Clave Technologies Ltd. (“Clave,” “we,” or “us”) is committed to protecting your privacy. 

This Privacy Notice (“Notice”) describes how we collect, use, disclose and safeguard your personal information when you access and use our digital interfaces, including our mobile app (the “App”) and  our website https://getclave.io/  (“Site”), or when you sign up for and access our services (“Services”).

Your use of our App and Services is subject to our Terms of Use, which govern your rights and responsibilities when acessing our offerings.

We encourage you to read this Notice carefully to understand how we handle your personal information. If you have any questions, concerns, or wish to exercise your data rights, please refer to the contact details provided at the end of this Notice.

Key Information

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 is the data controller of the personal information we collect about you, meaning we determine the purposes and means of processing your personal information when you use our Services and App. 

  
  

• When you use third-party services integrated into our App, those providers operate as independent data controllers, which means their own privacy policies govern how they process your information. In these cases, Clave acts solely as a data processor, securely transferring your verification data to these providers based on their instructions and in compliance with applicable regulations. For further details, please refer to Section 6 – Third-Party Services.

  
  

• We collect and process personal information for specific purposes, such as providing and improving our services, ensuring security, facilitating interactions with third-party providers, offering customer support, and complying with legal obligations. A detailed explanation of these purposes is available in Section 4 – Why We Use Your Personal Information.

  
  

• Your personal information may be shared with trusted third parties and service providers as necessary to deliver our services and meet legal requirements. Further details on data sharing practices are outlined in Section 3 – How and Why We Share Your Information.

  
  

• As a user, you have rights over your personal data under applicable data protection laws. To learn more about your rights and how to exercise them, please refer to Section 7 – Your Data Rights.

  
  

1. What Personal Information Do We Collect And How We Collect It?

As further described below, we collect personal information directly from individuals, from third parties, and automatically through your use of our App and Services.

1.1. Personal information collected directly from you

The personal information we may collect from you depends on how you use our Services and App. 

* Many of Clave’s core Services can be used without providing personal information. We employ passwordless authentication, ensuring that your credentials are securely stored on your device and never shared with us.

1.2. Information collected automatically

When you interact with our Site or App, we may automatically collect certain device and usage data. Additionally, we use cookies and similar tracking technologies to enhance security and improve functionality.

1.2. Information collected automatically

We may collect personal data from various third-party providers to facilitate integrations, enhance security, and improve our Services.

2. How Do We Use Your Personal Information.

We use your personal information to deliver, operate, improve, develop and personalise our Services, to provide you with a secure and smooth experience as you use them, and for legal compliance and loss prevention purposes. Learn more about how we use your personal information and our legal basis for each such data use:

2.1. Data Use Necessary to Contact with You

2.2. Data Use to Comply with a Legal Obligation

2.3. Data Use for Our Legitimate Interests

2.4. Data Use Based on Your Consent

Some features require your consent. If you enable device-based settings, we may access your photos, media, or camera for specific features, which you can manage in your device settings. For marketing communications, we use your preferences to send relevant updates, and you can withdraw consent anytime through your account settings, by contacting us, or by clicking “unsubscribe” in our emails.

3. How Do We Share Your Personal Information?

We may share your personal data with the following parties where necessary to provide our Services and for the purposes outlined in this Notice:

Third-Party Service Providers: We work with third-party service providers to operate and improve our Services, including:

• Electronic ID Verification Service Providers (AiPrise);

• Data hosting service providers;

• Analytics providers to enhance performance and usability; and

• Security service providers.

When we share information with third-party service providers, 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.

Integrated Third-Party Services: If you connect your account with third-party services such as Onramp Money or Rain Card, we may share the necessary data to enable these integrations. If you wish to use these third-party services, we encourage you to review Section 6 – Third-Party Services for more details on how your data is processed.

Business Transaction: We may share and/or transfer your personal information as part of a business transaction, such as a merger, acquisition, sale of assets, reorganisation, or other change of control. This includes situations where we are acquired, enter bankruptcy, or undergo a restructuring, in which case your personal information may be transferred to the acquiring entity or relevant third parties involved in the transaction.

Legal & Regulatory Compliance: 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.

4. Where Do We Transfer Your Personal Data To?

In some cases, we may transfer or store your personal data outside the UK, the European Economic Area (EEA), or Switzerland to provide our Services effectively. These transfers are necessary to ensure that our global infrastructure and third-party service integrations work seamlessly

We always ensure that any transfers of your personal data comply with applicable data protection laws. Depending on the destination country, we rely on the following safeguards:

• Adequacy Decisions: Where possible, we transfer data to countries that have been officially recognised by the European Commission or the UK government as having adequate data protection laws.

• Standard Contractual Clauses (SCCs): We use SCCs approved by the European Commission and the UK Information Commissioner’s Office (ICO) to ensure that your personal data receives a high level of protection, even when transferred outside the EEA or UK.

• In some cases, we may rely on specific legal exemptions under data protection laws for international transfers.

Our primary cloud storage and processing provider is Amazon Web Services (AWS). As a global cloud provider, AWS may store your personal data in data centres outside the UK. We have implemented appropriate safeguards to ensure the security and protection of your personal data during international transfers in accordance with applicable data protection laws.

5. Cookies And Similar Tracking Technologies

We use cookies and similar tracking technologies to automatically collect information about your browsing activity, device type, and interactions with our Site and Services. These technologies serve several purposes, including enhancing functionality and performance by analysing how our Site and Services are used and remembering your preferences to provide a more personalized experience. For more information about the cookies we use and how to change your cookie preferences, please refer to our Cookie Notice.

6. Third-Party Platforms

Some features within the Clave App allow users to access integrated third-party services, such as Onramp Money and Rain Card. These third-party providers operate independently of Clave and are governed by their own terms and privacy policies. When you engage with these services, their privacy policies apply to your use of their services and explain how your data is collected, used, and stored.

Certain third-party services, such as Onramp Money and Rain Card, require Know Your Customer (KYC) verification for legal and regulatory compliance. To streamline this process, Clave has integrated AiPrise, a third-party identity verification provider (Please see AiPrise Privacy Policy).

If you choose to access Rain Card or Onramp services via Clave, the KYC verification process takes place within the Clave App through AiPrise. Once verification is completed, the results—including Supplemental and Electronic Identification Information—are securely transferred to the relevant third-party provider (Rain Card or Onramp) to meet their compliance obligations. Clave does not impose KYC requirements for its own Services. KYC verification is only required when accessing regulated third-party services such as Onramp Money and Rain Card.

Clave does not control how these third parties process your data. Clave acts solely as a data processor, facilitating data transfers as required by the provider to deliver its services. For more details, please refer to the RainCard Terms and Privacy Policy, and Onramp Money Privacy Policy. 

7. 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.

8. How Long We Retain Your Personal Information For?

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 Section 10 – What Rights Do You Have Over Your Personal Data? for further information.

9. 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.

10. What Rights Do You Have Over Your Personal Data?

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:

  1. If you want us to establish the data's accuracy;

  2. Where you believe our use of the data is unlawful but you do not want us to erase it;

  3. 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

  4. 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 – Section 13 – 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 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 you for further information in relation to your request to speed up our response.

10. How To Lodge A Complaint With Your Data Protection Authority?

We hope we will be able to resolve any issues you may have. If you have a concern about how we use your personal information, 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.

11. Changes To The Privacy Notice

We keep our Privacy Notice under regular review. It is important that the personal information we hold about you is accurate and current. Please keep us informed of any changes to your personal information during your relationship with us, such as a new address or email.

12. How To Contact Usd

Questions, comments, and requests regarding this Privacy Notice are welcomed and should be addressed to our Privacy Team privacy@clave.com 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 Nur Baki Er at baki@clave.team.