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 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 parallel state 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 CCPA § 1798.140(ae), including government identifiers, financial account credentials, precise geolocation, or biometric data, through this website.
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 or profiling.
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 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 and sharing
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, or any other applicable state law. We have not sold or shared personal information in the preceding 12 months.
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 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 briefly by our hosting provider for operational and security purposes.
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.
Your rights
Depending on your state of residence, you may have the right to:
- Confirm whether we process your personal information and access that information;
- Correct inaccurate personal information;
- Delete personal information;
- Obtain a portable copy of your personal information;
- Opt out of the sale or sharing of personal information (we do not engage in either);
- Opt out of profiling for decisions producing legal or similarly significant effects (we do not engage in this);
- Limit our use of sensitive personal information (we do not knowingly collect any).
How to exercise rights. Email craig@claycapitalgroup.co with the subject line Privacy Request. We will verify your identity using information already on file before processing your request, and respond within the period required by your state’s law (typically 30 to 45 days).
Right to appeal. If we decline your request, you may appeal by replying to our denial. We will respond to the appeal within 60 days. If the appeal is denied, you may contact your state Attorney General.
Authorized agent.You may designate an authorized agent to make a request on your behalf. We will require written verification of the agent’s authority.
Children
This website is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If we learn we have collected personal information from a child under 13, we will delete it promptly.
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 or for the sale or sharing of personal information.
EU and UK residents
The firm is established in the United States and does not target EU or UK residents. If you are an EU or UK resident and contact us, we will process your information solely to respond to your inquiry under our legitimate-interests basis (GDPR Article 6(1)(f)).
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.