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Privacy Policy Protection and processing of your personal data 1. Applicable Regulations We comply at all times with the regulations in force regarding the protection of personal data, including the following provisions: •The French Data Protection Act No. 78-17 of January 6, 1978, as amended; •Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (GDPR - General Data Protection Regulation). 2. Data Controller The data controller is: Clustr 60 RUE FRANCOIS IER, 75008 PARIS, France contact@getclustr.app 3. Personal Data Collected Clustr only collects and processes data that has been voluntarily made public by users on professional social networks. No private data or data subject to privacy restrictions is collected. The data concerned may include: •Full name •Job title •Profile picture (if public) •Current company •Location (city or region) •Industry •Career history (if visible) •Public profile URL This data may be: •Provided by the client company as part of setting up the Service for its employees; •Collected from public sources, according to the visibility settings defined by the users themselves. Users can modify their profile visibility at any time. If a profile becomes private or restricted, Clustr no longer has access to it. 4. Purposes and Legal Basis Personal data is processed for the following purposes: •Collection of public professional profiles of employees or contacts; •Access to public professional information for B2B prospecting, analysis, or lead management; •Personalization and proper functioning of the Clustr service (interface, SaaS features). Legal Basis In accordance with Article 6.1.f of the GDPR, the legal basis for processing is the legitimate interest of Clustr and its professional clients, namely: •Having access to publicly available professional information to initiate B2B relationships; •Improving the relevance and performance of commercial or recruitment activities. This legitimate interest is balanced with the rights and freedoms of data subjects, particularly by processing only publicly accessible and non-sensitive data. 5. Recipients and Data Transfers Data is never sold or shared with third parties for commercial purposes. Third-Party Service Providers We use certain third-party services for features such as analytics or automated processing (e.g., AI models, enrichment). These providers may be located outside the European Union. In such cases, we ensure they provide an adequate level of protection (standard contractual clauses or other mechanisms provided for by the GDPR). No personally identifiable data (name, email, etc.) is transmitted to these providers without a legal basis or explicit consent. Only non-identifying data (e.g., job title) may be transmitted for algorithmic processing. Subcontracting We currently do not use any external subcontractors for personal data processing. 6. Data Retention Data is retained only for as long as necessary to fulfill the purposes of processing, and for a maximum of: •24 months from collection for data from public sources; •Or until a request for objection or deletion is made. 7. Data Security We implement appropriate technical and organizational measures to ensure the confidentiality, integrity, and availability of personal data, in accordance with industry standards and GDPR requirements. Our data is hosted within the European Union by certified providers offering a high level of security. 8. Data Subject Rights In accordance with Articles 15 to 22 of the GDPR, every data subject has the following rights: •Right of access to their data; •Right to rectification; •Right to erasure (right to be forgotten); •Right to object to processing (particularly for prospecting purposes); •Right to restriction of processing; •Right to data portability. These rights can be exercised at any time by contacting us at: contact@getclustr.app If you have any questions about exercising your rights, you may also file a complaint with the CNIL (French Data Protection Authority): www.cnil.fr