Last updated at: 01.02.2024

This is the privacy policy (“Privacy Policy”) for any application or web service owned or operated provided by Clave Technologies Ltd, company registration number 15115830, with its registered office address 5 Beaufort Court, Admirals Way, London, United Kingdom, E14 9X (“our”, “we”, or “Clave”). Clave is the controller of the collected personal data and we are committed to protecting and respecting your privacy.

1. The Data we Collect from You

1.1 Personal Data

"Personal data" refers to any information that relates to an identified individual. This can include but is not limited to names, email addresses, phone numbers, physical addresses, and any other data that can be used, either alone or in combination with other information, to identify an individual. In a privacy policy, defining "personal data" is crucial for informing users about what data is being collected, how it's being used, and how it's being protected.

1.2. How and what types of data we collect from you when you use the App

We may collect, use, store and transfer different kinds of personal data about you as follows:

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

1.3.How is your personal data collected?

1.4. Sharing of your Personal Data

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

2. Third parties

We do not have control over third-party websites or platforms, and they are not governed by this Privacy Policy. 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, such as Contact and Location Data.

3. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on [DATE]. It may change and if it does, these changes will be posted on Clave’s website page and, where appropriate, notified to you by email. The new policy may be displayed on-screen, and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

4. Data retention

By law we must keep basic information about our customers for six years after they cease being customers. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

5. Data Security

All information you provide to us is stored on our secure servers. Where you have chosen a password that enables you to access the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so. 2

6. Your Legal Rights

8. International Transfers

Our main 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 of the UK as part of its cloud infrastructure services. We have implemented appropriate safeguards and contractual measures, 3 to ensure the security and protection of your personal data during international transfers in accordance with applicable data protection laws.

9. Glossary

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Description of categories of personal data

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