Privacy Policy

Updated May 24, 2018

Your privacy is very important to us. Our services and products are built on a foundation of security and privacy. They are compliant with General Data Protection Regulation (GDPR) requirements and other legal provisions for data protection. Below you’ll find all necessary information to make educated decisions about how you want us to process your personal data.

This information applies to visitors of our website, clients and job applicants. We’ve broken it down into three main sections:

  1. Our Marketing and Sales activities.
  2. Recruitment by our Human Resources team

If you feel something is not addressed this Privacy Policy or have further questions, our Data Protection Officer (DPO) can be reached at gdpr@clearcode.cc.

The data controller for (1) Marketing and Sales -related activities is: Clearcode S.A. ( ul. Św. Antoniego 2/4, 50-073 Wrocław, Poland), Clearcode LLC

The data controller for (3) Recruitment is: Clearcode group, that includes Clearcode S.A. (mother company, ul. Św. Antoniego 2/4, 50-073 Wrocław, Poland), Clearcode LLC, Piwik PRO Sp. z o.o. (ul. Św. Antoniego 2/4, 50-073 Wrocław, Poland), Piwik PRO GmbH (Piwik PRO GmbH, Lina-Bommer-Weg 6, 51149 Cologne, Germany) and Piwik PRO LLC (Piwik PRO LLC, 222 Broadway, USA). Learn more about the Clearcode group at https://clearcode.cc/about/.

Marketing and Sales

We work hard to find and introduce new people to our services and products as well as improve the quality of our website. We want to communicate clearly and directly with everyone that visits our website. To do this we need data. However, we practice privacy by design, privacy by default and data minimization so we’ll take the smallest amount of data we can while still providing our visitors an enjoyable experience.

We request processing of personal data of visitors, such as IP address, a cookie identifier and email address (but only in the case that visitors request information be sent by email). We also collect non-personal data to learn how visitors found our website, what kind of device they’re using, how long they stayed, which pages they visited, etc. This non-personal data is tied to a temporary identifier that is removed after the end of each browsing session.

Privacy settings

We process personal data based on Consent according to Art. 6(1)(a) GDPR, which you are free to give or refuse. You’ll see consent options when you visit our website for the first time. You can change your decisions at anytime by clicking the button below. If you change your decision it will not affect the lawfulness of processing based on consent before its withdrawal.

Privacy settings

Individual data subject right (Your rights)

Remember there are number rights you can exercise:

You have the right to lodge a complaint with a supervisory authority (in Poland, the President of the Data Protection Office).

If you would like to exercise your individual rights, send us a message via the form below. The form uses cookies that identify you as a returning visitor so we know what data the request concerns. We will then remove or adjust data about you from our database and pass the request to our partners. We require your email to communicate with you during processing of your request.

Data requests

Please select below the type of data request along with any special requests in the body of the message. We will do our best to accommodate them. We require your email address to contact you about your request. We will not use this email address for any purpose other than the completion of your request.

Access data
Access data
Data erasure
Data rectification

Our partners - tools we use for Marketing and what we use them for

Piwik PRO Marketing Suite is our own analytics and customer data platform. We collect first-party data about website visitors based on cookies, IP and fingerprinting; we create user profiles based on user browsing history and calculate metrics related to website usage such as bounce rate, depth of visits, page views etc. We host our solution in Microsoft Azure infrastructure in the Netherlands and the data is stored for a period of 2 years for raw data and 3 years for aggregated data in reports. (Purpose of processing data: Analytics, Conversion tracking based on consent, Legal basis: Art. 6 (1)(a) GDPR).

Google Analytics is an analytics platform. We collect first-party data about website visitors based on cookies, IP address and fingerprinting; we create user segments based on user browsing history and calculate metrics related to website usage, such as bounce rate, depth of visits, page views etc. Your data is stored for a period of 26 months and applies to user-level and event-level data associated with cookies, user-identifiers (e.g., User-ID) and advertising identifiers (e.g., DoubleClick cookies, Android’s Advertising ID, Apple’s Identifier for Advertisers). >(Purpose of processing data: Analytics, Conversion tracking based on consent, Legal basis: Art. 6 (1)(a) GDPR).

HubSpot is an inbound marketing and sales platform that we use for email marketing, marketing automation, website personalization and integrating CRM data about leads with their behavioral data. HubSpot collects browsing history (only from our site) and user personal data acquired via lead capture forms. HubSpot products are hosted in U.S.-based data centers, and HubSpot stores user data for 12 months. (Purpose of processing data: Marketing Automation based on consent, Legal basis: Art. 6 (1)(a) GDPR).

Hotjar is a tool we use for analyzing and visually representing online user behavior. We use Hotjar heatmaps, polls and surveys to improve user experience on our website. Hotjar collects responses in real-time from any device. It retains data for 365 days from the date the data was captured and stores it in Ireland. (Purpose of processing data: Analytics based on consent, Legal basis: Art. 6 (1)(a) GDPR)

Google AdWords is an advertising system. We use it to display Clearcode ads in Google's search results (or in the Google Display Network); run ad or remarketing campaigns; track conversions; and create campaign performance reports. Google AdWords collects cookie-based behavioral data about users. Data collected by Google AdWords is retained for 30 days. (Purpose of processing data: Remarketing based on consent, Legal basis: Art. 6 (1)(a) GDPR).

LinkedIn Ads is an advertisement system we use to serve ads to LinkedIn users. We run ad and remarketing campaigns in the LinkedIn Ad Network and compile data for reports about campaign performance and conversion tracking. LinkedIn Ads collects cookie-based behavioral data about users. The data is retained for 365 days and then deleted. LinkedIn's data centers are currently located in the U.S. and Singapore. (Purpose of processing data: Remarketing based on consent, Legal basis: Art. 6 (1)(a) GDPR).

Facebook Ads is an advertisement system we use to serve Clearcode adds to Facebook users. We use it to run remarketing and ad campaigns in Facebook Ad Network, to create campaign performance reports, and conversion tracking. Facebook Ads collects cookie-based behavioral data about users and retains data in their data centers including in Lulea, Sweden in the European Union. (Purpose of processing data: Remarketing based on consent, Legal basis: Art. 6 (1)(a) GDPR).

Recruitment

The recruitment process is shared within the Clearcode group, that includes Clearcode S.A. (mother company), Clearcode LLC, Piwik PRO Sp. z o.o., Piwik PRO GmbH and Piwik PRO LLC. During recruitment we will gather and process personal data such as employment history, education and projects you’ve worked on. We get this information from your CV, the application form and from links or other information you provide us. To submit your application to us you must first agree to processing of your personal data (a check box on the application page) in accordance with Art. 6(1)(a) GDPR. Sending us your job application via jobs@clearcode.cc means that you acknowledge our privacy policy. The provision of your personal data is neither a statutory nor a contractual requirement, but we can't consider you for a position without the ability to process your personal data.

Only HR and team members who are directly involved in your recruitment process, usually representatives of the team you are applying to, have access to your data. Each team member has been trained in data security and is formally obliged by their contract to keep it private. All who would have access to your recruitment data have such a contract with the Clearcode group (defined at the beginning of this privacy policy).

We collect and use personal information you have provided only for the purposes of recruitment process. Data that we collect throughout recruitment is used only for the communication with candidates, to evaluate their qualifications and to make a final hiring decision. During the recruitment process we use software from external partners such as Google Suite and Dropbox. The maximum time your data is held is 36 months.

You have a right to access your data, correct or remove it, or completely withdraw your consent for processing it at any time. Such requests should be sent to our DPO: gdpr@clearcode.cc. The withdrawal of a consent does not affect the lawfulness of processing based on consent before its withdrawal.

Third-Party Websites

Links from our site to external websites do not operate under this Privacy Policy. For example, if you click on a referrer website link on our site, you may be taken to a website that we do not control. These third-party websites may independently solicit and collect information from you, including personal and financial data. We recommend that you consult the privacy statements of all third-party websites you visit by clicking on the “privacy” link typically located at the bottom of the webpage you are visiting.

Children’s Privacy

We forbid the use of the website to individuals age 18 and below, without the consent of a parent or guardian over the age of 18. We do not knowingly collect personal data from children under the age of 13.

Notice to California Users

Subject to the limitations under California Civil Code § 1798.83, if you are a California resident and have an established business relationship with us, you may ask us to provide you with a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year. You may also request the identity of certain third parties that received your personal information from us for their direct marketing purposes during the immediately preceding calendar year. You may make a request as described hereinabove once a year.

To make such a request, you can contact us at gdpr@clearcode.cc or mailing us at: Clearcode, 222 Broadway, 19th Floor, New York, NY 10038, USA. Please mention in your communication that you are making a “California Shine the Light” inquiry. We will respond within thirty (30) days.

Changes to the Privacy Policy

We will occasionally update this Privacy Policy. When changes to this Privacy Policy will be posted, the date at the top of this Privacy Policy will be revised. We recommend to check the website from time to time to inform yourself of any changes in this Privacy Policy or any of other policies.