Controller of Personal Information
The data controller of the Personal Information when you visit or use the Site is cleverbridge AG at Gereonstr. 43-65, 50670 Cologne, Germany (“Data Controller”).
cleverbridge, Inc. (350 N Clark, Suite 700, Chicago, Illinois, 60654, USA), cleverbridge Financial Services GmbH (Gereonstr. 43-65, 50670 Cologne, Germany), cleverbridge KK (Wakamatsu Bldg. 7F, 3-3-6 Nihonbashi-Honcho, Chuo-ku, Tokyo 103-0023 Japan), and cleverbridge Co., Ltd. (Level 4, Neihu New Century Building, 55 Zhouzi Street, Neihu District, Taipei, Taiwan) act as data processors on behalf of the Data Controller.
Contact: Inquiries, Access, and Updating Your Personal Information
If you wish to review, correct, block, or delete stored Personal Information about you, or if you would like to know the categories of Personal Information that we disclosed in the prior calendar year to partners and the names and addresses of those partners, please send us a brief request in writing, either via mail or email using our Help Center. Upon request, we will provide you with information about whether we hold any of your personal information. If, despite our efforts to maintain correct and up-to-date information, we have any incorrect information about you, then we will change it upon your request. You will normally receive a response to your request from us within thirty (30) days. Please note that we are required to respond to one request per person each year about whether we hold any of your personal information.
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 protection officer:
Data Protection Officer
50670 Cologne, Germany
email contact via our Help Center
Right to Lodge a Complaint with a Supervisory Authority
If you think that our processing of your Personal Information infringes your rights under applicable law, in particular under the Regulation (EU) 2016/679 (General Data Protection Regulation), you have the right to lodge a complaint with a supervisory authority, such as the public authority which is established in the EU member state of your habitual residence, place of work, or place of the alleged infringement. You can also lodge the complaint with the supervisory authority responsible for cleverbridge’s place of work, which is the North Rhine-Westphalia Commissioner for Data Protection and Freedom of Information (LDI NRW).
Types and Use of Information We Collect
In general, Personal Information you submit to us is used by us to respond to requests that you make, for the purpose of registration (if any), 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 to better tailor the features, performance, and support of the Site, or to enable third parties to carry out technical, logistical, or other functions on our behalf.
Following are the types of information we collect as well as their designated use.
“Personal Information” means any information relating to an identified or identifiable natural person 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 provide by using the Site:
Requests and use of the Site
- On certain Sites, we give users the option of providing us with account registration information. This information may include, among other things, your name, address, email address, and a password.
- When you contact us by email, fax, or telephone, or if you are using any of the email addresses, fax, or telephone numbers provided on the Site, then we may collect any Personal Information you choose to provide to us in connection with this communication.
- If you fill out any of the contact forms of the Site, then we may collect your name, email address, the description of your request, company and country (where required), and any other information you choose to provide for the purpose of answering your request.
The data will be processed on the basis of Art. 6 para. 1 lit. f GDPR, which permits the processing of data for the purposes of the legitimate interests pursued by us for direct marketing or on the basis of your consent pursuant to Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time. However, the lawfulness of the data processing already carried out remains unaffected by the revocation.
Newsletter and other promotional information
- If you request promotional information via any of the forms of the Site, or sign up for a newsletter or blog updates, then we will process your data, subject to your consent, for advertising, market research and tailoring electronic services.
- Unsubscribe instructions will accompany each newsletter or promotional communication you receive from us. You can withdraw your consent to receive those communications at any time in the future by contacting us as described under Contact: Inquiries, Access, and Updating your Personal Information.
The data will be processed on the basis of your consent pursuant to Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time. However, the lawfulness of the data processing already carried out remains unaffected by the revocation.
Automatic Data Collection and Analytical Data
In addition to the information you provide, we automatically collect information through different technologies as described below.
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.
More information about Google Analytics can be found here.
Our Site 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 Site by revealing online behavior related to our Site and collecting feedback from those 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.
Automatic Data Collection, Processing, and Use
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 Site informs us of which browser you are using, the date and time of your visit, the name of your Internet Service Provider (ISP), the Site you are using to visit us, and which parts of our Site you are visiting.
The information we collect automatically is called “Analytical Information.” Analytical Information means information that is not associated with or linked to your Personal Information. Analytical Information does not allow the identification of individual persons.
We may use this Analytical Information for internal purposes, such as determining certain settings for the Site like language or location, for maintaining our operating ability, preventing fraudulent access to our Site, or for analyzing usage patterns so that we may enhance our Site. We also reserve the right to use and disclose any Analytical Information at our discretion, as you will not be identified as an individual person.
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.
Personal Information from other Sources
We may receive Personal Information about you from other sources like third parties that provide services for us in connection with the Site. We may add this information to the data we collect from you via the Site for the purposes of preventing or detecting fraud or abuses of our Site and as set forth under Types and Use of Information We Collect.
Privacy of Minors
Persons under the age of eighteen (18) should not transfer any Personal Information to us. We will neither intentionally ask for Personal Information of persons under the age of eighteen, nor process their Personal Information.
Additional notice to residents of the United States: We do not intentionally collect or maintain information from visitors of the Site who are under thirteen (13) years old.
Disclosure of Personal Information
cleverbridge, Inc. (350 N Clark, Suite 700, Chicago, Illinois, 60654, USA), cleverbridge Financial Services GmbH (Gereonstr. 43-65, 50670 Cologne, Germany), cleverbridge KK (Wakamatsu Bldg. 7F, 3-3-6 Nihonbashi-Honcho, Chuo-ku, Tokyo 103-0023 Japan), and cleverbridge Co., Ltd. (Level 4, Neihu New Century Building, 55 Zhouzi Street, Neihu District, Taipei, Taiwan) act as data processors on behalf of the Data Controller to provide global customer support, fraud prevention, order fulfillment, client management, marketing and marketing services, and sales, business and platform development.
Third Party Service Providers
We provide analytical data to providers of analytics and tracking technologies as described in Cookies, Tracking and other Analytics Technologies.
Export and Processing of Personal Information in Countries Outside of the European Economic Community
For the purposes set forth under Types and Use of Information We Collect, your data may be transferred to our affiliates or to third party service providers based outside the European Economic Area in countries that, to date, may not have a data privacy level that is recognized as being equivalent to that of the European Union.
cleverbridge affiliates and third party providers that receive Personal Information from us 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 Contracts for transfer of Personal Information to third countries. A copy of the model contracts is available on the website of the European Commission.
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 respond to subpoenas or warrants served on us;
- protect and defend our rights or property, or the rights or property of visitors of the Site, our customers, our partners, or other third parties; or
- in certain situations, abide by lawful requests by public authorities to disclosure of Personal Information, including to meet national security or law enforcement requirements.
Data Security and Confidentiality
In order to maintain the highest level of user protection, we adhere to the applicable industry rules and regulations. Thus, we maintain commercially reasonable and appropriate physical, technical, and organizational measures and procedures to safeguard and secure your Personal Information during data processing, particularly collection, transmission, and storage. Your Personal Information is only accessible by authorized personnel familiar with cleverbridge’s data privacy policies. However, no company, including cleverbridge, can fully eliminate security risks associated with Personal Information.
cleverbridge will retain Personal Information for as long as needed for the purposes stated above. cleverbridge will retain and use this Personal Information as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.
In general, we delete your data as soon as it is no longer required for the above-mentioned purposes, unless temporary storage is still necessary. We store your data on the basis of legal proof and storage obligations, which result among other things from the German Commercial Code and the German Tax Code. According to which the storage periods are up to ten full years. In addition, we keep your data for the period during which claims can be asserted against our company.
Upon your request, we will block your personal information from further use based on applicable law. Once the statutory retention periods have expired, the data will be removed from our operative systems.
You recognize that any deletion of your Personal Information extends only to the data related to you as a person stored in systems under our control.
When we delete Personal Information that we have collected from or about you, we will take appropriate and economically reasonable measures to delete such information from our active databases but it may remain in our archives. Our archives are strictly restricted to prevent unauthorized access and processing.
Links to Other Websites
To contact us in writing please address your inquiry to:
Data Protection Officer
50670 Cologne, Germany
Last updated: May 2018