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 corporate website located at www.clvrbrdg.com (“Site”), cleverbridge AG is the controller of Personal Information and will process data including Personal Information as outlined in this Privacy Policy.
What This Privacy Policy Covers
This Privacy Policy describes cleverbridge’s use of Personal Information and Analytical Data that we collect when you visit or use the Site. 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.
This Privacy Policy does not apply to the processing of your Personal Information when you visit, use, or order from a cleverbridge online store. If you are looking for the Privacy Policy related to a cleverbridge online store, it is provided in connection with such store or can be accessed here.
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.
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
“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.
Cookies, Tracking and Other Analytics Technologies
cleverbridge uses cookies or similar technologies to analyze trends, administer the Site, track users’ movements around the Site, 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 to improve the user experience and maintain performance of the Site. 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.
We partner with third parties to either display advertising 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 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 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 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 may use Google Analytics, a web analytics service provided by 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. 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, 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.
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.
Click the button below to enable or disable Google Analytics tracking:
Hotjar
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.
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 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
Except as otherwise stated in this Privacy Policy, we do not use or share your Personal Information with third parties, unless you ask or authorize us to do so. We will not sell or rent any of your Personal Information to third parties for their marketing purposes and only share your Personal Information with third parties as described below.
cleverbridge Companies
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.
cleverbridge has developed global data practices to ensure your Personal Information is appropriately protected. Please note that Personal Information may be transferred, accessed, and stored globally as necessary for the purposes and disclosure stated in this Privacy 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 Contracts for the transfer of personal data to third countries (non-EU countries).
Third Party Service Providers
We may provide your Personal Information to third party service providers who work on behalf of or with us to provide you with the Site, related customer support, and to help us communicate with customers, partners, and prospects and to operate the Site. Insofar as we make use of the services of third parties to carry out our services, we process personal data according to the provisions of the GDPR. Categories of service providers who support us in providing our services to you include such services as communicating with you via email, processing payment transactions, shipping products, screening transactions for fraudulent activities, providing customer service or fulfillment services for us, and/or to remain compliant with applicable laws. However, these service providers do not have any independent right to use your Personal Information except as necessary to help us provide the Site and related processes. Transfers to subsequent third parties are covered by the provisions in this Privacy Policy regarding notice and choice and the agreements with our 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;
- enforce any agreement we may have entered into with you and to enforce the Privacy Policy;
- 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.
Data Retention
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
The Site may contain links to other websites that are not owned or controlled by cleverbridge. The provision of such links is for your convenience and does not signify our endorsement of such websites or location or its contents. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites. Please be aware that the terms of the Privacy Policy do not apply to any outside websites.
Changes in this Privacy Policy
This Privacy Statement is a living document. We may update this Privacy Policy to reflect changes to our information practices. We encourage you to periodically review this page for the latest information on our privacy practices.
Contact Us
To contact us in writing please address your inquiry to:
cleverbridge AG
Data Protection Officer
Gereonstr. 43-65
50670 Cologne, Germany
If you have any questions or suggestions regarding our Privacy Policy please contact us by sending us an email to inquiry@cleverbridge.com.
Last updated: May 2018
