1. Introduction

Welcome to the CLOOV S.R.L. Società Benefit (“Company,” “we,” “us,” or “our”) website. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal data when you visit or interact with our website (the “Service”). By accessing or using the Service, you consent to the practices described in this Privacy Policy.

2. Data Controller and Contact

The Data Controller for all personal data processed under this Privacy Policy is:

CLOOV S.R.L. Società Benefit
Viale Bianca Maria 28, 20129, Milano (MI), Italia
P.IVA 12459830969, SDI X2PH38J
Represented by: Chiara Airoldi and Olimpia Santella
Email: info@cloov.tech

For any questions or concerns regarding the processing of your personal data, you may contact us at info@cloov.tech.

3. Scope of this Privacy Policy

This Privacy Policy applies to personal data collected through:

  • Our website (including any subdomains or mobile versions).
  • Any related services, sales, marketing, or events that reference this Privacy Policy.

4. Legal Framework (GDPR and Other Applicable Laws)

We are based in Italy and process personal data in accordance with:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council (“General Data Protection Regulation,” GDPR).
  • Any additional relevant local data protection regulations (e.g., the Italian Legislative Decree no. 196/2003 as amended).

5. Types of Personal Data We Collect

We may collect personal data from or about you in a variety of ways, including:

  1. Information You Voluntarily Provide
    • Contact Information: name, email address, phone number, address, or similar details you provide when filling out forms or contacting us.
    • Communications: the content of any messages you send us, including email and form submissions.
  2. Information Collected Automatically
    • Usage Data: IP address, browser type, operating system, referral URLs, pages viewed, links clicked, and device identifiers.
    • Cookies and Similar Technologies: small text files or similar technologies used to collect information about your interactions with the Service. (See Section 8 on Cookies.)
  3. Information from Third Parties
    • We may receive additional information from third-party analytics providers, social media platforms, or other third-party integrations (where applicable).

6. Purposes and Legal Basis for Processing

We collect and process your personal data for the purposes and under the legal bases outlined below:

  1. Provision of Services:
    • Purpose: To operate, maintain, and provide features of our website.
    • Legal Basis: Performance of a contract or steps taken at your request prior to entering into a contract (Art. 6(1)(b) GDPR).
  2. Customer Support and Communications:
    • Purpose: To respond to your inquiries and communicate with you regarding customer support.
    • Legal Basis: Legitimate interests or performance of a contract (Art. 6(1)(f) or 6(1)(b) GDPR).
  3. Website Analytics:
    • Purpose: To analyze the use of our website to improve functionality, user experience, and to understand user preferences.
    • Legal Basis: Consent or legitimate interests (Art. 6(1)(a) or 6(1)(f) GDPR).
  4. Marketing and Promotional Communications (if applicable):
    • Purpose: To send you updates, newsletters, and promotional materials where you have opted-in to receive them.
    • Legal Basis: Consent (Art. 6(1)(a) GDPR). You can withdraw your consent at any time.
  5. Legal Obligations:
    • Purpose: To comply with legal obligations, respond to lawful requests, and prevent illegal activities.
    • Legal Basis: Compliance with a legal obligation (Art. 6(1)(c) GDPR).

7. Data Retention

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law. Once the retention period expires, your personal data will be deleted or anonymized.

8. Cookies and Similar Technologies

  1. Types of Cookies: We use “strictly necessary,” “functionality,” “analytics,” and, where applicable, “advertising” cookies to operate our website and enhance your user experience.
  2. Managing Cookies: You can manage cookie preferences through your browser settings or via the cookie consent banner (if provided). Disabling certain cookies may affect website functionality.

9. Data Sharing and Disclosure

We do not sell your personal data. We only share or disclose personal data as follows:

  1. Service Providers
    • With third-party vendors that perform services on our behalf (e.g., hosting providers, analytics platforms). These vendors are contractually obligated to protect your data.
  2. Legal Compliance and Protection
    • If required by law, in response to legal processes, or to protect our rights, property, or personal safety, or that of our users or the public.
  3. Business Transfers
    • In connection with a merger, acquisition, or sale of all or a portion of our assets, in which case your personal data may be transferred as part of the transaction. We will notify you of any changes in ownership or use of your personal data.

10. International Data Transfers

If we transfer your personal data outside the European Economic Area (EEA) to third-party service providers, we ensure that such transfers comply with applicable data protection laws, such as by implementing the EU Standard Contractual Clauses or other appropriate safeguards.

11. Your Data Protection Rights

Under the GDPR (where applicable), you have the following rights regarding your personal data:

  • Right of Access: Obtain confirmation whether we process your personal data and, if so, request a copy of it.
  • Right to Rectification: Request that we correct any inaccuracies in your personal data.
  • Right to Erasure (Right to be Forgotten): Request the deletion of your personal data under certain circumstances.
  • Right to Restrict Processing: Ask us to restrict or block the processing of your personal data in certain situations.
  • Right to Data Portability: Request a copy of your personal data in a structured, commonly used, and machine-readable format and transmit that data to another controller.
  • Right to Object: Object to our processing of your personal data where we rely on a legitimate interest as the legal basis.
  • Right to Withdraw Consent: Where we rely on your consent, you can withdraw it at any time.
  • Right to Lodge a Complaint: You have the right to lodge a complaint with your local Data Protection Authority if you believe your rights have been violated.

To exercise any of these rights, please contact us at info@cloov.tech. We will respond to your request in compliance with the GDPR and other applicable laws.

12. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. However, please note that no method of data transmission or storage is completely secure, and we cannot guarantee absolute security.

13. Third-Party Links

Our website may contain links to external sites that are not operated by us. We have no control over the privacy practices of these sites and assume no responsibility for their content or policies. We encourage you to review the privacy policies of any third-party sites you visit.

14. Children’s Privacy

Our Service is not directed to or intended for use by children under the age of 16. We do not knowingly collect personal data from children. If you believe we may have collected personal data from a child without appropriate consent, please contact us, and we will promptly address the issue.

15. Updates to This Policy

We may update this Privacy Policy from time to time. When we make changes, we will revise the “Effective Date” at the top of this page and, where appropriate, provide additional notice. We encourage you to review this Policy periodically to stay informed about how we process your personal data.

16. Data Processing for CVs and Partner Relationships

For more details on how we process personal data in compliance with EU Regulation No. 679/2016 (GDPR) and Legislative Decree No. 196/2003, as amended by Legislative Decree No. 101/2018, please refer to:

  • The Policy for received CVs, including those submitted by third parties, at the following link: https://drive.google.com/file/d/166tJ5YXUb7nKSRxgvUcJqSzMM9Ou7jIc/view?usp=drive_link
  • The Policy for collaborators and partners, covering data processing related to contractual or pre-contractual relationships, at the following link: https://drive.google.com/file/d/1IUjVWn7kjnJZWK0LbWm2kQsgTzAmx339/view?usp=drive_link.

16. How to Contact Us

If you have any questions or comments about this Privacy Policy, our data practices, or to exercise your data protection rights, please contact us at:

CLOOV S.R.L. Società Benefit
Viale Bianca Maria 28, 20129, Milano (MI), Italia
P.IVA 12459830969, SDI X2PH38J
Email: info@cloov.tech