This Privacy Notice explains how Clove Wealth Limited ("Clove Wealth", "we", "us") uses your personal information when you use the Clove mobile app during our pre-authorisation period.

During this period, Clove Wealth is not authorised by the Financial Conduct Authority (FCA). We do not provide regulated financial advice. We provide financial guidance and tools to help you understand your finances.

Who are we?

1. 1. Controller: Clove Wealth Limited ("Clove Wealth", "we", "us")
2. 2. Trading name: Clove
3. 3. Registered office address: 3rd Floor, 1 Ashley Road, Altrincham, Cheshire, WA14 2DT
4. 4. Email: help@clove.com
5. 5. ICO registration number: ZC097882

What does this notice cover?

1. 1. This notice applies when you use the Clove app for financial guidance (for example guidance content and tools).

If you do not provide your personal information

1. 1. Some information we request is needed to set up and secure your account.
2. 2. If you do not provide required information (for example your contact details), we may not be able to provide access to the app.

Personal information we collect

The personal information we collect depends on how you use the app. This may include:

A. Information you provide

1. 1. Identity and contact details: name, email address, phone number, and (where relevant) date of birth and address.
2. 2. Financial information: information you choose to provide in the app, such as income, assets, liabilities, expenditure and goals.
3. 3. Communications and records: messages, emails, call notes (if any), and records of guidance interactions.

B. Information we collect automatically

1. 1. App and device information: device identifiers, IP address, app activity logs, and diagnostic data.
2. 2. Security information: information used to keep accounts secure and prevent fraud and misuse.

C. Information from third parties (only where enabled)

1. 1. Information from Clove Workplace (where you also use Clove Workplace): if you sign up to the Clove customer app, we may receive certain information collected through Clove Workplace to help set up and improve your app experience, for example your salary and pension information if you shared this with us.
2. 2. Email inbox connectivity (Gmail): if you choose to connect your Gmail email account, we may access and process information in your mailbox to help you complete your profile and provide guidance.
3. 3.
   1. 1. Purpose: to help you complete your profile more quickly and accurately by identifying and extracting financial information from relevant emails and attachments (which we then surface to you for review).
   2. 2. Scope of access: we request read access to your mailbox so that we can read relevant email content and attachments.
   3. 3. Lookback period: we currently run searches over email content from within the last 2 years.
   4. 4. What we do with it: we run queries to identify and extract information relevant to your financial position (for example salary, bank accounts, investments, properties, mortgages and pensions).
   5. 5. What we store: we do not store raw email messages. Instead, we store:
   6. 6.
      1. 1. the extracted financial data as a "proposed change" that we show you in the app
      2. 2. source metadata about where that proposed change came from (for example an email identifier, the date of the email, the sender domain, and a confidence score)
   7. 7. Your control: we will show you what we have found so you can review it and approve or reject each proposed change.
   8. 8. Consent and disconnecting: we will only access your Gmail inbox if you choose to connect it. You can disconnect your Gmail account at any time in the app.
   9. 9. Access controls:
   10. 10.
       1. 1. Clove staff and contractors are not permitted to access or read the contents of your full mailbox
       2. 2. support staff may be able to view proposed changes (including rejected items) in order to help resolve customer support issues
   11. 11. No other use: we will not use your email data for any other purpose.

Special category data

1. 1. We do not require special category data (such as health information) to provide the app.
2. 2. If you choose to share sensitive information with us (for example health or support needs information), we will use it only as needed to provide appropriate support, and we will apply appropriate safeguards.

How we use your information

We use your personal information to:

1. 1. Provide the app and financial guidance features, including helping you understand and organise your financial information.
2. 2. Help you complete your profile using connected email (where enabled), including showing you proposed changes for review.
3. 3. Link your Clove Workplace and customer app experiences (where you choose to use both), including using information from Clove Workplace to help set up your account and improve your experience in the app.
4. 4. Communicate with you, including service messages and support responses, including handling complaints.
5. 5. Improve and secure the service, including testing, troubleshooting, analytics, and fraud prevention.
6. 6. Maintain records, including operational and audit records, and to handle complaints or disputes.

Lawful basis of processing

Under UK data protection law, we must have a lawful basis to use your personal information. We may rely on one or more of the following bases, depending on what we are doing:

1. 1. Contract (where processing is necessary to provide the app features you request).
2. 2. Legal obligation (where processing is required by law such as co-operating with the police or regulators or to prevent illegal activities).
3. 3. Legitimate interests (where processing is necessary for our legitimate interests, and those interests are not overridden by your rights).
4. 4.
   1. 1. For example, securing our systems, preventing misuse, improving the service, and understanding how the app is used.
5. 5. Consent (where required).
6. 6.
   1. 1. For example, where you choose to connect your Gmail account or provide us with sensitive data.

Who we share your information with

1. 1. We share personal information with third parties where needed to provide and support the app, including our technology and cloud providers.
2. 2. We may also share information with professional advisers and auditors, and with regulators, law enforcement, or courts where required by law.
3. 3. We do not sell your personal information or share your data with any third parties for marketing purposes.

International transfers

1. 1. Some suppliers may process personal information outside the UK and/or the EEA.
2. 2. Where we transfer personal information internationally, we use appropriate safeguards, such as UK adequacy decisions and approved contractual protections.

How long we keep your information

1. 1. We keep personal information for as long as necessary to provide the service and meet our legal and regulatory obligations.
2. 2. This typically includes retaining customer records for 6 years after the end of the customer relationship.

Your rights

Under UK data protection law, you have the right to:

1. 1. access your personal information
2. 2. correct inaccurate personal information
3. 3. request deletion
4. 4. restrict or object to processing
5. 5. request a copy of your data
6. 6. withdraw consent (where we rely on consent)

To exercise your rights, contact us at help@clove.com. We may need to verify your identity before responding.

You also have the right to complain to the UK data protection and information regulator, the Information Commissioner’s Office (ICO).

How to make a complaint

1. 1. If you have a complaint about how we use your personal information, please contact us at help@clove.com and we will do our best to resolve it.
2. 2. You can also complain to the ICO. We ask that you contact us first so we have an opportunity to address your concern.

Changes to this notice

1. 1. We may update this notice from time to time.
2. 2. We will post updates on this page and, where appropriate, notify you in the app or by email if changes are material.