Privacy policy

DATA PRIVACY NOTICE

​ This privacy notice contains information about the processing of your personal data in connection with the use of this website and the functionalities made available through it (hereinafter collectively referred to as the “Website”).

This Website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content. You can recognize the encrypted connection by the character string “https://” and the lock symbol in your browser line.

1 General Information

1.1 Data Controller

​​ The Website is operated by Clear Management Europe GmbH, Neuer Wall 50 c/o Regus, 20354 Hamburg, Germany (“Clear Europe”). Clear Europe is responsible for the processing of your personal data.

You can contact Clear Europe either in writing or by e-mail at clear.europe@thecleargroup.com.

1.2 Data Recipients

Unless otherwise described for the respective data processing activity, only those Clear Europe employees who are responsible for performing a specific task have access to your personal data. In addition, employees who are responsible for the operation of our IT systems may have access to some of your personal data as part of their work, e.g., the administration of an application or the performance of IT security tasks. Our employees are obligated to handle personal data confidentially.

As part of our business activities, we rely on the support of various service providers, in particular for the above-mentioned purposes. If these service providers are given access to personal data, we have concluded the necessary agreements to protect your personal data, in particular data processing agreements in accordance with Art. 28 GDPR, which obligate our service providers to maintain confidentiality. In some cases, we transfer personal data due to legal obligations. Data may be transferred to the police and public prosecutor’s office if a criminal offense is suspected or in the course of investigations. Further information on who receives access to your personal data can be found below in the description of the respective application.

1.3 Transfer to Third Countries

If we transfer data to service providers in so-called third countries, this is described for the respective application. Some of these third countries do not have an adequate level of data protection. In particular, if data is transferred to the USA, there is a risk that your personal data will be processed by the authorities there for control and monitoring purposes without you becoming aware of this or having sufficient legal remedies available to you. We regularly secure transfers to third countries by using the so-called EU standard contractual clauses. You can obtain a copy at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de.

1.4 Consent

If you give your consent to a processing activity, you may revoke your consent at any time with effect for the future without giving any reasons. To do so, please use the Clear Europe contact channels mentioned at the beginning of this notice or change the switch settings if you have given your consent via the switch settings you have selected.

1.5 Retention Period

In principle, we delete your data as soon as it is no longer needed for the required purpose and if there are no retention obligations. If you object to a processing activity pursuant to Art. 21 (2) GDPR, we will delete your data within four weeks of your objection, unless there are other statutory retention periods to the contrary or we are obliged to block the data. If the processing is based on your consent and you revoke your consent or the processing ends for other reasons, we will process the information necessary to prove the previously granted consent, i.e., date, time, details of the granting and subject of the consent, for a period of three years after the processing based on consent has ended.

2 DATA COLLECTION WHEN VISITING THE WEBSITE

​​ If you only use our Website for informational purposes, i.e., if you do not register or otherwise provide us with information, we only collect the data that your browser transmits to our server (so-called “server log files”). When you visit our Website, we collect the following data, which is technically necessary for us to display the Website for you:

  • Our Website visited
  • Date and time of access
  • Amount of data sent in bytes
  • Source/reference from which you reached the page
  • Browser used
  • Operating system used
  • IP address used

The processing takes place in accordance with Art. 6 (1) (b) of the General Data Protection Regulation (“GDPR”) on the basis of your use of our Website and our interests in improving the stability and functionality of our Website in accordance with Art. 6 (1) (f) GDPR.

We process your data in order to provide you with a functioning website, store the data for the duration specified by Clear Europe for this purpose and then delete your data.

Only Clear Europe employees who are responsible for maintaining the Website have access to your personal data.

We use third-party services on our Website. Further information about these services and the associated data processing can be found in this privacy notice and in particular in the section “Cookies and Third-party Services”.

3 CONTACT (E.G., BY EMAIL)

​​If you contact us by email, we will process the information necessary to carry out the communication, e.g., your email address, the information you provide and the date and time of the communication. If you also provide us with your name and other personal data, we will also process this data.

We use Microsoft 365, Microsoft Teams, both services of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA (“Microsoft”), to handle our communications.

The legal basis for this processing is Art. 6 (1) (b) GDPR or Art. 6 (1) (a) GDPR for information that is not mandatory and that you provide us with voluntarily. We process your data in order to answer your request or to give you advice. Your personal data will be stored for the duration specified by Clear Europe with regard to the fulfillment of the task and then deleted. This is based on the retention periods under commercial and tax law. Only Clear Europe employees who are entrusted with answering contact inquiries will have access to your personal data.

We have concluded a data processing agreement with Microsoft, which is based on the EU standard contractual clauses. The EU standard contractual clauses are available at: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de. Further information on data processing by Microsoft can be found at: https://privacy.microsoft.com/de-de/privacystatement.

4 COOKIES AND THIRD-PARTY SERVICES

​4.1 Cookies

Depending on your browser settings and whether you have given us your consent, cookies may be stored on your computer when you visit the Website in order to extend the functionality of the Website and make it more convenient for you to use. Cookies are small text files that are stored on your computer. Most of the cookies used by Clear Europe are deleted from your hard drive at the end of the browser session (“session cookies”). In addition, Clear Europe uses so-called permanent cookies (“persistent cookies”), which remain on your end device in order to recognize you the next time you visit the Website. If cookies are stored, they collect and process certain user information such as browser and location data as well as IP address values to an individual extent and as described in the server log files. Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie.

Details on the cookies used and the duration of the storage of the respective cookies can be found in the following information in this privacy notice regarding the respective application.

If personal data is also processed by individual cookies used by us, the processing is carried out in accordance with Art. 6 (1) (f) GDPR on the basis of our legitimate interest in improving the stability and functionality of our Website (so-called “necessary cookies”) or in accordance with Art. 6 (1) (a) GDPR on the basis of your consent for all other cookies (marketing and analysis cookies).

Please note that you can also set your browser so that you are informed when cookies are being stored and can decide individually whether to accept or reject them in certain cases or in general. Each browser differs in the way it manages cookie settings. Cookie settings are described in the help menu of each browser, which explains how you can change your cookie settings.

Please note that if you do not accept cookies, the functionality of our Website may be restricted.

4.2 Third-party Services

4.2.1 Web Analysis Services

​​​We use analysis services on our Website to collect information about our Website, provided that you have consented to the use of the corresponding cookies. The data obtained with the help of analysis services, such as the origin of visitors or the time they spend on our Website, provide us with information about visitor behavior on our Website. With the help of this data, we are not only able to eliminate weaknesses but also improve the efficiency of our Website. Further information on the analysis services used on our Website and information on the processing of personal data by the cookies used in this context can be found below.

  • Google Analytics

​We use Google Analytics to gain an overview of the behavior of website visitors and our digital marketing. The operator of this service is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. Google Analytics allows us to collect and analyze data specifically relevant to Clear Europe, such as how far visitors scrolled, which buttons were clicked, etc. Google Analytics also helps us, for example, to record demographic characteristics such as age, gender and interests, geographical characteristics such as language and location, as well as technical characteristics such as device type, browser and operating system, search history, YouTube history and data from Google partner websites. With the help of this data, we are not only able to optimize our Website but can also recognize how the respective sessions of visitors have ended. Google Analytics also helps us to recognize which website a visitor enters first, and which channel the visitor comes through (e.g., via a paid or unpaid ad, a Google search or direct access to the Website). This information allows Clear Europe to identify which marketing channels are working and which are not. Google Analytics also allows us to recognize visitor paths, i.e., where visitors go on our Website, whether they go back to the home page and how many visitors there are. With the help of this information, we can, for example, recognize whether a large number of visitors leave the Website due to a technical defect on the Website. The above data gives us a good overview of our Website and how it is used. Even if we collect data from visitors, we cannot use this data to draw any conclusions about you personally because we receive reports from Google Analytics that are based on aggregated data sets.

The following data is collected and processed with the help of Google Analytics:

IP address (anonymized)

Usage data

Click path

App updates

Browser information

Device information

JavaScript support

Visited pages

Referrer URL

Downloads

Flash version

Location information

Purchase activity

Widget interactions

Date and time of the visit

The legal basis for the processing is your consent in accordance with Art. 6 (1) (a) GDPR. If you do not want Google Analytics to collect and process the aforementioned data, you can refuse to give your consent or withdraw it at any time with effect for the future. The personal data will be stored for as long as necessary to fulfill the purpose. The data will be deleted as soon as it is no longer required to achieve the purpose. In addition to Google Ireland Limited, the data may also be transmitted to Google servers in the USA and to the following recipients as part of the processing:

– Google LLC.

– Alphabet Inc.

As part of the processing by Google Analytics, data may also be transferred to the third countries Singapore, Taiwan and Chile.

If, when using this service, personal data is transferred to locations outside the European Economic Area in countries for which the European Commission has not issued an adequacy decision (https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_de), the transfer is secured by so-called standard contractual clauses, which ensure that the processing of personal data is subject to a level of security that corresponds to that of the GDPR. If the standard contractual clauses are not sufficient for establishing an adequate level of security, consent will be obtained from you in advance as part of the consent management system in accordance with Art. 49 (1) (a) GDPR. The data transfer to the USA is partly based on the Data Privacy Framework under which Google LLC is certified. Details of the regulations can be found here: https://www.dataprivacyframework.gov/s/program-overview.

For further information on the privacy policy and cookie policy of Google Ireland Limited, please refer to https://policies.google.com/privacy?hl=en and https://policies.google.com/technologies/cookies?hl=en.

  • Google Signals

Since we have also activated the Google Signals service offered by Google, i.e., so-called cross-device tracking, your data mentioned above in relation to Google Analytics will be analyzed across devices and used for the purpose of personalizing advertisements. The operator of this service is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. Google can thus recognize whether you visit our website initially via a smartphone and later via a laptop. We ourselves only receive reports with anonymous data from which we can identify patterns in visitor behavior. Google Signals is active if you have a Google account and are logged into it when you visit our Website. Furthermore, you must have agreed to “personalized advertising” in relation to Google. If you do not want cross-device tracking, you must deactivate “personalized advertising” in your Google account. With the help of Google Signals, we can launch cross-device remarketing campaigns. This means that we also show you our advertising on third-party websites. You have the option of viewing or deleting your data at Google under “My Activities”.

The legal basis for the processing is your consent pursuant to Art. 6 (1) (a) GDPR. If you do not want Google Signals to collect and process the aforementioned data, you can refuse to give your consent or withdraw it at any time with effect for the future. The personal data will be stored for as long as necessary to fulfill the purpose. The data will be deleted as soon as it is no longer required to achieve the purpose. In addition to Google Ireland Limited, the data may also be transmitted to Google servers in the USA as part of the processing.

If, when using this service, personal data is transferred to locations outside the European Economic Area in countries for which the European Commission has not issued an adequacy decision (https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_de), the transfer is secured by so-called standard contractual clauses, which ensure that the processing of personal data is subject to a level of security that corresponds to that of the GDPR. If the standard contractual clauses are not sufficient to establish an adequate level of security, consent will be obtained from you in advance as part of the consent management system in accordance with Art. 49 (1) (a) GDPR. Data transfer to the USA is partly based on the Data Privacy Framework under which Google LLC is certified. Details of the regulations can be found here: https://www.dataprivacyframework.gov/s/program-overview.

4.2.2 Google Tag Manager

​This Website uses the Google Tag Manager (“GTM”). The operator of this service is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. Through the GTM, tags such as code snippets or pixels are used on our own Website by means of a so-called container, which inserts a kind of placeholder in the source code and in which the tools to be used are stored without Clear Europe having to interfere with the source code of our Website. Using the GTM, tools can be used on your own website without having to integrate them into the source code. Instead, only the code of the GTM needs to be integrated and then the GTM can be used as a central location to start or deactivate the desired tools.

The GTM works on the Website when a defined usage behavior activates a so-called trigger, so that a tag (i.e., a pixel tag, web beacon or html code) for the tool is then generated. The GTM collects the relevant data for the built-in tool and forwards it to the tool. In this context, it is therefore not only the case that the data categories described for the respective tools are transmitted to the respective providers of the tools; Google Ireland Ltd. also receives information about your usage behavior on our Website.

The legal basis for the processing is your consent pursuant to Art. 6 (1) (a) GDPR. If you do not want Google Tag Manager to collect and process the aforementioned data, you can refuse your consent or withdraw it at any time with effect for the future. The personal data will be stored for as long as necessary to fulfill the purpose. The data will be deleted as soon as it is no longer required to achieve the purpose. In addition to Google Ireland Limited, the data may also be transmitted to Google servers in the USA and other third countries as part of the processing. Clear Europe has concluded a data processing agreement with Google Ireland Ltd.

If, when using this service, personal data is transferred to locations outside the European Economic Area in countries for which the European Commission has not issued an adequacy decision (https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_de), the transfer is secured by so-called standard contractual clauses, which ensure that the processing of personal data is subject to a level of security that corresponds to that of the GDPR. You can obtain a copy of the EU standard contractual clauses here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de. You can view the main content of the agreement at: https://policies.google.com/privacy/frameworks?hl=de. If the standard contractual clauses are not sufficient for establishing an adequate level of security, consent will be obtained from you in advance as part of the consent management system in accordance with Art. 49 (1) (a) GDPR. The data transfer to the USA is partly based on the Data Privacy Framework under which Google LLC is certified. Details on the regulations can be found here: https://www.dataprivacyframework.gov/s/program-overview.

5 DATA SUBJECT RIGHTS

​You can contact Clear Europe either in writing or by email at clear.europe@thecleargroup.com to exercise the following rights:

  • Access your data in order to check and verify it,
  • Receive a copy of your personal data,
  • Obtain the rectification, erasure or restriction of processing, including the right to have incomplete or incorrect data completed by means of providing a supplementary statement,
  • Right to object to the processing; please note that you have a right to object to the processing of personal data processed by us on the basis of legitimate interests pursuant to Art. 6 (1) (f) GDPR in accordance with Art. 21 GDPR; a right to object to the processing exists if the objection is based on grounds relating to your particular situation; if the objection is directed against the processing of personal data for direct marketing purposes, you have a general right to object without the requirement of specifying a particular situation,
  • You may receive the data you have provided in a structured, commonly used and machine-readable format and transmit the data to another controller, provided that you have given your consent to the processing, or the processing is based on a contract.
  • If you have given us your consent to process your personal data, you can revoke your consent at any time with effect for the future.

You also have the right to lodge a complaint with a supervisory authority in connection with the processing of your personal data. To exercise this right, you can contact the authority responsible for your place of residence or the authority responsible for Clear Europe’s registered office in Hamburg: The Hamburg Commissioner for Data Protection and Freedom of Information, Ludwig-Erhard-Straße 22, 20459 Hamburg.

6 AUTOMATED DECISION-MAKING AND PROFILING

​Except for the services described in the context of Google Analytics and Google Signals, your personal data will not be used by Clear Europe for automated decision-making and profiling. Profiling takes place with your consent, as described above in the context of the individual services.

Updated: October 2023

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