Legal Notice

We also believe that the efficient collection, use and transfer of information serve to enhance the development of the Internet and electronic commerce, provided that such information is handled in a fair and responsible manner. Therefore, in order to inform you of our policies and activities with respect to the collection, use and transfer of personal data on the Internet, Cleverglow Limited is providing you with an electronic copy of this Policy. This Policy applies to websites that are owned and operated by Cleverglow Limited and/or companies that Cleverglow Limited controls, directly or indirectly (collectively, “Cleverglow”). Cleverglow Limited or one of companies that Cleverglow Limited controls, directly or indirectly, is the data controller with respect to personal data collected and processed via its respective website. In this capacity, each of these Cleverglow entities is registered with appropriate data protection authorities with respect to the processing of personal data via such websites.

In this Policy, “Personal Data” means information which relates to an individual and which identifies that individual, either directly or indirectly (together with other information that is reasonably likely to come into Cleverglow’s possession), such as your name, e-mail address or telephone number.

Collection of Personal Data
Generally, you can visit Cleverglow websites without providing any Personal Data about yourself.  However, for accessing some parts of our websites, such as downloading certain documents, or in connection with another specific purpose, we may need to collect Personal Data from you.  Providing Personal Data to us in these events is voluntary.  If you do not provide Personal Data to us, then you will not be able to benefit from the respective functionality offered by our websites, such as communication, downloading of documents or recruitment.  The purposes, for which your Personal Data is collected, are described below, along with a brief description of how your Personal Data may be handled in each case.

• Communicating with you.  We will follow up on comments and other requests that you submit to us through our website, such as online queries or registering your attendance at a conference.  This may include calling you back by telephone or communicating with you via email.
  
  
• Direct marketing and promotion.  Direct marketing and/or promotional efforts by or on behalf of Cleverglow may include providing you with specific information that you have requested online or providing more general information about other Cleverglow offerings.  When we collect Personal Data for direct marketing or promotional purposes, however, we generally offer you appropriate choices regarding the use of your Personal Data.
   
• Recruitment.  If you submit a resume or job application online, we will use your Personal Data for recruitment-related purposes, which may include contacting you via email, telephone or post.  In some cases, you may be required to register on our website in order that you may track the progress of your application online.  Except where you request otherwise, Cleverglow may keep your Personal Data on file for an appropriate time in order to consider you for other employment opportunities with Cleverglow in the future.
  
  
• Supplier administration.  Some Cleverglow websites enable third-party suppliers to register their interest in supplying products and services to Cleverglow.  We will use this Personal Data in connection with entering into or performing a transaction with the supplier and for other procurement-related purposes.
  
  
• Maintaining the website and conducting customer satisfaction surveys. We will use your Personal Data in order to maintain and improve our website.  We may also use your Personal Data in order to conduct customer satisfaction surveys.
  
  
• Compiling aggregate statistics regarding the use of its website.

Cookies and clicktrails
We may collect information through our website by using cookies and clicktrails. All information collected by means of cookies or clicktrails will be anonymised, aggregated and only used to develop and track traffic patterns and the volume of use of our websites.  Sometimes cookies are used to assist you in reaching the appropriate information and to tailor your visit to your individual preferences.  For example, a cookie can be used to remember your login information if you choose the “Remember me” option while signing in.  If you do not want to receive a cookie from our website, you may set your browser to refuse cookies or to notify you when you receive a cookie, which you may then refuse upon such notice.  To understand how to do this, please consult your browser’s help section.  However, refusing the cookies may prevent you from accessing some parts of the websites.

Global organisation
Cleverglow is a global organisation.  Whilst we have distinct legal entities (e.g., country subsidiaries) in many parts of the world, our internal processes and infrastructure are international in scope and nature and generally cross country borders.  Accordingly, you should be aware that we may share your Personal Data inside Cleverglow and transfer it to countries in the world where we have data centres or otherwise do business.  Some of these countries do not have specific data protection laws and so may provide less legal protection for your Personal Data.  In these instances, Cleverglow will process your Personal Data in the manner described by this Policy and in accordance with applicable law.

Third-party suppliers
Like many organisations, we use third-party suppliers to collect, use and otherwise process Personal Data on our behalf.  Our practice is to require such third parties to handle Personal Data in accordance with Cleverglow’s privacy and security policies.

Business reorganisations
Like many organisations, Cleverglow may reorganise its business operations around the world from time to time, whether by buying new businesses or selling or merging existing businesses.  This may involve us disclosing Personal Data to prospective or actual purchasers of parts of our business, or receiving personal data from potential sellers.  It is our practice to seek appropriate confidentiality protection for Personal Data disclosed in these types of transactions.

Legal disclosures
Cleverglow may disclose your Personal Data in order to enforce our website Terms of Use or in urgent circumstances to protect personal safety, the public or Cleverglow’s websites.  It is also possible that we may be required by law to disclose your Personal Data pursuant to judicial or other government subpoenas, warrants, or orders, potentially, in any country where we do business.

Sensitive Personal Data
As a general rule, Cleverglow does not collect “Sensitive Personal Data” through its website.  “Sensitive Personal Data” means Personal Data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, or concerning health or sex life.  By volunteering unsolicited sensitive Personal Data to us (e.g., by submitting your resume or a job application online), you expressly consent to your Personal Data being used as described in this Policy.

Accessing, correcting, updating and deleting Personal Data
If you have any questions or concerns regarding this Policy, or would like to request a copy of your Personal Data, then please contact the webmaster.  Also, if you consider your Personal Data to be incorrect or wish to have it deleted, then please equally contact the webmaster so that Cleverglow may make any necessary updates, corrections and/or deletions.

Data security and integrity
Cleverglow uses various technological and procedural security measures in order to protect the Personal Data we collect, use or transfer from loss, misuse, alteration or destruction.  However, you should be aware that, due to the open and unsecured character of the Internet, Cleverglow can not be responsible for the security of transmissions of the Personal Data over the Internet. 

Third-party websites
Cleverglow websites may provide links to third-party websites. Cleverglow does not make any representations or warranties with respect to such third-party websites. You should be aware that the owners and operators of such third-party websites might collect, use or transfer personal data under different terms and conditions than Cleverglow. Upon linking to a third-party website, you should inform yourself of the privacy policies of such third party websites.  You should also be aware that third-party websites may use cookies.