Data Privacy Terms

Version: 2018/05

 

The protection of personal data and thus your privacy is taken very seriously by us. At this point, we would like to outline how we protect your privacy and what it means to you when you use our services. In order to ensure the greatest possible protection of your privacy, it goes without saying that we comply with all legal provisions on data protection. This Privacy Policy applies to the online and app offerings of Cleverlize and Practice English Grammar, operated by the Cleverlize GmbH, which is available in major app stores, under the domain www.cleverlize.com and the various subdomains (hereinafter referred to as "our website" or “apps”).

 

1. Name and address for data protection

Responsible agency and service provider of the Cleverlize apps and websites is the Cleverlize GmbH, Winzererstr. 32, 80797 Munich (hereinafter referred to as "Cleverlize").
If you have any questions about privacy on our apps and
websites please contact: dataprivacy (at) cleverlize.com or write to: Cleverlize, c/o Lukas Steinbacher, Winzererstr. 32, 80797 Munich.

 

2. Principles of data collection

You can always visit our apps and websites without telling us who you are. In principle, we collect and use personal data of our users only to the extent necessary for the provision of a functional app and website and our content and services. 

Relevant legal bases: In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing.

Unless the legal basis is specified in the relevant section of the privacy policy, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 DSGVO, the legal basis for data processing to keep up the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) lit. b DSGVO, the legal basis for data processing in order to fulfill our legal obligations is Art. 6 (1) lit. c DSGVO, and the legal basis for data 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 is the legal basis.

 

3. Personal data

Personal data is information that can be assigned to you individually. Examples of this are, but not only your name, address, postal address, telephone number, your e-mail address or your geo-position. Non-personal data is information for example of the number of users of an app or a website.

3.1. Processing of personal data

Processing means any process or series of operations related to personal data, such as collecting, organizing, storing, adapting or modifying, reading, querying, using, with or without the aid of automated procedures; disclosure by submission, dissemination or other form of provision, reconciliation or association, restriction, erasure or destruction.

Personal data is collected through the apps and websites only if you provide it to us, e.g. by registering, filling in forms or sending e-mails. We use this information only for the purposes stated or as required by the according request. Submission to third parties will only be made if the law expressly permits this or if you have consented to the transmission as part of your registration or in the course of an active business relationship.

We store and use data entered by you in the contact form, such as first name, last name, telephone or e-mail, for the purpose of individual communication with you. Please note that the transmission of the data is not encrypted and therefore no confidential information should be sent via any contact form in our apps or websites.

3.2 Data deletion and storage duration

Your master data will be kept for the duration of the contract. After termination of the business relationship initiated by you, the data will be kept for a maximum of 4 years from your last transaction. If the termination of the business relationship is initiated by us for safety-related reasons or due to a bad debt, we retain your data within a maximum of 5 years after your last transaction.

3.3 Security of your data

Your personal data is protected by us from unauthorized access, use or publication. We ensure that the information you store on the server is located in a controlled and secure environment that prevents unauthorized access and disclosure. Our employees are committed to secrecy and the preservation of data secrecy.

The collection and use of personal data of our users according to paragraph no. 3, only takes place with the consent of the user. Insofar as we obtain the consent of the data subject for processing of personal data, Art. 6 para. 1 lit. a GDPR is the legal basis for the processing of personal data.

An exception applies to cases in which prior consent cannot be obtained for real reasons and processing of data is permitted by law. In the case, that processing of personal data is necessary for the performance of the service and enabling the contract to which the data subject is a party, Art. 6 para. 1 lit. b DSGVO is the legal basis. This also applies to processing operations required to carry out pre-contractual actions. Insofar as processing of personal data is required to fulfill a legal obligation to which we are subject, Art. 6 para. 1 lit. c DSGVO is the legal basis. If processing is necessary to safeguard the legitimate interests of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not prevail over the first interest, Art. 6 para. 1 lit. f DSGVO is the legal basis for processing.

By using our apps and websites you consent to the processing of the data collected about you in the manner described in this statement and for the named purposes. Incidentally, you can generally use the general information on Cleverlize’s app store description without disclosing your personal data to us.

 

4. Recording log files for statistical purposes

Each time you access our apps and websites, usage data is transmitted through the respective Internet browser and stored in log files, the so-called server log files. The records stored in this case contain the following data:

The IP addresses of the users will be deleted or anonymized after the end of use. In the case of anonymization, the IP addresses are changed in such a way that the details of personal or factual circumstances can no longer be assigned to a specific or identifiable natural person, or only with a disproportionately large amount of time, cost and manpower. We evaluate these log file records anonymously in order to further improve our offer and the Cleverlize apps and websites and to make them more user-friendly, to find and fix errors faster and to control server capacities. For example, it can be understood at what time the use of the Cleverlize apps and websites is particularly popular and provide the appropriate volume of data to ensure the fastest possible product performance. In addition, by analyzing the log files, we can more quickly detect and fix any errors on the Cleverlize apps and websites.

 

5. Cookies

"Cookies" are small files that allow us to store on your PC or other device specific information related to you, the user, while you use the offer on our apps, websites  and our products. Cookies, for example, help us to determine the frequency of use and the number of users of our services, as well as to make our offers as comfortable, efficient and interesting as possible for you. There are two types of cookies: session cookies and persistent cookies.

Session cookies are deleted as soon as you end the session. Temporary and permanent cookies are stored on the medium for a longer period of time or indefinitely. The cookies used in our apps and websites are not personal. With the activation of a cookie this receives only an identification number. Personal data such as name, IP address or similar are assigned to this identification number at any time. Using cookie technology, we only receive anonymous information, such as which pages on our apps and websites have been visited, and so on.
The following cookies are set by Cleverlize in particular:

5.1 Third party cookies

We serve a few advertisers who help us to make the apps and websites more interesting to you. Therefore, when visiting our websites, cookies from affiliate companies may be stored on your hard drive. These are temporary / permanent cookies that automatically delete after the specified time. These temporary or permanent cookies (lifetime 14 days to 10 years) are stored on your hard disk and delete themselves after the specified time. The cookies of our partner companies also contain pseudonymous only, mostly even anonymous data. For example, this may include information about which products you have viewed, whether something has been purchased, which products have been searched, etc. In doing so, some of our advertisers are also gathering information beyond our apps and websites, e.g. as which pages or apps you have previously visited or if you are interested in certain products. These pseudonymous data will never be merged with your personal information. Their sole purpose is to allow our affiliates to target you with advertisements that may actually interest you. You can prevent the setting of these cookies by deactivating the acceptance of third-party cookies in your Internet browser.

5.2 Google Analytics

Our apps and websites use Google Analytics, an app and web analytics service provided by Google Inc. ("Google"). Google Analytics uses so-called "cookies", text files that are stored on your computer or mobile device and that allow an analysis of your use of the apps and websites. The information generated by the cookie about your use of this apps and websites (including your IP address) will be transmitted to and stored by Google on servers in the United States. However, if IP anonymization is activated on apps and websites, your IP address will be shortened 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 get shortened there.

Google will use this information for the purpose of evaluating your use of the apps and websites, compiling reports on apps and websites activity for app and website  operators, and providing other services related to app and website activity and internet usage, including, but not limited to, Google Analytics demographics and interest reporting, Google Analytics Demographics and Interest Reporting allows us to collect data from Google's interest-based advertising and / or third-party data about our advertising audience (e.g. age, gender, and interests) in conjunction with Google Analytics for targeted and optimized advertising, strategies, and the content of our app and website use.

Google may also transfer this information to third parties if required by law or as far as third parties process this data on behalf of Google. Google will never associate your IP address with other data stored by Google.
You can prevent the storage of cookies by a corresponding setting of your browser software; however, please note that if you do this, you may not be able to use all the features of our apps and
websites to the fullest extent possible. You may also prevent the collection by Google of the data generated by the cookie and related to your use of the apps and websites (including your IP address) as well as the processing of this data by Google by using the browser plug-in available under the following link for download and installation: http://tools.google.com/dlpage/gaoptout?hl=de.

Our apps and websites use Google Analytics with the extension "anonymizeIp ()". As a result, IP addresses are processed shortened, a person-relatedness can be excluded. Insofar as the data collected about you is assigned a personal reference, it will be immediately excluded and the personal data will be deleted immediately.

We use Google Analytics to analyze and regularly improve the use of our apps and websites. With the statistics we can improve our offer and make it more interesting for you as a user. For the exceptional cases in which Personal Information is transferred to the US, Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-USFramework.

Third-party information: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Terms of Use: http://www.google.com/analytics/terms/en.html, Privacy Policy: http://www.google.com/intl/de/analytics/learn/privacy.html, and the Privacy Policy: http://www.google.com/intl/en/policies/privacy.

This site also uses Google Analytics for cross-device analysis of visitor traffic conducted through a user ID. You can disable cross-device analysis of your usage in your Google Account under My Data, Personal Information.

5.3. Prevent the storage of cookies

You can disable the storage of cookies in your browser, limit them to certain apps and websites or set your browser to notify them when a cookie is sent. You can also delete cookies from your PC's hard drive at any time. We point out, however, that in this case you may not be able to use all the functions of these apps and websites in full. For shared computers that are set to accept cookies, we recommend that you log out completely at the end of each session.

The execution of the aforementioned data processing operations and in the pursued purposes is in our legitimate interest. For this purpose, Art. 6 para. 1 lit. f DSGVO is the legal base.

 

6. Facebook

Our apps and websites use some technologies provided by Facebook, Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook"). These technologies are explained in more detail below.

6.1 Facebook Connect

If a so-called "Facebook Connect Button" is placed in our apps or on our website, you can log in to our website with your Facebook user data. In addition, Facebook Connect can automatically include information about your activities in our apps or on our website in your Facebook profile. In this respect, when you activate the button, you will be given both the opportunity to expressly consent to access your Facebook user data and to publish information and activities in your Facebook profile. The use of further data (e.g. contact via your email address) only takes place with prior express consent. Please note that Facebook receives information about the application or website via Facebook Connect, including what you are doing. To personalize the connection process, Facebook may in some cases receive a limited amount of information prior to authorizing the application or website. The purpose and scope of the data collection and the further processing and use of the data by Facebook as well as your rights in this regard and settings options for the protection of your privacy can be found in the privacy policy at: http://www.facebook.com/policy.php

6.2 Facebook Custom Audience

Within our Internet presence we use the "Facebook pixel" from Facebook Inc. 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook"). This allows users' behavior to be tracked after they have seen or clicked on a Facebook ad. This process is used to evaluate the effectiveness of Facebook advertisements for statistical and market research purposes and can help to optimize advertising measures.

The data collected is anonymous to us, so it does not give us any indication of the identity of the users. However, Facebook stores and processes the data so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes in accordance with the Facebook data usage guidelines. You can enable Facebook as well as its partners to connect advertising ads to Facebook and including on external websites. A cookie can also be stored on your computer for these purposes. In order to reject the use of cookies on your computer in general, you can set your Internet browser so that cookies can no longer be stored on your computer in the future or cookies that have already been stored will be deleted. However, disabling all cookies can result in some functions on our internet pages no longer being executed.

Our legitimate interest lies in the aforementioned data processing processes and the purposes pursued with them. For this purpose, Art. 6 para. 1 lit. f GDPR provides the legal basis.

 

7. Use of service providers and data transmission to third countries

We use service providers to provide services and to process your data relating to our services and products. The service providers process the data exclusively in accordance with our instructions and have been obliged to comply with the applicable data protection regulations. All processors have been carefully selected and will only have access to your data required for the provision of the Services to the extent and for the period required, or to the extent to which you have consented to the processing and use of the data.

If we process data in a third country (e.g. 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 base of your consent, on base of a legal obligation or on base of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in presence of the special conditions of Art. 44 et seq. DSGVO. Means, processing takes place 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").

 

8. Linking to apps and websites of other online services

Online services of other providers, which are linked in our apps and websites, are responsible for the compliance with the legal regulations on data protection on their own. In general, these online services also have their own privacy policy, which are relevant in respect to their services. We hereby declare that we do not assume any responsibility or liability for these apps and websites.

 

9. Rights, in particular information, revocation, cancellation, data transfer rights

You will receive information about your stored data free of charge at any time without giving reasons. You can also revoke your consent at any time with effect for the future. Cleverlize commits itself to the cancellation of personal data unless a deletion is contrary to mandatory legal storage requirements. The deletion of your personal data is usually done within a maximum of 5 working days after assertion.

It is pointed out that revoking all data processing operations can lead to limitation and suspension of execution of our business relationship as well as of execution of individual functions and achievements. In the event that you ask for your personal information, we will provide you or another person in charge, if you wish, with the data in a structured, common and machine-readable format. The latter, however, only if this is technically possible. All rights can be formally requested and requested either by e-mail or by post at the contact details specified in section 1 of this privacy policy.

You have the right to lodge a complaint with the competent supervisory authority against processing of your personal data, if you see your rights violated in accordance with the GDPR.
Please also consider the relevant data protection instructions of the app stores, where our apps are published.

 

10. Change of the privacy policy

We reserve the right to change this privacy policy at any time in accordance with the applicable data protection regulations. Please check therefore the current state of the data protection regulations, which can be found under www.cleverlize.com/privacy/peg, regularly.

Imprint: http://www.cleverlize.com/imprint