, Claritergroup Privacy Policy

Welcome to Claritergroup Privacy Policy.

Introduction 

Clariter SRL, Clariter LTD and Grupo Clariter LDA (“Clariter”, “we”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you. 

This page and its sub-pages tell you everything you need to know about how we protect the personal data we process and control relating to you (“your personal data”; “your data”) and which rights you have in relation to the processing of your personal data. 

Further information on Clariter can be found here. 

Clariter Ltd Forest House Business Center 8, Gainsborough Road, Leytonstone.  E11 1HT, London, UK  1-15 Clere St,London, EC2A 4UY, UK  
Clariter Srl Via Cristoforo Colombo 112, 00147 Rome, RM, IT  Via Luraghi, 20020, Arese, MI, IT  
Grupo  Clariter LDA Campo Grande, 28 – 5 A/D,1700-093 Lisbon, PT  

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended to override them. 

Controller  

Full name of legal entity: IOA Holding S.r.l. 

Email address: privacy@claritergroup.com 

Postal address: via Rubicone 8, 00198, Roma  

You have the right to make a complaint at any time to the relevant supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the authority so please contact us in the first instance.  

Changes to the privacy policy and your duty to inform us of changes  

We keep our privacy policy under review. This version was last updated on April 17th, 2019 and historic versions can be obtained contacting us.  

It is important that the personal data we hold about you is accurate and current. Please keep us informed and make sure the information you have supplied is accurate and up-to-date. 

Third-party links 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. 

The data we collect about you 

Personal data, or ‘information’, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

We may collect, use, store and transfer different kinds of personal data about you. 

We collect personal data about our employees, potential employees, clients, suppliers, business contacts, shareholders and website users. 

The data we collect will include: 

  • Identity Data includes your first name, maiden name, last name, title, gender, date and place and country of birth, nationality, residential address, country of domicile, identity card number. 
  • Contact Data includes your, delivery address, email address and telephone numbers. 
  • Technical Data includes your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. 

The data we collect may also include further information from the emails, letters and other communications you send and documents you provide to us when you visit our offices 

If the data we collect are not listed in this privacy statement, we will give individuals (when required by law) appropriate notice of which other data will be collected and how they will be used. 

Except for certain information that is required by law, your decision to provide any personal data to us is voluntary. You will therefore not be subject to adverse consequences if you do not wish to provide us with your personal data. However, please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this privacy statement, and you may not be able to use certain tools and systems which require the use of such personal data. 

If you provide us with personal data of another person, you are responsible for ensuring that such person is made aware of the information contained in this privacy statement and that the person has given you his/her consent for sharing the information with us. 

The above-mentioned categories of personal data have been obtained either directly from you or indirectly from certain third parties (for example, through our website’s technology). Such third parties include our affiliates, public authorities, public websites and social media, suppliers and vendors. 

Although we do not request or deliberately collect any Special Categories of Personal Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) or information about any criminal convictions and offences (together “Sensitive Data”) from you, you are responsible for the information you provide to us. 

How is your personal data collected?  

We use different methods to collect data from and about you including through:  

  • Direct interactions. We collect personal information about you whenever you use our website and when you correspond with us by post, phone, email or otherwise and when you visit our offices. 
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.  
  • Third parties or publicly available sources. We may receive personal data about you from other third parties, selected third party websites such as those where information about you is publically available, other platform users and our clients. 


How we use your personal data 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 

  • Where we need to perform the contract we are about to enter into or have entered into with you. 
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 
  • Where we need to comply with a legal or regulatory obligation. 


Purposes for which we will use your personal data  

We set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.  

Note that we may process your personal data for more than one lawful ground depending on the specific circumstances. Please contact us if you need further details about the legal ground, we are relying on. 


Necessary for the Performance of a Contract  

In certain cases, we need to process your personal data to comply with a contractual obligation or in order to take steps to enter into a contract at your request. For example, where we need to:  

  • Where you enquire about becoming or where you become a client 
  • Managing our contractual and/or employment relationship with you. 


Our Legitimate Interests  

Otherwise, we may process your personal data where it is necessary for our legitimate interests. Broadly legitimate interests means the interest of our business in conducting and managing our business activities to enable us to give you the best service/product and the best and most secure experience. More specifically however we also have an interest in developing our business and brand image, creating reports, providing internal IT administration and keeping our website updated and relevant to you.  

We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.  

Examples of where we process your personal data on the basis of our legitimate interests include where we;  

  • carry out analysis and market research on our own behalf or on behalf of our clients to improve the quality of our website;
  • administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting data);  
  • use data analytics to improve our website and services; (more details on how we run analytics on our website can be found in our cookies policy
  • keep a record of all our active website users;  
  • for ensuring that we recruit the appropriate employees; 
  • for ensuring proper communication and emergency handling within the organization. 


Compliance with a legal obligation  

If the law requires us to, we may need to process your personal data in response to a lawful request by a public authority or to comply with a legal or regulatory obligation, for example;  

  • we believe in good faith that the disclosure is necessary to protect our rights;  
  • to protect your health and/or safety or the health and/or safety of others;  
  • to investigate fraud or breaches of our site terms or any other terms between us;  
  • to notify you about changes to our terms and conditions of this privacy policy; and  
  • to respond to a Government request.  

We will not use your personal data for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so. 


Automated decision making 

We never make decisions about you using only technology where none of our employees or any other individuals have been involved. 


Cookies 

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 

Please see our cookie policy for further details. 

By continuing to use our site, you are agreeing to our use of cookies. Our lawful basis for processing the personal data we collect as a result of our use of cookies and the purposes for which it is processed are set out above. 


Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 


Disclosures of your personal data 

We may transfer personal data to our service providers, professional advisors, public and governmental authorities or third parties in connection with a (potential) corporate or commercial transaction.  

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 


International transfers 

The disclosure of personal information to the third parties set out above may involve the transfer of data to jurisdictions outside the European Economic Area (EEA). Any such transfers are made in accordance with the requirements of Articles 44 to 49 of the GDPR. Where such transfers are made to countries that do not have an adequacy decision in place, appropriate safeguards are implemented, such as: 

  • only transferring your personal data to them if they are part of the Privacy Shield, which imposes obligations on U.S. companies to protect Europeans’ personal data; 
  • using specific contracts approved by the European Commission; or 
  • obtaining your consent prior to the transfer. 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside the EEA. 


Data security 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 


Data retention 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 


Your legal rights 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights: 

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.  
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.  
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.  
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.  
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.   
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.  
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

If, despite our commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage and welcome individuals to come to Clariter first to seek resolution of any complaint. You have the right at all times to register a complaint directly with the relevant supervisory authority or to make a claim against Clariter with a competent court (either in the country where you live, the country where you work or the country where you deem that data privacy law has been infringed). 


No fee usually required 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 


What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 


Time limit to respond 

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.  


CONTACT US 

Please click here if: 

  • You have a general question about how Clariter protects your personal data. 
  • You wish to exercise your rights in relation to your personal data rights (as set out in the sections “Your Legal Right”.  
  • You wish to make a complaint about Clariter’s use of your data. 

Clariter Ltd Forest House Business Center 8, Gainsborough Road, Leytonstone.  E11 1HT, London, UK  1-15 Clere St,London, EC2A 4UY, UK  
Clariter Srl Via Cristoforo Colombo 112, 00147 Rome, RM, IT  Via Luraghi, 20020, Arese, MI, IT  
Grupo  Clariter LDA Campo Grande, 28 – 5 A/D,1700-093 Lisbon, PT  

Last changed on April 17th, 2019.