Your privacy is important to us. This policy addresses you as a visitor to the websites and landing pages created by Cleoo, either for its own use or for the purpose of generating marketing results for Cleoo’s customers.
At Cleoo, we are fully committed to maintaining the trust and confidence of our customers and the visitors to our websites. We take your privacy seriously and our top priority is maintaining the confidentiality of the personal data you provide and protecting it from unauthorized access.
As a company under private law, we are subject to the provisions of the European General Protection Data Regulation (GDPR). We have taken technical and organizational steps to ensure that both we and our external service providers meet the data protection requirements.
In this Policy, we have tried our best to cover all the questions you may have regarding our treatment of your personal data. If you’re in a rush, you can jump to the section you are most interested in by using the links below. However, every point is important, so we hope you can find the time to read through it all carefully.
Cleoo Limited (referred to in this Policy as “Cleoo”, “we”, “us” or “our”) is a provider of digital advertising services. We are headquartered in the UK (registered office at 22 Great James Street, London WC1N 3ES, United Kingdom) with two further offices in Switzerland and Singapore.
Our appointed data protection officer (“DPO”) is responsible for overseeing this Policy and responding to any related questions. You can get in touch with our DPO, Andrew Clarke, by emailing firstname.lastname@example.org or writing to:
Attn: DPO, Andrew Clarke Cleoo Limited Weltpoststrasse 5 CH-3015 Bern
When you engage with Cleoo, either online or directly by other means, we may ask you to provide us with personal data such as your contact details in order to submit an enquiry to us, sign up to receive our newsletter or information about our product or become a customer. You may also provide us with your personal data in other ways such as if you contact us in relation to employment opportunities or communicate with us through social media or our Customer Success teams. In these occasions, we will make the reasons why we are asking you to provide the personal data clear. Data we collect may include:
When you visit our websites or engage with us digitally through social media or other means, we may collect certain information automatically from your computer, tablet or mobile phone (a “Device"). In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
The information we may collect can be broadly grouped as follows:
Some of this information may be collected using cookies and similar tracking technology, as further explained below:
Instructions on how to ‘opt-out’ of cookie tracking are given by the browser you use.
California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
When someone visits one of our websites, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behavior patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of the visitors to our websites.
However, it helps to identify your browser and potentially displays to you advertisements linked to the Cleoo website/landing page you’ve reached.
You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of this website. You can also prevent the data generated by cookies about your use of the website (incl. your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: tools.google.com/dlpage/gaoptout.
Objecting to the collection of data
You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set to prevent your data from being collected on future visits to this site: Disable Google Analytics.
When someone visits one of our websites, we use a third-party service, Google Tag Manager, to collect information about your behavior on our website. This can include clicks and scrolls you undertake during your visit to the page. It helps Cleoo register certain actions taken on the page. You can find out more about Google Tag Manager by clicking the following link: http://www.google.de/tagmanager/use-policy.html
We can only collect and use your personal data if the law allows us to, by satisfying one or more of the reasons set out by applicable data privacy law.
THE MOST COMMON USES OF YOUR PERSONAL DATA WILL BE:
OUR LEGITIMATE INTERESTS INCLUDE:
You may not always be required to provide the personal information that we have requested. However, if you choose not to provide certain information, you may not be able to take advantage of some of our services. Any information that is required is clearly marked as mandatory. If you would prefer that we not collect certain personal information from you, please do not provide us with any such information, or opt out of providing this information where applicable.
Our websites and other digital services are not intended for children under the age of 16 and we do not knowingly collect data relating to children. If we are made aware that we have received such data, we will use reasonable efforts to locate and remove that information from our records.
When it comes to the collection of personal information from children under the age of 13 years old, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States' consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.
We do not specifically market to children under the age of 13 years old.
Where necessary for the proper performance of our services, our legal duties and other business-critical activities, we may share your personal data with third parties where it is reasonable and in line with the nature of the relationship. We take your privacy very seriously and do our best to establish a legitimate reason for the data to be shared before doing so. In particular, we want you to know that Cleoo is not in the business of selling, renting or trading email lists with other companies and businesses for marketing purposes.
The types of recipients we may share your personal data with are categorised as follows:
We require all third parties and organisations who we share your data with to respect the security of your personal data and to treat it in accordance with the law. We do not allow any of our third-party service providers or service providers to use your personal data for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.
To determine the appropriate retention period for any type of personal data, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use of disclosure of the data, the purposes for which we process the data and whether we can achieve those purposes through other means and the applicable legal requirements.
In some circumstances we may anonymise your personal data so that it may no longer be associated with you and use it for research of statistical purposes only. In this case, we may use this anonymised information indefinitely without further Policy to you.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used of accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
The measures we use to protect your personal information are designed to provide a level of security appropriate to the risk of processing your personal information. However, please be aware that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures that we have in place to safeguard personal information will never be defeated or fail, or that those measures will always be sufficient or effective.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Subject to applicable data protection law, you have the following rights in relation to your personal data:
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this policy.
Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
You can ask us to amend your communications settings or stop sending you marketing messages at any time by contacting us at email@example.com or writing to us at:
Attn: Customer Success Team
If you are have a question about this Policy or are unhappy with how we have used your personal data, please contact us at firstname.lastname@example.org or write to us at:
Attn: Customer Success Team
If you are in the UK, you also have the right to complain to the Information Commissioner’s Office. Contact details can be found at www.ico.org.uk. We would be grateful for the change to deal with your concerns before you contact the ICO so please get in touch with us in the first instance.
This policy is effective as of 1 November 2018.