01 · Who we are
This policy is published by Clyvonna LLC, a marketing studio incorporated in Iowa with its principal office at 5249 North Park Place NE, NUM 5945, Cedar Rapids, IA 52402, USA. We are the "controller" of personal data collected on this website and the "processor" of personal data we handle on behalf of our clients.
Our Data Protection contact is reachable at privacy@clyvonna.com.
02 · What we collect
From visitors to this website
- Pages you visit, referrer, approximate location (country / region), browser type — collected via privacy-friendly analytics (we use first-party measurement; no cross-site tracking).
- Cookies needed to keep the site working. See our Cookie Policy.
From prospects who contact us
- Name, work email, company, role, project brief — whatever you typed into the contact form or sent us by email.
- Calendar metadata if you booked time with us through a scheduling link.
From clients during an engagement
- Access tokens, login credentials issued to us under your name, and similar working credentials — held in an encrypted password manager.
- Customer data you share with us so we can do the work (audience exports, CRM segments, analytics). Treated as Processor data under Section 7 of our Terms.
We do not collect: credit card numbers (handled by our payment processor), social security or government IDs, health data, or biometric data. We are not in those businesses.
03 · Why we collect it
- To run the engagement — perform the contract we have with you (GDPR Art. 6(1)(b)).
- To respond to inbound enquiries — based on our legitimate interest in operating a studio (GDPR Art. 6(1)(f)).
- To run this website — necessary for the site to function, and our legitimate interest in measuring its performance in aggregate.
- To comply with the law — tax, accounting, anti-fraud, court orders (GDPR Art. 6(1)(c)).
04 · Who we share it with
A short list, in plain language:
- Cloud infrastructure providers (hosting, email, password management) — under their published data-processing terms.
- Our accountant and our lawyer when there is a real reason to involve them.
- Authorities, if we are legally required to.
We have never sold personal information and we will not. We do not share contact data with advertising networks, lead-generation marketplaces, or third-party "enrichment" tools.
05 · How long we keep it
- Active client data — for the duration of the engagement plus 30 days for export, per our Terms.
- Prospect emails — up to 24 months after the last contact, then anonymized or deleted.
- Tax and accounting records — seven (7) years, as required by US law.
- Website analytics — aggregated; no individual record is retained beyond 14 months.
06 · How we protect it
SSO-protected accounts with mandatory two-factor authentication for everyone on the team. Access to client data is scoped to the named squad on each account and reviewed monthly. Credentials live in an encrypted password manager — never in plain text, never in chat, never in email.
If we discover a personal-data breach that meets the legal threshold, we will notify the affected parties and the relevant supervisory authority within 72 hours, as required by GDPR Art. 33.
07 · Your rights — EEA residents (GDPR)
If you are in the European Economic Area, the United Kingdom, or Switzerland, you have the following rights under the General Data Protection Regulation:
- Access — ask us what personal data we hold about you.
- Rectification — ask us to correct inaccurate or incomplete data.
- Erasure — ask us to delete your data ("right to be forgotten").
- Restriction — ask us to limit how we process your data.
- Portability — ask for your data in a structured, machine-readable format.
- Objection — object to processing based on our legitimate interest.
- Withdrawal of consent — withdraw consent at any time where we relied on it.
- Complaint — lodge a complaint with your local data protection authority.
Write to privacy@clyvonna.com and we will respond within 30 days.
08 · Your rights — California residents (CCPA / CPRA)
If you are a California resident, you have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:
- Right to know what personal information we have collected, used, and disclosed about you.
- Right to delete personal information we collected from you, subject to legal exceptions.
- Right to correct inaccurate personal information.
- Right to limit the use and disclosure of sensitive personal information.
- Right to opt out of sale or sharing — though we do not sell or share personal information for cross-context behavioural advertising, this right is yours by default.
- Right to non-discrimination for exercising any of the above.
To exercise these rights, contact privacy@clyvonna.com. We will verify your identity using the email address on file and respond within 45 days.
09 · Children under 16
This service is not intended for anyone under the age of 16. We do not knowingly collect personal data from children. If you are a parent or guardian and believe a child has provided us with personal data, contact us at privacy@clyvonna.com and we will delete the data promptly.
10 · Changes to this policy
We update this policy when our practices change, when our infrastructure changes, or when the law changes. The "Effective" date at the top of this page is the date of the current version. Material changes are announced to active clients by email; for visitors, this page is the source of truth.
11 · Contacting us
Privacy questions, rights requests, breach reports — all go to privacy@clyvonna.com.
Clyvonna LLC
5249 North Park Place NE, NUM 5945
Cedar Rapids, IA 52402 · USA