Following is the Privacy Statement for ECLARO’s website and recruitment activities. The content is published here on the ECLARO official website to inform users accessing our site and individuals seeking for employment of the following:

• The personal data we will collect
• Use of collected data
• Who has access to data collected
• The rights to personal data

This applies to the terms and conditions of our website and our recruitment process.

1.0 Website Privacy Statement

ECLARO recognizes your interest in our services and we are committed to protecting information that you disclose when you visit us online.

This Privacy Statement describes the information that we acquire from you and provides guidelines on the use and confidentiality of the information that you provide.

• 1.1 Consent to the Collection and Processing of Information

By visiting our website or transacting with us online, you agree to the collection of personal and other information necessary to facilitate our transactions and improve the services we provide. You also consent to its legitimte use allowed by applicable laws and regulations.

Personal Information can include your name, age, date of birth, address, email, phone numbers and similar information that will identify you and/or your organization.

Other information we collect may include your IP address, internet service provider, the operating system you are using, and your browser. It also includes the duration of your visit to our website, the pages you visited and the HTTP referrer, among others.

• 1.2 Use of Information

ECLARO may share your personal information to our affiliates and third parties involved in marketing our products and services. This will enable us to know your present needs and find ways of further improving the services we provide to our clients. The third parties to whom we share your information are not authorized to disclose or sell it to any other party or to utilize it, except within the scope of its agreement with ECLARO.

ECLARO may also disclose personal information within the following boundaries:

(a) to comply with laws, regulations or court orders

(b) to enforce company policies

(c) to protect and defend its rights, property, and employees,

(d) to enforce its contracts with clients, and

(e) to protect the safety of individuals or the public.

Other information collected will allow us to learn about your experience in our website. It will serve as input in improving the content, design, features and our internet marketing strategies. For this purpose, it may be necessary to share the information to contracted advertising agencies and consultants.

• 1.3 Confidentiality and Security of Information

ECLARO will not disclose and share your information to third parties for commercial gain. ECLARO will take appropriate measures to secure your data while being processed or stored and protect them from alteration, misuse or loss.

• 1.4 Right to Information

You have a right to request that your personal information be supplemented or rectified or to have the data be destroyed if it is incomplete, outdated, false or unlawfully obtained or are no longer necessary for the purposes for which they were collected.

However, this should not be interpreted to mean that ECLARO assumes responsibility for the accuracy and truthfulness of the information that we receive online.

• 1.5 Amendments

ECLARO reserves the right to amend or revise this Privacy Statement for suitability or to comply with legal requirements without prior notice. Your continued access to our website is an acceptance of any change made in this Privacy Statement. Therefore, we encourage you to review it every time you visit us.

• 1.6 Website Tracking

This website uses a tracking technology to collect visitor behavior data. This data is collected anonymously and will be used for marketing and optimization purposes. Visitor data is saved anonymously and aggregated to a usage profile. Cookies may be used for this purpose, but only to collect and save data in anonymous form. The collected data will not be used to identify a visitor personally and is not aggregated with any personal data. The collection and storage of data may be revoked at any time with respect to subsequent services.

We are committed to protecting the personal data of all ECLARO applicants, whether applying for an employee or an intern role.

This describes how ECLARO collects, uses, discloses and stores personal data as part of our recruitment process. It also provides details of your personal data rights.

This applies to all candidates, potential employees, and individuals applying for a role with ECLARO at all times in the application and recruitment process.

• 2.1 Personal Data We Collect

The personal information we collect and process when you apply for a role with ECLARO includes but are not limited to:

• Identification and contact details, including your name, address, email address, contact information, gender, birthday, nationality, government identifiers such as National ID, passport, social security number.
• Employment history.
• Academic and professional qualifications, transcripts, and employment references.
• Details of your references, including their name, contact details, employer, and job role.
• Work authorization and details of your immigration/visa status.
• Information gathered through background checks such as criminal records, security clearance and credit scores.
• Information collected from publicly available sources, including social media platforms you use or other information available online.
• Other information you voluntarily provide throughout the process.

• 2.2 How We Use Your Personal Data

We collect and use your personal data primarily for recruitment purposes. In particular, to determine your qualifications for employment, assess your suitability and eligibility for work on certain projects that will help us reach a hiring decision.

If you are successful in the interview process, we will carry out background checks and validation of your experience and academic and professional qualifications. We will use a third-party organization to perform these checks and may share your resume and identification information that you have provided. Background checks will be completed only as permitted by local law.

If you accept a role at ECLARO, the information collected during the recruitment process may form part of your personnel file, to the fullest extent allowable, and will be processed in accordance with our data privacy policy.

If you are not successful in the interview process, we may keep your details so that we may reach out to you and invite you to apply for other positions that we think may be a good fit for you unless you request that we delete your application.

• 2.3 Disclosure of Data

We only disclose your personal data to those who require access to perform their tasks and duties, and to third parties that have a legitimate purpose for accessing it.

We will disclose your personal data to the following categories of recipients:

• Employees of ECLARO administering the recruitment process.
• Screening providers and third parties we are contracting to do a background check that verifies your employment history, academic and professional achievements.
• Third parties where you have consented or otherwise instructed ECLARO to share your personal data.
• Third parties to comply with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative, or judicial process.

We will implement measures to provide assurance that third-party organizations we use to process data on our behalf use information in a manner consistent with this Privacy Statement and applicable law. We will assure that the security and confidentiality of the information is maintained.

ECLARO does not sell personal data that we collect or process as part of the recruitment process or any related processes

• 2.4 Data Retention

Your personal data will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this privacy statement, our retention policy or otherwise required by applicable law.

California Consumer Privacy Notice

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”) when you visit the eclaro.com website or subscribe to receive our newsletter (our “Services”). ECLARO adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). We will process your personal information in accordance with this Privacy Notice and will be responsible for complying with applicable data protection laws.

Information We Collect
ECLARO collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we collect or process the following categories of personal information:

• Contact information, such as name, email address, postal address and phone number/s;
• Device and browser information which includes the name of the Internet service provider and the Internet Protocol (IP) address through which you access the Internet;
• Online identifiers such as the date and time you access our website, the pages that you access while at our website and the Internet address of the website from which you linked directly to our website; and
• Professional or employment-related information, such as your occupation and employer information.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our clients or their agents. For example, from information our clients provide to us related to the Services for which they engage us.
• Directly from you. For example, through information we ask from you when our clients or their agents subscribe and engage our Services.
• Directly and indirectly from you when using our Services or visiting our website. For example, usage details collected automatically in the course of your interaction with our platform or website.

Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfil or meet the reason for which the information is provided;
• To provide you with email alerts and other notices concerning our Services or to contact you if you request us to do so;
• To improve our Services to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. These service providers are authorized to use your personal information only as necessary to provide the requested services to us.  We will only transfer to those companies the personal information they need to deliver the service.

Your Rights and Choices
The California Privacy Rights Act (CPRA) provides California residents with specific rights regarding their personal information.  You may have certain rights available to you, which may include the following:

• Review the personal information we have about you or request a copy of it;
• Ask us to update or correct personal information if it is inaccurate;
• Request that we delete your personal information;
• Opt-out of sharing your personal information with third parties for some purposes; and
• Object to certain types of uses of your personal information.

Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).

 Deletion Request Rights
You have the right to request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
   
   
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at CCPA@useindio.com.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Other Uses and Disclosures of Information

We also use and disclose your personal information for other legitimate interests and legal reasons, as follows:

• To comply with applicable law or regulation, including laws outside of your country of residence;
• To respond to requests from public and government authorities, including authorities outside of your country of residence;
• To cooperate with law enforcement;
• To enforce our terms and conditions and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others;
• To comply with or monitor compliance with any corporate governance requirements; and
• In connection with a sale or business transaction, including any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock.

Data Retention
We retain your personal information for as long as necessary to provide the Services or for other essential purposes such as complying with our legal obligations.

Exercising Your California Privacy Rights
To exercise the rights described above, please submit a verifiable consumer request to us by writing to privacy@eclaro.com with the subject line “For the attention of the Data Protection Officer.”

Only you or your authorized agent may make a verifiable consumer request.  The request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  We will deliver our written response by email. Any disclosures we provide will only cover the 12-month period preceding the request.  The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination
We will not discriminate against you for exercising any of your CPPA rights. Unless permitted by the CPPA, we will not:

• Deny you use of our Services.
• Provide you a different level or quality of Services.

Changes to Our Privacy Notice
We reserve the right to amend this Privacy Notice at our discretion and at any time. The date this Privacy Notice was last updated is identified at the bottom of this document. You are responsible for periodically visiting our website and this Privacy Notice to check for any changes.

Contact Information
If you have any questions or comments about this Privacy Notice or on our Privacy Policy, or have any requests, or wish to make a complaint, you may contact us by writing to privacy@eclaro.com with the subject line “For the attention of the Data Protection Officer.”