Privacy Policy

Privacy Policy

Clupea has created this privacy policy because we gather important information from you and regard the privacy of data as one of the most vital aspects of our industry. This policy is a way in which we wish to be transparent with our methods and practices of information gathering and dissemination. Clupea complies with the E.U. General Data Protection Regulation (GDPR), which came into effect on May 25th, 2018.

The information we collect and how we use it

Website visitors

This privacy policy is intended to cover the information Clupea receives from individuals who visit our website, or any landing page connected to such (“Visitor”).

When additional information about Clupea or product in the Clupea suite is requested via our website, Clupea may, on occasion, request Visitor to provide contact information. This data may be in the form of, but not limited to, names, organizations, titles, phone numbers, addresses, and email addresses.

Clupea uses the data collected to perform the services requested such as contacting the Visitor for a requested demo or to complete some other service request. For example, the information may also be used to contact the Visitor for the purpose of promotions and events.

Clupea may also collect information regarding your interaction with our website. For example, cookies may be used, to collect data about the pages you visit, the links you click, and other actions you take on our pages. We also collect standard information your browser sends to every website you visit (provided these settings have not been deactivated), such as your I.P. address, access times, and referring website addresses. This information is primarily used, to compile non-identifying aggregate statistics about site usage and to improve the quality of our website.

Customer representatives
This privacy policy also describes how Clupea processes personal data about you in your capacity as a representative of a company that is a customer or a potential customer to Clupea.

As regards representatives for a company or an organisation that is customer or potential customer of Clupea, we collect, either directly or indirectly through our partners and suppliers, the following information about you: contact information, such as name, address, telephone number, email address, title, position and employer.

Your personal data is usually collected, either directly or indirectly through our partners and suppliers, from the company or organisation that you represent or directly from you, e.g. by email, our website, social media and similar online platforms, or in connection with events or meetings. Clupea may also use external information services to supplement existing data.

Your personal data is processed for the following purposes:

To be able to market the Company’s brand, products, and services.
To be able to provide Clupea’s products or services.
To be able to develop and improve Clupea’s products or services.
To ensure payment.
To be able to fulfil legal requirements, e.g. accounting requirements.
To be able to respond to and compensate customers in connection with complaints and warranty matters.
To be able to improve the quality of Clupea’s customer service.

Your personal data is processed on the basis of the following legal bases:

The processing is necessary for Clupea’s legitimate interest in marketing its products, services and brands to the customer, supplier, or partner that the representative represents (legitimate interest).
If and to the extent that processing in connection with Company events includes personal data concerning allergies, disabilities or similar data (health data), such processing is carried out on the basis of the representative’s consent.
The processing is necessary for Clupea’s legitimate interest to contact representatives in order to fulfil its obligations under the agreement with the customer that the representative represents.
The processing is necessary for Clupea’s legitimate interest in evaluating, developing, and improving its products, services, and marketing (legitimate interest).
The processing is necessary for Clupea’s legitimate interest in receiving payment for its provision of products and services (legitimate interest).
The processing is necessary for compliance with Clupea’s legal obligations.
The processing is necessary for Clupea’s legitimate interest in ensuring the quality of its products and services as well as to maintain its business relationships (legitimate interest).
The processing is necessary for Clupea’s legitimate interest in ensuring the quality and efficiency of Clupea’s customer service (legitimate interest).


With whom does Clupea share your personal data?
Any personal information collected, whether it is mentioned specifically above or any previously unmentioned type of information, will never be collected for the purpose of selling such data. However, Clupea may disclose your personal data to its suppliers and/or partners, if the suppliers and/or partners need your personal data to fulfil their undertakings toward Clupea. In addition, personal data may be transferred to suppliers of cloud solutions since Clupea uses cloud solutions to store certain information.

Transfers of personal data to third countries
Clupea may transfer your personal data to the USA. If personal data is transferred to a country outside the EU/EEA, Clupea will ensure that the transfer is legal, either on the basis that the European Commission has decided that the third country in question ensures an adequate level of protection or, in the absence of an adequacy decision, on the basis of appropriate safeguards, such as binding corporate rules or standard contractual clauses.

Your rights

A summary of your rights according to applicable legislation is set out in the table below.
Right of access. You have the right to access your personal data and to obtain a copy of the personal data concerning you that is processed by Clupea.
Right to rectification. If the personal data concerning you that is processed by Clupea is inaccurate, incomplete, or outdated, you have the right to obtain rectification of such personal data.
Right to erasure. You have the right to request the erasure of personal data concerning you. Unless Clupea has a legal basis to continue the processing of the personal data concerning you, such personal data will be erased.
Right to object. In certain circumstances you have the right to object against Clupea’s processing of your personal data.
Right to restriction of processing. In certain circumstances you have the right to obtain restriction of the processing of your personal data. Where processing has been restricted, Clupea may only under particular circumstances carry out other processing activities than storage in respect of the personal data.
Right to data portability. Where your personal data is processed on the basis of your consent or on a contract with you, you have the right to receive the personal data concerning you in a machine-readable format and request that those data are transmitted to another controller.

Cookies
When interacting with the Clupea website, cookies may be used to help make your experience smooth and rewarding. Cookies are small data files stored on your computer and technology used by most websites today. Cookies, used alone, do not identify you personally. They only recognize the browser used.
Clupea may also use persistent cookies to identify you as a prior Visitor to the Clupea webpage. We are especially careful about the security and confidentiality of the information stored in persistent cookies. For example, we will not store account numbers or passwords in persistent cookies. Users can disable their web browsers’ ability to accept cookies and will be able to browse our website.

Third-party cookies
Clupea may engage third parties to track and analyse non-personally identifiable usage and volume statistical information from Visitors to our website or service for marketing and administrative purposes. Such third parties may use cookies to help track Visitor behaviour. Such cookies will not be used to associate individual website Visitors to any personally identifiable information. All data collected by such third parties on behalf of Clupea is used only to provide us with information on site usage.

Third-party websites
Pages within Clupea’s website may contain links to other websites. We do not take responsibility for the privacy practices or the content of these other websites. When visiting these sites, it is your responsibility to need to check the policy of any web sites to understand its policies. When accessing a linked site, you may be disclosing your private information. It is your responsibility to keep such information private and confidential.

Contact
Do not hesitate to contact us at contact@clupea.com if you have any questions about this Privacy Policy, the processing of your data, or if you would like to exercise any of your rights under applicable data protection legislation.