1.1  This Privacy Policy explains how Clavana LLC (“Clavana”, “we”, “our”, “us”) collects, uses, and protects the personal data of individuals (“Users”) who access the Clavana website (the “Website”) or use Clavana’s services (the “Services”).

1.2  By using the Website or Services, you acknowledge that you have read and understood this Privacy Policy.

•  "User”: Any individual or entity accessing or using the Website or Services.

• “Client”: A User who has entered into a contract with Clavana for Services.

• “Services”: Clavana’s deal origination and introduction services.

• “Personal Data”: Any information relating to an identified or identifiable individual.

• “Contract”: Any engagement agreement between Clavana and a Client.

3.1  Clavana may but is not limited to, collecting the following categories of Personal Data:

• Identity & Contact Data: Name, email, phone number, job title, organisation, etc.

• Professional & Financial Data: Role, organisation details, billing information, investment preferences.

• Marketing & Communications Data: Preferences regarding communications and marketing.

• Technical & Usage Data: IP address, device type, browser type, login location, Website interactions, cookies.

​3.2  Clavana does not knowingly collect data relating to children under 18 and does not process Special Category Data (e.g. race, religion, biometric, or criminal data).

4.1 Personal Data is primarily provided directly by Users and Clients, for example when:

• Visiting or contacting us via the Website;

• Completing the Website contact form;

• Attending meetings, calls, or events with Clavana;

• Providing details to set up a Contract;

• Communicating via LinkedIn, email, or telephone.

4.2  We may also receive Personal Data indirectly from trusted third-party partners where individuals have consented to data sharing or where we have a legitimate interest.
4.3  The Website automatically collects Technical Data such as cookies, IP address, and usage statistics. See our Cookie Policy for more details. 

5.1  Clavana processes Personal Data for the following purposes:

• To provide and improve the Services;

• To communicate with Users and Clients;

• For marketing (with consent or legitimate interest, with opt-out available at any time);

• To comply with legal or regulatory obligations;

• To investigate unlawful or suspicious activity

5.2  Meeting recordings may occasionally be made with notice and consent. Recordings may capture video, audio, and shared content.

Clavana may share Personal Data with: 

• Other Clavana group entities;

• IT, CRM, and cloud service providers (e.g. Salesforce, HubSpot, Microsoft, Dropbox, QuickBooks, DocuSign);

• Professional advisors (e.g. lawyers, insurers, auditors);

• Marketing service providers;

• Regulators, courts, or law enforcement where required by law;

• Potential purchasers or investors in the event of a business transaction;

• Any party with the User’s explicit consent.

6.2   We ensure that any third party receiving Personal Data processes it securely and in compliance with this Privacy Policy.

7.1  Clavana relies on the following lawful bases under UK GDPR:

• Consent: where you have given explicit consent (e.g. for marketing).

• Contract: where processing is necessary to perform a Contract.

• Legitimate Interest: where processing is required for our business operations and does not override your rights.

• Legal Obligation: where processing is required to comply with laws.

8.1  Clavana retains Personal Data only as long as necessary to provide Services or meet legal/regulatory requirements.

8.2  We apply technical and organisational security measures including encryption, access controls, and regular reviews.

8.3  Data may be anonymised for statistical purposes and retained indefinitely.

9.1  Personal Data may be transferred outside your home jurisdiction, including between the United Kingdom, the European Economic Area (“EEA”), and the United States.

9.2  (UK/EEA clients) Where Personal Data is transferred from the UK or EEA to a country not recognised as providing adequate protection (e.g. the United States), Clavana ensures appropriate safeguards are in place, such as the UK/EU Standard Contractual Clauses or other lawful transfer mechanisms.

9.3  (US clients) Where Personal Data is transferred from the United States to the UK or EEA, such transfers are handled in accordance with applicable US federal and state privacy laws and with appropriate contractual safeguards.

9.4  For further details on the safeguards in place, please contact info@clavana.com

10.1  Clavana may revise these Terms from time to time. Material changes will be communicated to Users.
10.2  Continued use of the Website or Services following any updates constitutes acceptance of the revised Terms.

11.1  Under UK GDPR, you have the right to:

• Access your Personal Data;

• Request correction or completion;

• Request erasure;

• Restrict or object to processing;

• Request data portability.

11.2  You may withdraw consent at any time where consent is the basis of processing.
11.3  Requests can be submitted to info@clavana.com and will be responded to within one month.

12.1  Clavana may update this Privacy Policy periodically. Material changes will be communicated via the Website.
12.2  Users should ensure their Personal Data held by Clavana is accurate and up to date.

13.1  If you have concerns about our handling of your Personal Data, please contact us at info@clavana.com in the first instance.

13.2  (UK clients) Under the UK GDPR, you also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO):

• Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

• Helpline: 0303 123 1113

• Website: https://ico.org.uk

13.3  (US clients) If you are based in the United States, any concerns regarding data protection may be directed to the Federal Trade Commission (FTC):

• Address: Federal Trade Commission, 600 Pennsylvania Avenue, NW, Washington, DC 20580

• Helpline: +1 202-326-2222

• Website: https://www.ftc.gov

​Clavana LLC, United States