Data protection

This Privacy Policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as "Data") within our online offering and the websites, features and content associated with it, as well as external online sites, such as ours. our Social Media Profile (collectively referred to as the "Online Offering"). With regard to the terminology used, e.g. "Processing" or "Responsible" we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Responsible
Clear Systems GmbH
Managing Director: Marcus Leufgen
Schweinthal 25
91349 Egloffstein - Germany
Registered: Register court Bamberg
Registration number: HRB 7753

Contact
E-Mail: info@ClearSystems.de
Tel .: +49 (0) 9197/23 53 23 - 5
Mobile: +49 (0) 1520/98 2 44 11

Types of processed data

• inventory data (e.g., names, addresses) .- contact information (e.g., e-mail, telephone numbers).
• content data (e.g., text input, photographs, videos).
• usage data (e.g., websites visited, interest in content, access times).
• Meta / communication data (e.g., device information, IP addresses).

Categories of affected persons
Visitors and users of the online offer (hereinafter we refer to the affected persons as "users").

Purpose of processing

• Provision of the online offer, its functions and contents.
• Answering contact requests and communicating with users.
• Safety measures.
• Reach Measurement / Marketing

Used terms
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter the "data subject"); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (eg cookie) or to one or more special features, are the expression of the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.

"Processing" means any process performed with or without the aid of automated procedures, or any such process associated with personal data. The term goes far and includes virtually every handling of data.

"Pseudonymisation" means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data not assigned to an identified or identifiable natural person.

"Profiling" means any kind of automated processing of personal data that involves the use of such personal information to evaluate certain personal aspects pertaining to a natural person, in particular aspects relating to job performance, economic situation, health, personal To analyze or predict preferences, interests, reliability, behavior, whereabouts, or relocation of that natural person.

'Responsible person' means the natural or legal person, public authority, body or body which, alone or in concert with others, decides on the purposes and means of processing personal data.

"Processor" means a natural or legal person, public authority, body or body that processes personal data on behalf of the controller.

Relevant legal bases
In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 GDPR, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the answer to inquiries is Art. 6 para. 1 lit. b DSGVO, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c DSGVO, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f DSGVO. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO as legal basis.

Safety measures
We take appropriate technical measures in accordance with Art. 32 GDPR, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons and organizational measures to ensure a level of protection appropriate to the risk.

Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and segregation. In addition, we have established procedures to ensure the enjoyment of data subject rights, the erasure of data and the response to data threats. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings (Article 25 DSGVO).

Collaboration with processors and third parties
If, in the context of our processing, we disclose data to other persons and companies (processors or third parties), transmit them to them or otherwise grant access to the data, this is done only on the basis of a legal permission (eg if a transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) GDPR to fulfill the contract), you have consented to a legal obligation or on the basis of our legitimate interests (eg the use of agents, webhosters, etc.).

Insofar as we commission third parties to process data on the basis of a so-called "contract processing contract", this is done on the basis of Art. 28 GDPR.

Transfers to third countries
If we process data in a third country (ie outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure, or transmission of data to third parties, this will only be done if it is to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special requirements of Art. 44 et seq. DSGVO. That the processing is e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (eg for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").

Rights of data subjects
You have the right to request a confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.

You have accordingly. Art. 16 DSGVO the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.

In accordance with Art. 17 GDPR, they have the right to demand that the relevant data be deleted without delay, or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR.

You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transmission to other responsible persons.

You have gem. Art. 77 DSGVO the right to file a complaint with the competent supervisory authority.

Withdrawal
You have the right to consent according to. Art. 7 para. 3 DSGVO with effect for the future

right to
You may at any time object to the future processing of your data in accordance with Art. 21 GDPR. The objection may in particular be made against processing for direct marketing purposes.

Cookies and right to object to direct mail
"Cookies" are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie serves primarily to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, e.g. the contents of a shopping cart are stored in an online shop or a login status. "Persistent" or "persistent" refers to cookies that remain stored even after the browser has been closed. Thus, e.g. the login status will be saved if users visit it after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. A "third-party cookie" refers to cookies that are offered by providers other than the person responsible for providing the online offer (otherwise, if only their cookies are called "first-party cookies").

We can use temporary and permanent cookies and clarify this in the context of our privacy policy.

If users do not want cookies stored on their machine, they will be asked to disable the option in their browser's system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies used for purposes of online marketing can be in a variety of services, especially in the case of tracking, http://www.aboutads.info/choices/ on the American side or the EU side http://www.youronlinechoices.com/ be explained. Furthermore, the storage of cookies can be achieved by switching them off in the settings of the browser. Please note that not all features of this online offer may be used.

Deletion of data

The data processed by us are deleted or limited in their processing in accordance with Articles 17 and 18 GDPR. Unless explicitly stated in this privacy statement, the data stored by us will be deleted as soon as they are no longer necessary for their intended purpose and the deletion does not conflict with any statutory storage requirements. Unless the data is deleted because it is required for other and legally permitted purposes, its processing will be restricted. That the data is blocked and not processed for other purposes. This applies, for example for data that must be kept for commercial or tax reasons.

According to legal requirements in Germany, the storage takes place in particular for 10 years according to §§ 147 Abs. 1 AO, 257 Abs. 1 Nr. 1 and 4, Abs. 4 HGB (books, records, management reports, accounting documents, trading books, for taxation relevant Documents, etc.) and 6 years in accordance with § 257 (1) no. 2 and 3, para. 4 HGB (commercial letters).

According to legal regulations in Austria the storage takes place in particular for 7 J in accordance with § 132 exp. 1 BAO (accounting documents, receipts / invoices, accounts, documents, business papers, statement of income and expenses, etc.), for 22 years in connection with land and for 10 years in the case of documents relating to electronically supplied services, telecommunications, broadcasting and television services provided to non-EU companies in Member States for which the Mini-One-Stop-Shop (MOSS) is used.

Business-related processing
In addition, we process

• contract data (e.g., subject, term, customer category).
• Payment data (e.g., bank details, payment history)
  by our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

Order processing in the online shop and customer account
We process the data of our customers as part of the ordering process in our online shop to allow them to select and order the selected products and services, as well as their payment and delivery, or execution.

The processed data includes inventory data, communication data, contract data, payment data and those affected by the processing belong to our customers, prospects and other business partners. Processing is for the purpose of providing contractual services in the context of operating an online shop, billing, delivery and customer service. Here we use session cookies for the storage of the shopping cart contents and permanent cookies for the storage of the login status.

Processing is based on Art. 6 para. 1 lit. b (execution of order transactions) and c (legally required archiving) DSGVO. The information marked as required for the establishment and fulfillment of the contract is required. We disclose the data to third parties only in the context of extradition, payment or in the context of legal permissions and obligations to legal advisors and authorities. The data will be processed in third countries only if it is necessary for the fulfillment of the contract (for example, at the customer's request on delivery or payment).

Users can optionally create a user account, in particular by being able to view their orders. As part of the registration, the required mandatory information will be communicated to the users. The user accounts are not public and can not be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to their retention is for commercial or tax law reasons according to Art. 6 para. 1 lit. c DSGVO necessary. Information in the customer's account remains until its deletion with subsequent archiving in the case of a legal obligation. It is the responsibility of the users to secure their data upon termination prior to the end of the contract.

As part of the registration and re-registration and use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user's protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is necessary for the prosecution of our claims or there is a legal obligation in accordance with. Art. 6 para. 1 lit. c DSGVO.

The deletion takes place after expiration of legal warranty and comparable obligations, the necessity of the storage of the data is checked every three years; in the case of legal archiving obligations, the deletion takes place after its expiration (end of commercial law (6 years) and tax law (10 years) retention obligation).

External payment service providers
We use external payment service providers through whose platforms users and we can make payment transactions (eg, with a link to the privacy policy, Paypal (https://www.paypal.com/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/de/datenschutz/), Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay (https://www.giropay.de/ legal / data protection-agb /), Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https: / /www.americanexpress.com/de/content/privacy-policy-statement.html)

As part of the fulfillment of contracts, we set the payment service providers on the basis of Art. 6 para. 1 lit. b. DSGVO. Incidentally, we use external payment service providers on the basis of our legitimate interests. Art. 6 para. 1 lit. b. DSGVO in order to offer our users effective and secure payment options.

Amongst the data processed by the payment service providers are inventory data, e.g. the name and the address, bank data, e.g. Account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, summary and recipient-related information. The information is required to complete the transactions. However, the data entered will only be processed and stored by the payment service providers. That We do not receive any account or credit card information, but only information with confirmation or negative disclosure of the payment. The data may be transmitted by the payment service providers to credit reporting agencies. This transmission aims at the identity and credit check. For this we refer to the terms and conditions and privacy policy of payment service providers.

For the payment transactions, the terms and conditions and the privacy notices of the respective payment service providers, which are available within the respective websites, or transactional applications apply. We also refer to these for further information and assertion of rights of revocation, information and other data subjects.

contact
When contacting us (for example, by contact form, e-mail, telephone or via social media), the information of the user to process the contact request and their processing acc. Art. 6 para. 1 lit. b) DSGVO processed. User information can be stored in a Customer Relationship Management System ("CRM System") or comparable request organization.

We delete the requests, if they are no longer required. We check the requirement every two years; Furthermore, the legal archiving obligations apply.

Hosting and e-mailing
The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage and database services, e-mailing, security, and technical maintenance services we use to operate this online service.

Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer acc. Art. 6 para. 1 lit. f DSGVO i.V.m. Art. 28 DSGVO (conclusion of contract processing contract).

Collection of access data and log files
We, or our hosting provider, collects on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO Data on every access to the server on which this service is located (so-called server log files). The access data includes the name of the retrieved web page, file, date and time of retrieval, amount of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider ,

Logfile information is stored for security reasons (for example, to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data whose further retention is required for evidential purposes are excluded from the erasure until the final clarification of the incident.

Google AdWords and conversion measurement
We use the services of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043 on the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of our online service within the meaning of Art. 6 (1) lit. DSGVO) , USA, ("Google").

Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

We use Google's online marketing method "AdWords" to place ads on the Google advertising network (e.g., in search results, in videos, on websites, etc.) to show them to users who have a suspected interest in the ads. This allows us to better target advertisements for and within our online offering so that we only present ads to users that potentially match their interests. If a user e.g. Showing ads for products he was looking for on other online offers is called remarketing. For these purposes, upon access to our and other websites where the Google Advertising Network is active, Google will immediately execute a code from Google and become so-called (re) marketing tags (invisible graphics or code, also as " Web beacons ") incorporated into the website. With their help, the user is provided with an individual cookie on the device. a small file is saved (instead of cookies, comparable technologies can be used). In this file is noted which web pages the user visited, for what content he is interested and what offers the user has clicked, as well as technical information about the browser and operating system, referring web pages, visit time and other information on the use of the online offer.

Furthermore, we receive an individual "conversion cookie". The information obtained through the cookie is used by Google to generate conversion statistics for us. However, we only hear about the anonymous total number of users who clicked on our ad and were redirected to a conversion tracking tag page. However, we do not receive information that personally identifies users.

The data of the users are pseudonym processed in the context of the Google advertising network. That Google stores and processes e.g. not the name or e-mail address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. That from the perspective of Google, the ads are not managed and displayed to a specifically identified person, but to the cookie owner, regardless of who that cookie owner is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymization. The information collected about users is transmitted to Google and stored on Google's servers in the United States.

For more information about Google's data usage, hiring and disparaging options, please read Google's Privacy Policy (https://policies.google.com/technologies/ads) and Google's Ads Ads Settings (https: // adssettings.google.com/authenticated).

Youtube
We embed the videos on the YouTube platform of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.

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