Privacy Statement

Last updated: June 20, 2023

Who are we?

We are Clember B.V. (hereinafter "Clember" or "We"). This privacy statement describes how Clember collects, uses and discloses personal information. Guaranteeing the safety and privacy of your personal data is not only in your interest, but also in ours. We use adequate technical and organizational measures and procedures to keep the information accurate, current, and complete. If you indicate that certain information may not be used as a basis for further contact, we will respect that. As a result, your privacy is guaranteed. By using our services, you agree to the collection and use of information in accordance with this privacy statement.

This privacy statement relates to personal data we process as part of customer relationships, of business associates and contacts, visitors to Clember, job applications, and visitors to our website and users of our platform and services.

Personal data are all data that can be traced back to a person. Examples include your name, email address, telephone number, and account number. The personal data that we process can be divided into categories per purpose of processing for ease of reference. We use the following categories of personal data.

Categories of Personal Data and our purposes

Customers, prospects, suppliers, office visitors and business contacts: Name, (business) mobile phone numbers, (business) email address, and signatures.

This data is necessary for the following purposes:

  • Being able to sign agreements with (potential) customers.
  • Executing and administratively handling the agreements we sign with our customers.
  • The fulfilment of legal obligations, such as tax record retention requirements.
  • Maintaining and expanding a business network.

Job applicants, trainees and interns All information job applicants, trainees and interns share in their resume or cover letter. Usually this entails name, address, date of birth, (business) mobile telephone number, (business) email, training and education, and possibly a photograph.

This data is necessary for the following purposes:

  • To hire and assess the suitability of job applicants, trainees and interns.
  • Draft (employee/trainee/intern) proposals.

Website visitors and users of the Clember platform Name, (business) mobile phone number, (business) email address, IP-address, account username and password.

This data is necessary for the following purposes:

  • Executing and administratively handling the agreements we sign with our customers.
  • Account registration and login authentication to grant access to our platform.
  • Maintaining and expanding a business network.
  • React to questions and demo inquiries.
  • Securing our website and platform.
  • Technical and statistical purposes to provide an optimal user experience.

Lawfulness of processing

Processing of personal data by Clember is lawful and the following applies:

Performance of a contract: All our services will be concluded in a contract. When the contract is executed, users are granted access to our platform and services. Also, for the pre-contractual phase, the legal basis is also the contract.

Legal obligation: Clember collects personal data to be able to comply with its legal obligations, such as administration obligations as required by tax authorities.

Legitimate interest: Legitimate interest applies to us only as a basis for processing within the context of marketing and security purposes. For example, reaching out to prospects, business relations, or other marketing purposes.

Third parties

Clember does not collect personal data from third parties.

And yes, Clember uses third parties for processing activities, such as hosting our platform (in Amazon Web Services) and sending out emails (via Microsoft). We always do this in a careful manner and for this we take the required organizational, technical and contractual measures to ensure that your personal data is protected. If this is required by law, we will share your personal data with the relevant authorities. Under no circumstances will Clember sell personal data to other parties.

Data outside the EU Clember does not process data outside the EU unless it’s necessary for the services we provide. It could be, however, that a specific supplier is located outside of Europe. In that case, we will only use suppliers under the appropriate safeguards of the European laws and regulations.

How does Clember protect your personal data?

Clember has taken appropriate technical and organizational measures against loss or unauthorized processing of personal data. Clember uses various security techniques, including secure servers, periodically executed software updates, the use of (web application) firewalls, strong encryption and robust access control policies. But remember that 100% security can’t be guaranteed. For any questions regarding security or personal data processing, or if there are indications or suspicions of misuse of data or systems, please contact us via [email protected].

Retention and deletion

We will not retain your data any longer than is necessary to fulfil the purposes set out in this privacy statement.

Your rights

To exercise your privacy rights please contact us via [email protected].

You can exercise the following rights:

Right to information and access You can request access to the personal data we process of you.

Right to rectification If you believe the data we have on you is inaccurate, we will correct it.

Right to be forgotten You can ask for erasure of the data we have on you. We may need to process this data for other purposes (e.g., for our records and to fulfil our statutory duties) and can’t (fully) adhere to this request.

Right to restriction of processing You can have the processing of your personal data restricted if you believe we are processing your personal data unlawfully or incorrectly.

Right to object If you object to the processing of your personal data, we will discontinue this processing as soon as possible.

Right to data portability If you would like to transfer your personal data, please contact us.

Withdrawal of consent If you have given your consent for your personal data to be processed, you have the option to withdraw this consent.

Clember will reply to your request within four weeks or will inform you of the reasons why it is taking longer to reply.

Data breach process

Should you discover a data breach, you can report it to us via [email protected].

Use of cookies

Our website and platform uses cookies. Cookies are small text files that are transmitted when you use our website and platform and are stored on your computer, tablet or other mobile device. In addition to the cookies transmitted by Clember, third parties may also set cookies through our website.

We use different types of cookies and similar technologies to make your visit to our website and platform as easy and personal as possible. This gives you access to relevant information and enables you to share our content. Below we explain the various types of cookies used.

Essential cookies These essential cookies are necessary for you to browse our website and use its features, and use our platform, including access to the secure sections of the website and platform. These cookies result in a minimal invasion of privacy.

Functional cookies Functional cookies ensure that our website functions properly and that you can access and use our website and platform with ease. These cookies ensure that options you have selected in the past – including your username and password – are remembered, so you can log in automatically. Functional cookies likewise result in a minimal invasion of privacy.

Analytical cookies Analytical cookies enable us to further improve and update our website and platform. These cookies collect information on how you use our website and platform, including the pages you visited and the links you clicked on.

Marketing cookies and third-party cookies In some cases, we may also use third-party cookies. These cookies track your online activities and are set by advertising networks and other third parties. These cookies can be used for the following purposes:

  • Displaying relevant personalized content based on your visit and browsing behavior on our website and platform.
  • Documenting your interactions with Clember.
  • Measuring the effectiveness of a marketing campaign.
  • Creating a link with your profile and preferences.

Our privacy and cookie statement does not apply to third-party websites which are linked to our website through hyperlinks and/or cookies or pixels. Since we have no control over how they use cookies, we recommend that you also read the privacy and cookie statements of these third parties.

Most cookies are stored for a specific period, meaning they expire automatically after a set date. You can also delete cookies prior to the end of the retention period by adjusting your browser settings. Please check your browser instructions for further information.

Changes to this Privacy & Cookie Statement We reserve the right to amend this privacy statement if this is required by law or regulations. Because of this, you are requested to regularly read through the privacy statement so that you remain aware of its current content.


Should you have any questions, complaints or comments, please contact us via [email protected].

Filing a complaint with a competent supervisory authority We believe it is important to have satisfied customers. Even though we make every effort to achieve this, it may happen that you are dissatisfied. Should this happen, it is possible to file a complaint with the competent supervisory authority about the processing of your personal data. In principle, you can do so with the supervisory authority situated in the country where you reside. Should you have any doubts concerning the competent supervisory authority, you can always contact the Dutch Data Protection Authority (Dutch DPA).