CLAVE PRIVACY NOTICE
Last updated: September 27, 2024
Clave Technologies Ltd (“Clave”, “we”, “us” or “our”) is committed to respecting and protecting
the privacy of individuals who access and sign up for our services (“Users”, “you” or “your”).
This privacy notice (“Privacy Notice”) explains how and why we collect, store, use, and share
your personal information when you access or sign up for our services (“Services”) through our
mobile app (“App”) or when you access our website at https://www.getclave.io (“Site”).
It is important that you understand how we use your information. You should read this page in
full, but below are the key highlights and some helpful links:
● Clave operates as a non-custodial platform, designed to enhance the user experience
by providing a secure smart wallet through the App, enabling you to manage your
digital assets smoothly and seamlessly.
● Clave delivers the Services primarily through the App, while the Site is dedicated to
providing information and facilitating communication. The personal data we process on
the Site is limited to purposes outlined below. Learn more.
● Clave collects and uses personal information to provide our Services, enhance your
experience, protect the security and integrity of the Website and App, and comply with
legal obligations. Learn more.
● If you do not agree with the collection, use, or disclosure of your personal information
as described in this Privacy Notice, or if you are under 17 years of age, please do not
access or use any of our App, Website, or Services.
● If you have any questions about our processing of your personal data, contact us at
privacy@clave.com.
1. Important information and who we are
Clave is the controller and is responsible for your personal data. We process personal data in
compliance with applicable data protection laws, including, where relevant, the General Data
Protection Regulation (EU GDPR) and the retained EU law version of the General Data
Protection Regulation ((EU) 2016/679) as defined in the Data Protection Act 2018 (UK GDPR).
2. The types of personal data we collect about you
The personal information we collect about you depends on the particular activities carry out
through our Site and App.
2.1. Information you provide to us
You can sign up for Clave Services without sharing your personal data by using passwordless
authentication methods. All credentials are securely stored on your device and are never shared
with or processed by us. We respect your choice to maintain anonymity while using our
Services.
However, if you wish to access additional features, use specific Services, personalise your
account, provide feedback, or contact us, you may be asked to provide personal information.
Information Category Description
Basic Customer Data Name, surname, and email address
Account Information
Username, Guardian’s username, profile
picture
Supplemental Identification Information
(This data will only be collected if you wish to
use specific Services offered in collaboration
with our business Partner*, enabling you to
purchase cryptocurrency or other digital
assets via bank transfer or other payment
methods**.)
Government-issued identity document (e.g.,
national identity card, passport or driving
license), date of birth, nationality, residential
address, photographs and/or videos
Customer Data
Information about the transactions made on our
Services, type of transaction, wallet address,
deposit/withdrawal history, payment links,
amount, assets, other transaction metadata
Wallet Information
User’s public wallet address provided while
connecting the wallet to the Clave App
Additional information you submit to us
Feedback and responses provided to our
customer support team.
* We work with selected partners (“Partners”) to enhance your experience. If you use their
additional services, they may process your personal data as data controllers. For more
information on how your personal data is handled by these Partners, please refer to the privacy
policy or notice of the Partner whose services you wish to use.
** These services may also require you to complete KYC (Know Your Customer) procedures,
which involve verifying your identity to comply with legal and regulatory requirements. The KYC
procedures will be conducted by Clave before granting access to the relevant business Partner
and will be shared with the related business partner. Learn more.
2.2. Information collected automatically
As you interact with our Website and App, we may automatically collect device and usage data
about your equipment, browsing actions, and patterns. We also collect your personal data
through cookies and other similar technologies.
Information Category Description
Device Data
Internet protocol (IP) address, your login
data, browser type and version, time zone
setting and location, browser plug-in types
and versions, device ID, advertising ID, push
token***, other technology on the devices you
use to access the Website and App
Usage Data
Information about activity on the digital
content viewed, features accessed, such as
visited pages, searches, or links clicked
Information from cookies and similar
technologies
Some device and service information are
collected through the use of cookies and
similar technologies.
*** We use your device’s push notification system (iOS or Android) to send wallet updates
regarding your wallet activity, such as transaction confirmations, security alerts, and feature
updates. Push tokens do not contain personal data and are solely used to direct notifications to
your device. To avoid push token processing, you can disable notifications in your device
settings.
2.3. Information we obtain from third parties
We will receive personal data about you from various third parties as set out below:
Information Category Description
Blockchain Data Publicly available blockchain data, including
transaction history, wallet balance, assets
held, and associated metadata, helps us
accurately reflect the activity in your wallet
and ensure the security of your operations
within the blockchain network
Transaction Data Data on transactions processed through
third-party platforms, such as exchanges or
external wallet providers, including the date,
time, and amount of the transaction
3. How we use your personal data and our legal basis
We use your personal information to develop, operate, and deliver our Services, to provide you
with a secure and efficient experience, and for our legal obligations and anti-fraud purposes.
The law requires us to have a legal basis for collecting and using your personal data.
We have outlined below, in a table format, a detailed description of the various ways we intend
to use your personal data and the corresponding legal bases we rely on for each use.
3.1. Personal Data Collected During Your Use of Our Site
Our Purpose/Use Type of Personal Data Legal Basis
To provide and maintain our
Services
Device, Usage and
Information from cookies and
similar technologies.
Legitimate Interest
To administer and protect our
business and our Site
Device and Usage Data Legitimate Interest
To manage our relationship
with you which will include
providing customer support
Contact Information Legitimate Interest
3.2. Personal Data Collected During Your Use of Our App
Our Purpose/Use Type of Personal Data Legal Basis
To manage your account
Basic Customer Data, Login
and Wallet Information
Necessary to perform our
contract with you
To provide you with our
Services
Basic Customer Data,
Customer, Wallet,
Blockchain, Transaction,
Additional information you
submit to us
Necessary to perform our
contract with you
To facilitate additional
Services offered through our
business Partners and to
enhance the user experience
(optional)
Basic Customer Data,
Supplemental Identification
Information
Necessary to perform our
contract with you
To send / receive digital
assets
Blockchain, Wallet, and
Customer Transaction
Information
Necessary to perform our
contract with you
To sign transactions via
decentralized applications
Blockchain, Wallet, and
Customer Transaction
Information
Necessary to perform our
contract with you
To determine your legal
eligibility for certain services
Basic Customer Data and
Supplemental Identification
Information
Legitimate Interest
To promote safety, security
and integrity
Basic Customer Data,
Customer Transaction,
Wallet, Device and Usage
Information
Legitimate Interest
To provide functionality,
analyse performance, fix
errors, and improve usability
and effectiveness of the
Clave Services
Technical and Usage Data
Legitimate Interest
To customize your
experience with our Services
and otherwise improve our
Services
Account and Usage Data
Legitimate Interest
To manage our relationship
with you which will include; (i)
notifying you about changes
to our Terms or Privacy
Notice and (ii) providing
costumer support.
Basic Customer, Customer
Transaction, Wallet, and
Additional Information you
submit to us.
Legitimate Interest
Product and Services
updates via App notifications
Basic Customer Data and
Device Information
Consent
4. How and why we share your personal information
We may share your personal data where necessary with the parties set out below for the
purposes for which we will use your personal data above.
● We may share your personal information with third parties that we use in connection
with the operation of our business:
(i) third-party service providers that we engage to provide IT systems, software,
cloud computing services, data storage, data analytics, and log storage services;
and
(ii) third-party service providers such as auditors, professional advisors.
● If you wish to use specific services provided by our business Partners, we may share
your personal data with them.
● We may share your personal data with any third party to whom we sell, transfer, or
merge parts of our business or assets. Alternatively, we may seek to acquire or merge
with other businesses.
● We may disclose your personal data to courts, law enforcement agencies, regulatory
bodies, and government officials when required by law or reasonably necessary for the
establishment, exercise or defence of a legal or equitable claim.
When we share information with third-party service providers in this capacity, we require them
to use your information on our behalf in accordance with our instructions, and terms and only
process as necessary for the purpose of the contract.
5. How we transfer information internationally
We want to ensure that your personal data is stored and transferred securely. In some cases,
your personal data may be transferred to countries outside the UK or the European Economic
Area (EEA). When this occurs, we ensure that appropriate safeguards are in place to protect
your data. These safeguards include Standard Contractual Clauses (SCCs) approved by the
European Commission, which ensure that your personal data receives the same level of
protection it would within the EEA or the UK.
Our primary external third-party service provider for data storage and processing is Amazon
Web Services (AWS). As a global company, AWS may transfer and store your personal data
outside the UK as part of its cloud infrastructure services. We have implemented appropriate
safeguards and contractual measures to ensure the security and protection of your personal
data during international transfers in accordance with applicable data protection laws.
6. Cookies and other tracking technologies
A cookie is a small text file placed onto your device (such as a computer, smartphone, or other
electronic device) when you use our Site. For more information about the cookies we use and
how to change your cookie preferences, please see Cookie Notice.
7. Third-party links
We do not have control over third-party websites or platforms, and they are not governed by this
Privacy Notice. If you visit third-party sites through the links we provide, the operators of those
sites may collect information from you according to their own privacy policies. Before providing
any personal data to those websites, please review their privacy policies. We do not accept any
responsibility or liability for these policies or for any personal data that may be collected through
these websites or services.
8. Data Security
We have put in place appropriate technical and organizational security measures designed to
protect your personal data against accidental, unlawful or unauthorized destruction, loss,
alteration, access, disclosure or use. We protect your personal data from potential security
breaches by implementing specific technological security measures, including encryption,
firewalls, and secure layer technology.
In addition, we limit access to your personal data to employees, agents, contractors, and other
third parties who have a legitimate business need to know. They will only process your personal
data on our instructions, and they are subject to a duty of confidentiality.
9. Data Retention
We will not retain your personal information longer than necessary to fulfil the purposes for
which the data was collected or to fulfil our legal obligations or necessary for the establishment,
exercise of defence of legal claims or resolving disputes. We may retain your personal data for
a longer period in the event of a complaint or if we reasonably believe there is a prospect of
litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature
and sensitivity of the personal data, the potential risk of harm from unauthorised use or
disclosure of your personal data, the purposes for which we process your personal data and
whether we can achieve those purposes through other means, and the applicable legal,
regulatory, accounting or other requirements.
In some circumstances you can ask us to delete your data: see paragraph 11 below for further
information.
10. Information collected from minors
Our Services are intended for general audiences and are not designed to attract children under
the age of 17 (“Minimum Age”). We do not collect personal information from children under
Minimum Age without parental consent. If you believe that a minor under the age of Minimum
Age is using our Services, please contact our support team.
11. Your privacy rights
To the extent permitted by applicable data protection laws and regulations, you have the
following rights in relation to your personal data:
● Request access to your personal data. This enables you to receive a copy of the
personal data we hold about you and to check that we are lawfully processing it.
● Request correction of the personal data 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.
● Request erasure of your personal data in certain circumstances. This enables you to
ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing,
where we may have processed your information unlawfully or where we are required to
erase your personal data to comply with local law. Note, however, that we may not
always be able to comply with your request of erasure for specific legal reasons which
will be notified to you, if applicable, at the time of your request.
● Object to processing of your personal data where we are relying on a legitimate
interest (or those of a third party) as the legal basis for that particular use of your data
(including carrying out profiling based on our legitimate interests).
● Request the transfer of your personal data to you or to a third party. We will provide to
you, or a third party you have chosen, your personal data in a structured, commonly
used, machine-readable format.
● Withdraw consent at any time where we are relying on consent to process your
personal data. 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.
● Request restriction of processing of your personal data. This enables you to ask us
to suspend the processing of your personal data in one of the following scenarios:
(i) If you want us to establish the data's accuracy;
(ii) Where you believe our use of the data is unlawful but you do not want us to erase
it;
(iii) 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
(iv) You have objected to our use of your data but we need to verify whether we have
overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us – see below ‘How to
contact us’.
You will not have to pay a fee to access your personal data (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 could refuse to comply with your request in these
circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and
ensure your right to access your personal data (or to exercise any of your other rights). This is a
security measure to ensure that personal data is not disclosed to any person who has no right to
receive it. We may also contact you to ask you for further information in relation to your request
to speed up our response.
12. Complaints
We hope we will be able to resolve any issues you may have. If you have a concern about how
we use your personal data, we would like to work with you to resolve it.
You have the right to make a complaint at any time to your local data protection authority, such
as the Information Commissioner’s Office (ICO), the UK regulator for data protection issues
(www.ico.org.uk). For a list of EEA data protection supervisory authorities and their contact
details, see here. We would, however, appreciate the chance to deal with your concerns before
you approach the relevant data protection authority so please contact us in the first instance.
13. Changes to the Privacy Notice and your duty to inform us changes
We may update this Privacy Notice from time to time. The updated version will be indicated by
an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If
we make material changes to this Privacy Notice, we may notify you either by prominently
posting a notice of such changes or by directly sending you a notification. We encourage you to
review this Privacy Notice frequently to be informed of how we are protecting your information.
It is important that the personal data we hold about you is accurate and current. Please keep us
informed of any changes to your personal data during your relationship with us, such as a new
address or email.
14. How to contact us
Questions, comments and requests regarding this Notice are welcomed and should be
addressed to Clave, Privacy Team, privacy@clave.team or send a letter to 5 Beaufort Court,
Admirals Way, London, United Kingdom, E14 9X.
Clave’s GDPR Representative acts as the EU Representative for our users and visitors residing
in the EEA. If you wish to contact your representative, you may email them at
privacy@clave.team.