PRIVACY POLICY
Effective Date: April 19th 2023
1. General
2. Personal data that we collect
3. Purposes of processing personal data
4. Providing personal data to third parties
5. Parental consent
6. Transfer of personal data outside the EEA or your own country
7. Retention period
8. Your rights in regard to your personal data
9. Security
10. Amendments to the Privacy Policy
11. Contact
1. General
This Privacy Policy applies to information about you that Cliq Digital AG (“Company”, “we”, “our”, “us”) may obtain when you visit our websites under the domain www.cliqdigital.com (the “Site”). This Privacy Policy describes how we may collect, use, or share information about you; your choices regarding our use of your information; how we safeguard such information; and how you may contact us regarding our privacy practices.
Please read this Privacy Policy carefully, and if you have any questions, feel free to contact us. If you do not agree with the terms of this Privacy Policy, then do not browse and/or use our Site.
Information collected through the App may be synchronized from time to time between the App and Site, but we do not guarantee accurate or full synchronization.
2. Personal data that we collect
Personal information you provide
We may obtain personal information that you provide to us directly when you contact us, fill in a form, sign up for Investor Relations events or activities, marketing or informational newsletters or submit an application.
We may process the following types of personal data:
Communication
We will use your name, company name, home or business address, e-mail address, telephone number and any other personal information that you may voluntarily provide to us to the extent necessary to process your communications or inquiries with us.
Investor Relations events and activities
When registering for, participating in or contributing to any Investor Relations event, call or presentation organised or held by us , we will collect, process and use your name, contact details, company name, position, any other personal information, as well as and any of the contributions you made. We may record and publish the visual, audio and/or transcript of the call or event you are joining, participating in or contributing to, including any of the data arising therefrom. This may include your personal details as submitted when registering as well as your contribution to this call or event. We may publish the aforementioned data on the Site and/or on any other platforms, including those of our partners.
Applications
On our Site under “Careers” we may publish advertisements for vacancies with us or with one of our affiliated companies. The company named in the job advertisement is responsible for filling the vacancies and processing the respective applications.
If you submit an application to us or to one of our affiliated companies, we or the company affiliated with us will process your name and job title, contact information (including email address and mobile phone number), CV including your age and/or gender and, where applicable, information about your immigration status and whether you are legally able to work and if you provide us with this information, your education, work history and similar matters and information you provide to us and any other information, which may be relevant to potential employment with us or one of our affiliates. Please note that we may also receive information from third party recruiters, agents and similar organizations as part of the hiring process or as a referral from one of our employees or clients.
Newsletter
When you register for the newsletter, we collect the data from the form sent to us for registration (name, e-mail address, and, if applicable, telephone number for SMS). For the processing of the data, we will ask you for your consent during the registration process or during one of your subsequent visits to our website and will also refer you to this data protection declaration.
Cookies and similar technologies
To improve your experience with our website(s), we, or our service providers, may use cookies or similar technologies (for example clear GIFs/pixel tags, JavaScript, local storage, log files and other mechanisms to automatically collect and record information about your browsing activities and use of the Website). For more information about the cookies we use, see our cookie policy.
3. Purposes of processing personal data
We only use your personal data for the purposes described in this Privacy Policy and/or for the purposes described in other privacy notices that we might use for particular services. For any other purposes that are not described, we will use your personal data only in case we have obtained an additional prior consent from you or in case we are otherwise authorized or required by law to use your personal data for those other purposes; in regard to the latter case, we will inform you about such a scenario.
We collect and use your personal data for the purposes as justified under the legal basis as set out below.
For the performance of our agreement with you:
• To contact you when you reach us or request information from us through the contact form or any other form.
• To send you the news and marketing updates you signed up to.
• To provide you with access to the Investor Relations events, calls, presentations or other activities you registered for, participated in and/or contributed to.
To comply with a legal obligation to which we are subject:
• Any information referred to above in the section ‘Personal data that we collect ’ may be used to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law.
For our legitimate commercial interests:
• Improvement of our Services and developing new Services, such based on your use of our Services;
• Auditing, research and (statistical) analysis in order to maintain, protect and improve our Site and our Services contained therein/available through it and to get client insight;
• The personal data referred to above in the section ‘Personal data that we collect’ may also be used by us:
o to generate aggregated statistics about the visitors of our Site and Services;
o to assist in security and fraud prevention;
o for system integrity purposes (preventing hacking, cheats, spamming, etc.);
o to facilitate our business operations, to operate company policies and procedures;
o to enable us to merge, sell, acquire, or transfer assets; and
o for other legitimate business purposes permitted by applicable law.
For recruitment purposes in the ‘Careers’ section:
• to assess your suitability for any position you may apply at our Company or any of our subsidiaries, including internships;
• Where necessary and in accordance with this Policy, we will require references and information to carry out background checks.
For marketing communications:
• Upon your explicit consent hereto (to the extent such consent is required) or based on our legitimate commercial interest (to the extent this has not been objected to), your personal data may also be used by us in order to inform you about our Services and special events through our news updates. We may contact you via e-mail, telephone, post, SMS or equivalent electronic means - depending on what contact information we have received from you.
For Investor Relations events and activities:
• Upon your explicit consent hereto (to the extent such consent is required) or based on our legitimate commercial interest (to the extent this has not been objected to), your personal data may also be used by us in relation to your registration for, participation in and/or contribution to Investor Relations events, calls, presentations and other activities organised or held by us. We may record and publish the visual, audio and/or transcript of the call or event you are joining, participating in or contributing to, including any of the data arising therefrom. This may include your personal details as submitted when registering as well as your contribution to this call or event. We may publish the aforementioned data on our Site and/or on any other platforms, including those of our partners.
4. Providing personal data to third parties
We do not sell or otherwise transfer your personal data to third-parties except in cases as described in this Privacy Policy. We will share your personal data with:
1. Service Providers. We may engage third-party vendors, agents, service providers, hosting providers and affiliated entities to provide services to us, such as email providers, advisory services, support for customer support and IT services and recruitment services. In providing their services, they may access, receive, maintain or otherwise process personal data on our behalf. Consistent with applicable legal requirements, we take commercially reasonable steps to require third-parties to adequately safeguard your personal data and only process it in accordance with our instructions.
2. Third-parties in case of legal requirement. We will also disclose your personal data if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes (e.g. tax authorities); when we believe necessary or appropriate to disclose personal data to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Policy; to respond to any claims against us; and, to protect the rights, property, or personal safety of us, our customers, or the public.
3. Corporate Transaction. In addition, information about customers or clients may be disclosed as part of any merger, sale, transfer of our assets, acquisition, bankruptcy, or similar event.
5. Parental consent
With regard to persons younger than 16 years we require the parents or legal representatives to have given their consent before personal data are submitted to us. We will not knowingly collect any personal data submitted by minors of the respective legal representative has not allowed the collection of said information. Should personal data nevertheless have been submitted to us without such consent, we will remove the pertinent personal data as soon as possible after becoming aware that this is the case.
6. Transfer of personal data outside the EEA or your own country
Your personal data may be transferred to third parties in other countries for centralizing the files and/or for processing (operations) described in this Privacy Policy. Some of these countries may not be part of the European Economic Area (EEA).
Where we are legally required to do so, we have legally acceptable mechanisms in place that ensure an adequate level of protection for the transfers of personal data to parties outside your jurisdiction. For example, for data transfers from EU/EEA to countries outside this region, we have European Commission-approved Standard Contractual Clauses or similar safeguards in place, allowing such data transfers.
In addition to this, if you use our services while you are outside the EEA, your data may be transferred outside the EEA in order for us to provide those services.
7. Retention period
We will only process your personal data for as long as we need it to be able to provide you with our Services to you, to execute any other functions as described herein and/or to fulfil any legal requirements.
We retain your Personal Data for as long as required to satisfy the purpose for which they were collected and used, unless a longer period is necessary for our legal obligations (such as storing your details for billing purposes) or to defend a legal claim. Statutory retention periods may vary depending on the record at stake.
8. Your rights in regard to your Personal Data
In regard to the personal data we hold you are granted certain rights:
Your right of access
If you request us, we will confirm whether we are processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details).
Your right to rectification
You can request us to have your personal data rectified if the personal information we hold about you is inaccurate or incomplete.
Your right to erasure
You can request us to delete or remove your personal information such as where we no longer need it or if you withdraw your consent (where applicable), provided there is no overriding legitimate interest for continuing the processing. Erasing your personal data will delete the data only in our database. These deletions will not delete personal data that may have already been shared with or collected by third-parties, all as provided above in this Privacy Policy. Unless it is impossible or involves disproportionate effort, we will take reasonable steps to contact any other recipient of your personal data and request the deletion of your personal data.
Your right to restrict processing
In certain circumstances, you can request us to 'block' or suppress the processing of your personal information, such as where you contest the accuracy of that personal information or you object to us.
Your right to data portability
In certain circumstances, you have the right to obtain personal information you have provided us with (in a structured, commonly used and machine readable format such as Microsoft Excel) and to reuse it elsewhere or to ask us to transfer this to a third-party of your choice.
Your right to object
You have the right to request us to stop processing your personal information, and we will do so, if we are relying on our own or someone else’s legitimate interest to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or in case we are processing your personal information for direct marketing purposes.
Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
Your right to lodge a complaint with the supervisory authority
If you are of the opinion that we have violated your rights and/or are not in compliance with any applicable personal data protection regulation, you have the right to lodge a complaint with your relevant data protection authority.
Some of these rights may be limited where we have an overriding interest or legal obligation to continue to process.
Please note that we might not be able to provide you with our Services anymore in case you have exercised any of your rights described above. However, any time you reuse our Service after exercising any of the aforesaid rights, your then provided personal data may be processed, without regard to your previously exercised right(s), in accordance with the provisions of this Privacy Policy.
With regard to any respective request as described above that you may place, we have 1 (one) month from the date of your request to fulfill said request.
9. Security
We will treat all your data as confidential and will take all reasonable technical, physical and organizational measures to protect your personal data so that they are protected against unauthorised or unlawful use, alteration, unauthorised access or disclosure, accidental or wrongful destruction, and loss. Unfortunately, we cannot give assurance that the data transfer via the Internet and mobile communications network is safe. Therefore, we cannot guarantee the safety of this data transfer and you accept the inherent safety risks of using Internet and mobile networks for sending information.
10. Amendments to the Privacy Policy
This Privacy Policy came into effect on the Effective Date set out above. We reserve the right to amend or adapt this Privacy Policy. If any material changes are made to this Policy, we will publish these changes on our website(s).
Therefore, we encourage you to review our Privacy Policy periodically to be informed of how we use your personal information.
11. Contact
If you have any questions or you want to exercise your rights as set out in this Privacy Policy, you can contact: Cliq Digital AG, Grünstraße 8, 40212 Düsseldorf, Tel.: +49 (0)211 946 242 82 or send an email to support@cliq.de.