PRIVACY POLICY

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:

Your e-mail address;
Your Device Data, such as browser or operating system;
Marketing and Communicating Data;
Length of time on the App and time spent within certain sections;
Location Data;
Download Errors;

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?

Information you give us. This is information you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies.
Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work.

1.4. Sharing of your Personal Data

Where you have consented before the processing.
Where we need to perform a contract we are about to enter or have entered with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation

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

Request access to your personal data (commonly known as a "data subject access request"). 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. 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 (see below), 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) 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 also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processingof your personal data. This enables you to ask us to suspend the processing of your personal data 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.
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. 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.
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. We will advise you if this is the case at the time you withdraw your consent.

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

Contact Data: e-mail address.
Transaction Data: includes details about payments to and from you and details of in-App purchases.
Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting
Profile data includes your email, transaction history, your preferences, feedback and survey responses.
Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to traffic data and other communication data whether this is required for our own billing purposes or otherwise and the resources that you access.
Location Data: includes your current location disclosed by relevant technology 4

Contact Us

Email: info@clave.team