Clever Clover invests in early-stage businesses through a closed investment fund. Instead of focussing on web and digital startups, Clever Clover looks into the opportunities that innovative ideas and new business models can provide in traditional industries: it has partnered with companies in sectors such as food, travel, leisure and manufacturing.
2.0 Relevant legislation
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer (details of whom can be found in section 9.0) for clarification.
3.0 Personal information that this website collects and why we collect it
This website collects and uses personal information for the following reasons:
3.1 Site visitation tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section 6.0 below).
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
3.2 Contact forms – Gravity Forms
Should you choose to contact us using the contact form on our Contact us page, your personal data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices. Next to that, as a backup, your personal data will be stored temporarily (60 days) in this website’s secure database. This temporary backup of data is only in place so we are still be able to contact you when the email system somehow fails to send us data from the contact form. Our contact forms use the Gravity Forms plugin.
3.3 Email links
Should you choose to contact us using the contact form on our Contact us page or an email link like this one, none of the data that you supply will be stored by this website or passed to / be processed by any of the third party data processors defined in section 6.0.
3.4 Email newsletter
If you choose to join our email newsletter, the email address that you submit to us will be forwarded to MailChimp who provide us with email marketing services. We consider MailChimp to be a third party data processor (see section 6.0 below). The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.
Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.
While your email address remains within the MailChimp database, you will receive periodic (approximately three times a year) newsletter-style emails from us.
4.0 How we store your personal information
As detailed in section 3.2 above, if you submit a contact form on this website, your personal information will be stored temporarily within this website’s database. This is currently the only occasion where personal data will be stored on this website. This data is currently stored in an identifiable fashion; a limitation of the content management system that this website is build on (WordPress). In the near future we aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.
Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on this website as soon as we are able to.
5.0 About this website’s server
This website is hosted on a Transip VPS server in a twin datacenter of the The Datacenter Group in Amsterdam and Delft.
Some of the data centre’s more notable security features are as follows:
- Private property hermetically sealed by fencing
- 100+ cameras in and around the datacenters
- Sign up through secure customer portal
- ID-check upon entry
- Biometric access control in designated rooms
- Secured server racks
- 24/7/365 physical security
- All staff equipped with certificate of good conduct
- ISO certifications
All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.
More information about the data centre where this server is located you can find here.
6.0 Our third party data processors
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0. All 3 of these third parties are based in the USA and are EU-U.S Privacy Shield compliant.
7.0 Data breaches
We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
8.0 Data Controller
The data controller of this website is: CleverClover, a Dutch Private limited Company with company number (KvK / Chamber of Commerce): 56690509
Whose registered office is:
1023 BX Amsterdam
And whose operating office is:
1023 BX Amsterdam
9.0 Data Protection Officer
Mr. Mikhail Yegorov
Expert Business Development, CleverClover
10.1 Change log