POLICY

REGARDING THE PROCESSING OF PERSONAL DATA

Your privacy is one of our fundamental commitments, and therefore, we take utmost care to process your personal data in accordance with the principles set forth in the applicable legislation.

CLEVER SOFTWARE SOLUTIONS Inc, dba. CLEVER TALENT having its headquarters at 7718 79th PL, GLENDALE NY 11385 USA, tax code 27-3667374, ("SOFTWARE SOLUTIONS Inc ", "us") processes, as data controller, your personal data („Personal Data”). The purpose of this privacy policy („Policy”) is to explain how your Personal Data is processed by CLEVER SOFTWARE SOLUTIONS Inc .

1. CATEGORIES OF PERSONAL DATA, PROCESSING PURPOSES AND LEGAL GROUNDS

A. Contacting the user

a. Contacting the user

Personal Data: full name, e-mail address.

2. PROVIDING YOUR PERSONAL DATA

You may refuse to provide certain Personal Data but in such a case you may not be able to benefit from certain services specific to the relationship described in this Policy.

3. ABOUT LEGAL GROUNDS

The legal ground for processing the personal data differs depending on the specific situation and the Personal Data processed.

When we process your Personal Data based on your consent, we will seek your free, informed, specific and unequivocal consent for the respective processing. By expressing your consent, you will agree that we may collect, use, disclose, process and transfer Personal Data in accordance with this Policy.

4. THE SOURCE OF PERSONAL DATA

The source of Personal Data is: online user.

5. AUTOMATED INDIVIDUAL DECISION-MAKING

Your Personal Data shall not be processed in order to be subject to decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, pursuant art. 22 para. (1) of GDPR.

6. PROCESSING DURATIONS

The duration of processing of Personal Data varies depending on the specific processing operation:

In certain circumstances, we may retain your Personal Data for longer periods of time in order to have an accurate record of your relationship with us in the event of any complaints or if we reasonably believe that there is a prospect of a litigation.

7. TRANSFER OF PERSONAL DATA

We may transfer Personal Data, to the necessary extent, to the following categories of recipients: IT services suppliers, public authorities.

These recipients can be located in the European Union and/or in the European Economic Area. Where recipients are located outside the European Union and the European Economic Area, including in countries not recognized as ensuring an adequate level of protection, the transfer of Personal Data shall be carried out only if there are appropriate guarantees, in accordance with applicable law. In this respect, we rely on several guarantees, such as the standard contractual clauses issued by the European Commission. You may receive from us a list of recipients from third countries, as well as a copy of the agreed provisions that ensure an adequate level of protection of Personal Data. For any request to this effect, please contact us at the contact details mentioned below.

8. SECURITY OF PERSONAL DATA

The security of your Personal Data is important for us. Your Personal Data will therefore be processed by applying reasonable technical and organizational measures to protect Personal Data, such as limiting access to Personal Data, encryption or anonymization of Personal Data, storage on secure environments. However, despite our efforts, we cannot always guarantee the effectiveness of the security measures implemented, and therefore we cannot guarantee the security of Personal Data at any time.

9. RIGHTS IN CONNECTION WITH THE PROCESSING OF YOUR PERSONAL DATA

Access right: You have the right to obtain from us confirmation that your Personal Data is processed by us, as well as information on the specific processing, such as: the purposes of processing, categories of processed Personal Data, recipients of Personal Data, the period for which Personal Data is stored, the source of Personal Data, if we transfer the Personal Data abroad and how we protect it, your rights, the right to lodge a complaint before the supervisory authority.

Right to rectification: You have the possibility to request rectification of your Personal Data, provided that the applicable legal requirements are met. In the event of errors, after notification, we will immediately correct your Personal Data.

Right to erasure: In certain cases, you have the possibility to request the deletion of Personal Data, namely when: (i) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent on which the processing is based according and where there is no other legal ground for the processing; (iii) the Personal Data have been unlawfully processed; (iv) you exercise the right to object to the processing. We are not obliged to comply with your request when the processing is necessary (among others) for compliance with a legal obligation or for the establishment, exercise or defence of legal claims. There are also other circumstances in which we are not obliged to comply with this request for the deletion of Personal Data.

Restriction of processing: You may request us to restrict the processing of your Personal Data in the following circumstances: (i) you contest the accuracy of the Personal Data, for a period enabling us to verify the accuracy of the Personal Data; (ii) the processing is unlawful and then you oppose to the erasure of the Personal Data and request the restriction of their use instead; (iii) we no longer need the Personal Data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; (iv) you have objected to processing, pending the verification whether our legitimate grounds override yours. However, we can continue to process your Personal Data (i) when you consent; (ii) for the establishment, exercise or defence of legal claims or (iii) for the protection of the rights of another natural or legal person.

Right to data portability: Insofar the Personal Data is processed based on your consent or on the execution of the agreement and the processing is carried out by automated means, you have the right to have your data Personal Data provided to you in a structured format, which is currently used and can be read automatically and you have the right to request us to transfer this Personal Data to another controller. This right shall not adversely affect the rights and freedoms of others.

Right to opposition: In certain situations, such as when we process your Personal Data on the basis of a legitimate interest, you have the right to object to the processing of your Personal Data by us. In the event of unjustified objection, CLEVER SOFTWARE SOLUTIONS Inc is entitled to continue processing Personal Data. You also have the right to object to the processing of your Personal Data for marketing purposes.

Withdrawal of consent: Insofar you consented to the processing of your Personal Data, you can at all times withdraw your consent, without affecting the lawfulness of processing based on consent before its withdrawal.

Right not to be subject to any automatic individual decisions: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Such right cannot be exercised when the decision: (i) is necessary for entering into, or performance of, a contract between you and us; (ii) is authorized by law which lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or (iii) is based on your explicit consent.

Right to lodge a complaint with the supervisory authority: You have the right to lodge a complaint with The National Supervisory Authority for Personal Data Processing (“DPA”) in relation to any breach of your rights regarding the processing of your Personal Data. The contact details of the DPA are: 28-30 Gheorghe Magheru Boulevard, District 1, Postal Code 010336, Bucharest, Romania; e-mail: [email protected].

To learn more about the manner in which you may exercise the aforementioned rights, please contact us at: [email protected].

10. CONTACT

If you have any questions or concerns about this Policy or its implementation, you may contact us at: [email protected].