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Privacy Policy

Privacy statement

I Introduction

Welcome to our website. We are pleased that you are visiting our website. We respect your privacy. Data protection and data security when using our website are very important to us. With this privacy policy, we would like to inform you about the extent to which data is collected when you use our website and the purposes for which we use this data. We would also like to inform you about your rights in this regard.

II General information

In the following, we provide information about the collection of personal data when using our website in accordance with Art. 13 GDPR. Personal data means any information that can relate to you personally, such as name, address, e-mail addresses and user behavior.

(2) The controller within the meaning of Article 4(7) EU General Data Protection Regulation (GDPR) is:

cleversoft GmbH
Luise-Ullrich-Straße 14
80636 Munich
Germany
E-Mail: info@clever-soft.com
(see our Imprint).

You can contact our data protection officer at:

Bugl & Kollegen Gesellschaft für Datenschutz und Informationssicherheit mbH
Alexander Bugl
Sedanstr. 7
93055 Regensburg, Germany
Email: kontakt@buglkollegen.de

III About your rights

If personal data is processed by you as a user, you are considered a data subject in accordance with GDPR. Data subjects are entitled to the following rights vis-à-vis the controller:

  • Right of access by the data subject (Art. 15 GDPR)
  • Right to rectification or right to erasure (‘right to be forgotten’) (Art. 16, 17 GDPR)
  • Right to restriction of processing (Art. 18 GDPR)
  • Notification obligation regarding rectification of erasure of personal data or restriction of processing (Art. 19 GDPR)
  • Right to data portability (Art. 20 GDPR)
  • Right to object (Art. 21 GDPR)
  • Conditions for consent. The lawfulness of the processing carried out until the withdrawal remains unaffected due to the consent valid to date. (Art. 7(3) GDPR)
  • Right to lodge a complaint with a supervisory authority (Art. 77 GDPR).

The competent supervisory authority in data protection matters can be found under the following link.

IV Hosting

The hosting services we use are intended to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services, which we use for the purpose of operating this online presence.

 For this purpose, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, metadata and communication data of customers, interested parties and visitors of this online presence on the basis of our legitimate interests in an efficient and secure provision of this online presence, in accordance with Art. 6(1) point (f) GDPR in conjunction with Art. 28 GDPR (conclusion of order processing contract).

V Contacting us

a. Nature and purpose of the processing

 Our website mentions contact data such as addresses, telephone numbers and e-mail addresses for you to be able to contact us quickly, and communicate directly with us and the contact persons working for us. When you contact us, we process the personal data that you provide us with on the basis of your chosen means of communication. This may include your full name, address, the telephone number you used, the e-mail address you used and other personal data that you provide to us as part of the communication.

b. Legal basis of the processing

The processing of your personal data is based on a legitimate interest (Art 6 (1) point f GDPR). By providing our contact details, we aim at providing you with a simple way to contact us. The information you may provide will be stored by us for the purpose of handling your request and for possible follow-up questions. In the case you contact us to request a quote, we will use the data provided to carry out pre-contractual measures (Art 6(1) point b GDPR).

c. Data categories

Contact details, your message

d. Recipients

Recipients of the data are internal employees of the relevant departments.

e. Storage periods

Data will be erased no later than 6 months after the request has been processed. If a contractual relationship arises, we are subject to the statutory retention periods according to the German Commercial Code (Handelsgesetzbuch, HGB) and erase your data after these periods have expired.

f. Legal / contractual requirement

Providing your personal data is entirely voluntary. However, we can only process your request if you provide us with your name, e-mail address and the reason for the request.

g. Third country transfer

Processing does not take place outside the European Union (EU) or the European Economic Area (EEA).

h. Possibility to object

You are entitled to object to the processing of your personal data at any time. You can notify us of your revocation at any time using the contact option provided at the beginning of this privacy notice.

i. Automated decision-making and profiling

As a responsible company, we do not use automated decision-making or profiling for this data processing.

VI Newsletter

a. Nature and purpose of the processing

We will use data to deliver the subscribed newsletter to you by e-mail. Your name is used in order for us to be able to address you personally in the newsletter and, if necessary, to identify you if you choose to exercise your rights as a data subject. To receive the newsletter, you solely have to provide us with your e-mail address. When you subscribe to our newsletter, the data you provide will be used exclusively for this purpose. Subscribers may also be informed by e-mail about circumstances relevant to the service or subscription (e.g. changes to the newsletter offer or technical circumstances). The e-mail address you provide has to be valid for successful subscription validation. In order to verify that a subscription was actually initiated by the owner of an e-mail address, we use the "double-opt-in" procedure. For this purpose, we log the subscription submission to the newsletter, the sending of a confirmation e-mail and the receipt of the response requested herewith.

We would like to inform you that we evaluate your user behavior upon sending our newsletter. For this evaluation, the emails you receive contain so-called web beacons or tracking pixels, which are single-pixel image files stored by our service provider Clickdimensions. To perform these evaluations, we associate the data mentioned in VII and the web beacons with your e-mail address and an individual ID. Links received in the newsletter also contain this ID. The data obtained in this way enables us to create a user profile in order to tailor the newsletter to your individual interests. In doing so, we record when you read our newsletters, which links you click on in them and infer your personal interests from this. We link this data to actions you have taken on our website.

b. Legal basis of the processing

On the basis of your expressly given consent (Art. 6(1) point a GDPR), we will regularly send our newsletter or equivalent information by e-mail to your specified e-mail address. 

c. Data categories

Contact data, content of the message, user behavior

d. Recipients

Recipients of the data are internal employees of corresponding departments and Clickdimensions as a service processor.

e. Storage periods

This data will only be processed in this context for the duration of the required consent. After that, they will be erased.

f. Legal / contractual requirement

Providing your personal data is entirely voluntary. Without your explicit consent, we cannot send you our newsletter.

g. Third country transfer

Processing also takes place outside the European Union (EU) or the European Economic Area (EEA). To ensure the level of data protection in this third country, we have agreed to the standard data protection clauses with Clickdimensions.

h. Revocation of consent

You can revoke your consent to the storage of your personal data, its use for newsletter dispatch and tracking at any time with effect for the future. You will find a link to this effect in every newsletter. In addition, you can also unsubscribe directly on this website at any time or inform us of your revocation using the contact option provided at the beginning of this privacy notice.

i. Automated decision making and profiling

As a responsible company, we do not use automated decision-making or profiling for this data processing.

VII Website visit

When you use our website for information purposes only, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data, which are necessary for us in technical terms in order to display our website to you and to ensure its stability and security:

  • IP address
  • Date and time of query
  • Time zone difference from Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status/HTTP status code
  • Volume of data transferred in each case
  • Website from which the request originates
  • Browser
  • Operating system and its interface
  • Language and version of the browser software

We collect and store this data on the basis of our legitimate interest for a limited time in order to initiate a derivation to personal data in the event of unauthorized access or attempted access to local servers (Art. 6(1) point (f) GDPR).

VIII Use of cookies

What are cookies?

Cookies and similar technologies are very small text documents or pieces of code that often contain a unique identification code. When you visit a website or use a mobile application, a computer asks your computer or mobile device for permission to store this file on your computer or mobile device and access information. Information collected through cookies and similar technologies may include the date and time of your visit and how you use a particular website or mobile application.

Why do we use cookies?

We use cookies to understand how our website is used and how we can improve it. In addition, depending on your preferences, our own cookies may be used to show you targeted advertising that matches your personal interests.

What type of cookies do we use?

Functional

These cookies are always enabled because they are necessary for the functionality of the website. This includes, for example, the choice of language with which you visit the website.

Visitor behavior

These cookies allow us to improve the functionality of the site by tracking user behavior on this website. If you disable this setting, we will completely disable Google Analytics and any other tools used for you. We store this setting in the functional cookies to remember your choice on your next visit.

Tools

We would like to offer our visitors added value thanks to the tools offer from external providers such as Google Maps. However, through the loading of these tools, user data is transferred to third-party providers. You can deactivate these tools, but may then experience restrictions in the use of this website.

How can I turn off or remove cookies?

You can choose all but the necessary, i.e functional cookies. In the browser settings, you can change the settings to block cookies. In most browsers, you will find an explanation on how to do this in the so-called "help function". However, if you block the cookies, it is possible that you will not be able to use all technical features of our website and that this may have a negative impact on your user experience.

We have made it easy for you to manage your consents or revocations.

TypePurpose and contentStorage durationOn/Off
External MediaGoogle Maps7 daysAdjust settings
AnalysisGoogle Analytics7 daysAdjust settings

IX Use of Google Analytics

a. Nature and purpose of the processing

This website uses Google Analytics, a web analytics service provided by Google Building Gordon House, 4 Barrow Street, Dublin, D04 E5W5, Ireland. Google Analytics uses "cookies", which are text files placed on your computer to help the website analyse how visitors use the site. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. However, due to the activation of IP anonymization on these websites, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. On behalf of this website’s operator, Google will use this information to analyse your use of the website, compile reports on website activity and provide further services relating to website activity and Internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google. The purposes of data processing are to evaluate the use of the website and to compile reports on website activities. Based on the use of the website and the Internet, other related services shall then be provided.

b. Legal basis of the processing

The processing of the entered data is based on the user's consent (Art. 6 (1) point a GDPR).

c. Data categories

- IP address (truncated/anonymized)

d. Recipients

Recipients of the data are internal employees of corresponding departments and Google as an order processor. 

e. Storage duration

Data will only be processed in this context as long as the necessary consent has been given. Afterwards, they will be erased, provided that there are no legal retention obligations that prevent erasure. To contact us in this context, please use the contact details provided at the beginning of this privacy policy.

f. Legal / contractual requirement

The provision of your personal data is voluntary, based solely on your consent. If you do not grant your permission, this may result in functional restrictions on the website.

g. Third country transfer

Processing also takes place outside the European Union (EU) or the European Economic Area (EEA). To ensure the level of data protection in this third country, we have agreed to the standard data protection clauses with Google (Analytics). 

h. Revocation of consent

You can revoke your consent to the storage of your personal data at any time with effect for the future. 

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the available browser plugin: "Browser Add-On to disable Google Analytics".

i. Automatic decision-making and profiling

With the help of the tracking tool Google Analytics, the behavior and interests of visitors of this website can be analyzed. For this purpose, we create a pseudonymous user profile. 

X Google Maps integration

a. Nature and purpose of the processing

This website uses the offer of Google Maps. Google Maps is operated by Google Building Gordon House, 4 Barrow Street, Dublin, D04 E5W5, Ireland. This allows us to display interactive maps directly in the website and enables you to use the map function comfortably. You can find more information about data processing by Google in the Google privacy policy. There you can also change your personal privacy settings in the Privacy Center. When you visit our website, Google receives the information that you have called up the corresponding subpage of our website. This occurs regardless of whether Google provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your data will be directly associated with your account. If you do not want Google to associate your data with your profile, you must log out of Google before activating the button. Google stores your data as user profiles and uses it for the purposes of advertising, market research and/or demand-driven design of its website. Such an evaluation is carried out in particular (even for users who are not logged in) to provide tailored advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact Google to exercise this right.

b. Legal basis of the processing

The legal basis for the integration of Google Maps and the associated data transfer to Google is your consent (Art. 6(1) point a GDPR).

c. Data categories

- IP address 

d. Recipients

Recipients of the data are internal employees of corresponding departments and Google as an order processor. 

e. Storage duration

Data will only be processed in this context as long as the necessary consent has been given. Afterwards, they will be erased, provided that there are no legal retention obligations that prevent erasure. To contact us in this context, please use the contact details provided at the beginning of this privacy policy.

f. Legal / contractual requirement

The provision of your personal data is voluntary, based solely on your consent. If you do not grant your permission, this may result in functional restrictions on the website.

g. Third country transfer

Processing does not take place outside the European Union (EU) or the European Economic Area (EEA). 

h. Revocation of consent

If you do not want Google to collect, process or use data about you via our website, you can deactivate JavaScript in your browser settings. In this case, however, you will not be able to use our website or only to a limited extent. You can revoke your consent to the storage of your personal data at any time with effect for the future. 

i. Automatic decision-making and profiling

As a responsible company, we do not use automatic decision-making or profiling for this data processing.

XI Onlinepräsenzen in sozialen Medien

We use our social network accounts in order to inform social network users about our services and to communicate directly via the platforms if they are interested. We are currently represented in the following social networks: 

Our social media channels can only be accessed by visitors to the website via an external link. We do not use any plugins or other interfaces on our website than the respective networks offer for embedding the offers on websites.
We have no influence on data collection and its further use by the social networks. Hence, we have no knowledge about the extent to which, where and for how long the data is stored, to what extent the networks comply with existing erasure obligations, what evaluations and links are created with the data and to whom the data is forwarded. We therefore expressly draw attention to the fact that user data (e.g. personal information, IP address) is stored by the operators of the networks in accordance with their data usage guidelines and used for business purposes. 

We only process the data of users in our social media channels to the extent that users contact us and communicate with us, via, for example, comments or direct messages. The legal basis for the processing of user data is Art. 6 (1) point b and f GDPR.

  • Twitter
  • LinkedIn
  • Facebook
  • Xing

No functions and contents of the service Twitter, offered by Twitter Inc., 795 Folsom Street, Suite600, San Francisco, CA 94107 or 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, are part of the scope of our online offer. The Twitter channels can only be accessed via an external link. If visitors to the website are members of the Twitter platform, Twitter can match the call to the social media channel with the user's profile if the user visits our Twitter profile while logged in. We would like to point out that we have neither influence on the content nor the scope of use of the data collected by Twitter Inc. For further information in this regard, please refer to the Twitter Inc. privacy policy: http://twitter.com/privacy
Furthermore, we would like to point out that you can modify the settings of your Twitter accounts to protect your privacy accordingly.

No functions and contents of the LinkedIn service, offered by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland, are part of the scope of our online offer. The LinkedIn channels are only accessible via an external link.
If visitors to our website are members of the LinkedIn platform, LinkedIn can match the call to the social media channel with the user's profile if the user visits our LinkedIn profile while logged in. We point out that we have neither influence on the content nor the scope of use of the data collected by LinkedIn. For further information in this regard, we refer to the privacy policy of LinkedIn: https://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv

You can access the Facebook social media network via external links from our website. All functions in the social media network are made available by Facebook, 4 Grand Canal Square, Dublin 2, Ireland. The Facebook channels can only be accessed via an external link. If you are logged in to Facebook with your own profile and visit our social media channel, Facebook can match your visit with your logged-in profile. If you do not want your user account to be associated with your IP address, please log out of your Facebook account before using our website.

For more information on the way your data is processed, please refer to Facebook's privacy policy: https://facebook.com/privacy/explanation and to our "Facebook Fanpage" data policy, which you can view under XII of this policy.

No functions and contents of the service Xing, offered by New Work SE, Dammtorstraße 29-32, 20354 Hamburg, Germany, are part of the scope of our online offer. The Xing channels can only be accessed via an external link. If visitors to our website are members of the Xing platform, Xing can match the call to the social media channel with the user's profile if the user visits our Xing profile while logged in. We would like to point out that we have neither influence on the content not the scope of use of the data collected by Xing. For further information in this regard, please refer to the Xing privacy policy: https://www.xing.com/app/share?op=data_protection

XII Facebook Fanpage Data Policy

cleversoft GmbH operates an online presence on Facebook, a so-called Facebook Fanpage. For the visit of our fan page, the following supplementary information on data processing applies. Information about data protection on Facebook in general can be found here (https://www.facebook.com/about/privacy/).

1. Shared responsibility, contact details, company data protection officer:

We are jointly responsible with Facebook for the operation of our Facebook fan page in accordance with Art. 26 GDPR. For this purpose, we have defined in an agreement with Facebook who fulfills which obligations with regard to data protection. This agreement can be accessed here (https://www.facebook.com/legal/terms/page_controller_addendum). Accordingly, Facebook is primarily responsible for providing the data subject with information about the joint processing and enabling him or her to exercise his or her data protection rights. Notwithstanding the above, we hereby inform you about your visit to our Fanpage.

Our contact details are:

cleversoft GmbH
Luise-Ullrich-Straße 14
80636 Munich
Germany
E-mail: info@clever-soft.com

You can contact Facebook at:

Facebook Ireland Ltd.
4 Grand Canal Square,
Grand Canal Harbour,
Dublin 2, Irland

You can contact Facebook online here: (https://www.facebook.com/help/contact/2061665240770586)

You can contact our company data protection officier at:

Bugl & Kollegen Gesellschaft für Datenschutz und Informationssicherheit mbH
Sedanstraße 7
93055 Regensburg, Germany
E-Mail: kontakt@buglundkollegen.de

You can contact Facebook‘s data protection officer at:

https://www.facebook.com/help/contact/540977946302970.

2. Collection and storage of personal data and the nature, purpose and use thereof:

a) Data collected by Facebook:

If you are a Facebook user, Facebook collects the data described in the Facebook Data Policy under "What kinds of information do we collect? If you are not a Facebook user, cookies provided with identifiers, small text files, may still be stored in your browser, which enable so-called tracking of your user behavior.

As a rule, the user data during a visit to Facebook is also processed by Facebook for market research and advertising purposes. Based on the user behavior (including when you visit our Fanpage), complex user profiles are created, which Facebook can use to display personalized advertisements to the visitor within and outside of Facebook. More information on this can also be found in the Facebook data policy.
If you do not agree with this, you can object here (opt-out).

b) Data used by us (”Page-Insights”) and legal basis:

Facebook provides us with statistics and usage data that we can use to analyze the use of our fan page (so-called "page insights"). This enables us to continuously improve our offer on Facebook. We, as the operator, do not make any decisions regarding the processing of Insights data and any other information resulting from Art. 13 of the GDPR, such as storage duration of cookies on user end devices. The primary responsibility under the GDPR for the processing of Insights Data lies with Facebook and Facebook fulfills all obligations under the GDPR with regard to the processing of Insights Data.

We as the site administrator have no other way, including via user tracking, to evaluate user behavior on our Fanpage. It is also fundamentally not possible for us to identify the visitor of the Fanpage on the basis of the page insights. In particular, we are not entitled under the agreement to demand that Facebook disclose individual visitor data. Identification is only possible for us if we are able to assign individual profile pictures to "Like" Page Views; however, this is only possible to the extent that our Fanpage has been marked with "Like" by the corresponding visitor, and the "Like" Page Views is set to "public".

What information Facebook uses to create page insights can be found here.

The operation of our Faceboook fan page and the use of the page insights serves our legitimate interest in effective external presentation and efficient communication with our customers and prospects. This interest justifies the operation of the page both to the legitimate interests of Facebook users, as well as to visitors to our fan page who do not have a Facebook account. Accordingly, the legal basis is Art. 6(1) point f) GDPR.

3. Sharing of data with third parties:

Data collected by Facebook is shared and processed throughout the Facebook group. The Facebook group also includes, e.g., Instagram, WhatsApp and Oculus. For example, information collected through Facebook is used to display personalized ads to users on Instagram, or information from WhatsApp is used to take action against accounts that send spam through WhatsApp on Facebook. This information can be found in the Facebook Data Policy under "How do the Facebook Companies work together?".
The processing of data by Facebook may involve the transfer of user data outside the European Economic Area (EEA), in particular the USA.

4. Right to object:

If your personal data is processed on the basis of legitimate interests pursuant to Art. 6 (1) point f GDPR, you have the right to object to the processing of your personal data pursuant to Art. 21 GDPR, provided that there are grounds for doing so that arise from your particular situation or the objection is directed against direct marketing. In the latter case, you have a general right to object, which will be implemented by us without specifying a particular situation. If you would like to exercise your right to revoke or object, it is sufficient to send an e-mail to contact@clever-soft.com.

5. Data subject rights:

You have the right to revoke your consent to us at any time. As a result, we will no longer process your data based on this consent in the future. Sie haben das Recht, Ihre Einwilligung jederzeit gegenüber uns zu widerrufen. Furthermore, you have the right to information according to Art. 15 GDPR, the right to rectification according to Art. 16 DSGVO, the right to erasure according to Art. 17 GDPR, the right to restriction of processing according to Art. 18 GDPR, as well as the right to data portability according to Art. 21 GDPR. Furthermore, you have the right to lodge a complaint with a competent data protection supervisory authority (Art. 77 GDPR).
In principle, you can assert your data subject rights against Facebook as well as against us. Since only Facebook has direct access to your user data, you can most effectively assert your data protection rights against Facebook.

XIII Processing of your data in the context of automated decision-making / profiling

In principle, you have the right to opt out of decisions based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. In particular, these decisions may not regularly be based on special categories of personal data pursuant to Art. 9 (1) GDPR. We do not use any corresponding decision-making processes within the scope of our website and the associated data processing.