Controller of Personal Information
Any Personal Information provided or gathered by visiting the Site from cleverbridge is controlled by cleverbridge AG at Gereonstr. 43-65, 50670 Cologne, Germany (“Data Controller”). cleverbridge, Inc. (350 N Clark, Suite 700, Chicago, Illinois, 60654, USA) acts as data processor on behalf of the Data Controller.
cleverbridge has developed global data practices to assure your Personal Information is appropriately protected. Please note that Personal Information may be transferred, accessed and stored globally as necessary for the uses and disclosure stated in this policy. cleverbridge affiliates have entered into and executed agreements for the international transfer of Personal Information which allows for the processing of your data and which correspond to the European Union Model Clauses for transfer of Personal Information to third countries.
In general, information (including Personal Information) you submit to us is used by us to respond to requests that you make, to better tailor the features, performance and support of the Site, and to offer you additional information, opportunities, and functionality. We also use this information to prevent or detect fraud or abuses of our Site and enable third parties to carry out technical, logistical or other functions on our behalf. We may create Anonymous Information records from Personal Information by excluding information that makes the information personally identifiable to you.
Here are the types of information we collect as well as their designated use.
“Personal Information” is information that is personally identifiable like names, addresses, email addresses, or phone numbers, as well as other non-public information that is associated with the foregoing.
We collect the following Personal Information that you submit to us voluntarily:
- Upon accessing our Site, certain additional information is automatically collected and then saved in protocol files (so-called usage data). This information includes, among other things, your Internet Protocol (IP) address. We may use this information for internal purposes, such as maintaining our operating ability, preventing fraudulent access to our Site or analyzing usage patterns. For more information visit the “Automatic Data Collection and Anonymous Information” section.
- If you fill out any of the contact forms of the Site, we collect your name, company, country, email address, the description and details of your request and any other information you choose to provide.
- When you contact us by email or telephone or if you are using any of the email addresses or telephone numbers provided on the Site, we collect any Personal Information you may provide to us voluntarily in connection with this communication.
- Within the scope of cleverbridge’s personalized services, your data will, subject to your consent, be used for advertising, market research and tailoring electronic services. Unsubscribe instructions will accompany each newsletter or promotional communication you receive from us. In addition you can withdraw your consent at any time in the future. For more information visit the “Review and Correction of Personal Information” section.
We receive and store certain types of information whenever you interact with us. This automatic exchange of data between your browser and our server upon accessing our pages informs us of which browser you are using, the date and time of your visit, the name of your Internet Service Provider (ISP), the website you are using to visit us and which of our websites you are visiting.
The information we collect automatically is called “Anonymous Information”. Anonymous Information means information that is not associated with or linked to your Personal Information. Thus Anonymous Information does not permit the identification of individual persons.
We may use this Anonymous Information for internal purposes, such as maintaining our operating ability, preventing fraudulent access to our Site or analyzing usage patterns so that we may enhance our Site. We also reserve the right to use and disclose any Anonymous Information at our discretion, although you will remain anonymous as an individual user.
We automatically collect Information through different technologies as described below.
Our website uses technologies such as Cookies, beacons, tags and scripts. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by their respective providers on an aggregated basis.
Google will use this information to evaluate your use of the Site, compile reports on Site activity and provide other Site activity and internet related services. In addition, Google may also transfer this information to third parties if required by law or if third parties process the information on Google’s behalf.
By using this Site, you consent to the processing of data about you by Google in the manner described and for the aforementioned purpose. More information about Google Analytics can be found here.
Our website may also use, on some pages, the Hotjar analysis service to collect analysis and feedback. Hotjar is provided by Hotjar Limited (Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta), https://www.hotjar.com/.
Hotjar’s services allow us to analyze how visitors use our website by revealing the online behavior and feedback of our website’s visitors. We do not use Hotjar to collect Personal Information or transfer such information to Hotjar.
We use Hotjar to record on a non-personal basis, information such as mouse movements, mouse clicks, and scrolling activity. Information about the browser (type, version, screen size, etc.), basic information about the user (country, language, time zone), and data containing mouse movements, clicks, scroll events and keystrokes are transferred to Hotjar. Information that you enter into form fields and your IP address are masked with unreadable content before information is transmitted to Hotjar to protect your privacy.
Do Not Track Signals
Some Internet browsers include the ability to transmit “Do Not Track” (DNT) signals. At this time, however, the definitions and meanings of DNT signals and responses, and the correct behavior regarding DNT signals, are not defined. Until such time as the standard is finalized, this Site does not process or respond to DNT signals. To learn more about DNT, please visit donottrack.us.
Disclosure of Personal Information
Third Party Service Providers and Suppliers
We may provide your Personal Information to third party service providers and suppliers who work on behalf of or with us to provide you with the Site, related support, and to help us communicate with our users and clients and to operate the Site. Examples of such services include communicating with you via email, remain compliant with applicable laws, and/or providing support service for us. However, these service providers and suppliers do not have any independent right to use your information.
Law Enforcement, Governmental Authorities and Agencies
We may disclose information we have collected from and about you (including Personal Information) if we believe in good faith that such disclosure is necessary to
- comply with relevant laws or to respond to subpoenas or warrants served on us;
- to protect and defend the rights or property of us, our users, or third parties.
Export and Processing of Personal Information in Countries Outside of the European Economic Community
We hereby state that, for the purposes mentioned in the “Types and Use of Information We Collect” section, your data may be transferred to our subsidiary based in the United States that, to date, generally do not have a data privacy level that is recognized as being congruent to the European Union.
Please note, that cleverbridge affiliates have entered into and executed agreements for the international transfer of Personal Information which allows for the processing of your data and which correspond to the European Union Model Clauses for transfer of Personal Information to third countries.
Data Security and Confidentiality
In order to maintain the highest level of user protection, we adhere to applicable industry rules and regulations. Thus, we maintain commercially reasonable and appropriate physical, electronic, and managerial measures and procedures to safeguard and secure your Personal Information during data collection, transmission and storage. Your data are only accessible by authorized persons who are familiar with cleverbridge’s data privacy policies. However, no company, including cleverbridge, can fully eliminate security risks associated with Personal Information.
Right to Object
If you choose that you no longer want to be contacted by us for the purposes of offering you additional information, opportunities, and functionality, please contact us as described in section Contact Us.
An individual who wants to review, correct, block or delete their stored Personal Information, please send us a brief request in writing, either via post or email (see below). In the event that, despite our efforts to maintain data correct and up-to-date, false information has been saved, then we will change it upon your request. You will normally receive a response to your request from us within thirty (30) days.
For more information on whether we store Personal Information about you and what this data is or other data privacy topics, please contact our data privacy agent in writing as described in section Contact Us.
cleverbridge will retain Personal Information we process on behalf of our clients for as long as needed to provide services. cleverbridge will retain and use this Personal Information as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.
Upon full consummation of your contractual relationship with cleverbridge, your data (including Personal Information) will, upon your request, be blocked at the internal cleverbridge systems from further processing and deleted after completion of the mandatory legal storage periods.
You understand that any deletion of your Personal Information extends only to the data related to you as a person. cleverbridge will not have any liability whatsoever to you for any termination of your Account or related deletion of your Personal Information or data.
When we delete Personal Information that we have collected from or about you, it will be deleted from our active databases but may remain in our archives.
Notice to California Residents
If you would like to know
- the categories of Personal Information about you that we disclosed in the prior calendar year to Providers for the purposes of the Provider’s marketing and/or
- the names and addresses of such Providers,
please contact us as described in section Contact Us.
Please note that we are required to respond to one request per California resident each year, and we are not required to respond to requests made by means other than through email.
Links to Other Websites
Privacy of Minors
In principle, persons under the age of eighteen (18) should not transfer any Personal Information to us without the consent of a parent or legal guardian. We will neither intentionally ask for Personal Information of minors, nor collect or transfer them.
We do not intentionally collect or maintain information from those visitors of the Site who are under sixteen (16) years old.
To contact us in writing please address your inquiry to:
Data Protection Officer
50670 Cologne, Germany
Last updated: August 2016