Last updated: March 2026 · This policy applies to CLAVE, a B2B opportunity creation consultancy operated by CLAVE GTM LTD.
This policy is a working document. Fields marked with [brackets] must be updated with your registered company details before this policy is live. We recommend having this reviewed by a UK data protection solicitor before publishing.
CLAVE is operated by CLAVE GTM LTD, a company registered in England and Wales.
We are registered with the Information Commissioner's Office (ICO) as a data controller under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
When your organisation is onboarded to CLAVE, we collect:
| Data | Purpose | Legal basis |
|---|---|---|
| Organisation name, industry, and size | To configure your GTM intelligence environment | Contract performance |
| Administrator name and email address | To create your account and provide support | Contract performance |
| Username and hashed password | To authenticate access to the platform | Contract performance |
| Billing contact and credit usage | To manage your subscription and usage credits | Contract performance / Legal obligation |
CLAVE asks you to input information about your company's go-to-market context, including:
This data contains no personal data about individuals. It describes your company's positioning and is used solely to generate GTM intelligence outputs for your team.
Legal basis: Contract performance, this data is necessary to provide the core service.
When you run a journey on a target account (a company you are prospecting), CLAVE processes:
The individuals named in intelligence briefs (e.g. a CEO or CMO at a prospect company) are business professionals acting in their business capacity. CLAVE only processes publicly available professional information about them. We do not collect, store, or process any personal or private information about individuals.
Legal basis: Legitimate interests, to provide AI-powered B2B sales intelligence using publicly available business data.
If you connect your HubSpot account, CLAVE will:
Legal basis: Contract performance and legitimate interests. You remain the data controller for your HubSpot data. CLAVE acts as a data processor in respect of any personal data accessed through the HubSpot integration.
A Data Processing Agreement (DPA) governing this relationship is available on request.
We automatically collect:
| Data | Purpose | Legal basis |
|---|---|---|
| AI token consumption per operation | To calculate credit usage and billing | Contract performance / Legitimate interests |
| Feature usage logs (which agents were run, timestamps) | To improve the platform and diagnose issues | Legitimate interests |
| Error logs | For security monitoring and debugging | Legitimate interests |
CLAVE is currently hosted on infrastructure operated by the following sub-processors. We are committed to UK data residency and are in the process of configuring all data storage to UK/EU regions.
Neon (PostgreSQL Database)
Migrating → UKUnited States (migrating to UK, eu-west-2 London)
Primary application database. Stores all account data, brain context, journey outputs, and usage logs.
Cloud Infrastructure Provider (Application Hosting)
USUnited States
Hosts the CLAVE application server. All data in transit is encrypted via TLS.
OpenAI (AI Processing)
USUnited States
Powers the AI agents (Signal Interpreter, GTM Motion Planner, Execution Agent). Input data is used solely to generate your output and is not used to train OpenAI models under the API terms.
HubSpot
EUEuropean Union (EU)
CRM integration. Your HubSpot data remains in HubSpot's infrastructure. CLAVE reads it via API and does not retain a copy.
| Data | Purpose | Legal basis |
|---|---|---|
| Account and organisation data | Duration of your subscription + 12 months | Deleted on written request after cancellation |
| Brain and ICP context | Duration of your subscription | Deleted on account closure |
| Journey outputs and intelligence briefs | Duration of your subscription | Deletable on request at any time |
| Billing and credit records | 7 years | Required by UK financial regulation (Companies Act 2006) |
| Usage logs | 12 months rolling | Auto-deleted after retention window |
| CRM data (HubSpot) | Not retained | Fetched live, not stored |
As a data subject, you have the following rights. To exercise any of them, contact us at [privacy@yourdomain.com]. We will respond within one calendar month.
Right of access
Request a copy of the personal data we hold about you (Subject Access Request / SAR).
Right to rectification
Ask us to correct inaccurate or incomplete data about you.
Right to erasure
Ask us to delete your personal data ('right to be forgotten'), subject to our legal obligations.
Right to restriction
Ask us to pause processing of your data while a dispute is resolved.
Right to data portability
Receive your data in a structured, machine-readable format.
Right to object
Object to processing based on legitimate interests. We will stop unless we can demonstrate compelling legitimate grounds.
Right to withdraw consent
Where we rely on consent as a legal basis, you can withdraw it at any time without affecting prior processing.
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the ICO within 72 hours of becoming aware, as required by UK GDPR Article 33.
CLAVE uses only essential session cookies required for authentication and to maintain your login state. We do not use advertising, analytics, or tracking cookies. No cookie consent banner is required for essential cookies under the UK Privacy and Electronic Communications Regulations (PECR).
CLAVE may display information sourced from publicly available third-party websites (e.g. news articles, company announcements). We are not responsible for the privacy practices of those third parties. Links to external sites are provided for reference only.
For any questions about this policy, to exercise your rights, or to request a Data Processing Agreement, contact us:
If you are not satisfied with how we handle your request, you have the right to lodge a complaint with the UK supervisory authority:
Information Commissioner's Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
0303 123 1113
We may update this policy from time to time. When we make material changes, we will notify account administrators by email and update the "last updated" date at the top of this page. Continued use of CLAVE after notification constitutes acceptance of the updated policy.
© 2026 CLAVE GTM LTD. All rights reserved.