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Clanmark Privacy Policy

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Last updated: 1 September 2025

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This policy explains how Clanmark (“we”, “us”, “our”) processes your personal data when you use our website, app and related services (the “Services”). It is written to comply with the UK GDPR and Data Protection Act 2018, and—where applicable—the EU GDPR and certain U.S. state privacy laws. It does not constitute legal advice.

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Clanmark is a trust-first, invite-only classifieds network where users join with sponsors and can see how they’re connected to others (our “trust graph”). These features are integral to how we process data.

1) Who we are & how to contact us

Controller:
CLANMARK LTD
39 Long Acre, London, Greater London, England, WC2E 9LG

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Email: contact@clanmark.com

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Data Protection Officer: Not appointed.

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EU Representative (if required): We will update this policy if/when an EU Representative is appointed.

2) Scope

This policy applies to:

  • The Clanmark website and web app.
  • Any mobile apps or web features we operate.
  • Customer support, marketing communications, research and events.

3) Personal data we collect

3.1 Data you provide

  • Account & profile: name, email, phone, password, profile photo, biography, location you choose to show, professional/affiliation details, Clan memberships.
  • Sponsorship & trust graph: your sponsors, who you sponsor, connection paths and degrees, endorsements, referrals and related appeals.
  • Listings & transactions: listing content (text, photos, video), categories, prices, availability, locations you specify, service area, calendars, messages, offers, counter-offers, booking/rental details, reviews & ratings, disputes.
  • Identity & safety checks (where required or optional): verification selfies, ID documents/metadata (processed by our verification provider), proof of address, sanctions/PEP screening results, fraud signals.
  • Payments: via third-party processors; we receive limited tokens and status data (e.g., last 4 digits, payment method brand, success/fail, refunds, chargebacks). We do not store full card numbers.
  • Communications: emails, in-app messages, support tickets, recorded consent/withdrawals, feedback forms.
  • Referrals & contact import (optional): when you invite others we process the recipient’s contact details and message content. You must only share contacts if you have a lawful basis to do so.

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3.2 Data collected automatically

  • Usage & device: IP address, device identifiers, browser/OS, language, time zone, user agent, pages/screens viewed, clicks/taps, session duration, referring/exit pages, app version, crash logs.
  • Approximate location: derived from IP or device settings (if you allow).
  • Cookies/SDKs: essential cookies for security and sign-in; optional analytics/marketing cookies/SDKs (see §11).

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3.3 Data from others

  • Other users: sponsorships, invitations, reports, reviews, messages, and connection data about you.
  • Service providers/partners: identity and anti-fraud signals, payments, analytics, communications delivery and reliability data.
  • Public sources: information relevant to listing or identity verification (e.g., property or business registers).

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3.4 Special category data

Some Clans may reveal sensitive attributes (e.g., faith-based or professional health groups). Joining or posting in such Clans could indirectly disclose special category data. We rely on your explicit actions/consent to participate in those Clans; you can leave a Clan or change visibility at any time.

4) Why we use your data & lawful bases

We process personal data for:

  • Provide & operate the Services (contract): account creation, authentication, listings, search & discovery, messaging, payments, fulfilment, customer support.
  • Trust, safety & moderation (legitimate interests; sometimes legal obligation): sponsor-based access; showing connection paths; verifying identity or eligibility; preventing fraud, spam and platform abuse; content moderation; dispute handling; enforcing our Terms; and—where severe or repeated misconduct is found—removal and blocks designed to prevent evasion (including retaining minimal identifiers).
  • Service quality, research & analytics (legitimate interests; consent for non-essential cookies): performance, A/B tests, measuring feature effectiveness, debugging and incident response.
  • Marketing & invitations (consent or soft opt-in to existing users): product updates, feature announcements, referral flows and waitlist notifications. You can opt out at any time.
  • Activity notifications (legitimate interests): alerts when people you are connected to post or request sponsorship; all such notifications are configurable.
  • Legal compliance (legal obligation): tax and accounting records, responding to lawful requests, and regulatory reporting.
  • Automated risk signals & ranking (legitimate interests): risk scoring, verification prompts, listing quality and reputation signals affecting visibility or requiring extra checks. Significant decisions are reviewable by a human on request (see §10).

Where we rely on consent, you can withdraw it at any time in settings or by contacting us.

5) How we share data

We share personal data with:

  • Other users: your public profile, listings, reviews, limited connection paths (how you are connected), sponsorship status, and any information you choose to make visible.
  • Service providers (processors): hosting/IaaS, storage/CDN, analytics, identity verification, payments, communications (email, SMS, push/WhatsApp where applicable), customer support tooling, security and anti-fraud. These providers act on our instructions under data processing agreements.
  • Moderators/Clan leaders: where you join a Clan, leaders may access what they need to moderate that community under our policies.
  • Legal & safety: to comply with laws, enforce terms, protect rights, safety and property, and respond to lawful requests.
  • Corporate transactions: if we sell/merge/reorganise, data may transfer under appropriate safeguards and notice.

We do not sell your personal information.

6) International data transfers

We may transfer data outside the UK/EEA. Where we do, we use approved safeguards such as the UK IDTA and/or EU Standard Contractual Clauses (with the UK Addendum), plus transfer risk assessments. You can request a copy of relevant safeguards (redacted for confidentiality).

7) Retention

We retain data for as long as necessary for the purposes in this policy, then delete or anonymise it. Typical periods:

  • Account, sponsorship & trust records: while your account is active and up to 6 years after closure for legal and fraud-prevention purposes, including prevention of re-registration by permanently banned users (we may retain minimal identifiers such as hashed emails/phone numbers and device or payment risk tokens).
  • Listings, messages & transaction records: generally up to 24 months after account closure (longer if there is an active dispute, chargeback or legal obligation).
  • Cookie/analytics data: per our Cookie Policy or provider defaults.
  • Backups & logs: rotated on fixed schedules; may persist for a limited period after deletion events.

8) Your rights

Depending on where you live, you may have the right to access, rectify, erase, restrict or object to processing, port your data, and withdraw consent.

  • We may request identity verification before acting on a request.
  • We may decline requests that are manifestly unfounded or excessive, or where we have overriding legitimate grounds or legal obligations to retain data.
  • You can object to processing based on legitimate interests, including direct marketing.
  • UK/EEA users can complain to the ICO or their local authority.

Contact: contact@clanmark.com.

9) Sponsorship accountability & fairness

Our trust model relies on sponsorship-based access and community accountability. Certain moderation outcomes can affect both a user and their sponsors. We operate processes that are proportionate, explainable and appealable; we log decisions; and you may submit context or evidence for review.

10) Profiling & automated decision-making

To protect users and platform integrity, we use automated signals (e.g., device/usage patterns, verification status, chargeback/fraud indicators, listing quality/reputation). These can affect:

  • prompts for identity or payment verification,
  • temporary limits (e.g., posting/messaging),
  • visibility/ranking of listings.

Where an automated output significantly affects you, you can request human review and contest the decision via contact@clanmark.com.

11) Cookies & similar technologies

  • Essential cookies/SDKs (always on): security, authentication, load balancing, preferences.
  • Analytics & performance (consent where required): usage measurement, diagnostics, A/B tests.
  • Marketing/attribution (consent): measuring outreach and referrals.

Manage non-essential cookies via our Cookie Settings and your browser/app controls. We respect legally-recognized browser signals (e.g., Global Privacy Control) where required.

12) Children

Clanmark is for adults (16+) only. We do not knowingly collect data from children. If you believe a child has provided data, contact us for deletion.

13) Security

We apply administrative, technical and organisational measures appropriate to the risk, including encryption in transit, access controls, least-privilege practices, secure software development, vendor due diligence, logging and incident response. No system is 100% secure. Use strong, unique passwords and enable available security features.

14) Third-party sites & integrations

Our Services may link to or integrate with third-party tools (e.g., payments, identity verification, messaging). Their handling of your data is governed by their own policies. Review their privacy practices before use. We are not responsible for third-party practices.

15) U.S. state privacy notice (supplement)

Residents of certain U.S. states (e.g., CA, CO, CT, UT, VA) may have additional rights, including to know/access, correct, delete, opt-out of targeted advertising, opt-out of sales/sharing, and appeal denials. We do not “sell” personal information as those laws define it, nor do we process sensitive data to infer characteristics without consent. Use in-product controls or contact@clanmark.com to exercise rights; authorized agents may act for you where permitted by law.

16) Changes to this policy

We may update this policy to reflect changes in law or our Services. We will post the updated version with a new “Last updated” date and, where appropriate, provide a prominent notice or seek consent.

17) How to contact us

Questions or requests about this policy or your data?

  • Email: contact@clanmark.com
  • Address: CLANMARK LTD, 39 Long Acre, London, Greater London, England, WC2E 9LG

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Short summary

Clanmark processes your data to run an invite-only, sponsor-verified marketplace where you can see how you’re connected to others, and where trust & safety are core. We show limited connection paths, use sponsorship data to keep the network safe (including proportionate accountability for sponsors), support optional verification and reputation features, and provide granular controls and rights. You can exercise rights or ask questions at contact@clanmark.com.