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Privacy Policy

Your privacy is important to us (“CLEVR”). This Privacy Policy (the “Policy”) discloses our information practices, including our policies regarding the types of information that is gathered and tracked through our web site, descriptions of how such information is used, and identification of the parties with whom the information may be shared. This Policy will be applicable to the CLEVR Web sites. The ISMS of CLEVR NL B.V. is ISO 27001 certified.

1. Name and contact details of the responsible for data processing

This privacy policy applies to data processing by:

Responsible for data processing (GDPR)
CLEVR NL BV
Euroweg 100
3825 HD Amersfoort
The Netherlands

security@clevr.com
Tel.:+31 (0)33 744 00 04

Chief Executive Director
Jeroen Hanekamp

2. Collection and storage of personal data as well as the nature and purpose of their use
a) When visiting the website
When you visit our website  https://www.clevr.com, the browser used on your device automatically sends information to the server of our website. This information is temporarily stored in a so-called log file. The following information is recorded without your intervention and up to the automated Deletion saved:

  • IP address of the requesting computer,
  • date and time of access,
  • Name and URL of the retrieved file,
  • Website from which access is made (referrer URL),
  • the browser used and, if applicable, the operating system of your computer and the name of your access provider.

The data mentioned are processed by us for the following purposes:

  • ensuring a smooth connection of the website,
  • Ensure comfortable use of my website,
  • Evaluation of system security and stability as well
  • for further administrative purposes.

b) By using our contact form
For questions of any kind, we offer you the opportunity to contact us via a form provided on the website. It is necessary to provide a valid e-mail address so that we know who the request came from and to answer it. Further information can be provided voluntarily. The data processing for the purpose of contacting us is in accordance with Art. 6 para. 1 p. 1 lit. a GDPR based on your voluntarily granted consent. The personal data collected by us for the use of the contact form will be automatically deleted after completion of the request made by you.

c) by signing up for one of the CLEVR Academy courses
If you apply for one or more of the CLEVR Academy courses, CLEVR will use the Personal Data you provided as part of your application for the purposes of:

  • the processing and assessment of your application
  • Communicate with you by:
    - Responding to your questions;
    - Sending you administrative messages and information, including messages from instructors, students, and teaching assistants; notifications about changes to our course(s) and updates to our agreements;
    - Sending you information, such as by email or text messages, about your progress in courses and related content
  • Solicit feedback on courses taken.

d) Our commitment to the privacy of children

Of particular importance is the protection of the privacy of infants. For this reason, we do not collect or maintain information on our web site from anyone we know to be under the age of 16, and no part of our web site is structured to be attractive to anyone under the age of 16.



The legal basis for data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest follows from the data collection purposes listed above. In no case we use the collected data for the purpose of drawing conclusions about you. In addition, we use cookies and analysis services when visiting our website. Further details can be found under points 4 and 5 of this privacy policy.
The use of our website is usually possible without providing personal data. As far as on our sides personal data (for example name, address or email addresses) are raised, this takes place, as far as possible, always on voluntary basis. These data will not be disclosed to third parties without your explicit consent.

Please note that data transmission over the Internet (for example, when communicating by e-mail) may have security vulnerabilities. A complete protection of the data from access by third parties is not possible.

The use of contact information published by third parties for the purpose of sending unsolicited advertising and information materials is hereby expressly excluded. The operators of the pages expressly reserve the right to take legal action in the event of unsolicited promotional information, such as spam e-mails.
 
3. Disclosure of data
A transfer of your personal data to third parties for purposes other than those listed below does not take place.
We only share your personal information with third parties if:

  • You yours according to Art. 6 para. 1 sentence 1 lit. a GDPR have given express consent to this
  • disclosure pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR is required to assert, exercise or defend legal claims and there is no reason to assume that you have an overriding interest in not disclosing your data, 
  • in the event that disclosure pursuant to Art. 6 para. 1 sentence 1 lit. c GDPR a legal obligation exists, as well
  • this is legally permissible and according to Art. 6 para. 1 sentence 1 lit. b GDPR is required for the settlement of contractual relationships with you.
  • Data will not be transferred to countries outside the EU or the EEA (so-called third countries) unless we are obliged to do so by official or court order. 

4. Cookies

We use cookies on our site. These are small files that your browser automatically creates and that are stored on your device (laptop, tablet, smartphone, etc.) when you visit my site. Cookies do not harm your device, do not contain viruses, Trojans or other malicious software. In the cookie information is stored, each resulting in connection with the specific terminal used. However, this does not mean that we will receive immediate knowledge of your identity. On the one hand, the use of cookies serves to make the use of our offer more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages on our website. These become automatically after leaving our side deleted. In addition, to improve usability, we also use temporary cookies that are stored on your device for a specified period of time. If you visit our site again to use our services, it will automatically recognize that you have already been with us and what inputs and settings you have made, so you do not have to re-enter them. On the other hand, we use cookies to statistically record the use of our website and to evaluate it for the purpose of optimizing our offer (see section 5). These cookies allow us to renew

Visit our page automatically to recognize that you were already with us. These cookies are automatically deleted after a defined time. The data processed by cookies are for the purposes mentioned in order to safeguard our legitimate interests as well as those of third parties pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR required.

Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or a note always appears before a new cookie is created. However, disabling cookies completely may mean that you can not use all features of our website.

Read more on our cookie policy page.

 

5. Blog

When you read our blogs on the CLEVR Website, you do not have to leave any personal information. The blogs can only be read by opening on the CLEVR website.

6. Links to other websites

The CLEVR site may contain links to other websites or applications. CLEVR is not responsible for the privacy practices or the content of such websites. The links from a CLEVR Web site do not imply that CLEVR has supported or reviewed the third-party Web sites. We recommend that you contact the operators of these websites directly for information about their privacy policy.

7. General note about social media plugins

We rely on our website on the basis of Art. 6 para. 1 sentence 1 lit. f GDPR social plug-ins from the social networks Facebook, Xing, LinkedIn, Twitter, Instagram and Youtube.

a) Facebook

Our website uses social media plugins from Facebook to personalize their use. For this we use the “LIKE” or “SHARE” button. It is an offer from Facebook. If you visit a page of our website that contains such a plugin, your browser establishes a direct connection to the Facebook servers. The content of the plugin is transmitted by Facebook directly to your browser and integrated by this in the website. By integrating the plugins, Facebook receives the information that your browser has accessed the corresponding page of our website, even if you do not have a Facebook account or are currently not logged in to Facebook. This information (including your IP address) is transmitted from your browser directly to a Facebook server in the US and stored there. If you are logged in to Facebook, Facebook can assign the visit to our website directly to your Facebook account. If you interact with the plugins, for example by pressing the “LIKE” or “SHARE” button, the corresponding information is also transmitted directly to a Facebook server and stored there. The information will also be posted on Facebook and displayed to your Facebook friends. Facebook may use this information for the purpose of advertising, market research and tailor-made Facebook pages. For this purpose, Facebook uses user, interest and relationship profiles, e.g. to evaluate your use of our website in relation to the advertisements displayed on Facebook, to inform other Facebook users about your activities on our website, and to provide other services related to the use of Facebook. If you do not want Facebook to assign the data collected via our website to your Facebook account, you must log out of Facebook before visiting our website. The purpose and scope of the data collection and the further processing and use of data by Facebook, as well as your rights in this regard and settings options for the protection of your privacy, please refer to the privacy policy of Facebook.

b) XING

Our website uses the “share button” of XING. For this reason, when you access this website via your browser, you will be connected to the servers of XING AG, Gänsemarkt 43, 20354 Hamburg, Germany. This will provide the share functions (e.g., displaying the counter value). A storage of personal data of you by calling this website is not made. In particular, XING does not store IP addresses. Nor is your usage behavior evaluated. You can read up-to-date information on data protection with regard to the “Share Button” and other relevant information at https://privacy.xing.com/en/privacy-policy

c) LinkedIn

You can find plug-ins from either the LinkedIn social network or the LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, United States (hereafter “LinkedIn”). You can recognize the plugins of LinkedIn by the corresponding logo or the “Recommend” button. Please note that when you visit our website, the plugin establishes a connection between your respective internet browser and LinkedIn’s server. LinkedIn is informed that our website has been visited with your IP address. If you click on LinkedIn’s “Recommend Button” and at the same time you are logged into your LinkedIn account, you have the option of linking content from our website to your profile page on LinkedIn Profile. In doing so, you allow LinkedIn to associate your visit to our website with you or your user account. You must understand that we have no knowledge of the content of the submitted data and its use by LinkedIn.

For more details about collecting the data and your legal options, as well as setting options, please visit LinkedIn. These are under you
http://www.linkedin.com/static?key=privacy_policy&trk=hb_ft_priv provided.

d) Twitter

Our website contains features of Twitter Inc., 795 Folsom Street, Suite 600, San Francisco, CA 94107, USA. When you use Twitter, Twitter associates your Twitter account with the websites you frequent. This will be announced to other users on Twitter, especially your followers. In this way also a data transfer takes place to Twitter.

We, as the provider of our website, are not informed by Twitter about the content of the transmitted data or the data usage. You can find more information at the following link: http://twitter.com/privacy

Please note, however, that you have the option to change your privacy settings on Twitter to your local account settings at http://twitter.com/account/settings.

e) Instagram

Functions of the service Instagram are integrated on our sides. These features are provided by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, United States. If you are logged in to your Instagram account, you can link the contents of our pages to your Instagram profile by clicking on the Instagram button. This allows Instagram to associate the visit of our pages with your user account. We point out that we as the provider of the pages do not receive any knowledge of the content of the transmitted data and their use by Instagram.

For more information, see the Instagram Privacy Policy: http://instagram.com/about/legal/privacy/.

f) Youtube

We embed the videos from the YouTube platform of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Privacy Policy: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.

8. Privacy Policy for the use of Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, if IP anonymisation is activated on this website, your IP address will be truncated by Google beforehand within member states of the European Union or in other contracting states of the Agreement on the European Economic Area.

Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website usage and internet usage to the website operator. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google information.

You can prevent the storage of cookies by a corresponding setting of your browser software; however, we point out that in this case you may not be able to use all the functions of this website in full. In addition, you may prevent the collection by Google of the data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading the browser plug-in available under the following link and install: http://tools.google.com/dlpage/gaoptout?hl=en.

9. Privacy Policy for the use of Google Adsense

This website uses Google AdSense, a service for integrating advertisements of Google Inc. (“Google”). Google AdSense uses so-called “cookies”, text files that are stored on your computer and that allow an analysis of the use of the website. Google AdSense also uses so-called web beacons (invisible graphics). These web beacons can be used to evaluate information such as visitor traffic on these pages.

The information generated by cookies and web beacons on the use of this website (including your IP address) and the delivery of advertising formats are transmitted to and stored by Google on servers in the USA. This information may be shared by Google with Google’s contractors. However, Google will not merge your IP address with other data you have stored.

You can prevent the installation of cookies by setting your browser software accordingly; However, please be aware that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

The provider uses the remarketing or “similar audiences” feature of Google Inc. (“Google”) on the website. Using this feature, the provider can target advertisers to the website by displaying personalized, interest-based advertising ads to visitors to the provider’s website when they visit other websites on the Google Display Network. Google uses so-called cookies to carry out the analysis of the website usage, which forms the basis for the creation of interest-based advertisements. For this Google stores a small file with a sequence of numbers in the browsers of the visitors of the website. This number records website visits and anonymised data on the use of the website. There is no storage of personal data of visitors to the website. If you visit another website on the Google Display Network, you’ll see advertisements that are likely to include previously viewed product and information areas.

You may permanently disable the use of cookies by Google by following the link below and downloading and installing the plug-in provided there: https://www.google.com/settings/ads/plugin?hl=en.

10. Privacy Policy Google Maps

This website uses the Google Maps product of Google Inc. By using this site, you consent to the collection, processing and use of the automated data collected by Google Inc, its agents and third parties.

You can find the terms of use of Google Maps under “Terms of Use of Google Maps”.

11. Affected rights

You have the right:

  • in accordance with Art. 15 GDPR, to request information about your personal data processed by us. In particular, you may provide information about the processing purposes, the category of personal data, the categories of recipients to whom your data has been disclosed, the planned retention period, the right of rectification, deletion, limitation of processing or opposition, the existence of a Complaint right, the source of their data, if they were not collected from us, as well as the existence of an automated Demand decision-making, including profiling, and if necessary, meaningful information about their details;

  • in accordance with Art. 16 GDPR, immediately demand the correction of incorrect or completed personal data stored by us;

  • in accordance with Art. 17 GDPR, require the deletion of your personal data stored by us, unless the processing is for the exercise of the right to freedom of expression and information, for the fulfillment of a legal obligation, for reasons of public interest or for the assertion, exercise or defense of legal claims is required;

  • to demand the restriction of the processing of your personal data in accordance with Art. 18 GDPR, as far as the accuracy of the data is disputed by you, the processing is unlawful, but you reject its deletion and we no longer need the data, but you assert this, Exercise or defense of legal claims or you have lodged an objection against the processing according to Art. 21 GDPR;

  • to receive, in accordance with Art. 20 GDPR, your personal data provided to us in a structured, standard and machine-readable format or to request transmission to another person responsible;

  • according to Art. 7 para. 3 GDPR, to revoke your once given consent to us at any time. As a result, we are no longer allowed to continue the data processing based on this consent for the future, and

  • to complain to a supervisory authority in accordance with Art. 77 GDPR.

12. Right to object

If your personal data are based on legitimate interests in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR are processed, you have the right, in accordance with Art. 21.

GDPR objection to the processing of your personal data, as far as there are reasons for this, which arise from your particular situation or the objection against direct advertising. In the latter case, you have a general right of objection, which is implemented by us without stating a particular situation.

If you would like to exercise your right of revocation or objection, please send an e-mail to security@clevr.nl.

13. Data security

We use the widely used Secure Socket Layer (SSL) method in conjunction with the highest level of encryption supported by your browser. In general, this is a 256-bit encryption. If your browser does not support 256-bit encryption, we’ll use 128-bit v3 technology instead. Whether a single page of our website is transmitted in encrypted form is indicated by the closed representation of the key or lock symbol in the lower status bar of your browser.

Incidentally, we use appropriate technical and organizational security measures to protect your data against accidental or deliberate manipulation, in part or complete loss, destruction or protection against unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

14. Updating and changing this privacy policy

This privacy policy is currently valid and has the status 22.04.2021. Due to the further development of our website and offers or due to changed legal or regulatory requirements, it may be necessary to change this privacy policy. The current privacy policy can be viewed and printed by you at any time on the website at https://www.clevr.com/privacy.