Privacy policy

1. Definitions

Personal data: any information relating to an identified or identifiable natural person.

Data subject: the natural person to whom the personal data relate.

Processing: any operation performed on personal data, including collection, recording, storage, use, disclosure and erasure.

Controller: the person which determines the purposes and the means of the processing of personal data.

Processor: the person which processes personal data on behalf of and on the instructions of the controller.

2. The controller

The controller which independently determines the purposes and means of the processing of personal data is Clavena (the Controller).

Requests from data subjects concerning the processing of their personal data shall be addressed to hello@clavena.co.

3. Processing in connection with use of the site

The site contains no personal data collection forms. Cookies and equivalent technologies, web analytics systems and visitor counters are not employed. Fonts and images are hosted on the same resource, and accordingly access to the pages does not cause requests to be issued to third-party services.

On each request to the site, the server on which it is hosted records in its log the IP address, the date and time of the request, the resource requested and the type of browser. Those records are processed for the purposes of ensuring the operation and the security of the site; the legal basis is the legitimate interest of the Controller.

4. Processing in connection with correspondence

In an enquiry addressed to the Controller, the Controller receives the information which the data subject has chosen to include in the message, as a rule a name, an email address, the name of an organisation and a description of the circumstances.

The processing is carried out for the purposes of considering the enquiry, conducting pre-contractual negotiations and preparing a proposal; the legal basis is the taking of steps at the request of the data subject prior to entering into a contract. Where an enquiry does not result in a contract, the legal basis is the legitimate interest of the Controller in providing a reply to the person who has made contact.

No mailings are carried out. Personal data are not sold and are not transferred for the purposes of third parties.

5. Recipients of personal data

The Controller engages a third-party email service provider and a third-party hosting service provider, which act as processors on the instructions of the Controller under data protection agreements. The identities of those providers are disclosed upon request.

Personal data are not disclosed to any other person, save where the obligation to disclose is imposed by applicable law.

6. Retention periods

Correspondence which has not resulted in a contract is retained for 24 months from the date of the last message and is thereafter deleted; deletion from backup copies is completed within 30 days.

Correspondence and documents relating to contracts concluded are retained for the term of the contract and for the subsequent period required by the contract and by applicable record-keeping rules.

Server logs are retained for the periods applied by the hosting service provider.

7. Rights of the data subject

The data subject is entitled to be informed of the processing of their personal data, to obtain access to those data, to require their rectification or erasure, to require the restriction of the processing, to object to the processing, and to receive the data in a structured, machine-readable format.

A request for the exercise of these rights shall be addressed to hello@clavena.co. A reply is provided within one month of receipt of the request.

The data subject is further entitled to lodge a complaint with the supervisory authority for the protection of personal data of the country of residence, of the place of work, or of the place of the alleged infringement.

8. Amendment of this document

The Controller is entitled to amend this document. The version in force is published on this page and the date of that version is stated at the head of it.