Privacy policy

Privacy Policy

At ClarineT, we value your privacy and respect your interest in knowing how information about you is collected and used. This Privacy Policy describes how we collect, use, and disclose information that we gather about visitors to our websites, including (collectively, “Sites”), and from users of the Careers portal (Portal); the ATS and career portal applications (collectively, “Apps”), as well as our services available through the Sites, Apps, and Portal (collectively, “Services”), and the information we collect when we communicate with customers, suppliers, users, or other individuals related to the Services (whether by phone, email, or other method). This Policy also outlines your rights and choices with regard to the information collected about you.

Who are “we”?: This Privacy Policy sets out how ClarineT Srl and our affiliated companies (together ClarineT or “we”) handles your personal data. ClarineT Srl is the data controller for your personal data. Where processing of personal data is undertaken by our affiliated companies, they are joint controllers with ClarineT Srl for your personal data.

Who are “you”?: This Privacy Policy applies to any visitor to our Sites and the Portal (; users of the Services; individuals who contact us or with whom we communicated via phone, email, or otherwise; and Customers and Suppliers.

To EU Residents: ClarineT processes your personal data in accordance with the EU data protection legislation, including national or international legislation implementing the EU Data Protection Directive (until superseded), the Privacy in Electronic Communications (“ePrivacy”) Directive (EU), and the General Data Protection Regulation (EU) 2016/679 (“GDPR”), as amended or superseded.

Collection and use of personal data

Anonymous data gathered from our Sites will be used:

  • To improve our customer service and to make our services more valuable to you, including tailoring our website when you log in to enrich your personal online experience.
  • To enable us to develop and market other products and services.

Personal data collected / entered through Services will be used as follows:

If you use the Services (either through the Sites, Apps, email integration and parsing, email, phone or otherwise), we will collect, both personal data about you (such as your name, contact details, photographs, professional profile, etc.), as well as sensitive personal data (such as certain information in your resume, certifications, education certificates, etc.).

We use, store, process, disclose the personal data and sensitive personal we collect under this Privacy Policy in furtherance of our legitimate business interests, which include:

Provision of Services:

  • To perform our recruitment services to you and to facilitate the recruitment process.
  • To access data about you against vacancies which we judge may be suitable for you.
  • To send your information to clients in order to apply for jobs or to assess your eligibility for jobs.
  • To send your information to affiliated companies’ clients in order to apply for jobs or to assess your eligibility for jobs.
  • To send your information to affiliated companies’ clients in order to apply for jobs or to assess your eligibility for jobs.
  • To send your information to partnership’s (joint ventures, consortiums, alliances, or similar) clients in order to apply for jobs or to assess your eligibility for jobs.
  • To enable you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you.
  • To offer our full range of recruitment services to you.
  • To answer your questions and enquiries.
  • To disclose to third parties where we have retained them to provide services that you or our client have requested, such as references, qualifications and criminal reference checking services, verification of the details you have provided from a third party source, psychometric evaluations or skill tests, or similar.
  • To carry out obligations arising from any contracts entered into between you and us.
  • To allow you to participate in interactive features of our service should you choose to use those features.
  • To use your information on an anonymous basis to monitor compliance with our equal opportunities policy.

Customer Support:

  • To communicate with you about your use of the Services; respond to your communications, complaints and inquiries; provide support; and for other customer service and support purposes.


  • To assist in advertising the Services on third party websites.

Protect Legal Rights and Prevent Misuse:

  • To protect the Services; prevent unauthorized access and other misuse; and where we believe necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms of Use or this Policy.

Comply with Legal Obligations:

  • To comply with the law or legal proceedings; for example, we may disclose information in response to lawful requests by public authorities, including responding to national security or law enforcement disclosure requirements.

Marketing and Promotions:

  • To enable us to develop and market other products and services.
  • To send you details of reports, promotions, offers, networking and client events as well as general information about the industry sectors which we think might be of interest to you.

General Business Operations:

  • Where necessary to the administration of our general business, accounting, recordkeeping, and legal functions.


Purpose of Processing /Legitimate Business Interests (see above) Legal Bases of Processing (EU Users)*
Provision of Services

Customer Support

  • Necessary to enter into or perform a contract with you (upon your request, or as necessary to make the Services available)
  • Our Legitimate Business Interests*
Marketing and Promotions


  • Our Legitimate Business Interests**
  • With Your Consent
Protect Rights and Prevent Misuse

Comply with Legal Obligation

  • Compliance with law
  • Establish, defend, or protect of legal interests
General Business Operations
  • Our Legitimate Business Interests**
  • Establish, Defend or Protect Legal Interests
  • Compliance With Law

*For the personal data from the EU that we process, this column describes the relevant legal bases for such processing under GDPR (and local implementing laws of EU member states); this does not limit or modify the obligations, rights, and requirements under the privacy laws of non-EU jurisdictions.

** For the personal data from the EU, the processing is in our legitimate interests, which are not overridden by your interests and fundamental rights.

From time to time, we may seek your consent to process, use or disclose your information for any other purpose not listed above.

We will not sell information about you to a third party or allow a third party to use information we provide for its own marketing purposes.

Data Retention

We keep your personal data for as long reasonable necessary for the purposes set out in Section above.  Except as noted below, we will retain your account profile data as necessary for our legitimate business purposes or to comply with our legal obligations (such as record keeping, accounting, fraud prevention and other business administrative purposes); generally, where we no longer have a legitimate business purpose to retain it, we will anonymize or delete such personal data within 180 days after the closing of your account. However, we will maintain your personal information longer where required for tax or accounting purposes, to ensure we would be able to defend or raise a claim, or where we have a specific need to retain, though we will generally not keep personal data for longer than seven years following the last date of communication with you. Legitimate business purposes that we may rely on to keep your personal data when you are not a customer include direct marketing (where you have not opted-out) for up to two years, facilitating the restoration or establishment of a user account in the future, maintaining ClarineT’s business intelligence systems for analytics and other internal purposes, etc. Where your information is no longer required, we will ensure it is disposed of in a secure manner.

Data Access / Disclosure / International Transfers

The personal data you provide to us, including sensitive personal information, may be accessible by our affiliated companies, clients, and the third parties specified above. Some of these affiliated companies, clients and third parties are located outside the European Economic Area. Accordingly, your personal information will be sent to or be capable of being accessed from outside the European Economic Area. When we transfer your personal information outside the European Economic Area we will take steps with the aim of ensuring that your privacy rights continue to be protected as outlined in this Privacy Policy.

Children’s Personal Data

The Services are not directed toward children and we do not encourage children to participate in providing us with any personally identifiable information. We do not knowingly collect any personal data from children under the age of 13. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal data through the Services. If you have reason to believe that a child under the age of 13, without a parent or guardian's consent has provided personal data to us through the Services, please contact us at, and we will use commercially reasonable efforts to delete that information.

Data Security Commitment

Although total security does not exist on the Internet, ClarineT shall make commercially reasonable efforts to safeguard the information that you submit to ClarineT.

How We Protect Your Information

We have implemented technical, physical, and administrative safeguards to protect your information. However, no company, including ClarineT, can guarantee the absolute security of Internet communications. Access to your data is limited to authorized ClarineT staff.

Transfer of Data in case of M&A o liquidation

We reserve the right to transfer your information to a third party in the event of a sale, merger, liquidation, receivership or transfer of all, or substantially all, of the assets of our company, provided that the third party agrees to adhere to the terms of this Privacy Policy and provided that the third party only uses your personal data for the purposes that you provided it to us. You will be notified in the event of any such transfer and you will be afforded an opportunity to opt-out.

Third Party Sources

Subject to applicable laws, we may gather information about you from integration with career tools including LinkedIn, Indeed, CareerBuilder, Dice, etc. Any information you submit to a website not belonging to ClarineT is governed by that site’s privacy statements, not this one. We encourage you to carefully read the privacy statement of any website you visit.

Service Providers

We engage certain trusted third parties to perform functions and provide services to us, including, without limitation, website hosting and maintenance, customer relationship management, database storage and management, and direct marketing campaigns. We will share your personally identifiable information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your data.

Link to Other Websites, Third Party Widgets

This Privacy Policy only applies to information collected by ClarineT.

Links to Other Websites. Our Services include links to other websites with privacy practices that may differ from ours. Any information you submit to a website not belonging to ClarineT is governed by that site’s privacy statements, not this one. We encourage you to carefully read the privacy statement of any website you visit.

Plugins and Social Media Widgets. Our Sites may include social media features and widgets (collectively “Widgets”), such as a "share this" button or other interactive mini-programs that run on our Services. Widgets can be used to provide you specific services from other companies (e.g., displaying the news, opinions, music, etc.). Personal data, such as your email address, may be collected through the Widgets. Cookies may also be set by the Widgets to enable them to function properly. Widgets displayed on our Sites are not hosted by ClarineT and are subject to the privacy policies of the third party company providing the Widget, and not this Policy.

Your Choices and Rights

Individuals in the EEA, and outside, have the following rights with respect to their personal data:

  • Access. You can ask us to confirm whether we are processing your personal data; give you a copy of that data; and provide you with other information about your personal data such as what data we have, what we use it for, who we disclose it to, whether we transfer it abroad, how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any profiling, to the extent that such information has not already been provided to you in this Policy.
  • Rectification. You can ask us to rectify inaccurate information. We may seek to verify the accuracy of the data before rectifying it.
  • Erasure. You can ask us to erase your personal data, but only where it is no longer needed for the purposes for which it was collected; you have withdrawn your consent (where the data processing was based on consent); following a successful right to object (see 'Objection' below); it has been processed unlawfully; or to comply with a legal obligation to which we are subject. We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims. There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request.
  • Restriction. You can ask us to restrict (i.e., keep but not use) your personal data, but only where its accuracy is contested (see 'Rectification' above), to allow us to verify its accuracy; the processing is unlawful, but you do not want it erased; it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend legal claims; you have exercised the right to object, and verification of overriding grounds is pending. We can continue to use your personal data following a request for restriction where we have your consent; to establish, exercise, or defend legal claims; or to protect the rights of another natural or legal person.
  • Objection. You can object to any processing of your personal data which has our 'legitimate interests' as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. Once you have objected, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. In addition, you can object to the processing of your personal data for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing without providing any reason. We will then cease the processing of your personal data for direct marketing purposes.
  • Portability. You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it 'ported' directly to another Data Controller, but only where our processing is based on your consent and the processing is carried out by automated means.
  • Withdrawal of Consent. You can withdraw your consent in respect of any processing of personal data which is based upon a consent which you have previously provided.

Data Controller / How to Contact Us/Dispute Resolution

Data Controller: ClarineT Srl Via Benigno Crespi 57, 20159 Milano MI Italy – Legal Representative

If you have any questions or concerns regarding the way in which your personal data is being processed or you want to exercise your rights above according to EU General Data Protection Regulation (GDPR), please reach out to ClarineT using the contact information below:

  • Legal Representative, who serves as Company’s data protection contact, and can be contacted at or by post ClarineT Srl Via Benigno Crespi 57, 20159 Milano MI Italy

Changes to this Policy

We may update this Privacy Policy to reflect changes to our privacy practices. If you are a ClarineT customer, Site user, supplier and we make any material changes that affect the way we treat information that we have previously collected from you, we will notify you by email (sent to the collected e-mail address) or by means of a notice through the Services prior to the change becoming effective.

The continuous use of the service constitutes the deemed acceptance by the user of the current policy and every subsequent updated version.

We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.


This Privacy Policy was last updated on 24/05/2018.