Clinch Technology Limited (“Clinch”, “we”, “us”, “our”) know that our users and customers (“you”, “your”) care about how your personal data is used and shared and we take your privacy seriously. We are focused on protecting your personal data and doing the right thing by you in terms of your privacy rights.
This policy does not apply to the practices and processing of our Customers, to companies that we do not own or control, to individuals that we do not employ or manage, or to services provided by other companies but accessible through our Website.
We process Personal Data when you are accessing or using our Website or Services as a non-registered user (“User”) or as our registered customer (“Customer”). Our Services are accessible to you after you have signed up on our Website and have logged on as Customer to your Clinch Account.
2. WHAT INFORMATION DOES CLINCH COLLECT?
We gather Personal Data, if and to the extent it is necessary to provide our Services to you, and if we are entitled or obligated to process Personal Data under applicable law. Set out below in this Section 3 are the categories of Personal Data that we use and the purposes for which we use them. The categories of companies or persons who may receive Personal Data are set out Section 5 below.
2.1. Information You Provide to Us:
Your Personal Data: We process Personal Data you actively and knowingly provide to us. For example, we collect Personal Data such as your name and email address if you sign up for a newsletter or you request a demo of our services.
If you sign up for our Services, some information is mandatory to create an individual Clinch Account. The same applies if you would like to use a specific feature within our Services. We will inform you which information is mandatory in each single case so that you can choose to use the respective Service or not. If you choose not to provide us with certain information, you may not be able to register with us or to take advantage of some of our features.
Your Candidates’ Personal Data: In order to provide you with our Services, we also process Personal Data you choose to provide us with respect to your candidates, potential job applicants, members of your talent network and other prospective employees (collectively the “Candidates”). The Candidates’ Personal Data (“Candidate Information”) that we typically process includes the names and email addresses of your Candidates, but will also include any other information you or the Candidates choose to provide us with (which must only be provided in compliance with applicable law).
Sensitive Data: We do not knowingly process information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation (collectively, “Sensitive Information”). If you ask Candidates for Sensitive Information or they reveal any Sensitive Information to you through our Services, you must ensure that you remain compliant with all applicable laws including (but not limited to) ensuring that you obtain prior consent in relation to the collection and processing of Sensitive Information.
Anonymized Information: We may also anonymize Personal Data so that no natural person can be individually identified anymore. We use that anonymized and/or aggregated information for our own purposes or provide that information to our partners for visitor statistics and analysis of our Website, Services and our partners services.
2.2. Information Collected Automatically:
Whenever you interact with our Website or Services, we – or service providers commissioned by and processing data on behalf of us – automatically process information on server logs by using so-called “browser cookies” or similar technical means. These technical means are either transferred to or communicate with your computer or mobile device to remember that you have registered and are logged in to your Clinch Account, or to recognize the browser or mobile device and tell us how and when pages on our Website are visited.
Log Data: When you visit the Website, whether as a Customer or a non-registered User just browsing, our servers automatically record information about the browser or mobile app with which our Website is opened (“Log Data”). Log Data includes computer’s/mobile’s browser type, the requested webpage of our Website or feature of our Service, webpages visited before our Website, the time spent on those pages or features, subjects of searches on our Website and Services, access times and dates, and other related statistics.
Analytics and Monitoring: We use this Log Data to monitor and analyse the use of the Website and the Services and for the Website’s technical administration, to increase our Website’s functionality and user-friendliness, and to better tailor it to our visitors’ needs. Additionally, we use Log Data including your IP address for security purposes like whitelisting, and prevention and recognition of attacks and malware.
Analytics on Our Customers’ Websites: Additionally, as part of our provision of the Services to you, if you install certain software code provided by us on your website, we will also process Log Data generated by this integration on our Customer’s website to anonymously monitor and analyse the use of our Services on that website, and for the respective technical administration, to increase our Service’s functionality and user-friendliness, and to better tailor it to your visitors’ needs.
Prevent or Opt-out: In any case, you are able to change the preferences on your browser or mobile device to prevent or limit your computer or device’s acceptance of these technical means, but this may prevent you from taking advantage of some of our Website’s or Service’s features.
2.3. Email and Other Communications:
We may contact you by email or by other means. For example, we may communicate with you about your use of the Website or Services. If you do not want to receive email or other communications from us please follow the instructions we provide to you in each of our emails.
3. WHERE DO WE STORE YOUR PERSONAL DATA?
We process and store information (including Personal Data) about our Users and Customers in Germany and the United States of America.
As a Customer, your Enterprise Agreement will include specific terms in relation to data protection. Additionally, in the event of data processing on behalf of our Customers, a data processing agreement (or similar) will also be entered into.
4. WILL CLINCH SHARE ANY OF THE PERSONAL DATA IT RECEIVES?
We neither rent nor sell your Personal Data or your Candidates’ Information in personally identifiable form to anyone. However, we may share such Personal Data with third parties as described below.
4.1. Trusted Third Parties:
We employ other companies and people to either perform tasks on our behalf or to provide specific features to you on your request. Unless we tell you otherwise, such third parties do not have any right to use the Personal Data we share with them beyond what is necessary to assist us. This includes third party companies and individuals employed by us to facilitate our Services, including the provision of maintenance services, database management, web analytics and general improvement of the Services. We note that we may be subject to liability for sharing information to third parties in a manner inconsistent with our promises or the Privacy Shield Principles.
4.2. Protection of Clinch and Others:
4.3. With your Consent:
Except as set forth above, you will be notified when your Personal Data may be shared with third parties and will be able to object to the sharing of this information. Please take note: Our Website offers publicly accessible blogs and community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them.
5. IS THE PERSONAL DATA SECURE?
We take appropriate and reasonable precautions to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction. You can find details concerning our security measures (such as encryption) in our Security Policy.
6. WHAT RIGHTS DO I HAVE?
In relation to your Personal Data, you always have the following rights to the extent available under applicable law:
We will retain your information for as long as your Clinch Account is active or as reasonably necessary to provide you with the Services (and there may be specific terms in any applicable Enterprise Agreement which deal specifically with our data retention obligations).
You may request deletion of your Personal Data by contacting us at email@example.com. Please note that some information may remain in our private records after your deletion of such information from your account (only if and to the extent permitted by applicable law). We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may use any aggregated and anonymized data derived from or incorporating your Personal Data after you update or delete it, but not in a manner that would identify you personally.
To request removal of your Personal Data from our blog or community forum, contact us at firstname.lastname@example.org or follow the instructions provided in the email communication you received.
If we make material changes in the way that we must obtain or renew your active prior consent for processing your Personal Data, we will notify you by sending you an email prior to the change becoming effective. If you don’t agree to the changes you may not be able to use the features or services that are related to this consent.
8. OUR COMMITMENT TO PRIVACY
9. CONCERNS AND RESOLUTION
Attn: Data Protection Officer Clinch Technology Limited WeWork Block D, Iveagh Court, Harcourt Street, Dublin 2, Ireland