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This privacy notice contains essential information on the methods and purposes by which Clutch S.r.l. (the “Controller”, “Clutch” or the “Company”) processes your personal data in its capacity as Data Controller.
You are invited to read this document carefully and to submit any requests for clarification or further information using the contact details provided below.
Clutch is the Data Controller of the personal data referred to in this privacy notice:
Name: Clutch S.r.l.
Registered office: Via Giuseppe Piazzi 2–4,
20159 Milan (MI), Italy
VAT number and Tax Code: 13506030967
Email: privacy@clutch-hr.it
Clutch Data Protection Officer’s email: dpo@clutch-hr.it
The personal data processed include, by way of example and not limited to, first name, last name, place and date of birth, tax code, residence, gender, telephone contact details, education, work experience, and any additional data you may have included in your CV and/or otherwise communicated to the Controller in the context of its recruitment, executive search, and consulting activities.
If you have been contacted by Clutch via LinkedIn or through a professional email address you use on the LinkedIn platform, for the purpose of assessing your potential interest in Clutch’s services, the personal data we process are limited to your first and last name, contact details, and any further information relating to your professional activity that you have made publicly available on LinkedIn.
Please also be informed that the Controller may process “special categories of personal data” pursuant to Article 9 of the GDPR. In particular, this includes data capable of revealing health status, such as membership in protected categories, which may be included in your CV or otherwise provided to the Company. Such data may be processed in order to assess applications for job positions falling within the scope of targeted employment placement. In the absence of such circumstances and of the conditions set out in Article 9 of the GDPR, such data will not be taken into consideration and will be promptly deleted.
The processed data are collected directly from you as the data subject and/or from third parties in relation to your previous work experiences (only with your prior consent) and/or from publicly accessible sources, such as websites or your profile on professional social networks (e.g., LinkedIn).
3.1 – Such data are processed for purposes connected with or instrumental to the performance of the recruitment and selection activities carried out by the Controller, as well as for the provision of other services offered by Clutch to employers and/or candidates for the relevant job positions, such as consulting activities during the so-called onboarding phase following the hiring of a candidate (to the extent that such processing activities are carried out by Clutch in its capacity as Data Controller and not as a data processor on behalf of the relevant employer).
Any personal data you provide that fall within the special categories of data pursuant to Article 9 of the GDPR will be processed, only where necessary and relevant, for the purpose of assessing your application for job positions falling within the scope of targeted employment placement.
With regard to ordinary personal data, the legal basis for the processing for the above purposes is the performance of pre-contractual measures taken at your request (Article 6(1)(b) of the GDPR).
With regard to special categories of personal data, the legal bases for the processing are the necessity to comply with obligations and to exercise specific rights of the Data Controller or of the data subject in the field of employment law and social security and social protection, to the extent that the Company is authorized by Union or Member State law or by a collective agreement under Member State law, and provided that appropriate safeguards for the fundamental rights and interests of the data subject are in place (Article 9(2)(b) of the GDPR).
3.2 – Subject to your prior consent, your personal data may be processed for the purpose of obtaining information relating to your professional references from previous employers and—where applicable—communicating such information to the company for which the recruitment process is ongoing.
The legal basis for this processing is the data subject’s consent (Article 6(1)(a) of the GDPR).
3.3 – The Controller may also process publicly available information relating to your profile on social networks or other professional websites (e.g., LinkedIn, company websites) in order to pursue the purposes set out in section 3.1, as well as to propose potential meetings to discuss possible professional collaborations with Clutch and to assess your interest in receiving our services, and to verify that the data you have provided as a candidate for a job position correspond to what you have declared.
Such processing is limited exclusively to information of a professional nature and is carried out solely for the purpose of assessing the specific risks associated with the type of activity to be performed based on the profile sought, while adopting all necessary measures to ensure an appropriate balance between your interests, rights, and fundamental freedoms and our legitimate interest.
The Controller may also collect and process publicly available contact details obtained from professional websites for the purpose of contacting you in connection with its recruitment and selection activities.
The legal basis for such processing is the Company’s legitimate interest (Article 6(1)(f) of the GDPR).
3.4 – Where necessary, your data may be processed in order to establish, exercise, or defend the Controller’s rights in out-of-court and/or judicial proceedings. The legal basis for such processing is the Company’s legitimate interest (Article 6(1)(f) of the GDPR).
The provision of data is mandatory for the purposes of recruitment and selection activities and in order to benefit from the services offered by the Controller. Failure to provide such data will prevent the Company from carrying out these activities and will result in your application not being considered by potential employers.
An exception applies to the provision of data referred to in section 3.2 above, which is optional and provided on a voluntary basis.
Without prejudice to the data retention obligations provided for by law, Clutch will retain the personal data in question only for the time strictly necessary to fulfill the purposes of the processing. Data collected during a recruitment process for one or more specific job positions may also be retained beyond the end of such process, or beyond the point at which it becomes clear that their processing is no longer necessary for that process, in anticipation of further job opportunities, without prejudice to your right to object to the processing.
In particular:
– the data processed for the purposes referred to in sections 3.1 and 3.2 will be processed for 36 months from the last activity carried out, without prejudice to your right to request deletion at any time;
– the data processed for the purposes referred to in section 3.3 will be processed for 36 months from the last activity carried out, without prejudice to your right to object to the processing at any time. Data processed to contact you regarding possible professional collaborations will be deleted after six months if no response is received from you and, in any case, within 36 months from your last activity expressing interest in the services provided by Clutch;
– the data processed for the purposes referred to in section 3.4 will be processed for the entire duration of the dispute, until the expiration of the time limits for bringing any appeals.
We inform you that, pursuant to applicable law, you are granted the following rights expressly recognized by the GDPR:
Such requests, as well as any requests for clarification or further information, may be addressed to the Data Controller, including through the appointed Data Protection Officer (DPO), using the contact details indicated above.
The data may be disclosed to entities acting as independent data controllers (including the Company’s client companies, professionals, public authorities, audit or supervisory bodies), including in compliance with legal obligations, or processed on behalf of the Company by entities appointed as Data Processors and provided with appropriate operating instructions (including, for example, service providers, consultants, and external collaborators), always within the limits of the purposes set out above.
The personal data we collect may be stored, retained and/or processed where we or our partners, affiliates and third-party providers have facilities for such purposes (for example, in the case of cloud storage, at the location of the relevant servers). Such locations may differ from the country in which you initially provided your data and may include countries that are not members of the European Union (such as the United States or Switzerland).
Any transfer of your data to other countries is carried out in compliance with the requirements of the GDPR and, in particular, is based on an adequacy decision of the European Commission, the use of the Standard Contractual Clauses adopted by the Commission, or other legal bases provided for under Chapter V of the GDPR.
At our discretion, we may update our privacy policies to reflect changes in our business processes, current accepted practices, or legislative or regulatory amendments. Should we decide to amend this privacy notice, we will publish the updated version at the same link through which this privacy notice is accessible.
Last updated: 9 May 2025.
