Clave Consulting AS

Model privacy policy

Valid from 25.08.19


This privacy policy explains how Clave Consulting AS collects and process personal information on users to the Poption recruitment platform ('Poption'). Clave Consulting AS is the data controller for the processing of personal data, and may be contacted at

Nothing within this privacy policy is intended to limit your statutory data privacy rights as a data subject.

2.Legal basis for our processing of personal data

By registering for the Poption recruitment platform you consent to the terms of this privacy policy and to have your personal data as defined below collected and processed by Clave Consulting AS.

Clave Consulting AS does not intend to process special categories of personal data, such as data on racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

Clave Consulting AS will only process special categories of personal data as specified above at your request, i.e., when you submit such data to Clave Consulting AS through your use of Poption. By submitting such special categories of personal data you are deemed to have provided us with your informed, expressly and freely given consent to process such data.

3.How personal data is collected through your use of Poption

Clave Consulting AS may collect your personal data:

  1. during your registration of a profile with Clave Consulting AS through Poption,
  2. when you use Poption to submit information by filling out forms, subscribe to notifications (e.g., email), modify your user profile,
  3. by monitoring your use of the service, through e.g. web analytic tools.

We may also collect your personal data through your use of supported third party services. Use of these third party services are governed by the third party's own terms and data processing provisions. By logging in to these third party services from Poption you are deemed to have consented to our processing of the personal data submitted to us by the third party service, pursuant to your request.

Poption currently supports the following third party services:

  1. Vitnemålsportalen, provided by Feide pursuant to the following data privacy provisions:
  2. LinkedIn, pursuant to the following data privacy provisions:

4.Purpose of the processing of personal data

Clave Consulting AS will process information as mentioned above for the purposes of:

  1. providing the Poption service;
  2. improving or otherwise modifying the Poption service;
  3. replying to you communications and contacting you for recruitment purposes;
  4. performing our statutory obligations towards you as a data subject.

5.Retention period

Clave Consulting AS will retain your personal data until the purposes of the processing have been fulfilled, at the latest within 6 months from the end of your specified graduation semester or within 60 months from today, whichever comes first. Personal data will be deleted or anonymized at the end of the retention period, unless statutory obligations prevents such deletion.

6.Where personal data is processed

The data controller is Clave Consulting AS, which may be contacted at

Clave Consulting AS may use processors and sub-processors and transfer personal data to these sub-processors, including sub-processors in countries not within the EU or EEA. In such cases, Poption will transfer personal data subject to appropriate safeguards provided by the sub-processors, such as a legally binding and enforceable instrument between public authorities or bodies (e.g., the EU-US Privacy Shield Framework), or standard data protection clauses adopted by the EU Commission. A copy of such safeguards may be obtained by contacting Clave Consulting AS.

7.Transfer of personal data to others

Notwithstanding the above, Clave Consulting AS will not transfer or provide access to Data Subject's personal data to any third party except when, to the extent, and to persons

(i) With the data subject's consent,

(ii) required by law, or

(iii) necessary in order to perform Clave Consulting AS's statutory obligations, or to exercise its legal rights, or defend against claims or other process.

Clave Consulting AS ensures that it has implemented and will continue to employ appropriate measures to ensure that personal data are processed securely and in compliance with the applicable law.

8.Your rights as a data subject

Right of access and right to rectification or erasure of personal data

Upon the data subject's request, Clave Consulting AS will grant the data subject access to, all personal data that Clave Consulting AS maintains about the data subject, unless such personal data is otherwise available to the data subject or Clave Consulting AS is legally prohibited from disclosing such personal data.

If any personal data prove to be incorrect or misleading, the data subject is entitled to have the data rectified or restricted. Registered data subjects can access, correct and erase their personal data through the Poption recruitment platform.

Rights in connection with disclosure

In all cases where Clave Consulting AS is allowed to disclose personal data to third parties, it will ensure that the person to whom disclosure is made grants the respective Data Subject the same rights as those set forth herein with respect to the processing of such Personal Data (including the right to be informed about the data maintained on the Data Subject and the right to correct or have corrected incorrect or misleading information).

Right to data portability

The data subject has the right to receive the personal data concerning him or her, which he or she has provided to Clave Consulting AS, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from Clave Consulting AS.

Right to lodge a complaint with a supervisory authority

The data subject has the right to lodge a complaint with a supervisory authority if the data subject considers that the processing of personal data relating to him or her infringes his or her rights.

Right to withdraw consent

The data subject may at any time withdraw its consent to Clave Consulting AS's processing of personal data pursuant to this privacy policy. Upon withdrawal of consent, Clave Consulting AS shall immediately seize processing of the data subjects personal data and ensure that any personal data related to the subject has been erased.

9.Change of policy

Clave Consulting AS may amend or repeal this privacy policy at any time by posting a revised privacy policy or a new policy document in its place. If such revised or new policy includes a significant change to the way that personal data may be treated, Clave Consulting AS will notify registered users of the fact that its privacy policy has changed by sending users an email to the address associated with their user account, and by posting a prominent notice on the Poption recruitment platform.