PRIVACY POLICY

Last updated: May 2026

Clear S.r.l.S.B. ("Clear", "Company", "we", "our", or "us") is committed to protecting and respecting your privacy in accordance with Regulation (EU) 2016/679 ("GDPR") and applicable data protection laws.

This Privacy Policy explains how we collect, use, disclose, process, and protect personal data when you visit or interact with our website, services, communication channels, and business activities.

By accessing or using our website and services, you acknowledge that you have read and understood this Privacy Policy.

1. DATA CONTROLLER

The Data Controller is:

Clear S.r.l.S.B.
Largo San Giuseppe 3
16121 Genova (GE), Italy
VAT Number: 02892600996
Email: administration@clearsrlsb.com

2. PERSONAL DATA WE COLLECT

We may collect and process the following categories of personal data:

2.1 Contact and Identification Data

• Full name

• Company name

• Email address

• Phone number

• Job title or professional role

• Country and business information

• Any information voluntarily submitted through contact forms or communications

2.2 Professional and Business Information

In connection with our consulting, compliance, audit, certification, software, and supplier qualification activities, we may process:

• Corporate information

• Compliance-related documentation

• Supplier and operational information

• Business communication records

• Information related to audits, certifications, due diligence, quality systems, or regulatory activities

2.3 Technical and Usage Data

When visiting our website, certain technical information may automatically be collected, including:

• IP address

• Browser type and version

• Device information

• Operating system

• Date and time of access

• Website interaction data

• Server log information

3. PURPOSES OF PROCESSING

We process personal data for the following purposes:

3.1 Website and Communication Management

• Responding to contact requests

• Managing commercial inquiries

• Organizing meetings and business communications

• Providing requested information regarding our services

3.2 Service Delivery

• Providing consulting, audit, certification, compliance, and software-related services

• Managing supplier qualification and due diligence processes

• Supporting quality management systems (QMS)

• Managing business relationships and contractual activities

3.3 Legal and Regulatory Compliance

• Complying with applicable laws and regulations

• Meeting regulatory obligations

• Protecting legal rights and legitimate business interests

3.4 Website Security and Maintenance

• Ensuring website security

• Preventing unauthorized access or misuse

• Monitoring technical functionality and performance

3.5 Newsletter and Informational Updates

Where voluntarily requested by users, we may provide newsletters, industry insights, blog updates, or information related to our services and activities.

Users may unsubscribe at any time.

4. LEGAL BASIS FOR PROCESSING

We process personal data based on one or more of the following legal grounds under Article 6 GDPR:

• Consent of the data subject

• Performance of a contract or pre-contractual measures

• Compliance with legal obligations

• Legitimate interests pursued by Clear, including business development, security, service management, and operational continuity

5. DATA RETENTION

Personal data is retained only for as long as necessary for the purposes for which it was collected, including compliance with legal, regulatory, contractual, accounting, or reporting obligations.

Retention periods may vary depending on:

• Nature of the relationship

• Type of service provided

• Regulatory obligations

• Legitimate business needs

When no longer necessary, personal data will be securely deleted or anonymized.

6. DATA SHARING AND DISCLOSURE

We do not sell personal data.

Personal data may be shared, where necessary, with:

• IT and hosting providers

• Professional advisors and consultants

• Regulatory authorities

• Certification bodies

• Technical and operational service providers

• Business partners involved in service delivery

• Public authorities where required by law

All third parties are required to process personal data securely and in accordance with applicable data protection laws.

7. INTERNATIONAL DATA TRANSFERS

Due to the international nature of some of our activities and service providers, personal data may be transferred outside the European Economic Area (EEA).

Where such transfers occur, Clear implements appropriate safeguards in accordance with GDPR requirements, including contractual protections and adequate security measures.

8. DATA SECURITY

Clear implements appropriate technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

Such measures may include:

• Access controls

• Secure infrastructure

• Encrypted communications where applicable

• Internal confidentiality procedures

• Restricted access to sensitive information

However, no system can guarantee absolute security.

9. DATA SUBJECT RIGHTS

Under applicable data protection laws, individuals may have the right to:

• Access personal data

• Request correction of inaccurate data

• Request deletion of personal data

• Restrict or object to processing

• Request data portability

• Withdraw consent at any time

• Lodge a complaint with a supervisory authority

Requests may be submitted to:

administration@clearsrlsb.com

We may request verification of identity before processing certain requests.

10. THIRD-PARTY SERVICES

Our website may include integrations or links to third-party services used for communication or meeting scheduling purposes.

Such third-party services operate independently and are subject to their own privacy policies and terms.

Clear is not responsible for the privacy practices of external websites or third-party platforms.

11. CHILDREN

Our website and services are not directed to minors.

We do not knowingly collect personal data from children or individuals legally considered minors under applicable laws.

12. COOKIES AND TECHNICAL DATA

Our website may use technical or strictly necessary cookies required for website functionality, security, and infrastructure management.

At this time, Clear does not intentionally use advertising profiling systems, behavioral tracking technologies, or third-party marketing analytics tools.

Additional information regarding cookies may be provided through a dedicated Cookie Policy and consent banner where applicable.

13. CHANGES TO THIS PRIVACY POLICY

We reserve the right to update or modify this Privacy Policy at any time in order to reflect legal, technical, or operational changes.

Updated versions will be published on this page with the relevant revision date.

Users are encouraged to periodically review this Privacy Policy.

14. CONTACT

For any questions regarding this Privacy Policy or the processing of personal data, please contact:

Clear S.r.l.S.B.
administration@clearsrlsb.com