Privacy Policy

1. Who we are

In short: Clavesta runs clavesta.com and the Clavesta app, and this policy covers both.

Clavesta (“Clavesta,” “we,” “us”), currently operated by its founder before it incorporates, operates the clavesta.com website, the Clavesta web and mobile app, and related emails and services (together, the “service”). Clavesta is a technology platform that matches home buyers and sellers for direct home sales (including seller financing and assumable mortgages) and guides both sides toward a closing handled by licensed professionals they choose. Clavesta is the business responsible for the personal information described in this policy.

This policy applies to people in the United States who visit our site or create an account. It doesn’t cover the independent title companies, attorneys, loan originators and servicers you may work with to close a deal; they handle your information under their own privacy notices. Our Terms of Use also apply to your use of the service.

2. Information we collect

In short: mostly what you give us, some information from our verification, screening and payment partners and public property records, and technical data from your device.

Information you give us

• Account details: email address, password (stored by our authentication provider in hashed form) or Google sign-in, display name, and whether you’re buying, selling or both.
• Buyer profile: areas you’re interested in, price and monthly payment ranges, down payment, preferred rate and term, timeline, and optional self-reported income type and credit range. Your income type and credit range are used only for your own match results and are never shown to sellers.
• Mortgage check (optional): if you choose to save it, your answers (gross monthly income, monthly debts, savings, credit range, employment, VA eligibility, whether you’re considering rural areas, and whether you’re a first-time buyer) are kept privately on your account, used only to show you your own estimate, never shown to sellers, never used for matching or ranking and never sent to our AI provider. You can delete them any time. If you don’t save them, they stay on your device.
• Listings: the property address, home facts, photos, asking price and financing terms, timeline, and details of any existing mortgage (balance, rate, payment, loan type, servicer). If you upload a mortgage statement to fill these in, we process the document to extract those figures.
• Messages and notes: the chat messages and interest notes you send to other members, reports you file, and support requests.
• Deal records: viewing requests and check-ins, term sheet proposals and your typed-name signatures, documents you upload to a deal’s document vault, and the reason you give when ending a deal.
• Consents and acknowledgments: your acceptance of our Terms, the biometric notice, the background screening authorization (including your typed name as your signature) and viewing acknowledgments, with the version, date and time, and your browser’s user agent.
• Trusted contact: if you share a viewing with someone you trust, the email address you enter. We use it to send that one email and don’t store it.

Information from our partners and public sources

• Identity verification (Persona): the result of your ID check (verified, declined or needs review) and your first and last name as shown on your ID. See Biometric information notice.
• Background screening: the result of your safety check (clear or needs review) and a reference to the report held by the consumer reporting agency. See Background screening.
• Payments (Stripe): whether a payment succeeded, the amount, tax where applicable, and payment and refund references. Stripe doesn’t give us your full card number.
• Property records (RentCast): public-record facts about a property address, including an estimated value and the recorded owner’s name. We use the owner’s name to confirm that a seller owns the home they list.
• Google sign-in: if you sign in with Google, your name, email address and Google account identifier.
• Other members: information other members provide about you, such as a report or a message.

Information collected automatically

• Device and log data: IP address, browser and device type, app version, pages and screens requested, and timestamps, which our hosting providers record to deliver the service and protect it from abuse.
• Security signals: App Check with Google reCAPTCHA Enterprise, which evaluates signals from your browser to confirm requests come from our real app.
• Error reports: when the app hits an error, a short description, the screen, and the app version (with personal details removed).
• Product events: records of actions such as signing up, publishing a listing, completing verification or making a purchase, used to run and improve the service.
• Analytics: Google Analytics in the app, which record usage events without names, emails, addresses or message text. See Cookies and analytics.

We do not collect precise geolocation from your device. We may infer an approximate location (such as your city or state) from your IP address. Property addresses you enter for a listing or a search are not device location.

3. Sensitive personal information

In short: some of what we handle is sensitive, like ID, face scans, background checks and private messages. We use it only to provide the service and keep people safe.

Some information connected with Clavesta is “sensitive” under state privacy laws:

• Government ID: Persona collects your government ID (which may show your ID number, date of birth and address) on our behalf. Clavesta receives only your verified name and the result.
• Biometric information: the face geometry Persona creates from your selfie and ID photo, collected only with your written consent. Clavesta never receives it.
• Background screening information: sex-offender registry and criminal conviction information in a consumer report, held by the consumer reporting agency. Clavesta receives the result and, if a person needs to review it, the report through the agency.
• Account login: your email and password, which our authentication provider stores in hashed form.
• Contents of messages: the chat messages you exchange with other members, which we process to deliver them and to scan them for safety.

We use and disclose sensitive personal information only to provide the service you request, verify identity, keep people safe, prevent and investigate fraud and illegal activity, and meet legal obligations. We don’t use it to infer characteristics about you, for advertising, or to profile you. Because we limit our use to these purposes, California’s right to limit the use of sensitive personal information doesn’t require a separate opt-out, but you can ask us about it at any time.

4. Biometric information notice

In short: a face scan is made only after you agree in writing, only to verify your identity, by Persona, not Clavesta. It is never sold, and it is destroyed within 30 days after your verification decision.

This section is our written notice and public retention and destruction policy for biometric identifiers and biometric information under the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), Washington’s biometric identifier law (RCW 19.375) and similar laws. It applies to everyone, wherever you live.

What is collected

A photo of your government ID and a selfie. From them, Persona creates a scan of your face geometry to confirm the selfie matches your ID photo and that you’re a live person.

Who collects and stores it

Persona Identities, Inc. (“Persona”), our identity-verification provider, collects, stores and processes it on Clavesta’s behalf under a written contract. Clavesta does not receive, store or have access to your face scan or ID images. We receive only the result and the name on your ID.

Why

Only to verify your identity when you get Clavesta Verified and to prevent fraud and fake accounts. It’s not used for any other purpose.

Consent

Before any capture, the app shows this notice and asks you to agree in writing (a checkbox you tick yourself). We record the version and time of your consent. Nothing is captured if you don’t agree.

No sale or profit

Neither Clavesta nor Persona sells, leases, trades or otherwise profits from your biometric data.

Disclosure

Your biometric data is not disclosed to anyone other than Persona, unless you consent, it’s needed to complete a transaction you request, or the law or a valid warrant or subpoena requires it.

Retention and destruction

Persona permanently destroys your face scan and selfie within 30 days after the verification decision, and your ID images and the other details read from your IDwithin 1 year after the decision. If you delete your Clavesta account first, we instruct Persona to delete your verification data at that time. In no case is biometric data kept longer than the purpose for collecting it requires, and never more than 3 years after your last interaction with Clavesta.

Security

Persona stores and transmits biometric data using a reasonable standard of care for our industry, at least as protective as the way it protects other confidential and sensitive information, including encryption in transit and at rest.

Washington residents

Biometric data may be “consumer health data” under Washington’s My Health My Data Act. We collect it only with your consent, only for identity verification, never sell it, and honor your rights to access and delete it and to withdraw consent, as described in this policy.

To ask about or request deletion of your biometric data, write to privacy@clavesta.com. If you withdraw consent before your check is finished, we’ll stop the check.

5. Background screening (safety check)

In short: in-person viewings need a background check that you authorize separately. It looks only at sex-offender registries and criminal convictions. The other person only ever sees “complete” or “not yet.”

• When: only if you want to take part in in-person viewings. Chat, video tours and every other feature work without it.
• Your authorization: before any check, you see a standalone disclosure and sign a separate authorization with your typed name, as required by the federal Fair Credit Reporting Act (FCRA).
• What’s checked: national and state sex-offender registries and criminal convictions. Arrests that didn’t lead to a conviction are never used.
• Who runs it: an independent consumer reporting agency. You give your identifying details (such as date of birth) directly to the agency on its secure page. Clavesta doesn’t collect or store your Social Security number or date of birth.
• What Clavesta keeps: your authorization record, the result, dates, and a reference to the report. The report itself stays with the agency.
• Individual review: a result that needs review goes to a trained Clavesta team member, who considers only safety-relevant offenses under a written policy. Before any adverse decision, you get a copy of the report, A Summary of Your Rights Under the Fair Credit Reporting Act, and at least 5 business days to dispute or explain.
• Who sees it: only you and authorized Clavesta staff. The other party in a deal sees only whether your safety check is complete, never the result or the report.

6. How we use information

In short: to run Clavesta, keep it safe, process payments, communicate with you, improve the service and follow the law.

• Provide the service: create your account, build your buyer profile or listing, calculate matches and feasibility, connect buyers and sellers, deliver messages, schedule viewings, and run the Deal Path, including the closing steps, the providers and the closing date you record.
• Verification and safety: verify identity, confirm seller ownership, run safety checks you authorize, enforce viewing requirements, respond to “I feel unsafe” alerts and reports.
• Trust, fraud prevention and fair housing: scan messages and notes, review flags, detect fake accounts and abuse, and enforce our Terms and Community Guidelines.
• Payments: process Clavesta Verified and Unlock purchases, calculate tax where it applies, issue refunds and keep financial records.
• Communications: send service emails and in-app notifications (matches, messages, viewings, verification and safety-check updates, receipts, reminders) and legally required notices. With your permission, we send product and launch updates; you can unsubscribe at any time.
• Improve the service: understand how features are used through product events and analytics, and fix errors.
• Legal: comply with laws, respond to lawful requests, and establish, exercise or defend legal claims.

We don’t make decisions that produce legal or similarly significant effects about you based solely on automated processing. Matching compares your stated criteria with listing terms; it never uses protected characteristics, and AI never decides whether you can use a feature.

7. Message monitoring for safety

In short: every chat message and interest note is checked automatically before it’s delivered, to stop scams and discrimination.

Before a chat message or interest note is delivered, automated rules and an AI model check it for signs of fraud (such as requests to pay outside Clavesta, wire instructions, gift cards or crypto, or requests for sensitive data), pressure tactics, and fair-housing violations. Depending on the result, the message is delivered, delivered with a safety note, or blocked with an explanation. Flagged messages go to a Clavesta team member, who may dismiss the flag or hide the message. Reports you file about a conversation are reviewed the same way.

We never record, listen to or monitor phone or video calls. Video tours use a meeting link the seller provides, on that meeting service’s own terms.

8. AI processing

In short: we use Google’s Gemini models, through Google Cloud, for a few features. Google processes the content for us and doesn’t use it to train its models.

We send content to Google’s Gemini models, through Google Cloud’s Vertex AI, to:

• scan chat messages and interest notes for safety (see Message monitoring);
• write plain-English summaries of documents you ask us to explain in a deal’s document vault;
• read a mortgage statement you upload and fill in the loan balance, rate, payment, loan type and servicer; and
• answer questions you ask the Clavesta Guide, using our own published guides as sources.

Google acts as our service provider for this processing under its Google Cloud terms, which prohibit using our content to train its models. AI output is educational and can be wrong; see ourTerms.

9. Who we disclose information to

In short: service providers who work for us, the other side of a deal, and people you choose to send information to. Nobody buys your data from us.

Service providers

These companies process personal information on our behalf, under contracts that limit their use to providing services to us:

Other members

• Sellers see a buyer’s first name, verified status, maximum down payment and monthly payment, timeline and match fit when the buyer expresses interest. Never income type, credit range, email or ID details.
• Buyers see a listing’s city, price, terms and photos; the exact address only with an active Unlock after the seller accepts their interest.
• Connected members see each other’s first name, verified status, messages, viewing details, term sheets, deal documents, Deal Path progress, the providers and closing date either of them records, and whether each safety check is complete (yes or no only).

People and companies you choose

• Providers for your closing: Clavesta doesn’t send your information to title or escrow companies, attorneys, loan originators, servicers or other providers, including the ones the Deal Path suggests. You decide what to share when you contact them. They’re independent businesses with their own privacy practices, and they never pay Clavesta.
• Trusted contact: when you share a viewing, we email the person you name the time, general area and both first names (and the address, if you’re the buyer with an Unlock).

Legal, safety and business transfers

We may disclose information if we believe in good faith it’s required by law or legal process, to protect anyone’s safety (including in an emergency), to investigate fraud or violations of our Terms, or to protect our rights. If Clavesta is involved in a merger, acquisition, financing or sale of assets, information may be transferred as part of that deal, and this policy will continue to apply to it.

10. No sale or sharing

In short: we don’t sell your information, and we don’t share it for targeted advertising. We haven’t in the past 12 months.

Clavesta does not sell personal information, does not share it for cross-context behavioral advertising, and does not use it for targeted advertising, and hasn’t done so in the past 12 months. We have no actual knowledge of selling or sharing personal information of anyone under 16. If your browser sends a Global Privacy Control (GPC) signal, we treat it as a request to opt out of sale and sharing; because we don’t sell or share, you’re already opted out. We don’t disclose personal information to third parties for their own direct marketing.

11. Cookies and analytics

In short: we use only what’s needed to run the service, plus Google Analytics without ads. You can turn analytics off.

• Essential storage: the app and site use browser storage and cookies to keep you signed in, remember settings (such as your analytics choice) and protect against abuse with App Check. These are necessary for the service and can’t be turned off.
• Analytics: the app use Google Analytics (GA4) to count events such as sign-ups, listings published and purchases. Event data never includes names, emails, addresses, message text or other free-form input. Advertising features (ad storage, ad personalization and ad user data) are always off, and Google Analytics keeps event data for no more than 14 months.
• No advertising cookies: we don’t use advertising or cross-site tracking cookies, and we don’t allow ad networks on the service.

12. Your privacy choices

In short: turn off analytics here or in the app, manage emails, and control what you share.

Analytics on this site: this site doesn’t currently run analytics or advertising cookies, so there’s nothing to turn off.

• Analytics in the app: Settings > Privacy > “Do not track analytics” turns Google Analytics off in that browser.
• Email: turn off notification emails in Settings (in-app notifications continue), and unsubscribe from marketing or launch emails with the link in any of them. Legally required notices, such as background-screening notices, are sent regardless.
• What you share: you decide what goes in your profile, listing and messages, whether to verify, and whether to authorize a safety check.
• Global Privacy Control: honored as described in No sale or sharing.

13. How long we keep information

In short: as long as your account is open, then we delete it, except records we must keep for the other side of a deal, tax, safety or legal reasons, which we de-identify.

When we say information is “de-identified” below, we replace your account ID with a one-way code so it’s no longer linked to you.

14. Deleting your account

In short: you can delete your account yourself in the app. It’s permanent.

Delete your account in Settings, or ask us at privacy@clavesta.com. Deleting your account:

• deletes your listings and photos, buyer profile, matches, notifications, uploads, verification record, safety check record, reminders and consent records, and your sign-in;
• asks Persona to delete your verification data;
• withdraws your pending interests, closes your conversations and replaces your messages with “[deleted]”;
• cancels open viewings, and keeps deal records the other party still needs, de-identified; and
• keeps orders, support and safety records only in de-identified form, as described in How long we keep information.

Deletion can’t be undone. An active Unlock or verification ends with the account.

15. Security

In short: we limit who can see what, log staff access, and encrypt data. No system is perfect.

We use administrative, technical and physical safeguards appropriate to the sensitivity of the information, including encryption in transit and at rest, access rules that let each member read only their own records and those of their connections, App Check to block requests from anything other than our app, and staff access limited to authorized team members performing moderation, refunds, verification review, safety checks and support, with every staff decision recorded in an audit log. We don’t keep raw identity-verification or screening payloads, and we never receive card numbers. No method of transmission or storage is completely secure. If a breach affects your personal information, we’ll notify you and regulators as the law requires.

16. Your privacy rights

In short: wherever you live in the US, you can ask to access, correct, delete or take a copy of your information.

We extend these rights to every member and visitor, regardless of state:

• Access and know: confirm whether we process your information, and get the categories and specific pieces we hold, where they came from, why we use them and who we disclose them to.
• Portability: get a copy of information you gave us in a usable format.
• Correction: fix inaccurate information. (Your verified name can only be changed through support, because it’s tied to your ID check.)
• Deletion: delete information we hold about you, subject to legal exceptions such as tax records and safety records.
• Opt out: of sale, sharing, targeted advertising and profiling with significant effects. We don’t do any of these.
• Withdraw consent: for biometric processing, background screening and marketing emails, at any time, for the future.
• Non-discrimination: we won’t deny service, charge different prices or provide a different quality of service because you exercised a privacy right.

Residents of states with comprehensive privacy laws, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia, have these rights by law. Minnesota residents may also ask for the list of specific third parties we disclosed their information to.

17. California residents

In short: the categories California law asks us to list, what we use them for and who receives them.

Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA), this section is our notice at collection and describes the personal information we collected in the past 12 months. We collect it from the sources in Information we collect, for the purposes in How we use information, and keep it as described in How long we keep information. We disclose each category for business purposes only; we don’t sell or share any category.

We don’t collect professional, employment or education information, and we don’t collect protected-classification characteristics for matching. You can use an authorized agent to make a request (see How to exercise your rights). California’s “Shine the Light” law: we don’t disclose personal information to third parties for their direct marketing.

18. How to exercise your rights

In short: email us from your account’s address, and we’ll answer within 45 days.

• Make a request: email privacy@clavesta.com from the email address on your account and tell us what you’d like. You can delete your account yourself in Settings.
• Verification: we confirm requests by replying to the email address on your account, and may ask for more information for requests involving sensitive information. We’ll only use what you give us to verify your request.
• Authorized agents: an agent can make a request for you with your signed permission; we may still ask you to confirm your identity with us directly.
• Timing: we confirm receipt within 10 business days and respond within 45 days. If we need more time (up to 45 more days), we’ll tell you why.
• Cost: free, unless requests are manifestly unfounded or excessive.

19. Appeals

In short: if we say no, you can ask us to look again.

If we decline your request in whole or in part, you can appeal by replying to our decision or emailing privacy@clavesta.com with “Privacy appeal” in the subject line. A different team member will review it, and we’ll respond in writing within 45 days, explaining what we decided and why. If you’re not satisfied, you may contact your state attorney general (or, in California, the California Privacy Protection Agency).

20. Children

In short: Clavesta is for adults 18 and over only.

The service isn’t directed to anyone under 18, and people under 18 may not create an account. We don’t knowingly collect personal information from anyone under 18. If you believe a minor has given us information, email privacy@clavesta.com and we’ll delete it.

21. Where information is processed

In short: in the United States.

Clavesta serves people in the United States and stores its data in the United States. Our service providers may process some information in other countries under contractual protections. The service isn’t intended for people outside the United States.

22. Changes to this policy

In short: we’ll update the date and tell you first about big changes.

We’ll update this policy as the service changes and revise the “Last updated” date. If we make a material change, we’ll notify you by email or in the app before it takes effect, and we’ll ask for your consent where the law requires it (for example, before using information in a materially different way than we said when we collected it).

23. Contact us

In short: privacy questions go to privacy@clavesta.com.

Privacy questions and requests: privacy@clavesta.com
Help with the service: support@clavesta.com