Who we are
Clay Capital Group LLC (“Clay Capital,” “we,” or “us”) is a Minnesota limited liability company. Our office of record is 202 N Cedar Ave, Ste 1, Owatonna, MN 55060. Direct contact: craig@claycapitalgroup.co. The firm is the controller (and, where applicable, the “business” as defined under California Civil Code § 1798.140(d)) of personal information collected through this website and during engagements.
Categories of personal information we collect
Using the categories defined under California Civil Code § 1798.140(v) and the parallel taxonomies of the Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Tennessee, New Jersey, Delaware, Maryland, and Minnesota consumer privacy statutes:
- Identifiers — name, email address, phone number, business address.
- Commercial information — project memos, pro formas, capital-stack documents, sponsor materials, and other engagement documentation you voluntarily share.
- Professional or employment information — title, firm affiliation, role on a project.
- Internet or other electronic network activity — server logs (IP, user agent, request path, timestamp), retained briefly by our hosting provider for operational and security purposes.
We do not collect sensitive personal information as defined under California Civil Code § 1798.140(ae) or the parallel definitions in other state laws (including government identifiers, financial-account credentials, precise geolocation, racial or ethnic origin, religious beliefs, union membership, health information, sexual orientation, biometric data, or genetic data) through this website or in the ordinary course of an engagement. To the extent any sensitive information is ever incidentally provided in a project memo, you have the right to direct us to limit its use to the purposes for which it was provided.
Categories of sources
Personal information is collected directly from you (when you contact the firm or share project documents), and from our hosting provider (server logs only).
Business and commercial purposes
We use personal information solely to (i) evaluate, route, document, and complete the engagement you have asked us to consider; (ii) communicate with you about that engagement; (iii) maintain records required by law; and (iv) operate and secure the website. We do not use personal information for cross-context behavioral advertising, targeted advertising, or profiling that produces legal or similarly significant effects.
Categories of third parties to whom we disclose personal information
We do not share project information with prospective lenders, trade partners, or other counterparties without your express prior consent on a deal-by-deal basis. We use only the following service providers (acting as our processors / service providers / contractors under written agreements that limit their use of personal information to performing services for us): our hosting provider (Vercel, Inc.), our email provider (Zoho Corporation), and our domain provider (Cloudflare, Inc.). We may disclose personal information to comply with legal process or to protect our legal rights.
Sale, sharing, targeted advertising, and profiling
We do not“sell” or “share” personal information as those terms are defined under the California Consumer Privacy Act as amended by the California Privacy Rights Act, the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, the Texas Data Privacy and Security Act, the Oregon Consumer Privacy Act, the Montana Consumer Data Privacy Act, the Iowa Consumer Data Protection Act, the Tennessee Information Protection Act, the New Jersey Data Privacy Law, the Delaware Personal Data Privacy Act, the Maryland Online Data Privacy Act, the Minnesota Consumer Data Privacy Act, or any other applicable state law. We do not engage in targeted advertising or in profiling in furtherance of decisions producing legal or similarly significant effects. We have not sold or shared personal information in the preceding 12 months and have no plans to do so.
Use of artificial intelligence
The firm may use commercial AI tools to assist with internal review of engagement materials (for example, to summarize a project memo for the principal’s review). The firm does not use AI to make automated decisions that produce legal or similarly significant effects on you, and the principal personally reviews and decides every engagement.
How long we keep it
Engagement records are retained for the duration of the engagement plus seven (7) years, consistent with the firm’s tax recordkeeping obligations under 26 C.F.R. § 1.6001-1 and any applicable contractual obligations to counterparties. Server logs are retained for no more than 90 days by our hosting provider for operational and security purposes. Personal information will be deleted or de-identified at the end of these retention periods unless a longer period is required by law.
How we protect it
We use commercially reasonable administrative and technical safeguards to protect information shared with the firm. Email correspondence is conducted on Zoho Mail with standard transport encryption. We do not store sensitive financial credentials, account numbers, or government identifiers on this website. In the event of a security incident affecting personal information, the firm will notify affected individuals and applicable regulators in accordance with Minn. Stat. § 325E.61 and any other applicable state breach-notification statutes within the time periods required by law.
Your rights
Depending on your state of residence, you may have the right to:
- Confirm / access — confirm whether we process your personal information and obtain a copy;
- Correct — correct inaccurate personal information (available under CA, VA, CO, CT, TX, OR, MT, TN, NJ, DE, MD, MN; not available under UT or IA);
- Delete — request deletion of personal information;
- Portability — obtain a portable copy of personal information you provided to us;
- Opt out of sale or sharing — opt out of any sale or sharing of personal information (we do not engage in either);
- Opt out of targeted advertising — opt out of targeted advertising (we do not engage in this);
- Opt out of profiling — opt out of profiling in furtherance of decisions producing legal or similarly significant effects (we do not engage in this);
- Limit sensitive PI — direct us to limit use and disclosure of sensitive personal information to that which is necessary to perform our services (we do not knowingly collect any);
- Non-discrimination — exercise these rights without retaliation, denial of services, or differential pricing.
How to exercise rights. Email craig@claycapitalgroup.co with the subject line Privacy Request. We will verify your identity using information already on file (typically by matching against email and project-engagement records) before processing your request, and respond within the period required by your state’s law (typically 45 days, with one 45-day extension where reasonably necessary; CA permits 90 days for certain access requests).
Right to appeal.If we decline your request, you may appeal at no cost by replying to our denial within a reasonable period. We will respond to the appeal in writing within sixty (60) days of receipt with a written explanation of any actions taken or not taken. If the appeal is denied, you may contact your state Attorney General. Minnesota residents may also contact the Minnesota Attorney General’s Office.
Authorized agent.You may designate an authorized agent to make a request on your behalf. We will require: (i) signed written permission from you authorizing the agent to act, or a valid power of attorney granted under the laws of your state; (ii) verification of your own identity directly with the firm; and (iii) verification of the agent’s identity. Where state law requires us to honor a power of attorney without separate verification (Colorado, Connecticut, Oregon, and others), we will do so.
Children and minors
This website is not directed to children, and the firm does not knowingly collect personal information from children under 13 in violation of the Children’s Online Privacy Protection Act (15 U.S.C. § 6501 et seq.). If we learn we have collected personal information from a child under 13, we will delete it promptly. The firm does not knowingly process the personal information of minors under 16 for purposes of sale, sharing, or targeted advertising (California, Colorado, Connecticut), and does not knowingly process the personal information of minors under 17 for purposes of sale, sharing, targeted advertising, or profiling without obtaining the consent required by the New Jersey Data Privacy Law, the Delaware Personal Data Privacy Act, and the Maryland Online Data Privacy Act.
Cookies and tracking
The website uses only the minimum cookies required for functional operation. We do not use cookies, pixels, SDKs, or similar technologies for cross-context behavioral advertising, targeted advertising, or for the sale or sharing of personal information.
EU and UK residents
The firm is established in the United States and does not offer goods or services to, or monitor the behavior of, individuals in the European Union or the United Kingdom. If you are an EU or UK resident and contact us, we will process your information solely to respond to your inquiry, on the basis of our legitimate interests under GDPR Article 6(1)(f) and the corresponding provision of the UK GDPR. You may exercise the rights afforded under those regulations (including access, rectification, erasure, restriction, portability, and objection) by emailing the address below, and you have the right to lodge a complaint with your local supervisory authority.
State-specific disclosures
California residents.The categories above constitute the firm’s “Notice at Collection” under Cal. Civ. Code § 1798.100(b) and the CPPA regulations. We have not sold or shared personal information, or used or disclosed sensitive personal information for purposes other than those permitted by § 1798.121, in the preceding 12 months. The retention periods above satisfy the disclosure required by § 1798.100(a)(3).
Minnesota residents.The firm complies with Minn. Stat. § 325O. Because the firm does not engage in profiling, sale of sensitive data, or processing that presents a heightened risk of harm to consumers, the firm does not currently conduct data protection assessments under § 325O.06. If our processing changes such that an assessment becomes required, we will conduct one. You may contact the Minnesota Attorney General regarding the firm’s compliance.
Virginia, Colorado, Connecticut, Texas, Oregon, Montana, Iowa, Tennessee, New Jersey, Delaware, Maryland residents. The rights and procedures described above apply to you. Your state-specific appeal rights and the role of your state Attorney General are preserved in full.
Changes to this notice
We may update this privacy notice from time to time. The version and effective date above reflect the most recent revision. Material changes will be communicated to active engagements directly. Prior versions are available on request.
Contact
Questions about this notice or how we handle information should be directed to craig@claycapitalgroup.co.