Legal
Privacy policy and terms
Last updated [DATE]
Privacy policy
Who we are
This policy explains how [COMPANY LEGAL NAME] ("Clavis Sub Rosa", "we", "us") handles personal information collected through this website and in correspondence with us. We are the controller of that information. Our registered address is [REGISTERED ADDRESS].
What we collect
We collect as little as we can.
- Introduction requests. The details you send through our introduction form: your name, who introduced you, on whose behalf you write, how to reach you, and any note you choose to add.
- Correspondence. What you send us by email, message or telephone.
- Information about principals. Once a principal is accepted, the information needed to act for them. This is also governed by our engagement terms and our mutual non-disclosure agreement.
- Technical information. Our hosting provider keeps short-lived server logs, such as IP address, browser type and the time of a visit, for security and to keep the site running.
What we do not collect
This website sets no advertising or analytics cookies, runs no analytics, and loads no third-party trackers or advertising technology. We do not build profiles of visitors, and we do not sell or rent personal information, or share it for advertising.
How we use information
- To read and respond to introduction requests, including confirming the introduction.
- To provide our services to principals who have engaged us.
- To keep our systems and correspondence secure.
- To meet our legal and regulatory obligations.
Our legal bases
Where data protection law such as the GDPR or UK GDPR applies, we rely on: steps taken at your request before entering into an agreement; performance of our agreement with you; our legitimate interest in vetting introductions and running a secure, discreet service; compliance with legal obligations; and your consent where we ask for it, which you may withdraw at any time.
Who we share it with
Only those who help us operate, under strict confidentiality: our encrypted email provider, our website host and our form-processing service. When we arrange something on your behalf, we share with the relevant supplier only what is needed, and only at your instruction. We disclose information to authorities only where the law requires it.
International transfers
We act for principals worldwide, so information may be processed outside your country. Where required, we protect such transfers with recognized safeguards, such as the European Commission's standard contractual clauses.
How long we keep it
Introduction requests that do not proceed are deleted within [90] days. Records relating to principals are kept for the length of our engagement and afterwards only as long as the law requires. Server logs are kept for no longer than [30] days.
How we protect it
All correspondence is encrypted. Access to information is limited to those who need it, and every member of our team is bound by confidentiality.
Your rights
Depending on where you live, you may have the right to access, correct or delete your information; to restrict or object to how we use it; to receive a copy in a portable format; and to withdraw consent. Residents of California and other US states with privacy laws may request to know, correct or delete the personal information we hold. We will not treat you differently for exercising these rights. You may also complain to your local data protection authority.
To make a request, write to privacy@clavissubrosa.com. We may need to confirm your identity before acting on it.
Children
This website and our services are not directed at anyone under 18, and we do not knowingly collect information from them.
Changes to this policy
We may update this policy. The date at the top shows when it last changed.
Terms of use
About this website
This website is operated by [COMPANY LEGAL NAME]. By using it, you agree to these terms. If you do not agree, please do not use the site.
Information only
The website describes our private office in general terms. Nothing on it is an offer of services. Services are provided only to accepted principals, under a separate written agreement. Submitting an introduction request does not create a client relationship, and we may decline any request without giving a reason.
Our name and emblem
The name Clavis Sub Rosa, the Rose Key emblem, and the text and design of this website belong to us. You may not copy, adapt or use them without our written permission.
Using the site
You agree not to misuse the site: for example, by attempting to gain unauthorized access, interfering with its operation, or submitting false or misleading information.
No warranties
The site is provided as it is. Calendar dates and other information are given in good faith but may change, and we do not guarantee that they are complete or current.
Limitation of liability
To the fullest extent the law allows, we are not liable for any loss arising from your use of the website. Nothing in these terms limits liability that cannot be limited by law.
Links to other sites
Where we link to other websites, we are not responsible for their content or their privacy practices.
Governing law
These terms are governed by the laws of [JURISDICTION], and its courts have exclusive jurisdiction over any dispute about them.
Changes
We may update these terms. The date at the top shows when they last changed.
Contact
[COMPANY LEGAL NAME], [REGISTERED ADDRESS]. Privacy questions: privacy@clavissubrosa.com.