Last updated: 14 May 2018
1. General information
Protecting your personal data is particularly important to us. In this data protection policy we therefore describe how we use your personal data when you visit our website www.closelink.net or use services on our website (e.g. registration; registration for our newsletter; making contact; use of the Closelink platform etc.).
c/o WeWork, Axel-Springer-Platz 3, 20355 Hamburg (“Closelink”) is the responsible entity under data protection law.
If you have questions about this data protection policy, you can contact us at any time by email at firstname.lastname@example.org.
2. Collection and processing of personal data when visiting and using our website
2.1. Data that is automatically collected and stored when visiting our website
Each time the website is called up, data is collected and stored automatically and this is transmitted by your browser. This is stored in the server's log files. This relates to the following data:
Information on the browser type and version used
User’s operating system
Internet service provider and IP address of the user
Date and time of the call-off
Website that the user previously visited and from where they navigated to our website (so-called referrer URL) as well as websites that are called up by the user via our website.
We do not assign this data to particular users, rather it is stored separately from other personal data.
2.2. Data that you actively provide to us
We also process your personal data that you transfer to us, e.g. when you log in, make contact with us or order our email newsletter.
If you register on our website, we collect the following information from you:
Name of your company;
Other personal information that you also provide to us
3. The purposes for which we process your personal data
We use the stipulated data exclusively for the following purposes:
Improvement of our website via usage habits
Use of our information portal
Correspondence relating to orders
Sending invoices and handling the payment process
To inform you about news and special offers for our products and services if you have issued explicit consent to another department to receive such information. You can cancel such information at any time and revoke the consent you have issued by sending us an email (email@example.com);
To inform you about news and special offers for our products and services; we may also send you emails about our products and services without your consent if you have previously purchased or used these. This does not apply if you have opposed this process by sending us an email (firstname.lastname@example.org);
To answer your questions.
4. Legal basis for data processing; duration of storage
The legal basis for collecting and processing the personal data described above depends on the relevant personal data and the specific context in which it is collected. The processing of data that is collected automatically when using our website takes place based on our justified interests under Article 6 Sub-paragraph 1 (f) of the General Data Protection Regulation (GDPR) to understand how our website is used, to improve our offer on www.closelink.net and to answer your enquiries. If you register on our website and use our platform, we also process your data for the purpose of implementing the contract under Article 6 Sub-paragraph 1 (b) GDPR. If we obtain your consent to processing your personal data, for example to send you our newsletter, the data processing is based on Art. 6 Sub-paragraph 1 (a) GDPR.
Personal data is saved for the duration of the relevant statutory storage period. After the end of the period, it is deleted as soon as there is no legal basis any more for processing your data.
5. Data transfer to third parties
We use external service providers to process your data. We carefully select and appoint these and they are bound by our instructions and checked at regular intervals. We appoint the following service providers to provide our services:
Hosting supplier (to provide the website, host our servers).
Service provider to provide the support functions (provide the live chat, software for dispatch and receipt of messages via the contact form and ordering process).
Service provider to determine and analyse errors on the website, check and monitor stability.
Service provider to produce invoices
We send newsletters via the third-party supplier "Mailchimp", 675 Ponce de Leon Ave NE Suite 5000, Atlanta, Georgia, 30308, United States. For this purpose we provide information that you made available to us during registration to Mailchimp. We point out that we analyse your user behaviour when sending the newsletter. For this analysis the emails we send include so-called web-beacons. So when you open the newsletter, information such as your IP address, time of opening and information about your browser is called up. You will find information about the services and operation of Mailchimp at https://mailchimp.com/legal/privacy/.
When you use our website, we store certain information on your computer's hard drive using so-called cookies (small text or image files). Cookies allow us to modify the website to your interests and needs. For example, a cookie may contain information on the pages you have visited which enables us to appropriately modify the website for your next visit. Cookies do not give us access to other areas on your computer.
Most web browsers enable cookies to be deleted or a warning to be received before a cookie is stored on your hard drive. Please refer to your browser's documentation or the help screen to learn more about this option. But please note that it may not be possible to use all of the services or offers on our website if you deactivate cookies.
8. Use of tracking tools, social media
8.1. Google Analytics
Our website uses Google Analytics, a web analysis service by Google Inc. (Google). Google Analytics uses so-called “cookies”, text files that are saved on your computer and enable the use of the website to be analysed. The information created by the Google Analytics cookie on your use of this website is generally transferred to and stored on a Google server in the US. On this website Google Analytics was extended to include the “ga('set', 'anonymizeIp', true);” code to ensure IP addresses are collected anonymously (IP masking). This enables your IP address in the EU member states or other member states of the European Economic Area to be shortened by Google in advance.
The complete IP address is only transferred to a Google server in the USA and shortened there in exceptional circumstances. Google will use this information to analyse your use of the website, create reports on website activities for the website operator and to provide services associated with using the website and internet.
The IP address transferred from your browser as part of Google Analytics is not associated with any other data stored by Google. You can also prevent the recording of the data created by the Google Analytics cookie related to your use of the website (incl. your IP address) and the processing of this data by Google by downloading and installing a browser plug-in available from the following link: http://tools.google.com/dlpage/gaoptout?hl=de
You can prevent the recording by Google Analytics by clicking the following link. An opt-out cookie is set that prevents the future entry of your data when visiting this website:
8.2. Google AdWords
Our website uses the Google AdWords service. Google AdWords is an online advertising program by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).
In addition, as part of our usage of the Google AdWords service, we also use so-called conversion tracking. If you click an advert provided by Google, a cookie for conversion tracking is placed on your computer/device. These cookies become invalid after 30 days, do not contain any personal data and are not used for personal identification. The information obtained with the aid of the conversion cookie is used to create conversion statistics for AdWords customers who have chosen conversion tracking.
You can prevent the installation of cookies by adjusting the relevant setting in your browser software; but in this case we expressly point out that you may not be able to use the full functions of this website. You can also deactivate interest-related adverts on Google and interest-related Google adverts on the web (within the Google display network) in your browser by activating the “Off” button at http://www.google.de/settings/ads or deactivation found at http://www.aboutads.info/choices/. You can find additional information on the related setting options and data protection at Google from https://www.google.de/intl/de/policies/privacy/?fg=1.
8.3. Facebook Pixel / LinkedIn Conversion Tracking
On our website we use the "Facebook Pixel" of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA, and "LinkedIn Conversion Tracking" of LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland (jointly referred to as “third-party suppliers”). This enables us to track users’ behaviour by clicking on an advert placed by us on www.facebook.com or www.linkedin.com from our website. A cookie will be stored on your device. We can therefore analyse the range of our adverts and optimise our advertising measures. The relevant third-party supplier collects and stores this data such that a connection to the relevant user profile is possible and the third-party supplier can use the data for its own advertising purposes.
You can deactivate the Facebook Pixel via this link and LinkedIn Conversion Tracking via this link; you can also modify your data protection settings via https://www.facebook.com/settingssettings and https://www.linkedin.com/psettings/advertising. You can find other information on the Facebook Pixel at https://www.facebook.com/privacy/explanation, and on LinkedIn Conversion Tracking at https://business.linkedin.com/de-de/marketing-solutions/conversion-tracking.
8.4. Integration of YouTube videos
We have integrated YouTube videos in our website that are stored at www.youtube.com and can be played directly from our website. [These videos are integrated in the “extended data protection mode”. This means that no data is transferred to YouTube if you do not play the videos.] The data stated below is only transferred if you play the videos. We have no influence on this data transfer. Through your visit to the website, YouTube receives notification that you opened up the relevant sub-page of our website that contains a YouTube video. In addition, the data listed under Number 2.1 is sent to YouTube. This transfer occurs independently of whether you have set up a user account with YouTube using which you are logged in. To prevent assignment to your YouTube user account, you must first log out of YouTube. YouTube stores your data as usage profiles and uses these for the purposes of advertising, market research and improving its website. You have an objection right and if you wish to use it, you must contact YouTube. You can find additional information at https://support.google.com/youtube/answer/2801895?hl=de.
9. International data transfer
We must forward your personal data to business partners and service providers who are located outside the European Economic Area (EEA). Our servers are located in Germany. The processing of data outside the EEA takes place in the USA. In the event of processing your data outside the EEA, we ensure an adequate protection level using Privacy Shield certification or the conclusion of standard contractual clauses.
10. Your rights
If you wish to access, correct or delete your personal data, you can contact us at any time using the contact data stated in the "How to contact us" section.
If you are located in the European Union you can also oppose the processing of your personal data, request that we restrict the processing of your personal data or request data portability. You can also exercise these rights by contacting us under the "How to contact us" section.
You have the right at any time to reject the receipt of advertising messages that we send you. Unsubscribing is possible at any time via the link planned for this purpose in the newsletter or relevant notification. To reject other forms of advertising (e.g. by post), please contact us via the contact data under the "How to contact us" section.
You can also revoke your consent at any time if we collect and process your personal data with your consent. The revocation of your consent has no influence on the legality of processing your personal data undertaken before revoking your consent, nor on the processing of your personal data that we have undertaken due to a justified interest and for which no consent is required.
You also have the right to complain to a data protection authority about the collection and use of your personal data. For further information, please contact the relevant data protection authority: Hamburg Officer for Data Protection and Freedom of Information, Klosterwall 6 (Block C), 20095 Hamburg, www.datenschutz-hamburg.de.
11. Updates to this data protection policy
We reserve the right to update this data protection policy from time to time if the legal, technical or economic conditions change. If we update our data protection policy, we will undertake appropriate measures to inform you in line with the importance of the changes undertaken by us. We will obtain your consent to all necessary changes to data protection notifications if and to the extent to which this is required under applicable data protection laws. You can see when this data protection policy was most recently updated by checking the date of the last update within this data protection policy.
12. How to contact us
If you have questions or concerns about the use of your personal data, please contact us at: email@example.com.