Privacy

Cleverals, S.L. (hereinafter, the COMPANY), in accordance with current legislation on the Protection of Personal Data, informs users of its online website (hereinafter, the User), about the Privacy Policy that will apply to the processing of personal data that the User voluntarily provides when accessing the website https://www.cleverals.com/ (hereinafter, the Website).

The COMPANY declares its commitment to comply with the legislation in force at all times regarding data protection, specifically with the General Data Protection Regulation (RGPD), and other applicable legislation. In accordance with Article 5 of Law 15/1999, of 13 December, on the Protection of Personal Data, users are informed that the personal data provided on the Website will be subject to automated processing and will become part of the files owned by the COMPANY, as the party responsible for the files duly registered in the General Register of the Spanish Data Protection Agency, for the purposes of providing services and management of users registered on the COMPANY’s Website.

Basic information on data protection

In accordance with the applicable legislation, the Privacy Policy that the COMPANY uses in the processing of Users’ data is detailed below.

I. Who is responsible for the Data you provide us with?

All personal information provided or collected through Cleverals will be processed mainly by Cleverals, S.L., the data controller.

II. What is the legitimacy for the processing of your data?

The legal basis for the processing of data is contact by any of the means available on the website (forms, e-mail contact, chat and telephone), the execution of the User’s registration on the COMPANY’s website and the subsequent use that the User may make of it.

III. What information does the COMPANY collect?

The information we receive on the COMPANY’s website from users is collected as follows.

a) Information that Users provide directly to us:

THE COMPANY collects and stores certain information that the User enters on the COMPANY’s Website or provides to the COMPANY in any other way.

• Registration Data: the information that the User provides to us when creating an account, or when filling in an application form, on the COMPANY’s Website. This is the User’s name, the User’s email address, and sometimes the User’s telephone number.
• User Profile Information: the information that the User adds on the Website in order to be able to use the COMPANY’s service. That is, preference information in relation to the service. From your account on the COMPANY’s website, you can view and edit your personal profile data at any time.
• Additional information that the User wants to share: the information that the User could provide to COMPANY for other purposes. For example, the billing address, in case of requesting to receive invoices from COMPANY.

b) Information provided to us indirectly by Users:

• Data derived from the use of the Website: the COMPANY collects data derived from the use of the Website by the User each time he/she interacts with the Website.
• Application and device data: the COMPANY stores the data of the connection device that the User uses to access the services. These are: Internet IP address used by the User to connect to the Internet with their computer or mobile, information from their computer or mobile, such as their Internet connection, their browser type, version and operating system, and device type, the full Uniform Resource Locators (URL) clickstream, including date and time, the User’s cookie number, browsing history and User preferences.
• Data derived from the origin of the User: if the User arrives at the COMPANY’s Website through an external source (such as a link from another website or a social network), the COMPANY collects the data from the source from which the User comes from the COMPANY.
• Data derived from “cookies”: the COMPANY uses its own and third-party cookies to make browsing easier for its users and for statistical purposes.
• Data derived from external third parties: the COMPANY could collect information or personal data from external third parties only if the User authorises these third parties to share the aforementioned information with the COMPANY. For example, in the event that the User creates an account through his Facebook, Facebook could give us the User’s personal data if he has them in his Facebook profile (name, gender, age…).

IV. For what purpose are the data collected?

1. The COMPANY uses the data it collects from Users to provide the services requested by the User. The general purposes are detailed below:
   • To provide you with the services for which you have contacted us.
   • Communicate with you about our services or our site.
   • Respond to and deal with your queries.
   • Notify you about account or service issues (such as resetting your password).
   • Any other purpose specified at the time the information is collected.
2. The COMPANY may send promotional messages and/or offers related to the service it offers to the User’s e-mail address, but always within the framework for which the User provided his/her data, or in relation to those related to the services that are advertised through the COMPANY’s website.
3. The COMPANY also uses the information to research and analyse how to improve the services it provides to Users, as well as to develop and improve the features of the service it offers. Internally, the COMPANY uses the information for statistical purposes.
4. The COMPANY may also use Users’ information for the purpose of detecting and investigating fraud, as well as other illegal activities and potential violations of our “Terms of Use” and “Legal Notice”.
5. If the User connects his or her account to another social network or third party website, the COMPANY may use the information provided to that social network or third party, provided that such information has been made available to the COMPANY in compliance with the privacy policy of that social network or third party website.
6. Likewise, the COMPANY may use the personal data provided by the User to send communications via e-mail and/or SMS to the User about the operation of the service.
7. The data of the COMPANY’s Users are stored in servers located in Spain. The COMPANY declares that these servers comply with the applicable legislation on Data Protection and with the commitments set out in this Data Privacy Policy.

V. Data processing of job seekers contacting the COMPANY

These terms and conditions, as well as the rest of this legal notice, apply to individuals who contact or submit their CV to the COMPANY to apply for a position; hereinafter referred to as the “Candidate”.

• Purpose
  To manage and facilitate the Candidate’s recruitment process for one of the open positions at the COMPANY. The information will be used as follows:
  • To proceed with the selection process of candidates and hiring; as well as to answer all the Candidate’s questions.
  • To allow sending the CV to the COMPANY to apply for a job position.
  • To conduct tests and interviews to assess the Candidate’s knowledge.
  • To contact previous employers to verify references provided.
  • To provide information about current and future job offers.
  • Generally, to assess the Candidate’s suitability for the job position and their skills and abilities.
• What type of personal data do we hold about you and how do we collect it?
  • Details that you provide when registering or applying for a job vacancy at the COMPANY or when requesting information about employment opportunities, which includes your CV, previous experience in other companies, training information, jobs and references, and any additional information you provide during interviews.
  • The results of skill assessments, questions, and answers given during interviews.
  • Academic and professional information: your academic history, membership in professional bodies, courses taken, and qualifications obtained.
  • Any additional data you provide in your messages and communications, comments, or queries.
• Legal Basis for Data Processing
  Compliance with the regulations applicable to the company-candidate/employee relationship. The legal basis is the legitimate interest and consent of the user/applicant/official bodies/website visitor.
• Recipients of the Data
  The Candidate’s data may be accessed by technology service providers that provide the COMPANY with selection process management services, such as Zoho EU.
• Conservation
  The Candidate’s data will be retained for the duration of the selection process and, if the Candidate does not object in writing to the processing of their data, it will be kept for as long as necessary for the purposes set out above. It is important to consider that the Candidate may be interested in participating in future recruitment processes; therefore, the data will be retained for up to twenty-four (24) months after the completion of the selection process.

VI. How long will we keep your data?

We will only retain your personal information for as long as is necessary for the purposes set out in the section “What data is collected for” and “Data processing of job seekers contacting the COMPANY” or to comply with legal obligations.

VII. Does the COMPANY share the information it collects?

We may share or provide your information with:

• Service providers, in order for you to receive the requested service. They will have access to the information necessary to perform their functions, but may not use it for other purposes. Service providers must treat personal information in accordance with this Privacy Policy and applicable data protection legislation.
• Third party service providers who provide us with customer service, marketing, data or payment processing, business analytics, or similar services.
• Third parties in order to comply with a legal regulation. The COMPANY may disclose your personal information when necessary to comply with the law, enforce the terms of use, or protect the rights, property, or safety of the COMPANY, its users, or third parties. Upon lawful request, the COMPANY may share personal information with authorities in connection with requests for information relating to criminal investigations and suspected illegal activities.
• Changes in ownership. If a third party acquires a majority of our company’s assets, or the ownership of our company changes, we inform you that the COMPANY may transfer your data to the acquirer’s entities for the purpose of continuing to provide the services that are the subject of the data processing. At the time of the change, the COMPANY will inform you who the new controller is; and the new controller will contact you to inform you about your identification data.

VIII. What rights do Users have?

Users may exercise their rights of access, rectification, cancellation and opposition in relation to their data, bearing in mind that the exercise of these rights is very personal, so it will be necessary for the affected party to prove their identity. The exercise of these rights must be made in writing, signed by the owner of the data, indicating their address, attaching a copy of their National Identity Document or other supporting document; and in the case of acting on behalf of someone, or of a legal entity, a photocopy of the document accrediting such representation. Any means that can prove the sending and receipt of the application must be used, the COMPANY places at your disposal its postal address and the following e-mail address ‘info ARROBA cleverals.com’.

The rights of limitation and portability can only be requested from 25 May 2018. Finally, we also inform you of the link to the Spanish Data Protection Agency where you can find all the information and exercise your rights.

IX. How do we protect User data?

The COMPANY has adopted the necessary measures to maintain the required level of security, according to the nature of the personal data processed and the circumstances of the processing, in order to avoid, as far as possible and always according to the state of the art, its alteration, loss, unauthorised processing or access. As mentioned above, the personal data provided will not be transferred to third parties without prior authorisation from the owner of the data.

X. About the use of cookies

To log in to the control panel you will need to have cookies enabled, which are transmitted from the cleverals.com server. Cookies are small files that store information on your computer that will identify you, indefinitely, on our server.

XI. Changes to the Privacy Policy

The COMPANY may update this Privacy Policy, and terms and conditions of use, in the future. Updates will be effective upon posting on this site. We will notify our users of any material changes to this Privacy Policy by sending a notice to the e-mail address they have provided to us or by posting a notice on our site. We encourage you to check this Privacy Policy periodically to review the most current version.

Please be advised that by accepting these Terms of Use you consent to the terms set out in these Terms of Use.

XII. Safeguard of Validity

In the event that any provision of this Legal Notice is considered null, invalid, or unenforceable by a judicial or administrative authority, such nullity, invalidity, or unenforceability shall not affect the other provisions contained in this document. The remaining provisions of this Legal Notice shall retain their full force and effect.