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This Privacy Policy contains essential information on the methods and purposes by which Clutch S.r.l. (the “Data Controller” or “Clutch”), as the owner of this website (the “Site”) and the Data Controller of the personal data collected and processed through the Site, processes such personal data, as well as on the rights of the data subjects to whom the data relate.
Users are invited to read this document upon their first use of the Site and to periodically review it in order to stay informed of any changes made by Clutch.
This Privacy Notice is provided exclusively for this website. Clutch is not responsible for any other websites to which users may be redirected via hyperlinks.
Clutch is committed to ensuring the protection of users’ privacy and compliance with all applicable laws and regulations on the protection of personal data.
Clutch is the Data Controller of the personal data collected through and in connection with the use of this website:
Name: Clutch S.r.l.
Registered office: Via Giuseppe Piazzi 2–4, 20159 Milan (MI), Italy
VAT number and Tax Code: 13506030967
Email: info@clutch-hr.it
Clutch Data Protection Officer’s email: dpo@clutch-hr.it
The data we collect include both information knowingly and actively provided by users when interacting with the features and services made available through the Site (e.g., responding to job postings or using features that allow users to contact and/or schedule an appointment with Clutch), as well as any information automatically transmitted by users’ IT devices during access to and navigation of the Site or interaction with the features made available through it.
Through this Site and in the course of its normal operation, the Data Controller may collect browsing data whose transmission is implicit in the use of Internet communication protocols. When you visit our website, our servers may automatically record standard data provided by your web browser. Such data may include the Internet Protocol (IP) address of your device, browser type and version, pages visited, date and time of the visit, time spent on each page, other details relating to the visit, and technical details relating to any errors encountered.
These data are used solely for the purpose of obtaining anonymous statistical information on the use of the Site and to ensure its proper functioning, and are deleted immediately after processing.
Please note that, even where such data do not in themselves constitute personal data, they may be combined with other data in order to identify individuals and associate them with specific behaviors (such as browsing the Site or carrying out IT-related activities concerning it). Such data may be used to ascertain liability in the event of alleged cybercrimes to the detriment of the website and/or Clutch.
Through the “Meet one of our consultants” page of this Site, or other pages that allow users to contact Clutch, the Company may request personal information which may include one or more of the following data: (i) first and last name, (ii) email address, (iii) telephone/mobile number, (iv) job position, (v) company, and (vi) location (city/country).
Additional personal information may be freely and voluntarily provided by the user (e.g., through the dedicated fillable text fields, which typically constitute the content of an email sent to Clutch).
The data described in section 2.1 are processed by the Data Controller to enable users’ technical and functional access to the Site, the analysis of aggregated traffic data, and cybersecurity purposes. The legal bases for such processing are compliance with legal obligations and the Data Controller’s legitimate interest in ensuring the proper functioning and security of the Site. In this case, we collect only the personal data reasonably necessary to allow the website to function and to be browsed.
The data described in the previous section 2.2 are collected by the Data Controller in order to allow users to interact with the features of the Site and to make use of the services specifically connected to it (e.g., data provided through contact forms). The legal basis for such processing is the performance of requests submitted to the Data Controller by the data subjects.
Further and more detailed information on the processing of personal data provided for use in the context of the recruitment and selection activities carried out by the Data Controller is available in the privacy notice, which we invite you to read here: Candidate users privacy notice.
When we collect and process personal data, and for as long as we retain them, we take appropriate measures to protect them against loss and theft, as well as against unauthorized access, disclosure, copying, use, or modification. While we make every effort to protect the personal data you provide, please be aware that no method of electronic transmission or storage is completely secure, and absolute data security cannot be guaranteed.
In any event, Clutch will always act in compliance with applicable personal data security regulations, including in the event of, and following, any personal data breach.
Without prejudice to statutory data retention obligations, Clutch will retain the personal data voluntarily provided by you only for the time necessary to fulfill the purposes of the processing. With regard to the data referred to in section 2.2 above, this period depends on the subject matter and nature of the request submitted by the user through the Site’s Contact page.
Where data are processed for purposes extending over time, they will be retained for a reasonable period starting from the last action that demonstrates the data subject’s interest in Clutch. In particular, information on the retention periods applicable to data provided for recruitment and selection purposes is available here: Candidate users privacy notice.
Longer retention periods may apply to data that are necessary (i) to establish, exercise, or defend the Data Controller’s rights in out-of-court and/or judicial proceedings, solely for the protection of the Controller’s rights, and (ii) to comply with legal obligations.
Pursuant to applicable law, each data subject has the following rights concerning their personal data, as expressly recognized by the GDPR:
Such requests, as well as any requests for clarification or further information, may be addressed to the Data Controller by writing to the contact details indicated in section 1 above.
Personal data may be disclosed to third parties acting as independent data controllers (including the Controller’s client companies, professionals, public authorities, supervisory or oversight bodies, in the case of data voluntarily provided by the user), 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).
The personal data we collect may be stored, retained, and/or processed where we or our partners, affiliates, and third-party service providers have facilities for such purposes (for example, in the case of cloud-based storage, at the location of the relevant servers). These locations may differ from the country in which the user initially provided their 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, on the basis of an adequacy decision of the European Commission or through the use of Standard Contractual Clauses adopted by the Commission.
Last updated: 18 June 2024.
