Privacy Policy

Last Updated

Dec 18, 2025

Privacy Policy for CLER AB

CLER AB (“CLER”, “we”, “us”, “our”) is committed to ensuring the lawful, fair, and transparent processing of personal data. This Privacy Policy explains how we collect, use, store, protect, and disclose personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable Swedish data protection legislation.

By accessing our website or using our services, you acknowledge that your personal data may be processed as described in this Privacy Policy.

1. Data Controller

The data controller responsible for the processing of personal data described in this Privacy Policy is:

CLER AB
Engelbrektsgatan 9
114 32 Stockholm
Sweden
Email: info@clerglobal.com

2. Categories of Personal Data Processed

We may process the following categories of personal data:

Identity and contact data

Name
Company name
Company email address
Telephone number

Technical and usage data

IP address
Device and browser information
Approximate location data
Cookie identifiers and similar online identifiers
Website interaction and analytics data

Communication data

Information submitted through contact forms
Customer support and business communications

Transactional and relationship data

Information related to purchases, agreements, or ongoing business relationships

3. Methods of Data Collection

Personal data may be collected through:

Website contact forms and enquiries
Account registration or onboarding
Customer and business communications
Cookies, pixels, and similar tracking technologies
Website analytics tools
Purchases or contractual interactions
Newsletter subscriptions

4. Purposes of Processing and Legal Bases

We process personal data for the following purposes and legal bases:

To provide and manage services, contracts, and customer relationships
Legal basis: Performance of a contract (Article 6(1)(b) GDPR).
To handle enquiries, customer support, and general communication
Legal basis: Performance of a contract and legitimate interests (Article 6(1)(b), 6(1)(f) GDPR).
To send newsletters and marketing communications to individuals who have opted in
Legal basis: Consent (Article 6(1)(a) GDPR).
To analyse website usage, performance, and improve user experience
Legal basis: Consent (Article 6(1)(a) GDPR), where required.
To conduct customer segmentation, business analysis, and performance insights
Legal basis: Legitimate interests (Article 6(1)(f) GDPR).
To maintain IT security, prevent fraud, and ensure system integrity
Legal basis: Legitimate interests and legal obligation (Article 6(1)(f), 6(1)(c) GDPR).
To comply with legal obligations, including accounting and record-keeping requirements
Legal basis: Legal obligation (Article 6(1)(c) GDPR).

Where processing is based on consent, such consent may be withdrawn at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Disclosure of Personal Data

We may disclose personal data to the following categories of recipients:

Hosting and infrastructure providers
Analytics providers
CRM and customer communication providers
Payment, logistics, or operational partners where relevant
External consultants and professional service providers

All third parties process personal data on our behalf under GDPR-compliant data processing agreements.

We do not sell personal data or disclose it for unauthorised commercial purposes.

6. International Transfers

Some of our service providers may process personal data outside the EU/EEA or allow access from third countries, including the United States.

Where personal data is transferred outside the EU/EEA, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) and, where required, supplementary technical and organisational measures, in accordance with GDPR requirements.

7. Data Retention

Personal data is retained only for as long as necessary for the purposes for which it was collected or as required by law:

Customer and business relationship data: retained for the duration of the relationship
Marketing data: retained until consent is withdrawn or the individual unsubscribes
Technical and analytics data: typically retained for 12–36 months
Accounting and transactional data: retained for 7 years in accordance with Swedish bookkeeping legislation

After the applicable retention period, personal data is securely deleted or irreversibly anonymised.

8. Automated Decision-Making and Profiling

We do not engage in automated decision-making, including profiling, that produces legal or similarly significant effects on individuals within the meaning of Article 22 GDPR.

Limited profiling may occur for analytics, segmentation, or marketing measurement purposes. Such profiling does not have legal or similarly significant effects on data subjects.

9. Data Subject Rights

Under the GDPR, data subjects have the following rights:

Right of access
Right to rectification
Right to erasure (“right to be forgotten”)
Right to restriction of processing
Right to object to processing based on legitimate interests
Right to object at any time to direct marketing
Right to data portability
Right to withdraw consent at any time

Requests to exercise these rights can be submitted to: info@clerglobal.com

Data subjects also have the right to lodge a complaint with the Swedish Authority for Privacy Protection (IMY) or another competent supervisory authority.

10. Security Measures

We apply appropriate technical and organisational measures to protect personal data, including:

Encryption and secure communication (HTTPS)
Access control and authentication mechanisms
Secure hosting and storage environments
Regular security reviews

While we take reasonable precautions, no method of transmission or storage can be guaranteed to be completely secure.

11. Cookies and Tracking Technologies

We use cookies and similar technologies in accordance with applicable law. Non-essential cookies are used only where users have provided consent via our cookie banner.

For more detailed information, please refer to our Cookie Policy.

12. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy from time to time. Any material changes will be published on our website. The latest version will always be available online.

13. Contact

For questions regarding this Privacy Policy or our data protection practices, please contact: info@clerglobal.com