Last updated 17 September 2026
Privacy notice
Demonstration site. This is a preview build of the ClearFrank sell flow. The recycler shown is illustrative and no partner agreement is in place for it, so nothing on this page is a contract or an offer. The live service is at clearfrank.com.
This explains what personal information ClearFrank collects when you get a price for a device, verify it or sell it, why we need it, who we share it with and what your rights are. We've kept it as short as we can while still telling you everything the law says you're entitled to know.
Who we are
ClearFrank Ltd is the controller of your personal information. We're a company registered in England and Wales (company number 17360264) at Unit 9 Muirhead Quay, Freshwharf Estate, Barking, Essex, IG11 7BG. We're registered with the Information Commissioner's Office under registration number [ICO registration number].
For anything about your personal information, email [privacy contact email] or write to us at the address above.
How ClearFrank works, and why that matters for your data
ClearFrank shows you offers for your device from partners: a recycler, retailers, network operators and charities. When you accept an offer, the partner you chose is the one buying your device (or, for a donation, the charity receiving the value). We introduce you and verify the device; we don't buy it ourselves.
That means your details go to the partner you choose, so they can complete the sale with you. The partner then uses them as a controller in their own right, under their own privacy notice. We always name that partner, with its company number, on the page before you confirm.
What we collect
| Information | When |
|---|---|
| Your name, email address and phone number | When you lock in a deal |
| Your postal address | When you lock in a deal, so the device can be collected or a send-in pack posted |
| How you want to be paid: bank account name, sort code and account number, or PayPal email | When you lock in a deal for a cash payment |
| A Gift Aid declaration | Only if you donate and tick the Gift Aid box |
| Your confirmation that your device has no cracked or chipped screen, cracked back glass or liquid damage, and when you gave it | When you lock in a cash sale or donation |
| Photos of your device taken when it arrives | Only if it arrives with that kind of damage |
| Your device: make, model, storage, the condition you choose, your network and the prices you were shown | When you get a price |
| Diagnostic results from Phonecheck: IMEI or serial number, battery health, screen, sensors, lock and blacklist status | Only if you run the device test |
| For ClearFrank Verify: your name and email, the marketplace or insurer the check is for, and the certificate result | When you verify a device for a listing or insurance |
| Technical information: your approximate country, and the phone model your browser reports | Automatically when you visit, used to show the right market and suggest your device |
We don't collect your date of birth, and we don't ask for or keep card details. We don't use tracking or advertising cookies (see Cookies).
Why we use it, and our lawful basis
| Purpose | Lawful basis |
|---|---|
| Showing prices, running the device test, locking in your deal and passing your order to the partner you chose | Contract: it's needed to do what you've asked |
| Arranging your payment (including any difference ClearFrank pays you under our guarantee), or your donation and Gift Aid | Contract, and legal obligation for Gift Aid records |
| Checking devices aren't lost, stolen, blacklisted or on finance, and preventing fraud | Legitimate interests: protecting you, our partners and us from fraud and stolen goods |
| Keeping order and financial records | Legal obligation: tax and accounting law |
| Answering your questions and complaints | Contract, or legitimate interests where you're not a customer |
| Anonymous price statistics (which models and networks are quoted, and at what price) | Legitimate interests: improving our prices. These records don't identify you |
| Keeping the site secure and working | Legitimate interests |
We don't send marketing emails. If that ever changes, we'll only do it if you've opted in, and every email will let you opt out.
We don't make decisions about you based solely on automated processing that have legal or similarly significant effects. The Phonecheck test sets your price before you lock it in, and once it's locked you're never offered less: if the second test doesn't match, ClearFrank pays you the difference.
Who we share it with
- The partner you choose: the recycler, retailer, network operator or charity named on your deal. They receive what they need to complete it: your name, contact details, address, device and order details, diagnostic result and, for a cash sale, your payment details.
- Phonecheck, which runs the device diagnostic through its app.
- Cloudflare, which hosts the website and stores our data.
- Resend, which sends order emails. Order emails never contain your full bank details; they show only the last four digits of your account number.
- HMRC, through the charity, if you make a Gift Aid declaration.
- The police or other authorities, where the law requires it, or where we reasonably suspect a device is stolen or a transaction is fraudulent.
- A buyer of our business, if ClearFrank is ever sold or merged, under the same protections as this notice.
We never sell your personal information.
Transfers outside the UK
Some of our service providers process data outside the UK, including in the United States. When that happens we make sure it's protected, either by relying on UK adequacy regulations (including the UK Extension to the EU–US Data Privacy Framework where the provider is certified) or by using the International Data Transfer Agreement or Addendum approved by the ICO. You can ask us for details.
How we keep it safe
Payment details are encrypted before they're stored, and only authorised staff can see them in full. The site is served only over encrypted connections. Our partners must erase all data from any device they buy to a recognised standard, and they may not access or copy anything on it.
Before you send a device, please back it up, sign out of your accounts (including Find My / iCloud or Google) and reset it. Our partners wipe devices anyway, but you're the best person to make sure nothing is left behind.
How long we keep it
| Information | Kept for |
|---|---|
| Order records: name, contact details, address, device, price and reference | 6 years after the end of the tax year of the sale, as tax law requires |
| Bank or PayPal payment details | 90 days after you've been paid, in case a payment needs to be traced, then deleted |
| Diagnostic results linked to an order | As long as the order record |
| Diagnostic results where you didn't go ahead | 12 months |
| ClearFrank Verify certificates | 6 years, so a certificate can still be checked by the marketplace or insurer |
| Anonymous price statistics | Indefinitely, as they don't identify you |
Your rights
You have the right to:
- get a copy of the personal information we hold about you;
- have inaccurate information corrected;
- have your information deleted, where we don't need to keep it for a legal reason;
- restrict or object to how we use it, including anything we do on the basis of legitimate interests;
- receive the information you gave us in a portable format; and
- withdraw your consent, where we rely on consent.
To use any of these rights, email [privacy contact email]. It's free, and we'll reply within one month. For information a partner holds as their own controller, you can also contact them directly.
If you're unhappy with how we've handled your information, please tell us first so we can put it right. You also have the right to complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint or on 0303 123 1113.
Cookies and similar technologies
We only use storage that's strictly necessary for the site to work, so we don't ask for cookie consent:
| Name | Type | Why | How long |
|---|---|---|---|
cf_site | Cookie | Keeps you signed in while the site is in private preview | Up to 30 days |
cf_market | Session storage | Remembers which country's prices you chose | Until you close the tab |
cf_ref | Session storage | Remembers which partner site sent you, so they're credited for the referral | Until you close the tab |
We don't use analytics, advertising or social media cookies. If we add any in future, we'll ask for your consent before setting them and update this notice.
Children
You must be 18 or over to sell a device through ClearFrank. We don't knowingly collect information from anyone under 18.
Changes to this notice
We'll update this notice when how we use personal information changes, and change the date at the top. If a change materially affects information we already hold about you, we'll tell you before it applies.
See also our customer terms.