Draft pending legal review
Items in brackets are not filled in yet. This policy describes how Clamp works today and will be finalised before general availability.
Who we are
Clamp is a crypto sub-ledger for finance teams, operated by [Company legal name], [registered address], registered under [company number and register] ("we", "us"). For personal data about our own users and visitors we are the controller. You can reach us about privacy at [privacy contact email].
Data we collect
| Category | What it includes | Where it comes from |
|---|---|---|
| Access requests | Name, work email, company, role, number of wallets, your optional note | The request access form |
| Account data | Name, email address, company membership, role, password hash, authenticator app secret | You, or the administrator who invites you |
| Sign-in records | Time of sign-in and sign-out, failed attempts, IP address, browser | Our sign-in service when you use it |
| Activity records | Changes you make in Clamp (settings, period locks, users, exports), with your name and the time | Your use of the application |
| Server logs | IP address, requested address, time, response status | Every request to our servers |
| Website visits | Page, referring site, browser, device type, country; no IP address and no cookies | Our self-hosted analytics (Umami) when you browse this website |
We do not collect payment card data, government identifiers or special categories of personal data.
How we use it
- To review access requests and contact you about them.
- To create and secure your account, including two-factor sign-in and locking an account after repeated failed attempts.
- To provide the service: show your company's books to the people your company has authorised, and record who changed what.
- To keep the service secure and available: detect abuse, investigate incidents, enforce rate limits.
- To meet legal obligations.
We do not sell personal data, do not use it for advertising and do not use it to train machine learning models.
Legal bases
Where the EU or UK General Data Protection Regulation applies, we rely on: performance of a contract (providing accounts and the service), our legitimate interests (reviewing access requests, securing the service, keeping an audit trail that your company and its auditors rely on), and legal obligations (keeping records the law requires).
Data in your books
The wallet addresses, transactions, balances, prices and reports your company keeps in Clamp belong to your company. For that data we act on your company's instructions as its processor, under [Company legal name]'s data processing terms with your company. Most of it is public blockchain data; it can become personal data when an address is linked to a person.
Each company's records are kept in a separate database. API keys you store are encrypted with AES-256-GCM and can only be decrypted for the company they belong to.
Service providers
| Provider | Purpose | Data they receive |
|---|---|---|
| Hetzner Online GmbH, Germany | Servers, storage and backups | All data stored in Clamp, encrypted in transit |
| Blockchain data providers: Etherscan, Routescan, mempool.space, TronGrid, Toncenter, a Solana RPC provider, an XRP Ledger node operator | Reading transaction history and balances | The wallet addresses being synced, without names or account data |
| Market data providers: Coinbase, Bitfinex, Bitstamp, Binance, KuCoin, OKX, CoinGecko, Gate.io | Asset prices | Asset symbols and dates only, no personal data |
| [Email delivery provider] | Invitation and password emails | Name and email address |
Where data is stored
Clamp's servers and backups are in Germany, in the European Union. Some blockchain data providers listed above may be located outside the European Economic Area; they receive wallet addresses only. Where a transfer of personal data outside the EEA is needed, we use [transfer safeguard, for example Standard Contractual Clauses].
How long we keep it
| Data | Kept for |
|---|---|
| Access requests that are declined | [period, for example 12 months] |
| Account data | While the account exists, then deleted within [period] |
| Sign-in records | 1 year |
| Activity records (audit log) | For as long as your company keeps its books in Clamp, because they form part of its audit trail |
| Server backups | 7 days, then overwritten |
| Server logs | [period] |
| Website visit statistics | [period, for example 24 months] |
Security
Every user signs in with a password and an authenticator app. Connections are encrypted. Each company has its own database, and the application's database role cannot change table structure or rewrite activity records. Servers accept administrative access only by key from known addresses, and we apply security updates automatically.
Cookies and analytics
This website sets no cookies and loads nothing from third parties: no advertising, no embedded fonts or scripts from other domains. We count visits with Umami, which we run on our own server: it uses no cookies, does not store IP addresses (an address is turned into an anonymous identifier that changes every day) and records the page, referring site, browser, device type and country. Visitors whose browser sends a Do Not Track signal are not counted. When you sign in to the application, our sign-in service sets cookies that keep your session; they are strictly necessary and expire when the session ends or after at most 10 hours.
Your rights
Depending on where you live, you can ask us for access to your personal data, correction, deletion, restriction of processing, a copy in a portable format, or object to processing based on legitimate interests. Write to [privacy contact email]; we answer within one month. If the data is part of your company's books, we will pass your request to your company, which decides on it. You can also complain to a data protection authority, for example [competent supervisory authority].
Changes
We will update this page when our processing changes and change the date at the top. Material changes are announced to account holders by email before they apply.
Contact
[Company legal name], [registered address]. Email: [privacy contact email].