Privacy
Policy

Who We Are

Clavis (“Clavis”, “we”, “us”, “our”) is operated by Clavis Properties Ltd, a company registered in England and Wales. Our registered office address and ICO registration details are available on request.

Clavis operates as a deal principal in the UK property market. We acquire contractual interests in distressed property assets via formal Option Agreements negotiated with company directors, insolvency practitioners and liquidators, and subsequently assign those interests to verified cash buyers. We are not an estate agent, introducer or financial adviser.

For the purposes of the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, Clavis Properties Ltd is the data controller in respect of any personal data we process in connection with our activities.

How We Obtain Personal Data

We collect personal data through the following routes:

• Directly from you — when you submit an enquiry via our website contact form, email us, call us, or respond to our outreach.
• Publicly available sources — including UK Companies House filings, The London Gazette insolvency notices, HM Land Registry title registers, and the Insolvency Service register. We use these sources to identify company directors and appointed insolvency practitioners in connection with distressed property assets.
• Professional referrals — from solicitors, accountants, insolvency practitioners or other advisors who have your consent or a legitimate professional basis to make introductions.
• Our investor register — when verified cash buyers register their acquisition criteria with us.

Where we contact you as a company director or insolvency practitioner using publicly available information, we do so on a business-to-business basis under Article 6(1)(f) UK GDPR (legitimate interests). We will always identify ourselves clearly in any such communication and provide an easy route to opt out.

What Data We Collect

Depending on your relationship with Clavis, we may collect:

We do not knowingly collect special category data (health, race, religion, etc.) and request that you do not include such information in any correspondence or form submission.

How We Use Your Data

We use personal data for the following purposes:

• To assess, negotiate and execute Option Agreements on distressed property assets
• To package and present controlled deal opportunities to our verified buyer register under NCNDA terms
• To facilitate the assignment of our contractual interest to a cash buyer
• To verify the identity and financial credentials of prospective buyers
• To communicate with company directors, insolvency practitioners and their professional advisors in connection with specific assets
• To respond to and manage inbound enquiries submitted via our website or other channels
• To maintain our buyer register and match buyers to opportunities that meet their stated criteria
• To comply with our legal and regulatory obligations, including NAPSA membership requirements
• To improve our website and monitor usage via anonymised analytics

We will not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects without your explicit consent.

Lawful Basis for Processing

We rely on the following lawful bases under Article 6 UK GDPR:

Where we rely on legitimate interests, we have conducted a balancing test and are satisfied that our interests are not overridden by your rights, particularly given the B2B context of our operations and the use of publicly available professional information.

NCNDA & Deal Confidentiality

All deal opportunities presented by Clavis to prospective buyers are shared under a Non-Circumvention, Non-Disclosure Agreement (NCNDA). By accepting a deal pack from Clavis, recipients agree that the information contained therein is confidential and may not be used to circumvent Clavis’s contractual interest.

Personal data contained within deal packs — including the names and contact details of company directors, insolvency practitioners or other relevant parties — is shared solely for the purpose of facilitating the assignment of Clavis’s Option Agreement interest. Recipients of deal packs may not use this data for independent contact or any purpose outside the terms of the NCNDA.

Who We Share Data With

We do not sell, rent or trade personal data. We may share data with:

• Verified cash buyers — to facilitate the assignment of an Option Agreement, under NCNDA terms
• Solicitors and conveyancers — where a transaction is progressing and legal instruction is required
• Insolvency practitioners and their firms — in connection with the acquisition and negotiation of a specific asset
• NAPSA — as required by our membership obligations and professional code of conduct
• IT and software service providers — including Formspree (form processing) and any CRM or secure file-sharing tools we use to manage our pipeline; all are subject to appropriate data processing agreements
• Professional advisors — including lawyers and accountants, where required in the ordinary course of business, under duties of confidentiality
• Law enforcement or regulators — where required by law or to protect our legal rights

All third parties with whom we share personal data are required to handle it in accordance with applicable data protection law.

International Transfers

Clavis is based in the United Kingdom. Where we use third-party service providers that process data outside the UK or European Economic Area (for example, US-based SaaS tools), we ensure that appropriate safeguards are in place — such as the UK International Data Transfer Agreement (IDTA), Standard Contractual Clauses, or reliance on an adequacy decision.

You may request details of any international transfers and the safeguards applicable by contacting us at info@clavis.properties.

Retention

We retain personal data only for as long as necessary for the purposes for which it was collected:

At the end of the relevant retention period, data is securely deleted or anonymised. You may request early deletion subject to any overriding legal obligations — see Section 10 below.

Your Rights

Under UK GDPR, you have the following rights in relation to your personal data:

• Right of access — to receive a copy of the personal data we hold about you (Subject Access Request)
• Right to rectification — to have inaccurate data corrected without undue delay
• Right to erasure — to request deletion of your data where there is no overriding legal basis for retention
• Right to restriction — to request that we limit processing of your data in certain circumstances
• Right to data portability — to receive your data in a structured, machine-readable format where processing is based on consent or contract
• Right to object — to object to processing based on legitimate interests, including any B2B outreach
• Rights in relation to automated decision-making — we do not carry out solely automated decision-making that produces legal or significant effects

To exercise any of these rights, please contact us at info@clavis.properties or write to our registered office. We will respond within one calendar month. We may need to verify your identity before processing your request.

To opt out of business-to-business outreach specifically, please email optout@clavis.properties with your name and company. We will remove you from our active outreach list promptly and retain a record of your preference to ensure you are not re-contacted.

Cookies

Our website uses a minimal number of cookies. We do not use third-party advertising or tracking cookies.

You can control or disable cookies via your browser settings at any time. Disabling strictly necessary cookies may affect the functionality of the contact form.

Security

We take data security seriously. Appropriate technical and organisational measures are in place to protect personal data against unauthorised access, loss, destruction or disclosure. These include:

• Encrypted transmission of data via HTTPS across all pages
• Access controls limiting personal data to authorised personnel only
• Secure, password-protected storage for deal documentation and buyer records
• Regular review of third-party service providers for compliance with data security standards

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner’s Office (ICO) within 72 hours and inform affected individuals without undue delay, as required by UK GDPR.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our operations, applicable law, or regulatory guidance. When we make material changes, we will update the “Last updated” date at the top of this page.

Where changes are significant and you are an active member of our buyer register or a party to an ongoing transaction, we will notify you directly by email. Continued engagement with Clavis following an update constitutes acceptance of the revised policy.

We encourage you to review this page periodically. Previous versions of this policy are available on request.

Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise your data protection rights, or have a concern about how we have handled your personal data, please contact us in the first instance:

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s independent data protection supervisory authority: