Cleverti is committed to respecting your privacy.
When submitting your data, you acknowledge that you have the power and ability to do so.
Due to the open nature of the internet, Cleverti advises you not to submit confidential information online.
1. Name and contact of the Data Controller
The Organization responsible for the treatment is Cleverti – Tecnologias e Inovação, Lda based in Alameda Fernão Lopes, 16 – 13º, 1495-190 Lisboa, Portugal, NIPC 508828589 phone +351 214 124 600, email: [email protected]
2. Whish data do we collect and what do we use them for?
a. Direct Collection
As a website visitor, you are not required to provide any personal data to visit Cleverti’s website. Your personal data are only collected when you subscribe to an available functionality required for Cleverti to provide any information or clarification requested, allow access to events, newsletters, articles, etc. This presupposes the completion of specific forms where personal data are collected. In addition, Cleverti may contact you for the purpose of presenting Cleverti’s offer, sending proposals and/or scheduling meetings.
The data we collect for these purposes are as follows:
v. Company Name
Providing data marked with an * is mandatory if you wish to receive personalized information regarding our services, attend webinars and other events, download information about our offer, subscribe newsletters and/or receive proposals for the provision of services, as well as prior or subsequent communications.
Providing your personal data does not constitute a legal or contractual obligation, neither a necessary requirement to enter into a contract, unless you have applied for a job or internship with the company and have been selected.
In such case, providing the following personal data will be required:
Identification document number and validity – Citizen’s Card, Identity Card, Passport, etc.
Social Security number
Failing to provide such data results in the impossibility of celebrating an employment or internship contract.
b. Indirect Data Collection:
Cleverti, through Google Analytics, collects the following aggregated data: geographical origin (city, country), language, device type, operating system, browser, operator, age range, gender, date and time of access and addresses of referencing data, IP address.
Cleverti will monitor all statistical information related to the use of our website in an aggregated and anonymous way. The data used for this purpose does not contain personally identifiable data or private information.
Analysis from the aggregated statistical information will be carried out to interpret the patterns of use of the website and to continuously improve service levels and user satisfaction. The aggregated statistical information resulting from the analyses carried out may be disclosed to third parties or publicly.
3. Cookies Policy
“Cookies” are small text files that are stored on your computer or mobile device through your browser, retaining only generic information related to your User’s preferences. They allow access to specific areas of the website and a faster and more efficient navigation, eliminating the need to repeatedly enter the same information.
By clicking on the cookies banner on Cleverti’s website, you are accepting the introduction of cookies on your computer or other devices as stated above, without limiting your control and management rights.
All browsers allow the user to accept, refuse or delete cookies, namely by selecting the appropriate settings in the respective browser. At any time, the user can, through the browser, decide to be notified about the reception of cookies, as well as block their entry into their system. Removing or blocking cookies on the website may limit access to some areas of the website. To know our cookies policy, click here.
4. What we do with your data (purposes and legal basis)
If you have sent us your curriculum vitae, we will consider you in recruitment processes, so the data will be sent to the Recruitment Area for analysis, processing and eventual selection.
Cleverti collects your contact details in order to provide the information or clarification requested or to allow you access to webinars, papers, newsletters, articles, etc, as defined at a. Direct collection.
Cleverti may also, with your consent, use the contact data you provided in Marketing campaigns or communications regarding our service offering or those of our Partners. In these situations, you are given the possibility to object to the sending of subsequent communications for the purposes of direct marketing, by selecting the corresponding field or sending an email to [email protected]
Forms: Sending requested information and providing access to webinars, case studies, articles, newsletters, etc. – Basis: User consent
Contact via email: Reply to the information requested by the user. Rationale: User consent
Spontaneous application / response to a job advertisement: Selection and recruitment Basis: User consent in cases of spontaneous application; in the cases where an employment or internship contract is celebrated, the basis is contract performance.
Google Analytics: Website Optimization: Rationale: Cleverti’s Legitimate Interests
Web beacons and conversion pixel Facebook and Linkedin: measuring effectiveness of communication on social networks Rationale: Cleverti’s legitimate interests
The data subject may request Cleverti to analyse the prevalence of the grounds for the processing of personal data over the interests, rights and freedoms of the data subjects.
5. Data Recipients
In the case of submitting applications and curricula vitae, the Recruitment Area is the recipient of data; in the case of contacts for sending Proposals, recipient is the Sales Area.
In the remaining cases, Cleverti’s Marketing or Management are the recipients (in cases of exercise of rights by Data Owners).
6. How long and where do we store your data
Cleverti will keep and maintain data until:
User ́s instructions to proceed otherwise;
Its maintenance is no longer permitted by law;
The date on which Cleverti no longer has a valid basis for processing your data,
whichever occurs first.
7. Disclosure of data
Cleverti does not disclose personal data collected, unless required by law or by competent authorities.
8. Transfers to third countries
There are no data transfers to third countries.
9. Protection of data against unauthorized access, alteration or destruction
Cleverti takes the necessary and legally required precautions to ensure the protection of information collected through Cleverti’s website. These precautions ensure the offline security of such information.
Among others, the following technical and organizational measures are implemented to guarantee the security and confidentiality of personal data: physical security (through access control), logical separation of records, access passwords and access levels, firewalls and antivirus programs.
10. Your Rights
All personal data are processed in accordance with the provisions of Law No. 67/98 and of October 26 and in the EU Regulation 2016/679 of the European Parliament and of the Council, with the holders of personal data having the following rights, being able to exercise them, personally at our facilities or in writing, via email to [email protected] , at any time and free of charge.
Right of access: to know if Cleverti has your data and if so the right to access them.
Right of rectification: to correct or complete incorrect or incomplete personal data.
c. Right to data erasure: erasure of your personal data if they are no longer necessary for the purpose communicated to you; your consent is withdrawn; if the data have been processed unlawfully and if the data subject opposes the processing of their data and there are no prevailing legitimate interests of Cleverti.
Right to limitation of treatment: in this case Cleverti will only be able to store the data. It applies if the holder disputes the accuracy of his/her data; if the processing is unlawful, but the data subject objects to the erasure and if Cleverti no longer needs the data, but they are required by the data subject for the purposes of declaring, exercising or defending a right in a legal proceeding.
Right of portability: the holder may wish to receive their data from Cleverti in a structured, commonly used and machine-readable format. This right applies when data has been collected based on your consent or the performance of a contract with Cleverti and the data is being processed by automated means.
Right of opposition: in cases where Cleverti processes your data for the purposes of direct marketing, the holder can at any time oppose this treatment, and the data will no longer be processed for this purpose. In other cases, that is, when the legal basis of the treatment is Cleverti’s legitimate interests, the holder may object to the treatment at any time for reasons related to their particular situation. Likewise, you may object if Cleverti uses the data for purposes other than those for which the personal data were collected.
When the legal basis for the processing of data has expired, the Data Subject has the right to withdraw his/her consent at any time and without detriment, and for this purpose contact us via email to [email protected]
The Data Subject has the right to file a complaint with the National Data Protection Commission or any other supervisory authority.
The Data Subject may at any time exercise their rights of access, erasure, rectification and limitation of the processing of their personal data, without any detriment.
11. Contact us
For any question related to the processing of your personal data, you can contact Cleverti by phone (+351 214 124 600) or send an email to [email protected]
12. Revisions and changes