cleverbridge Privacy Policy

Last updated: 26/09/2019

cleverbridge AG, cleverbridge, Inc., cleverbridge Financial Services GmbH, cleverbridge KK, and cleverbridge Co., Ltd. ("cleverbridge", "we") take very seriously the privacy and protection of Personal Information. When you visit the cleverbridge Online Store ("Store") or cleverbridge corporate website ("Site") or order products and services (collectively, "Products") from cleverbridge, cleverbridge AG is the controller of Personal Information and will process data including Personal Information as outlined in this Privacy Policy. Unless otherwise defined herein, capitalized terms shall have the meanings assigned to such terms set forth in the General Terms and Conditions of cleverbridge.

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What This Privacy Policy Covers

This Privacy Policy describes cleverbridge's use of Personal Information and Analytical Data that we collect when you visit the Site or the Store, or when you order a Product. This Privacy Policy does not apply to the processing of your Personal Information that is collected by third parties that cleverbridge does not own or control or that do not support cleverbridge in providing the Site, Store or Products, including Suppliers of the Products that you order.

Controller of Personal Information

The data controller of the Personal Information when you visit the Site or the Store, or when you order Products 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 Suppliers and the names and addresses of those Suppliers, 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:

cleverbridge AG
Data Protection Officer
Gereonstr. 43-65
50670 Cologne, Germany
email contact via our Help Center

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

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).

Please note that we provide Personal Information to the Suppliers of the Products as lined out in Supplier of the Products from a Store.

Types and Use of Information We Collect

In general, Personal Information you submit to us is used by us to provide you with the Products that you order, process payments, respond to requests that you make, for the purpose of registration (if any), and to offer you additional information, opportunities, and functionality related to the Products that you order. We also use this information to prevent or detect fraud or abuses of our Site or Store and to better tailor the features, performance, and support of the Site or Store, 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

"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 or the Store or by ordering Products:

Requests and fulfillment of the contract

  • In order to purchase Products through the Store, you have to provide and we will process your name, email address, zip code, address (where required to fulfill your order), and all the financial information necessary for billing and recurring billing (where applicable) or a subset of the foregoing.
  • The information necessary for billing depends on the selected payment method and therefore may include credit card number, card verification code, account number, account name, billing zip code, or any other information required for the payment methods that you have selected.
  • We also collect your zip code for the purpose of identifying fraudulent activities, calculation of tax, transaction processing and support, and statistical purposes. We only transfer your zip code to the Suppliers for purposes of fulfilling your order through our Store and statistical purposes. We do not sell your zip code in connection with other information, do not connect it with data sets external to the transaction, and do not use it ourselves for advertising purposes.
  • We collect your IP address and transfer it to the Supplier for the purpose of identifying fraudulent activities, export compliance, calculation of tax, and transaction processing and support. Your IP address will be truncated by our systems before sending the data to the Supplier.
  • 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.
  • We will only send you Product-related announcements that are not promotional in nature (for example, notices related to your purchase of Products) and only when we believe it is necessary to do so.
  • 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 or the Store, 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 or the Store, 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 basis for data processing is Art. 6 para. 1 lit. b GDPR, which permits the processing of data for the performance of a contract or pre-contractual measures.

Newsletter and other promotional information

  • If you request promotional information via any of the forms of the Site or the Store, 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.
  • 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.
  • 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.

Automatic Data Collection and Analytical Data

In addition to the information you provide, we automatically collect information through different technologies as described below.

Cookies, Tracking and Other Analytics Technologies

cleverbridge and our Suppliers use cookies or similar technologies to analyze trends, administer the website, track users' movements around the Site and Store, and to gather demographic information about our user base as a whole. The basis for data processing is Art. 6 para. 1 lit. f GDPR, which permits the processing of data for the purposes of the legitimate interests pursued by us and our Suppliers to improve the user experience and maintain performance of the Site and Store. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Site or Store, including the ability to order Products.

We partner with third parties to either display advertising on the Store or to manage advertising on other sites. These third parties may use technologies such as cookies to gather information about your activities on the Store and other sites in order to provide you advertising based upon your browsing activities and interests. The basis for data processing is Art. 6 para. 1 lit. f GDPR, which permits the processing of data for the purposes of the legitimate interests pursued by us and our Suppliers for direct marketing. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads. Also, the opt-out itself is stored in a cookie, so that means that when you clear your cookies, switch to another browser, use a different device, or otherwise modify your cookies, you will have to opt out again.

In order to view more details on which cookies, tracking and other analytics technologies are active in your browser and to opt out, you can use tools like Privacy Badger, uBlock Origin, or Ghostery. Please note that those tools are just examples among many tools that can be used. You understand that we in no way endorse the use of these tools and we are not in any way affiliated to their respective developers, so we do not assume any liability for any consequences arising from the use of these tools.

Our Site and Store may use your browser's local storage to store content information or to recognize your personal preferences or login information (if any). Third parties with whom we partner to provide certain features on the Site and Store may use the local storage to collect and store information. Various browsers may offer their own management tools for removing information from their local storage. Please refer to your browser's manual for more information on how this can be done individually.

Google Analytics

Our Site and Store may use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland when you are located in the European Economic Area or Switzerland, or Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States ("Google"). Google uses cookies to help analyze the use of the Site. The basis for data processing is Art. 6 para. 1 lit. f GDPR, which permits the processing of data for the purposes of the legitimate interests pursued by us and our Suppliers to improve the user experience and maintain performance of the Site and Store. The information generated by the cookie about your use of the Site is sent to a Google server in the United States and stored there. Please note, that your IP address will be truncated by our systems before sending the data to a Google server. Therefore, you will not be identified as an individual person in Google Analytics, but only as part of the user base.

Google will use this information to evaluate your use of the Site and Store, compile reports on Site and Store activity, and provide other Site and Store 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.

If you do not want Analytics to be used in your browser, you can install the Google Analytics browser add-on. As Google uses cookies you can set your browser to refuse such cookies or to indicate when a cookie is being sent as described in the cookies section of this Privacy Policy.

Hotjar

Our Site and Store 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 and Store by revealing online behavior related to our Site and Store 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.

For more information see Hotjar's Privacy Policy at https://www.hotjar.com/privacy. You can choose to disable the Hotjar service by visiting https://www.hotjar.com/opt-out.

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 or Store informs us of which browser you are using, the date and time of your visit, the name of your Internet Service Provider (ISP), device information, including device ID, the Site you are using to visit us, and which parts of our Site and Store 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 or Store like language or location, for maintaining our operating ability, preventing fraudulent access to our Site or Store, or for analyzing usage patterns so that we may enhance our Site and Store. 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 meanings of DNT signals and responses, and the correct behavior regarding DNT signals, are not defined. Until such time as the standard is finalized, our Site and Store do not process or respond to DNT signals. To learn more about DNT, please visit donottrack.us.

List of tracking and other analytics technologies

The following is a list of tracking and other analytics technologies which may be in use on cleverbridge's Site and Store. You can choose to disable or enable these technologies by clicking the button below.

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