This Privacy Notice explains how Clove Group Limited ("Clove Group", "we", "us") uses your personal information when you use Clove Workplace (the workplace product), including the workplace dashboard, workplace workshops, and any 1:1 sessions or follow-ups you choose to take with the Clove team.

This notice is intended for workplace users (employees who access Clove Workplace) and workplace administrators (people who administer a workplace account).

This notice does not cover the personal information processed when you use Clove’s financial guidance app as a customer. That is covered by the separate Financial Guidance App Privacy Notice (Clove Wealth Limited).

Who are we?

1. 1. Controller: Clove Group Limited ("Clove Group", "we", "us")
2. 2. Registered office address: 3rd Floor, 1 Ashley Road, Altrincham, Cheshire, WA14 2DT
3. 3. Email: help@clove.com
4. 4. ICO registration number: ZC097867

What does this notice cover?

1. 1. This notice applies when you:
2. 2.
   1. 1. access or use Clove Workplace using your work email
   2. 2. attend or register for a workplace workshop or session delivered through your employer
   3. 3. use concierge services or have any 1:1 sessions with the Clove team
3. 3. Depending on how your employer uses Clove Workplace, your employer may provide us with limited employee information to help set up access.
4. 4. If you also sign up to the Clove customer app, some information collected through Clove Workplace may be used to support your app experience as described below.

If you do not provide your personal information

1. 1. Some information is needed to set up your access to Clove Workplace and administer workplace accounts.
2. 2. If you do not provide required information (for example, a work email address), we may not be able to provide access to Clove Workplace.

Personal information we collect

The personal information we collect depends on how you use Clove Workplace and what your employer has set up. This may include:

A. Information you provide

1. 1. Account and contact details: name, work email address, and (where applicable) phone number.
2. 2. Workplace details: employer name, job title, and workplace role (for example user or administrator), where relevant.
3. 3. Salary, Pension and equity information (where relevant): if you choose to share it with us, we may collect information such as your salary, pension contribution details and stock option or equity plan details.
4. 4. Communications and interactions: messages you send to us, questions asked during workshops, and support requests.
5. 5. Booking, attendance, and engagement details: registration and attendance records for workplace workshops or sessions, and engagement and usage metrics within Clove Workplace (for example logins and content views).

B. Information we collect automatically

1. 1. Device and usage information: device identifiers, IP address, browser/app information, access logs, and activity within the workplace dashboard.
2. 2. Security information: information used to keep accounts secure and prevent fraud and misuse, for example login and authentication data.

C. Information we receive from third parties

1. 1. Employer-provided information: your employer may provide limited details to help us create or manage your Clove Workplace access (for example name, work email address, and job title).
2. 2. HR and payroll systems (employer enabled): where your employer enables it, we may receive information from your company HR and payroll provider to support the workplace service, such as your salary, pension contribution information and stock option or equity plan information.
3. 3. Workplace administration information: workplace company details and administrator contact details.

Special category data

1. 1. We do not actively request special category data (such as health information) to provide Clove Workplace.
2. 2. If you choose to share sensitive information with us (for example in a question during a workshop or in a support message), we will process it only where necessary to respond to you and in accordance with applicable law.

How we use your information

We use your personal information to:

1. 1. Provide Clove Workplace, including enabling you to access workplace content and materials.
2. 2. Administer workplace accounts, including setting up and managing workplace administrators, enrolment lists, and access controls.
3. 3. Provide engagement reporting to workplace administrators (your employer’s representatives), such as workshop attendance and usage metrics.
4. 4.
   1. 1. Workplace administrators can see the full list of attendees for a session.
   2. 2. Workplace administrators can see aggregate / anonymised engagement reporting, but not how any specific individual has engaged or interacted.
   3. 3. We do not share personal information obtained through 1:1 sessions with your employer.
5. 5. Support linked Clove products you choose to use, including sharing relevant information collected through Clove Workplace with Clove Wealth Limited if you sign up to the Clove customer app, so we can help set up your account and improve your experience.
6. 6. Deliver workplace workshops and follow-ups, including registration, attendance tracking, and sending relevant follow-up materials.
7. 7. Communicate with you, including service messages, support responses, and workshop-related updates.
8. 8. Improve and secure Clove Workplace, including troubleshooting, analytics, testing, and fraud prevention.
9. 9. Maintain records, including operational and audit records and handling complaints or disputes.

Automated decision-making and profiling

We do not make automated decisions about you that produce legal or similarly significant effects. Clove Workplace may use personalisation or content recommendations to surface relevant materials based on factors such as your role or engagement history. This does not constitute automated decision-making with significant effects and does not determine your access to products or services.

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 Clove Workplace).
2. 2.
   1. 1. For example, providing access to the workplace dashboard and delivering the service to your employer.
3. 3. Legal obligation (where processing is required by law).
4. 4.
   1. 1. For example, handling lawful requests from regulators or law enforcement and meeting record-keeping obligations.
5. 5. Legitimate interests (where processing is necessary for our legitimate interests, and those interests are not overridden by your rights).
6. 6.
   1. 1. For example, securing our systems, preventing misuse, improving the service, and measuring engagement with workplace content.
7. 7. Consent (where required).
8. 8.
   1. 1. For example, where you opt in to optional communications or features.

Who we share your information with

We share personal information with third parties where needed to provide and support Clove Workplace, including:

1. 1. Workplace administrators (your employer’s representatives), who can access engagement reporting through Clove Workplace (for example aggregated workshop attendance and usage metrics). We do not share personal employee information obtained through 1:1 sessions with workplace administrators.
2. 2. Other companies in the Clove group (including Clove Wealth Limited) where you choose to use linked products. If you sign up to the Clove financial guidance app, we may share relevant information collected through Clove Workplace to help set up and improve your app experience. For example, the data we will pass on may include your salary and pension information if you shared this with us.
3. 3. Technology and cloud providers that support our systems.
4. 4. Professional advisers and auditors.
5. 5. Regulators, law enforcement, and courts (where required by law).

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 Clove Workplace and meet our legal and regulatory obligations.
2. 2. If your employer stops using Clove Workplace, you may still be able to retain access as an individual user. In that case, we will keep your information for as long as needed to provide Clove Workplace to you.
3. 3. If you end the relationship, we will typically retain personal records for 6 years after the end of the relationship to manage disputes, enforce our terms, and meet legal obligations.

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

We may update this notice from time to time. We will post updates on this page and, where appropriate, notify you via Clove Workplace if changes are material.