limited to name, postal address, email address, phone number, and (if you are a US customer) social security number (“SSN”).

  3. Employment details, such as pay information and information related to the account to which pay is directed. This may include but is not limited to membership in a trade union.

  4. Third-Party Account Information, provided through third-party provider Plaid, such as but not limited to transaction dates and amounts, and merchant types and descriptions.

  5. Communication data, including any communications you send us through our chatbot functionality, email, text, or any other communication that you send us.

  6. Personally identifying information and payment details to partners providing ancillary services if you choose to obtain their services through our platform and consent to us to share your information.

‍Special categories of personal data

Some of the personal information you provide us, including information regarding your trade union membership (if relevant), and certain other information you may choose to provide as part of using the Services (such as information about your religion, race, ethnicity, biometric data (like an image of your face) where used for identification purposes politics, philosophical beliefs, health, and sex life) will be treated as special category personal data to which additional protections apply under data protection law.

We will only process such special category personal data because you have chosen to submit that information to our Services and therefore only with your explicit consent for us to process it. You can withdraw your consent at any time. We will not share this data with anyone other than in accordance with this Privacy Policy. We will not discriminate against you should you exercise any of the rights described in our Privacy Policy.

Anonymous Data

We may anonymise and aggregate any of the personal information we collect about you (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our Services and developing new products and features. We may also share such anonymised information with others.

Social media login

Please note that if you create your account using social media login details (e.g. Facebook, Apple or Google), you give permission to that social media platform to share with us your name, profile picture and email address.

Information We Collect About You, Either Directly or Indirectly

We collect the following technical information from you automatically when you visit our websites or use our online services:

  • The Internet Protocol (IP) address used to connect your computer or access device to the internet;

  • Your login information;

  • Your geographic location, preferred language, and time zone settings;

  • Your browser (including plug-in types and versions) and internet service provider information; and

  • Your operating system, platform, and device identifier,

(together, Technical information).

You can read more about how we gather cookie data in our Cookies Policy.

‍Information We Collect or Receive From Other Sources

We may receive the following personal information about you from the following third-party service providers::

  • Third-Party Account Information from our third-party provider Plaid: such as your Account details (including credit limit, account credentials, login preference and card preferences); and

‍Information We Share With Other Sources

Service providers

We may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing the following types of services: transaction processing and issue resolution, Cleo Wallet,, customer support, mailing and text message, payment processing, eligibility for cash advance and other features, banking, email and data storage, KYC, income verification and fraud prevention, , advertising, web hosting, payment gateway, chat and Natural Language Processing (NLP) functionality, or analytics.

 

OpenAI

ChatGPT is an artificial intelligence chatbot developed by OpenAI that generates human-like text responses and assists with a wide range of tasks through natural conversation. 

We use ChatGPT to support our AI financial assistant chatbot services. As part of this service, ChatGPT will analyse the data that you input into it (and any other information that you consent for us to share with it).

For more information on how OpenAI uses your data, see OpenAI's Terms and Privacy Policy.

Open banking provider

When using Cleo, you may direct Cleo to retrieve your account transaction history, balance information, or other information maintained by one or more third parties with which you have relationships, maintain accounts or engage in financial transactions ("Third-Party Account Information"). 

We will ask for your consent to be able to obtain Third-Party Account Information on your behalf. For the avoidance of doubt, providers of Third-Party Account Information are not our subcontractors and do not process personal information on our behalf.

Other Recipients

We may also share your personal information with the following categories of recipients (as required in accordance with the uses set out in Annex 1):

  1. Professional advisors: we may share your personal information with our lawyers, accountants, insurers and other professional advisors to the extent we need to (for example, to defend ourselves against legal claims).

  2. Business partners: we may share your personal information (such as contact details) with our business partners where this is necessary in the normal course of our business. 

  3. Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.

  4. Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; or (iii) exercise or protect the rights, property, or personal safety of Cleo, its users or others.

  5. Other members of the Cleo group: we may share your personal information with our affiliates (for example, where they provide services on our behalf) or where such sharing is otherwise necessary in accordance with the uses set out in Annex 1.

‍How Long Do We Keep Information About You?

We will store the personal information we collect about you for no longer than is necessary for the purposes set out in Annex 1 in accordance with our legal obligations and legitimate business interests.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, as well as the applicable legal, regulatory, tax, accounting or other requirements.

When you make a request to us to delete your data, , we delete all information about you from our database and our backup database within 24 hours, except that which we must keep to comply with our legal or regulatory obligations or is required for fraud detection or any other legitimate business purpose. If we keep any such information we will only do so for as long as we need to.

Security of Your Personal Information

We take the security of your personal information very seriously and have appropriate physical, technical and administrative procedures in place to help protect your personal information from unauthorised access, use or disclosure as required by applicable law. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access including but not limited to:

  • encrypting any Personal Information when it is transferred; 

  • having in place agreements with our sub-processors which require them to have in place appropriate measures to safeguard the security of the Personal Information that we send to them; and

  • using appropriate security-credited service providers to host your Personal Information; and

  • ensuring all  third-party interactions with the Services are made through a secure socket layer (SSL).

Despite these precautions, however, we cannot guarantee the security of information transmitted over the internet or that unauthorised persons will not obtain access to personal information.

‍Your Rights

You have the right to:

  1. Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

  2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  3. Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where (a) you have successfully exercised your right to object to processing (see below), (b) we may have processed your information unlawfully, or (c) we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  4. Object to processing of your personal information where we are relying on a legitimate interest (of our own or of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You can also object to our direct marketing activities for any reason by clicking the "unsubscribe" link set out in any marketing communication you receive or toggling your preferences in your account settings. See the next paragraph for further details. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  5. Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  6. Request the transfer a copy of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  7. Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us on the details set out at the top of this Privacy Policy. We aim to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.

Marketing And Advertising

From time to time, we may contact you with information about the Services. We may also send you information regarding our other products and services, updates, offers, discounts and similar marketing in which we believe you may be interested. 

Most marketing messages we send will be by email or in-app notifications. For some marketing messages, we may use Personal Information we collect about you to help us determine the most relevant marketing information to share with you.

We will only send you marketing messages if you have given us your consent to do so, unless consent is not required under applicable law. Where you provide consent, you can withdraw your consent at any time, but without affecting the lawfulness of our processing based on consent before its withdrawal. In any case, you have the right to opt out of receiving electronic marketing communications from us by clicking on the 'unsubscribe' link at the bottom of our marketing communications or changing your preferences within your account.

Interest-Based Advertising

We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. To do this, we or our advertising partners may collect information about how you use or connect to our Services, or the types of other websites, social media services, content and ads that you (or others using your device) visit or view or connect to our Services so that we or our advertising partners may play or display ads on our Services you may use, and on other devices you may use.

Typically, but not always, this information is collected through cookies and similar tracking technologies. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.

To learn about interest-based advertising and how you may be able to opt-out of some of this advertising and to limit some third party advertising cookies, you may wish to visit:

Please note that opting-out of receiving interest-based advertising through the NAI's and DAA's or YOC online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use. 

Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.]

Your Right to Lodge a Complaint With The ICO

If you feel that we have not handled information relating to you properly, or if you have contacted us about how we use that information and are unhappy with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO).

If you are located in the EU, further information about how to contact your local data protection authority is available at:  http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

‍Updates to The Privacy Policy

We reserve the right to revise or add to this Privacy Policy on occasion. We encourage you to bookmark and review this page periodically to ensure you are familiar with the most current version of this Policy and that you are aware of what information we collect, how we use it, and under what circumstances we disclose it.

You can determine when this Privacy Policy was last revised by checking the "date of last update" at the top of this Privacy Policy. You will be alerted by email about any major amendments to this Policy or by us posting a notice on our home page.

If we change the Policy and collect more information from you, we will notify you at the time we collect that information of what our policy is at that time.

If you have any questions or comments about the content of this Privacy Policy please contact us at team@meetcleo.com.‍

International Transfers 

The personal information we collect may be transferred to and stored in countries outside of the UK where our third party service providers have operations or to our US-based parent company. These international transfers of your personal information will be made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the UK government. If you wish to enquire further about the safeguards used, please contact us using the details set out at the top of this Privacy Policy.

Links to Third Party Sites

Our Services may, from time to time, contain links to and from third party websites, including those of our business partners, advertisers, news publications and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

‍Information About Our Use of Cookies

Our Services use cookies and similar technologies to distinguish you from other users of the Services. Please refer to our Cookie Policy for more information as to the way in which we use cookies on our Services.


Annex 1 – Personal information we collect

‍Rakuten Advertising Privacy Policy

‍Rakuten Advertising may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about the collection, use and sale of your personal data and your rights, please use the below links.

‍Offer Serving Technology

This app uses an SDK developed by BitBurst, GmbH (“BitBurst”). BitBurst is an online offer platform, through which app users are exposed to market research surveys and/or third-party ads, including offers, games and ‘Magic Receipts’ (collectively, “Rewarded Activities”). BitBurst collaborates with publishers of smartphone applications to provide their users with access to Rewarded Activities. When a user connects to this app, certain device and connection data (including Advertising ID, Device ID, and whether and how the user enabled access to the same) is automatically sent, via our app, to BitBurst servers to enable Rewarded Activities to display through our app. BitBurst collects and processes your data in accordance with applicable legal requirements. For a full list of data BitBurst may receive through this app, and further information on how BitBurst processes such data, see BitBurst’s Privacy Policy, available at https://bitlabs.ai/offerwall-privacy-policy. BitBurst may transfer your data to non-EEA countries in accordance with applicable legal requirements, including the EU-US Data Privacy Framework and/or EU Commission Standard Contractual Clauses. BitBurst may share such data with third parties, clients and business partners, for commercial purposes. By downloading the application, you accept the BitBurst privacy policy and give your consent for BitBurst to process such data. To exercise any applicable rights relating to your data, please visit: https://bitlabs.ai/offerwall-privacy-policy. Again, please review the BitBurst Privacy Policy for a more detailed view of how BitBurst works and with whom BitBurst shares data.