WEBSITE PRIVACY POLICY
Please note that this Privacy Policy applies to personal data that is collected and processed via our Website (as defined below) by KleverCargo Services B.V., with registered seat at Veemkade 328 1019 HD Amsterdam, the Netherlands, CIN 88795594, TIN NL864781659B01, (hereinafter: “KleverCargo”, or “we”) as a data controller.
KleverCargo is highly aware and understands that privacy is of great importance to you, so we take personal data protection very seriously.
Therefore, as a data controller and by creating this Privacy Policy, we make the processing of your personal data transparent and understandable. In this Privacy Policy, we explain how we collect, share, and use your personal data, as well as how you can exercise the rights you have as a data subject.
This Privacy Policy applies to all individuals who access our website at www.klevercargo.com (hereinafter: “Website”), send us inquiries via the Website, or apply for a working position at KleverCargo.
This Privacy Policy, along with our Terms and Conditions and Cookie Policy, constitutes an agreement that applies to you. Therefore, we suggest you read it carefully in order to find out all the necessary information regarding the protection of your personal data.
Please note that this Privacy Policy applies only to the use of the KleverCargo Website. The use of KleverCargo Platform is governed by a separate Privacy Policy, Terms of Use and corresponding policies and not by this agreement.
Every term that is capitalized but undefined in this Privacy Policy shall have a meaning given to it in our Terms and Conditions.
In case you have any questions regarding this Privacy Policy, please contact us at privacy@klevercargo.app.
1. Definitions
2. Personal data we collect
3. Why do we collect your personal data?
4. What do we not do?
5. Data subjects under the age of 16
6. Personal data security
7. With whom do we share your personal data?
8. International transfer of your personal data
9. How long do we keep your data?
10. Your rights
11. Changes to privacy policy
1. Definitions
Term: Consent
Meaning: Your explicit consent on the processing of personal data. Persons who are 16 years of age or older may give free consent to the processing of their personal data.
Term: Cookies
Meaning: Small pieces of data stored on your device (computer or mobile device). This information is used to track your use of the Website and to compile statistical reports on Website activity. For a more detailed explanation of the use of cookies and how you can manage them, please see our
Cookie Policy.
Term: Data Controller
Meaning: An entity that alone or jointly with others determines the purposes and means of the processing of personal data. For the purposes of this Privacy Policy, KleverCargo acts in the capacity of Data Controller.
Term: Data Processor
Meaning: Any natural or legal person who processes the data on behalf of the controller.
Term: Data Subject, or you
Meaning: Any natural person that shares personal data with us via Website, or in relation to Website (e.g. via email).
Term: “GDPR”
Meaning: General Data Protection Regulation 2016/679.
Term: Personal data or data
Meaning: Any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, either directly or indirectly. Therefore,
data about a company or any legal entity is not considered to be personal data but registering on behalf of a legal entity may include sharing personal data.
For example, information about one-person companies may constitute personal data where it allows the identification of a natural person. The rules also apply to all personal data relating to natural persons in the course of professional activity, such as the employees of a company or organization, and business e-mail addresses like “firstname.surname@company.com”. This Privacy Policy does not apply to information from which no individual can reasonably be identified (anonymized information).
Term: Processing
Meaning: Any operation or set of operations that are performed on personal data or sets of personal data. This includes activities such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
Term: Services
Meaning: Making available any content by us on the Website. The Service does not include services that KleverCargo otherwise provides without the use of the Website (e.g. services provided via KleverCargo Platform).
2. Personal data we collect
Information about you may be collected and received in several ways:
Personal data that we collect from you, including:
Data you share with us voluntarily,
Data we collect automatically when you use our Website, and
Personal data we collect about you from third parties.
A. Personal data you share with us voluntarily
Include information such as:
Your name and contact information
When you choose to contact us via the
Contact page on our Website or otherwise, we will ask you to leave your name and your e-mail address.
When you sign up for our Newsletter, it would be necessary to share your e-mail address with us.
Additional information
If you contact us via the Contact page on our Website or otherwise (including, but not limited to inquiries regarding our Platform or our services), we may receive additional information about you, such as a business address, your profession, content of the messages or attachments you may send us, or any other information you decide to share with us.
In case you decide to submit an application for a working position at KleverCargo, via the Careers page, we will ask you to send your Cover letter and CV to our email address. During the application process for any of the open working positions at KleverCargo, we may require additional information regarding your professional life, which can be relevant for your future working position.
All personal information that you provide to us needs to be true, complete, and accurate, and you are obliged to notify us of any changes to such personal information.
B. Personal data we collect automatically when you use our Website
We automatically collect Technical data and Mobile Service data, that include information such as:
Your IP address,
Device type,
Unique device identification number,
Browser-type,
Broad geographic location (e.g. country or city-level location).
We may also collect information about how your device has interacted with our Website, which includes the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who visit our Website, where they come from, and what content on our Website is of interest to them.
This information is collected primarily by using cookies and similar tracking technology, as explained further in our Cookie Policy.
C. Personal data we collect about you from third parties
In some cases, we may obtain your personal data without you giving us such data directly.
If you apply for a working position at KleverCargo, we may obtain information about you:
from recruitment agencies – (e.g. when a recruitment agency contacts us to identify you as a potential candidate);
through publicly available sources online – (e.g. on your current employer’s website, or on a professional networking site such as LinkedIn); and
by reference or word of mouth – for example, through a referral from a former employee/employer or from a referee you have identified.
If you are our client, we will process identification and background information as part of our business acceptance, as well as to fulfil any other legal or regulatory requirements to which we may be subject.
3. Why do we collect your personal data?
Purpose: Responding to your inquiries
We collect your personal data in order to respond to the inquiries you sent us via the
Contact page on our Website, as well as to respond to you regarding the rest of your requests addressed to us.
Data we collect: Your name and e-mail.
Legal basis: Processing is necessary for the performance of the Agreement or to enter into such an Agreement with you.
Purpose: Sending Newsletter
If you decide to subscribe for receiving our Newsletter, we will collect your e-mail address and your name.
Data we collect: Your name and e-mail.
Legal basis: Processing is based on your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal. You may unsubscribe from receiving Newsletter from us. If you wish to do so, simply follow the instructions found at the end of the email you received after signing up for Newsletter.
Purpose: Sending personalized offers and monitoring of your behavior
When sending us an inquiry, you may agree to the monitoring of your behavior patterns by KleverCargo and sending you personalized offers on products and services based on the behavior patterns observed by KleverCargo. This means that you may give us your consent to process data about your past inquiries and/or interaction on our Website, and send you information about other products we believe you might be interested in based on that information.
Data we collect: Your name and e-mail.
Legal basis: Processing is based on your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal. You may unsubscribe from receiving personalized offers and monitoring of your behavior. If you wish to do so, simply follow the instructions found at the end of each e-mail. We may use your email for this purpose until you unsubscribe.
Purpose: Processing your application for open working positions
After you send us your application, which you submit by sending an inquiry at klevercargo.com/careers we will need to examine it in order to determine whether you as a candidate fulfill our requirements.
Data we collect: Your name, email address, and any additional personal data contained in your Cover letter and CV.
Legal basis: It is in our legitimate interest to decide whether to appoint you to the role since it would be beneficial to our business to appoint a suitable candidate to that role. We also need to process your personal data to decide whether to enter into a contract with you. In case we do not accept your job application, your Personal Data will be erased in accordance with Section 9 of Privacy Policy.
Purpose: Managing and improving our Website, analyzing the use of Website, improving our Services Information we collect automatically are used to:
manage and operate our Website,
improve usability and performance of Website, by keeping it updated and relevant,
analyze the use of Website and measure interests of visitors of our Website,
ensuring that content on Website is presented most effectively for you and your computer or mobile device.
Data we collect: Technical Data and Mobile Service Data.
Legal basis: Your consent – unless providing Personal Data is necessary to provide a Service or part thereof, provision of your Personal Data is not a statutory or a contractual requirement and you may refuse to disclose any data.
You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.
4. What do we not do?
KleverCargo will never:
Sell any kind of personal information or data.
Disclose this information to marketers or third parties not specified in Section 7 of the Privacy Policy.
Process your data in any way other than stated in this Privacy Policy.
5. Data subjects under the age of 16
Our Website is not intended for children, and we do not knowingly collect data relating to children. If you are under the age of 16, please do not provide any personal information about yourself to us.
If we detect that we have collected personal information from a person under the age of 16, such information will be deleted promptly. If you believe we have collected personal information from a person under the age of 16, please contact us at privacy@klevercargo.app.
6. Personal data security
We take administrative, technical, organizational, and other measures to ensure the appropriate level of security of personal data we process. Upon assessing whether a measure is adequate and which level of security is appropriate, we consider the nature of the personal data we are processing and the nature of the processing operations we perform, the risks to which you are exposed by our processing activities, the costs of the implementation of security measures and other relevant matters in the particular circumstances.
Some of the measures we apply include access authorization control, information classification (and handling thereof), protection of integrity and confidentiality, data backup, firewalls, data encryption and other appropriate measures. We equip our staff with the appropriate knowledge and understanding of the importance and confidentiality of your personal data security.
Remember – all information you submit to us by email is not secure, so please do not send sensitive information in any email to KleverCargo. We never request that you submit sensitive or personal information over email, so please report any such requests to us by sending an email to privacy@klevercargo.app.
8. Applicable law and Dispute resolution
We may transfer your personal data to countries other than the one you reside in. In that case, we will also apply appropriate technical and organizational measures to ensure an adequate level of security in respect of all personal data we process. If the GDPR applies to you, we make sure that such transfer is made:
1. to the countries within the EEA;
2. to the countries which ensure an adequate level of protection;
3. to the countries which do not belong to those specified under item 1. and 2, but only by applying the appropriate safeguard measures (such as Standard Contractual Clauses adopted by the European Commission).
If you would like to obtain more information about these protective measures, please contact us at privacy@klevercargo.app.
Your personal data is stored on servers located in Frankfurt, Germany.
www.digitalocean.com
www.digitalocean.com/legal/gdpr
www.digitalocean.com/security
9. How long do we keep your data?
KleverCargo does not keep your personal data longer than the time necessary to fulfil the purpose for which the data is collected, or no longer than the time for which we have your consent. In determining data retention periods, we take into consideration local laws, contractual obligations, and the expectations and requirements of our customers and suppliers. When we no longer need personal information, or when you request us to delete your information, where this is legal, we will securely delete or destroy it.
In case you have applied for a working position in our company by sending your Cover letter and CV via email support@klevercargo.app, we will erase your personal data within 6 months after your application has been received unless you become one of our team members.
10. Your rights
As a Data Subject in the EEA, whose personal information we hold, you have certain rights under the GDPR. This part of the Privacy Policy aims to give you a general understanding of these rights. In relation to each of the rights noted below, we provided a reference to the specific provision of the GDPR from which that right arises.
Right to access (Article 15 GDPR)
You can send us a request for a copy of the personal data we hold about you. We have ensured that appropriate measures have been taken to provide such in a concise, transparent, intelligible and easily accessible form, using clear and plain language. Such information is provided in writing free of charge. It may be provided by other means when authorized by the Data Subject and with prior verification as to the subject’s identity.
Information is provided to the Data Subject at the earliest convenience, but at a maximum of 30 days from the date the request was received. Where the retrieval or provision of information is particularly complex or is subject to a valid delay, the period may be extended by two further months where necessary.
Right to Correction of Your Personal Data (Article 16 GDPR)
If the personal data we have about you is incorrect, you have the right to request that we correct those data. Where notified of inaccurate data by the Data Subject, we will rectify the error within 30 days and inform any third party of the rectification if we have disclosed the personal data in question to them.
Right to Withdraw the Consent (Article 13(2)c) GDPR)
If you have provided your consent to the collection, processing and transfer of your personal data, you have the right to fully or partly withdraw your consent. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal ground for the processing.
You have the right to request from us that your personal data is deleted in certain circumstances including:
The personal data are no longer needed for the purpose for which they were collected;
You withdraw your consent (where the processing was based on consent);
You object to the processing and no overriding legitimate grounds are justifying us processing the personal data;
The personal data have been unlawfully processed; or
To comply with a legal obligation.
However, this right does not apply where, for example, the processing is necessary:
- To comply with a legal obligation; or
- For the establishment, exercise or defense of legal claims.
Right to the restriction of processing (Article 18 GDPR)
If the accuracy of the personal data is contested, you consider the processing is unlawful but you do not want it erased, we no longer need the personal data but you require it for the establishment, exercise or defense of legal claims or you have objected to the processing and verification, you can exercise your right to the restriction of processing.
Right to Lodge a Complaint
If you have any concerns or requests in relation to your personal data, please contact us at
privacy@klevercargo.app and we will respond within 30 days. If you are unsatisfied with how we process your data, you may contact the competent supervisory authority.
In case you believe that we are processing your personal data in violation of the GDPR, you have the right to lodge a complaint with the supervisory authority located in the EEA where you reside or work or where the alleged infringement took place.
To exercise these rights, please contact us at privacy@klevercargo.app.
11. Changes to our privacy policy
Any changes we may make to our Privacy Policy will be posted on this page and where appropriate may be notified to you by email or advised to you on the next login to KleverCargo. If you continue with the use of the Website after the changes were implemented, that will signify that you agree to any such changes.
Last updated on and effective as of 28.02.2023.