Last Updated: July 2026
At Clustie, your privacy is important to us. This policy explains how we collect, use, share and protect your personal data when you interact with our company in compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR), whether through our consultancy services or when using our digital products, including Clustie app. Clustie is the commercial brand used by Full Venue, S.A., which is the legal entity responsible for the data processing activities described in this policy.
This policy is provided for your information and does not require your agreement: it describes how we process your personal data and the rights available to you.
1. Who We Are
Clustie is the brand and product name used by Full Venue, S.A., a company focused on Data Science and Artificial Intelligence to help businesses enhance their marketing performance, and the developer of Clustie app, a digital platform designed for clustering and segmentation of first-party data for businesses and marketing teams.
All data processing activities related to Clustie's services or platforms are carried out by Full Venue, S.A. Whenever this Privacy Policy refers to “Clustie”, “we” or “us”, it refers to Full Venue, S.A. as the relevant legal entity.
2. Contact Details
Full Venue, S.A. has appointed a Data Protection Manager (DPM) to oversee our compliance with data protection laws and to address any questions or concerns regarding your personal data. Please note that this role is an internal data protection contact point and not a formally appointed Data Protection Officer (DPO) under the GDPR.
Data Controller: Full Venue, S.A.
Name: Tiago Costa Rocha
Avenida Fernão de Magalhães 1862, Torre das Antas, 3º Andar, Fração BL
4350-158 Campanhã, Porto (Portugal)
**E-mail: **tiago@clustie.ai | hello@clustie.ai
If you have questions or concerns about how your data is handled, or if you wish to exercise your data protection rights, please contact us or our DPM using the details above. This is without prejudice to your right to lodge a complaint with a supervisory authority at any time.
3. Scope of This Policy
This Privacy Policy applies to all data we collect and process in the context of:
- Clustie's consultancy services;
- Clustie's web platform and website (www.clustie.ai);
- Related communications and marketing campaigns; and
- Recruitment activities, including applications to open roles and unsolicited applications submitted through our Careers page, by e-mail or via third-party platforms (such as LinkedIn).
4. The Data We Collect
We may collect, use, store and transfer different kinds of personal data including:
- Identity Data: name, company, job title
- Contact Data: email, phone number, address
- Inquiry and Message Data: any additional information users provide when contacting us, such as messages submitted through forms, support requests or feedback
- Technical Data: IP address, browser type, device info
- Usage Data: how data subjects use websites, platforms and services (including Clustie)
- Profile Data: user preferences, feedback, login credentials (for Clustie)
- Transaction Data: billing and payment information
- Marketing Data: communication preferences
- Recruitment Data: if you apply for a role at Full Venue, S.A. , whether to an open vacancy (including through the application form on our Careers page) or through a spontaneous application, by e-mail or via third-party platforms such as LinkedIn, we collect your name, phone number, email and CV/resume (more details on Section 7)
We also collect aggregated data for statistical purposes. We do not intentionally collect special categories of personal data (e.g. data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health data or data concerning a person's sex life or sexual orientation).
We ask candidates and users not to include such sensitive information in their communications or CVs. If you nevertheless provide special category data, we will either delete it where it is not necessary or process it only where we can rely on an appropriate legal basis under the GDPR (for example, where it is necessary to comply with employment law obligations).
The data used to run our digital products, including Clustie, is often collected from Clients and Companies we work with, and pertains to data holders who maintain a relation with such Clients and Companies and in respect to which said Clients and Companies are the Controllers or Processors of such personal data, with Full Venue, S.A. acting as the (Sub) Processor.
5. How We Collect Your Data
We collect data through:
- Direct interactions: form submissions, emails, account registration on Clustie
- Job applications: CVs, cover letters or any related materials submitted directly to us by candidates, including spontaneous applications sent without reference to an open vacancy
- Automated technologies: cookies and server logs
- **Controllers and Processors: **personal data collected and controlled by our business clients or their processors in respect of which Clustie acts as a (sub-)processor, in accordance with a data processing agreement that sets out our role and obligations under the GDPR
- Third parties: analytics providers, advertising networks and platforms (such as Meta, from which we may receive data and insights about our advertising campaigns), public sources
6. How We Use Your Data
We use your personal data for:
- Providing Clustie consultancy services
- Operating and improving the Clustie platform
- Managing accounts and customer relationships
- Processing and delivering orders
- Responding to inquiries or support requests
- Sending relevant communications and marketing
- Ensuring website and platform security
- Complying with legal or regulatory obligations
Lawful Bases: We rely on the following lawful bases to process your data:
- Performance of a contract
- Legitimate interests
- Legal obligations
- Consent (when required, e.g. for marketing electronic communications services)
The lawful bases described in this section apply to personal data we process in connection with our clients, users and marketing contacts. Our specific lawful bases for recruitment and job applications are described in Section 7.2 below. By way of example:
- We rely on performance of a contract to provide our consultancy services, operate Clustie accounts and manage billing and payments;
- We rely on legitimate interests to improve our products and services, ensure the security of our websites and platform, and communicate with existing clients about similar services, provided that your interests and fundamental rights do not override those interests (you can always object - see Section 14); and
- We rely on consent where required by law, for example for certain forms of electronic direct marketing or for placing non-essential cookies, and you can withdraw your consent at any time.
7. Recruitment and Job Applications
Full Venue, S.A. welcomes both applications to open vacancies and spontaneous applications from candidates who contact us on their own initiative. This section sets out the lawful basis on which we collect and use candidate data.
7.1. Data We Collect
When you submit a spontaneous application or apply to a vacancy, whether by e-mail, through our website, a careers page, LinkedIn, or referral, we may collect:
- Identity and contact data (name, email, phone number, address)
- CV/resume content (education, work history, skills, certifications, languages)
- Cover letter and any other information you choose to include
- Interview notes and assessment or evaluation records, if you proceed further in a recruitment process
Please avoid including special categories of personal data (such as information about your health, religious beliefs or trade-union membership) in your application. If you do so, we will only process such data where we have a clear legal basis, or otherwise delete or minimise it.
7.2. Lawful Basis
These lawful bases apply to personal data we process in the context of recruitment activities, including applications submitted through our Careers page, by e-mail or via third-party platforms. We process candidate data on the basis of:
- Legitimate interests, in evaluating candidates, running recruitment processes, and maintaining a pool of potential candidates for future vacancies, provided that these interests are not overridden by your rights and freedoms;
- Pre-contractual steps taken at your request, where you progress in a hiring process and we need to process your data in order to assess your suitability and negotiate a potential employment contract; and
- Consent, where you explicitly agree that we may keep your data for a longer period to consider you for future roles or contact you about other opportunities. You can withdraw this consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
7.3. How We Use It
- Assess your suitability for current or future roles at Full Venue, S.A.
- Contact you regarding your application, the recruitment process, or other opportunities that may match your profile
- Maintain a candidate pool for spontaneous applications, in case your profile fits a future vacancy
- Comply with applicable employment and equal opportunity laws
7.4. Retention
We retain spontaneous application and candidate data for up to 12 months from the date of receipt or last contact, after which it is deleted or anonymized, unless:
- you give explicit consent for a longer retention period, so we may consider you for future roles;
- you are hired, in which case your data transitions to your employment file, subject to our employment data retention rules; or
- we are required to retain it for a longer period to comply with a legal obligation or to establish, exercise or defend a legal claim.
You may request the earlier deletion of your candidate data at any time by contacting us at hello@clustie.ai.
7.5. Your Rights
As a candidate, you hold the same rights described in Section 14 (Your Rights) of this policy, including the right to access, correct, or request erasure of your data, the right to withdraw your consent at any time (which does not affect the lawfulness of processing carried out before withdrawal), and the right to object to being considered for future roles. To exercise these rights, or to withdraw your application from consideration, contact us at hello@clustie.ai.
7.6. Sharing
Candidate data may be shared internally with team members involved in the hiring decision, and, where used, with recruitment or HR software providers acting as processors on our behalf and bound by confidentiality and data protection obligations. We do not sell candidate data or share it with third parties for their own marketing purposes.
8. Marketing and Communications
Clustie may send you marketing communications based on your prior consent or, in some cases, our legitimate interests where permitted by law (for example, when we contact existing clients about similar services). You have the right to withdraw your consent or object to such communications at any given time. To opt out, you can:
- Use the unsubscribe link included in our marketing e-mails
- Contact us directly at hello@clustie.ai
We will not send you electronic direct marketing (such as e-mail or SMS campaigns) without a valid legal basis and, where required, your prior consent.
Clustie communications (other than marketing related) are currently limited to operational messages that are necessary for service delivery, such as account notifications and system updates. These operational communications are essential and therefore cannot be unsubscribed from. If you have any questions or concerns regarding Clustie communications, please contact us at hello@clustie.ai.
9. Cookies and Analytics
We use cookies and similar tracking technologies to improve your experience and help us understand how our websites are used.
What are cookies? Cookies are small text files placed on your device to store information about your preferences and activity.
How we use cookies:
- To remember your preferences and settings
- To analyze site traffic and usage patterns
- To personalize content and marketing communications
- To enhance security and prevent fraud
Managing cookies: You can control or disable cookies through your browser settings. Please note that blocking certain cookies may affect website functionality or your user experience.
Third-party cookies: We may also use third-party services that use cookies to collect information about your use of our websites for analytics and performance purposes, as well as for advertising and marketing purposes. These providers are bound by confidentiality and data protection obligations.
**Cookie choices: **Except for cookies that are strictly necessary for the functioning of our websites, we will only place cookies (including analytics and similar tracking technologies) on your device with your prior consent, in line with applicable data protection laws. When you first visit our websites, you will see a cookie banner that allows you to accept or reject non-essential cookies, and you can change your preferences at any time through the cookie settings available on the site.
10. Data Sharing
We may share your personal data with:
- Internal team members who require access for service delivery
- Trusted third-party service providers (e.g. cloud hosting, analytics, CRM tools, recruitment software) acting as processors on our behalf and bound by confidentiality and data protection obligations
- Business partners, if applicable and where we have a legal basis to do so
- Regulatory or legal authorities when required
We do not sell your personal data. All third parties are required to respect the confidentiality and security of your data and to process it only on our documented instructions or as required by law.
11. International Data Transfers
We may transfer your data outside the European Economic Area (EEA), for example when we use cloud hosting, analytics or recruitment providers located in other countries. When we do so, we ensure that your data is protected with appropriate safeguards, such as:
- A decision by the European Commission confirming that the recipient country ensures an adequate level of protection for personal data; or
- Standard Contractual Clauses or other contractual safeguards approved under the GDPR, together with additional technical and organisational measures where necessary.
You can contact us at hello@clustie.ai if you would like more information about the international transfers that may affect your data and the safeguards we use.
12. Data Security
We implement technical and organizational measures to protect your data from loss, unauthorized access or misuse, in line with the GDPR's security requirements. Only authorized personnel have access to personal data and are bound by confidentiality obligations.
13. Data Retention
We retain personal data only as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, tax or accounting obligations. Retention periods may differ depending on the category of data and the context in which it was collected (for example, client account data, marketing contacts or candidate data). Where we cannot specify a fixed period, we use criteria such as the duration of our relationship with you, applicable legal retention periods and the time needed to resolve disputes or enforce our agreements. Candidate data submitted through job applications, including spontaneous applications, is retained in accordance with Section 7.4.
When no longer needed, we securely delete or anonymize the data. Anonymized data may be retained solely for research, statistical or analytical purposes, as it does not contain any personally identifiable information.
14. Your Rights
Under GDPR, you have the right to:
- Access your personal data
- Request correction or erasure
- Object to or restrict processing
- Object to the use of your data for direct marketing at any time
- Request data transfer (portability)
- Withdraw consent (where applicable)
- Lodge a complaint with a supervisory authority (in Portugal, this is the Comissão Nacional de Proteção de Dados (CNPD))
To exercise any of these rights, contact us at hello@clustie.ai. We aim to respond within one month.
15. Third-Party Links
Our websites may link to third-party sites or services. We are not responsible for their content, security or privacy practices. We encourage you to review the privacy policies of any third-party sites you visit before providing them with your personal data.
16. Changes to This Policy
We may update this policy occasionally to reflect changes in our practices or legal requirements. Any updates will be posted on our website with a revised "Last Updated" date at the top of the policy. We encourage you to review this policy regularly to stay informed about how we collect, use and protect your data.
Contact Us
For any privacy-related concerns or requests, please reach out to us at:
E-mail: hello@clustie.ai