Privacy Policy
The purpose of this privacy policy is to brief you on how personal data is processed by us. We are compliant with the legal stipulations regarding data protection because the protection of your privacy is of paramount importance to us.
Data Protection Officer
If any questions arise regarding our data protection efforts, personal data processing, or the security of your rights as a data subject, you may contact us and our data protection officer at the following address:
External Data Protection Officer
ePrivacy GmbH
represented by Prof. Dr. Christoph Bauer
Burchardstrasse 14, 20095 Hamburg
Please email info (at) cleverclx.com with any questions or concerns about your information.
Direct communication with our data protection officer, especially in cases of high sensitivity, should be done via post due to potential security gaps in email communication.
Personal Data
All information about identified or identifiable persons is considered personal data. The categories of personal data processed by us include the following:
- Your contact details (for example: first and last name, address, e-mail address, phone number),
- Your correspondence with us,
- Log files with information about your visit to our website,
- Online identifiers (such as cookie IDs, IP addresses, advertising IDs),
Use of Cookies
A cookie is a text file with an identification number which is transmitted to a user’s computer when a website is used, along with the other data actually requested and stored there. The file remains in place for access at a later point and acts to authenticate the user. Cookies do not present any threat to the computer because they are not executable programs, just simple files. The internet browser accepts cookies automatically, depending on the settings chosen by the user. The user can deactivate the storage of cookies or be notified when a cookie is set. Deactivation of cookies may result in certain website functions becoming unavailable or available only in a limited capacity. Setting of cookies by our website can be halted at any time through your internet browser settings.You can also always delete active cookies using your internet browser settings or other software programs. Cookies from partner companies (third parties) may be stored on your hard drive when you visit our website when we work with advertising partners to assist us in making our online offer more intriguing for you. If they are essential for the operation of this site, we are allowed to store cookies on your device. We require your consent for all additional types of cookies. Various types of cookies are used by this site. Some cookies are set by third parties appearing on our pages. You can adjust or rescind your permission whenever you want through the cookie declaration on our website. Cookies used for the duration of a session and automatically deleted when the implementing browser is closed are called Session Cookies. These help to ensure that, for instance, video and audio files can be played and your user input is stored temporarily at the time of entry, improving user-friendliness. Cookies that stay on your device after the browser is closed are Persistent cookies. These cookies are able to, for instance, save your user preferences, like language settings, and analyze behavior of users on our website. Length of time for storage of persistent cookies coincides with the respective duration of the individual cookie. They are automatically deleted thereafter.
Processing Purpose
The purposes we have for processing your data are as follows:
- Correspondence with you,
- Advertising,
- Quality assurance and statistics,
- Provision and optimization of our services and website,
- Service improvement
Legal Basis
The following legal bases are applied to the processing of your data:
- Your consent, if you have given us such consent (Art. 6 para. 1 lit. a) GDPR),
- The implementation of our legitimate interests (Art. 6 para. 1 lit. f) GDPR)
Legitimate Interests
We seek the following legitimate interests when processing your data:
- The enhancement of our offer,
- The protection of our systems against misuse,
- The production of statistics,
- Marketing purposes,
- Data Storage and Security Platforms to store and retain your Information,
- Provision of service, including the Site and accompanying customer support,
- Performing research, technical diagnostics or analytics,
- Sending emails and updates,
- The storage of our correspondence with you
Data Provision Requirement or Obligation
It is not required or obligatory to provide your data except when it is expressly stated.
Data Sources
We do not gather data about you from third parties.
Storage Period
We store your data,
- if you have agreed to the processing, at maximum until your consent is revoked;
- if we need the data for the execution of a contract, at maximum for the duration of our contractual relationship;
- if we use the data on the basis of a legitimate interest, at maximum for as long as your interest in deletion or anonymization does not outweigh the data;
insofar as statutory storage obligations exist, until the end of the storage periods. - If you want to delete or amend any of your personal information that we may currently have stored, please contact us at info (at) cleverclx.com, with reference to the website to request deletion. Your request may take up to 30 days to be processed.
Data Recipient
We collaborate with the following service providers with access to your data when processing it:
Facebook, Facebook Custom Audiences:
Facebook Custom Audience of Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland is the service we use on our website and is integrated by means of the Facebook pixel. A direct connection between our website and the Facebook servers is established when you visit our website, and the pages you visit are transmitted to those servers. Facebook assigns this information to your personal Facebook account if you are logged in. It is possible to determine if the user was directed to our site by clicking on one of our Facebook ads. This allows us to optimize our advertisements (“Facebook ads”) and present them only to users with an interest in our offer.
Review Facebook’s data use policy here: https://www.facebook.com/policy.php
You are able to edit your advertising preferences under “Settings” in your profile, then “Advertising settings” when registered and logged in to your Facebook account.
Facebook:
Social media plugins from Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are integrated into our website. They are recognizable by the “like” or “thumbs up” symbol or the blue “f” logo. You can see a list of Facebook plugins here: https://developers.facebook.com/docs/plugins/?locale=de_EN. Visiting our website establishes a connection to the Facebook servers. This visit can be assigned to your user account if you are logged in to Facebook. Facebook will also assign to your profile and save any interaction you have with the plugin (e.g. clicking the “thumbs up” button). We do not have any sway over the scope and content of the data collected by Facebook.
Facebook’s data use policy: https://www.facebook.com/policy.php
You have to log out of your account in order to prevent collected data from being assigned to your profile.
Google Ads/Remarketing:
On our website, we use the Google AdWords service of Google Ireland Limited, Gordon House, 4 Barrow Street, Dublin, D04 E5W5, Ireland. Reaching our website through a Google ad results in a cookie being installed for 30 days, enabling us to record the actions on our website following the click on our ad. We can then better analyze and optimize our campaigns and present advertising related to your interests.
Google’s privacy policy: https://policies.google.com/privacy?hl=de
In order to prevent the processing of your data you can download or rather set and save an opt-out cookie via this link: https://adssettings.google.com/authenticated
Google Analytics:
We use the Google Analytics service of Google Ireland Limited, Gordon House, 4 Barrow Street, Dublin, D04 E5W5, Ireland. We use cookies to gather and analyze usage data on our website in order to maximize functionality and enhance our services. The anonymization extension “_anonymizeIp()” is used to conduct the recording of the IP address anonymously.
Google’s privacy policy: https://policies.google.com/privacy?hl=de
It is possible for you to prevent the processing of your data using an opt-out cookie from one of these links: https://tools.google.com/dlpage/gaoptout?hl=de
or https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=de
Outbrain:
Our website integrates the Outbrain service of Outbrain Inc. 39 West 13th Street, 3rd floor, New York, NY 10011, USA. Outbrain directs online users to content that is of interest and pertinent to them. For this purpose, only pseudonymous data is processed.
Outbrain’s privacy policy: https://www.outbrain.com/legal/privacy#privacy-policy
You can refuse Outbrain’s collection and storage of data at any time, effective going forward. Follow the link below to do so: https://my.outbrain.com/recommendations-settings/home
After clicking on “View my Profile” you can move the switch under “Select your recommendation settings below” to “Non-Personalized Recommendations (Opt Out)”.
Taboola:
We use the Taboola service of Taboola Inc., Taboola Germany GmbH, c/o MindSpace Friedrichstraße 68, 10117 Berlin, Germany. A cookie from this service is placed on our website and detects how you navigate our website and which websites you often visit. We can then develop a personalized offer for you by recommending content that aligns with your interests.
For the privacy policy of Taboola: https://www.taboola.com/de/privacy-policy.
In order to prevent the processing of your data you can download or rather set and save an opt-out cookie via this link: https://www.taboola.com/de/privacy-policy#user-choices-and-optout
Youtube:
Our website incorporates social media plugins from YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066, USA, a company of Google Ireland Limited, Gordon House, 4 Barrow Street, Dublin, D04 E5W5, Ireland. A visit to our website establishes a connection to the YouTube servers using the “enhanced privacy mode” that YouTube provides. Transmission of the fact that you have visited our site using your IP address only happens after you interact with the plugin (for instance, by clicking on an embedded video). The visit to our website can be connected by YouTube to your user account if you are logged in to YouTube at the time. Interacting with an embedded video, for instance, will cause YouTube to assign this to your profile and save it. We cannot influence the scope or content of the information collected by YouTube.
Privacy policy of Google: https://policies.google.com/privacy?hl=de
You have to log out of your account in order to avoid assignment of collected data to your profile.
JWPlayer:
We work with the LongTail Ad Solutions, Inc., d/b/a JW Player to provide video content.
8 W 38th St., Ste. 901 New York, NY 10018 USA.
Accessing a page that presents any JWPlayer video clips, establishes a direct connection between your browser and a JW Player server in the USA. Data on your visit and your IP address is stored in that location. Information on interactions with the JW-Player plugins (e.g. clicking the start button) is likewise transmitted to JW-Player and stored there.
For more information, please visit https://www.jwplayer.com/privacy.
OneSignal:
To insert push messages, we employ OneSignal, 2194 Esperanca Avenue, Santa Clara, CA 95054, USA. OneSignal may process your data and store it on their systems. Using respective browser settings or the page below, you can, at any time, rescind your permission and the subscription to push messages can be temporarily suspended or terminated.
For further information, you can visit https://onesignal.com/privacy_policy.
Cake:
Cake, Accelerize Inc. 20411 SW Birch St. Suite 250 Newport Beach, CA 92660, USA is what we use to optimize our online and marketing offerings, as well as to measure reach and conduct market research. We process online identifiers from you in order to get the statistical information we require regarding the use of our online offerings and user behavior across numerous online offerings. If you do not want to give consent to this, please go to http://getcake.com/privacy-policy/#rights.
For further information, please visit http://getcake.com/privacy-policy/#rights.
Yandex Direct
Yandex Direct is used by us to measure ad performance.
YANDEX LLC, a company incorporated under Russian law, with a head office registered at 16 Lva Tolstogo St., Moscow 119021, Russia (“YANDEX” LLC), or its affiliates for particular Services or in specific jurisdictions.
For users in the European Economic Area (EEA) or Switzerland Yandex is represented by its Finnish entity, Yandex Oy, a company incorporated under Finnish law, with an office registered at Moreenikatu 6, 04600 Mantsala, Finland.
For users in Israel Yandex is represented by its Israeli entity Yandex.Go Israel Ltd, a company incorporated under Israeli law, with an office registered at: 148 Menachem Begin St., Tel Aviv, Israel 6492104.
Getting to our website through a Yandex ad installs a cookie that lets us record the actions taken on our website after our ad is clicked. Our ad campaigns can then be better analyzed and optimized, giving us the chance to exhibit advertisements related to your interests. Your personal data will only be kept by Yandex for the period of time needed to fulfill the purpose for which it was gathered or to conform with legal and regulatory requirements. For more information, please visit the https://yandex.com/legal/confidential/.
Microsoft Advertising (Bing Ads)
In order to measure ad advertising we use the “Bing Ads” conversion and tracking tool from Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18 D18 P521, Ireland.
Both we and Microsoft may employ cookies to recognize when someone has reached a predetermined destination after clicking on an ad and being directed to our online services. Only the total number of users who clicked on a Bing ad and got redirected to the destination page (conversions) is learned by us. IP addresses are not stored and no additional personal information regarding the user’s identity is disclosed.
To object / To revoke your consent, please use http://choice.microsoft.com/de-DE/opt-out. The function duration of the cookie used is 6 months. For further information, please visit https://privacy.microsoft.com/de-de/privacystatement.
Plista
We employ the services of plista GmbH, Torstraße 33-35, 10119 Berlin to provide recommendation technology. Plista uses technologies to regulate and optimize the display of advertising material for the user (usage-based advertising). Plista uses permanent cookies to process usage data and metadata u.
To revoke your consent, please use https://www.plista.com/de/about/opt-out/.
For further information please visit https://www.plista.com/de/about/privacy/.
Transfer to Third Countries
We transfer data to countries outside of the European Economic Area. Transfer only occurs to third countries confirmed by the EU Commission to have adequate levels of protection or in which we are able to have contractual agreements or other suitable guarantees to ensure the careful handling of personal data, such as certifications or established compliance with international security standards.
Data Subject Rights
You maintain the following rights as a data subject:
- To request information about the processing of your data and to get a copy of your personal data. Among other things you may request information on the purposes of the processing, the categories of personal data processed, the recipients of the data (if a transfer is made), the duration of the storage or the criteria for determining the duration;
- To receive personal data relating to you in a structured, standard and machine-readable format or to transfer it to another person in charge;
- To correct your data. If your personal data is incomplete, you have the right to complete the data, taking into consideration the purposes of the processing;
- To have your data deleted or blocked;
- To have the processing restricted;
- To object to the processing of your data;
- To revoke your consent to the processing of your data for the future and
- To complain to the responsible supervisory authority about unauthorized data processing.
Privacy Notice and Disclosures for California Residents
Data Recipient: This privacy notice is only applicable to visitors, users, and others residing in the State of California when you visit our website. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect: We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (personal information).
Specifically, the following categories of personal information have been collected by us from website visitors within the last twelve (12) months:
Category A – Identifiers
Yes
Category B – Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
No.
Category C – Protected classification characteristics under California or federal law
No.
Category D. Commercial information.
No.
Category E. Biometric information.
No.
Category F. Internet or other similar network activity.
Yes.
Category G. Geolocation data.
Yes.
Category H. Sensory data.
No.
Category I. Professional or employment-related information.
No.
Category J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
No.
Category K. Inferences drawn from other personal information.
No.
The categories of personal information listed above are secured from the following types of sources:
Directly and indirectly from you when visiting our website. For instance, usage details collected automatically in the course of your interaction with our platform or website.
Use of Personal Information
The personal data collected by us may be used or disclosed for any of the following business purposes:
To provide, support, personalize, and develop our Websites, products, and services.
To individualize your Website experience and to deliver content and product and service offerings related to your interests, including targeted offers and ads through our Websites, third-party sites, and via email or text message (with your permission, where required by law).
To support in preserving the safety, security, and integrity of our Websites, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Websites, products, and services.
Sharing Personal Information
Your personal information is disclosed by us for business purposes to the following categories of third parties:
Service providers.
In the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides specific rights to consumers (California residents) regarding their personal information. In this section, your CCPA rights are described and it is explained how you can exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
The categories of personal information we collected about you.
Our business or commercial purpose for collecting that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
Deletion Request Rights
You have the right to ask us to delete any of your personal information we collected from you and kept, subject to certain exceptions. After receiving and confirming your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Your deletion request may be denied if retaining the information is required for us or our service providers to:
Complete the transaction for which the personal information was collected, provide a good or service requested by you, take actions reasonably anticipated within the context of our ongoing business relationship with you, or elsewise fulfill our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute responsible parties for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their rights to free speech, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in interest of the public that conforms to all other applicable ethics and privacy laws, if deleting the information would likely render impossible or grievously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Enact additional internal and lawful uses of the information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email info (at) cleverclx.com and include the website.
Response Timing and Format.
We make an effort to respond to a verifiable consumer request within forty-five (45) days of receiving it. If more time is required (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. If needed, our response will also outline the reasons we cannot comply with a request. For data portability requests, we will choose a format to provide your personal information that is readily usable and should allow the unhindered transmission of the information from one entity to another entity. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If it is determined that the request warrants a fee, we will inform you as to why that decision was made and give you an estimate of the cost prior to completing your request.
Non-Discrimination
You will not be discriminated against by us for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Refuse you use of our services
Provide you a different level or quality of goods or services
Nevertheless, certain financial incentives permitted by the CCPA that we may offer can result in variable prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior agreement to opt in, which you may rescind at any time.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, you can send an email to info (at) cleverclx.com.
Contact Information
Any questions or comments you have about this privacy notice, our privacy policy, the ways in which your personal information is collected and used by us, the choices and rights you have regarding such use, or any wish to exercise your rights under California law, can be directed to us via email at info (at) cleverclx.com.
Version of the Privacy Policy
We amend the information in this privacy policy if our processes are changed.
Status of this privacy policy: 11/25/2022