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Privacy Policy for Klutch.io - The Klutch project

Last updated: 8 October 2024

1. Introduction​

Thank you for visiting our website. We take data protection very seriously and make every effort to protect your personal data as part of our web offering.
We understand personal data to be all data concerning a natural person’s personal and factual relationships. Personal data that are collected on our website are exclusively used for our own purposes.

Declaration of consent: If your consent was obtained for personal data collected for processing, Article 6 Paragraph 1 lit. a of the EU General Data Protection Regulation (GDPR) is the legal basis for data processing.

Contract: When processing personal data to fulfill a contract to which you are a contractual party, Article 6 Paragraph 1 lit. b GDPR is the legal basis. This also applies to processing that is required to implement measures in advance of a contract.

Statutory obligation: If personal data is processed to fulfill a legal obligation to which our company is subject, Article 6 Paragraph 1 lit. c GDPR is the legal basis. In the event that your existential interests - or those of another natural person - make the processing of personal data necessary, the legal basis is Article 6 Paragraph 1 lit. d GDPR.

Justified interest: If the processing is required to maintain a justified interest of our company or a third party and the interests, basic rights, and freedoms of the affected person do not outweigh the interest stated first, Article 6 Paragraph 1 lit. f GDPR is the legal basis for the processing. The justified interest of our company is in implementing our business activity.

We process your data for the following company interests:

  • Optimization of the website for a better user experience
  • Measurement of goals of our sales campaigns
  • Communication to carry out our business activities

3. Automatically Collected Information​

Your personal data is processed by us as part of our data processing. You have the rights from the Third Chapter of the GDPR with regard to our company. We comply with the rights to information, correction, restriction of processing, deletion, or the ability to transfer your personal data. You can assert these rights as follows:

Right to information
You have the right to request a confirmation from us on whether we process your personal data. If this is the case, you have the right to receive information on this personal data and the following information:

  1. the processing purposes;
  2. the categories of personal data that were processed;
  3. the recipients or categories of recipients to whom the personal data was published or will be published, in particular for recipients in third countries or international organizations;
  4. if possible the planned duration for which the personal data is stored, or, if this is not possible, the criteria for setting this term;
  5. the existence of a right to correction or deletion of your personal data or a right to restrict the processing by the responsible person or a right to object to this processing;
  6. the existence of a complaint right to a supervisory authority;
  7. if the personal data are not collected from the affected person, all information available on the origin of the data;
  8. the existence of automated decision-making including profiling under Art. 22 Para. 1 and 4 GDPR and - at least in these cases - meaningful information on the logic involved, extent, and the desired effects of such processing for the affected person.

If personal data is transferred to a third country or international organization, you have the right to be informed about suitable guarantees under Article 46 GDPR in relation to the transfer. We provide a copy of the personal data that are subject to the processing. For all further copies that you request, we may require an appropriate fee based on the administrative costs. If you make a request for information electronically, and if you have not stated anything further, we have to provide the information in a common electronic format. The right to receive a copy may not adversely affect the rights and freedoms of other people.

Right to correction
You also have the right to request the correction without delay of incorrect personal data relating to you. Whilst taking into account the purposes of the processing, you have the right to request the completion of incomplete personal data - even using an additional declaration.

Right to deletion (“right to be forgotten”)
You also have the right to request that we delete your personal data without delay and we are obligated to delete the data without delay if one of the following reasons applies:

  1. Your affected personal data are no longer required for the purposes for which they were collected or any other processing.
  2. You revoke your consent on which the processing is based as per Art. 6 I lit. a or Art. 9 Para. 2 lit. a GDPR and there is no other legal basis for the processing.
  3. You object to the processing under Art. 21 Para. 1 GDPR and there are no other priority justified reasons for the processing or you object to the processing under Art. 21 Para. 2 GDPR.
  4. Your personal data was processed illegally.
  5. The deletion of your personal data is required to fulfill a legal obligation under Union law or the law of the member state to which we are subject.
  6. Your personal data were collected for information company services offered under Art. 8 Para. 1 GDPR.

(2) If we have published your personal data and are obliged to delete it under Art. 1, whilst taking into account the available technology and implementation costs, we must undertake appropriate measures, including of a technical nature, to inform the person responsible for data protection who is processing the personal data that you have requested the deletion of all links to this personal data or copies or replications of this personal data. This does not apply if the processing is required a) to execute the right to freedom of expression and information; b) to fulfill a legal obligation that requires processing under the law of the Union or member states to which we are subject or to undertake a task that is in the public interest or to execute public authority that was transferred to us; c) for reasons of public interest relating to public health under Article 9 Paragraph 2 Letters h and i and Article 9 Paragraph 3; d) for archive purposes in the public interest, academic or historic research purposes, or for statistical purposes under Article 89 Paragraph 1 if the right stated in Paragraph 1 is expected to make the implementation of the objectives of this processing impossible or seriously adversely affect them, or e) to assert, exercise, or defend legal claims.

Right to restriction on processing
(1) The affected person has the right to request the restriction of processing from the person responsible if the following requirements are met:

  1. the correctness of the personal data is disputed by the affected person for the duration it takes the person responsible to check the correctness of the personal data
  2. the processing is illegal and the affected person rejects the deletion of the personal data and instead requests a restriction on the use of the personal data;
  3. the responsible person no longer requires the personal data for the processing purposes but the affected person does require them to assert, exercise, or defend legal claims, or
  4. if you have submitted an objection against the processing under Article. 21 Paragraph. 1 GDPR and it is not yet clear whether the justified reasons of the responsible person outweigh your reasons.

(2) If the processing was restricted, this personal data - apart from its storage - can only be processed with the consent of the affected person or to assert, exercise, or defend legal claims or to protect the rights of another natural person or legal entity, or due to the important public interest of the Union or a member state. 4.5.2016 L 119/44 Official Journal of the European Communities DE

(3) An affected person that has brought about a restriction on processing is informed by the person responsible before the restriction is lifted.

Article 19 Notification obligation relating to the correction or deletion of personal data or restricting its processing
The person responsible informs all recipients whose personal data was published of all corrections to or deletions of the personal data or a restriction on the processing under Article 16, Article 17 Paragraph 1, and Article 18 unless this proves to be impossible or is associated with disproportionate costs. The person responsible informs the affected person about these recipients if the affected person requests this.

Article 20 Right to Data Transfer
(1) The affected person has the right to receive their personal data that they provided to a responsible person in a structured, common, machine-readable format and they have the right to transfer these data to another responsible person without hindrance by the person responsible to whom the person data was provided, if

  1. the processing is based on consent under Article 6 Paragraph 1 Letter a or Article 9 Paragraph 2 Letter a or a contract based on Article 6 Paragraph 1 Letter b and
  2. the processing takes place using automated processes. (2) In executing your right to transfer data under Paragraph 1, the affected person also has the right to ensure that your personal data is transferred directly from one responsible person to another if this is technically feasible.

(3) The utilization of the right in Paragraph 1 of the Article stated above does not affect Article 17. This right does not apply to processing personal data that are required to undertake a task that is in the public interest or to exercise public authority that has been transferred to the person responsible.

(4) The right under Paragraph 2 may not adversely affect the rights and freedoms of other people. You also have the right to call our data protection officer for advice on the stated rights and all questions related to the processing of your personal data. In addition, our customers can also assert their complaint right to the responsible supervisory authority.

Right to objection

  1. You have the right for reasons arising from your special situation to object to the processing of your personal data at any time as a result of Art. 6 Para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. The responsible person no longer processes your personal data unless they can demonstrate binding reasons requiring protection for the processing that outweigh your interests, rights, and freedoms, or the processing is used to assert, exercise, or defend legal claims.
  2. If your personal data is processed for direct advertising purposes, you have the right to object to the processing of your personal data for such advertising purposes at any time; this also applies to profiling if it is in connection with direct advertising.
  3. If you object to the processing for the purposes of direct advertising, your personal data is no longer processed for these purposes.
  4. You have the opportunity to exercise your objection right in relation to the use of the services of the information company - notwithstanding Directive 2002/58/EU - when technical specifications are used for automated processes.
  5. You have the right for reasons arising from your specific situation to object to the processing of your personal data for academic, historical research, or statistical purposes under Art. 89 Para. 1 unless the processing is required in the public interest.

Notwithstanding any other administrative law or legal assistance, you have the right to complain to a supervisory authority if you are of the opinion that the processing of your personal data infringes the GDPR.

4. Web server logs​

When using our website the connection information is stored in the server log files.

This information includes:

  • IP address of the system used to call up
  • Browser information such as operating system used and screen resolution
  • Website called up
  • Originating website
  • Time of call up

The web server logs are only processed for security purposes.

We use the logged data only for statistical analyses for the purposes of operating, securing, and optimizing the offering. However, we reserve the right to check the logged data subsequently if there are specific concerns leading to a justified suspicion of illegal use.

5. Contact form​

Within the scope of the contact form, you have the option to send us any data. The data is passed on from our web server by email to our company's email inbox.

6. Cookies​

This website uses cookies. Cookies are text files that are stored on your device. Cookies can be read, transferred or modified by the website when calling up the website. We only use cookies with random, pseudonym identification numbers. These identification numbers are used to analyze your usage behavior on our website. At no time is the usage profile assigned to the name of a natural person. If you use special functions (e.g. shopping basket or “stay logged in”) on our website, cookies are also used for these functions.

It is possible at any time to object to the setting of cookies by making the relevant change in the browser's settings. Set cookies can be deleted. It is emphasized that when deactivating cookies not all of the functions of our website may be fully available.

The precise functions of the cookies can be viewed from the more detailed information in this data protection policy.

7. Google Tag Manager​

We use "Google Tag Manager" on our website, a service of Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland (hereinafter referred to as "Google"). Google Tag Manager enables us as marketers to manage website tags via an interface. The Google Tag Manager tool that implements the tags is a cookie-less domain and does not itself collect any personal data. Google Tag Manager takes care of triggering other tags, which in turn may collect data. Google Tag Manager does not access this data. If a deactivation has been made at the domain or cookie level, this remains in place for all tracking tags implemented with Google Tag Manager.

Third-Party Provider Information: Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland.

Further information on data protection can be found on the following Google web pages:
Privacy policy: https://policies.google.com/privacy?hl=en
Google Tag Manager Terms of Service: https://www.google.com/intl/de/tagmanager/use-policy.html

8. Google (Invisible) reCAPTCHA​

We use "Google (Invisible) reCAPTCHA" on our website, a service of Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland (hereinafter referred to as "Google"). Google (Invisible) reCAPTCHA processes information about your user behavior on our website.

We use Google (Invisible) reCAPTCHA to check whether the input is made by a human or abusively by automated, machine processing. The procedure thus serves to defend against spam, DDoS attacks, and similar automated malicious access. The use of Google (Invisible) reCAPTCHA thus directly serves to ensure the integrity and functionality of our systems. This is also our legitimate interest. The legal basis is Art. 6 para. 1 p. 1 lit. f) GDPR.

The IP address transmitted as part of Google (Invisible) reCAPTCHA is not merged with other Google data unless you are logged into your Google account at the time of using Google (Invisible) reCAPTCHA. If you want to prevent this transmission and storage of data about you and your behavior on our website by Google, you must log out of Google before you visit our site or use Google (Invisible) reCAPTCHA.

You can object to the collection and forwarding of personal data or prevent the processing of this data by deactivating the execution of JavaScript in your browser. In addition, you can prevent the execution of Java-Script code altogether by installing a Java-Script blocker (e.g. https://noscript.net/ or https://www.ghostery.com). Please note that in this case, you may not be able to use the full functionality of our website.

Information from the third-party provider: Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland.

Further information from the third-party provider on data protection can be found on the following website: https://policies.google.com/privacy.

9. Google Analytics​

"If you have given your consent, this website uses Google Analytics 4, a web analytics service provided by Google LLC. The responsible party for users in the EU/EEA and Switzerland is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google").

Scope of processing
Google Analytics uses cookies that enable an analysis of your use of our websites. The information collected by means of the cookies about your use of this website is generally transferred to a Google server in the USA and stored there.

We use the User ID function. With the help of the User ID, we can assign a unique, permanent ID to one or more sessions (and the activities within these sessions) and analyze user behavior across devices.

We use Google Signals. This allows Google Analytics to collect additional information about users who have enabled personalized ads (interests and demographics), and ads can be delivered to these users in cross-device remarketing campaigns.

Google Analytics 4 has IP address anonymization enabled by default. Due to IP anonymization, your IP address will be truncated by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. According to Google, the IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. During your website visit, your user behavior is recorded in the form of "events".

Events can be:

  • Page views
  • First visit to the website
  • Start of session
  • Your "click path", interaction with the website
  • Scrolls (whenever a user scrolls to the bottom of the page (90%))
  • Clicks on external links
  • Internal search queries
  • Interaction with videos
  • File downloads
  • Ads seen/clicked
  • Language setting

Also recorded:

  • Your approximate location (region)
  • your IP address (in shortened form)
  • technical information about your browser and the end devices you use (e.g. language setting, screen resolution)
  • your internet service provider
  • the referrer URL (via which website/advertising medium you came to this website)

Purposes of the processing
On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website and compiling reports on website activity. The reports provided by Google Analytics are used to analyze the performance of our website.

Recipients
Recipients of the data are/maybe

  • Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (as a processor according to Art. 28 DSGVO).
  • Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
  • Alphabet Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA

It cannot be ruled out that US authorities may access the data stored by Google. Third country transfer Insofar as data is processed outside the EU/EEA and there is no level of data protection corresponding to the European standard, we have concluded EU standard contractual clauses with the service provider to establish an appropriate level of data protection. The parent company of Google Ireland, Google LLC, is based in California, USA. A transfer of data to the USA and access by US authorities to the data stored by Google cannot be ruled out. The USA is currently considered a third country from a data protection perspective. You do not have the same rights there as within the EU/EEA. You may not be entitled to any legal remedies against access by authorities.

Storage period
The data sent by us and linked to cookies are automatically deleted after 14 months. Data whose retention period has been reached is automatically deleted once a month.

Legal basis
The legal basis for this data processing is your consent pursuant to Art.6 para.1 p.1 lit. a GDPR.

Revocation
You can revoke your consent at any time with effect for the future by calling up the cookie settings and changing your selection there. The lawfulness of the processing carried out on the basis of the consent until the revocation remains unaffected. You can also prevent the storage of cookies from the outset by setting your browser software accordingly. However, if you configure your browser to reject all cookies, this may result in a restriction of functionalities on this and other websites. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by a. not giving your consent to the cookie setting or b. downloading and installing the browser add-on to disable Google Analytics HERE. For more information on Google Analytics terms of use and Google's privacy policy, please visit https://marketingplatform.google.com/about/analytics/terms/de/ and https://policies.google.com/?hl=en.

10. Google Analytics advertising functions​

We also use the extended functions of Google Analytics on this website in addition to the standard functions. The Google Analytics advertising features implemented on this website include:

  • Google Display Network Impressions Reports
  • Google Analytics reports on performance by demographic characteristics and interests.
  • Integrated services for which Google Analytics collects data for advertising purposes, including collection of data via cookies for ad preferences and anonymous identifiers.

For this purpose, in addition to the data collected by the Google Analytics analytics tool, additional data is collected via Google cookies for ad preferences and anonymous identifiers on accesses. We use this information to improve our web offerings.

You can prevent the use of Google Analytics advertising functions in various ways:

  1. by setting your browser software accordingly;
  2. via the Google ad settings on https://www.google.com/ads/preferences/?hl=en
  3. using the appropriate cookie setting, or
  4. by deactivating on the Network Advertising Initiative (NAI) website at http://www.networkadvertising.org

Please note that in this case you may not be able to use the full functionality of this website.

11. Google Ads​

Our website uses Google Ads Conversion Tracking. This is an analysis service of Google Inc., Amphitheater Parkway, Mountainview; California 94043, USA. The service sets a cookie on your computer if you have arrived at our page from a Google advert. We do not use the cookie to identify you personally. It is only used to detect whether a visitor has arrived at our website from an advert that we purchased. Which advert was used to visit our website and whether you then browsed our website again can therefore be tracked. We use the knowledge from this analysis to modify our adverts in a more targeted way.

You can find more information and the Google data protection policy at: http://www.google.de/policies/privacy/.

12. Google Ads Remarketing​

We use the remarketing function within the Google Ads service. With the remarketing function, we can present users of our website with advertisements based on their interests on other websites within the Google advertising network (in Google Search or on YouTube, so-called "Google Ads" or on other websites). For this purpose, the interaction of the users on our website is analyzed, e.g. which offers the user was interested in, in order to be able to display targeted advertising to the users on other sites even after they have visited our website. For this purpose, Google stores cookies on the end devices of users who visit certain Google services or websites in the Google display network. These cookies are used to record the visits of these users. The cookies are used to uniquely identify a web browser on a specific end device and not to identify a person.

Recipient:
For more information about Google's privacy policy, please click here:
http://www.google.com/intl/en/policies/privacy and https://services.google.com/sitestats/en.html.

Alternatively, you can visit the Network Advertising Initiative (NAI) website at http://www.networkadvertising.org .

Transfers to third countries are possible. So-called standard contractual clauses pursuant to Art. 46 GDPR have been concluded as suitable guarantees. Further information can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_de.

Deletion/revocation:
You can prevent participation in this tracking procedure in various ways:

  1. by adjusting your browser software settings accordingly; in particular, suppressing third-party cookies will result in you not receiving third-party ads;
  2. by installing the plug-in provided by Google at the following link: https://www.google.com/settings/ads/plugin;
  3. by disabling the interest-based ads of the providers that are part of the self-regulatory campaign "About Ads" at the link http://www.aboutads.info/choices; this setting will be deleted when you delete your cookies;
  4. by permanently disabling it in your Firefox, Internet Explorer or Google Chrome browsers at the link http://www.google.com/settings/ads/plugin,
  5. using the appropriate cookie setting. We point out that in this case, you may not be able to use all features of this offer in full.

13. YouTube Videos​

As soon as even a paused image of a video is displayed on our website, a communication link is created to the YouTube server by which the service receives various data. This data includes the IP address of your computer, any cookies, and information already stored on your computer that was stored during previous contacts with YouTube. If no data has been stored yet, the service stores cookies on your computer for the first time. For contact with YouTube, the service also receives notifications on a user account you may have with YouTube. Additional information on the interaction with the video such as clicking the start, pause, and end buttons is also transferred to the supplier. You can end the data processing by visiting a page that does not contain a video and deleting all cookies from your computer.

You can find more information on data processing and data processing information from YouTube at https://policies.google.com/privacy.

YouTube is represented by law through Google Inc. 1600 Amphitheatre Parkway Mountain View, CA 94043, USA.

14. Leadinfo​

We use the lead generation service of Leadinfo B.V., Rotterdam, Netherlands. This service recognizes visits by companies to our website based on IP addresses and shows us publicly available information, such as company names or addresses. In addition, Leadinfo sets two first-party cookies to evaluate user behavior on our website and processes domains from form entries (e.g. " leadinfo.com ") to correlate IP addresses with companies and improve the services. For more information, see https://www.leadinfo.com.

15. LinkedIn Analytics and LinkedIn Ads​

We use the conversion tracking technology on our website as well as the retargeting function of LinkedIn Corporation.

With the help of this technology, visitors to this website can be served personalized advertisements on LinkedIn. Furthermore, the possibility arises to create anonymous reports on the performance of the advertisements as well as information on website interaction. For this purpose, the LinkedIn Insight tag is embedded on this website, which establishes a connection to the LinkedIn server if you visit this website and are logged into your LinkedIn account at the same time.

In the privacy policy of LinkedIn under https://www.linkedin.com/legal/privacy-policy you can find more information about data collection and data use, as well as the options and rights to protect your privacy. If you are logged in to LinkedIn, you can deactivate the data collection at any time at the following link:
https://www.linkedin.com/psettings/enhanced-advertising.

16. Hotjar​

We use Hotjar to better understand the needs of our users and to optimize the services and experience on this website. Using Hotjar's technology, we get a better understanding of our user's experiences (e.g., how much time users spend on which pages, which links they click, what they like and don't like, etc.), and this helps us tailor our offerings to our users' feedback. Hotjar works with cookies and other technologies to collect data about our users' behavior and about their devices, in particular IP address of the device (collected and stored only in anonymized form during your website use), screen size, device type (Unique Device Identifiers), information about the browser used, location (country only), language preferred to view our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually prohibited from selling the data collected on our behalf.

For more information, see the 'About Hotjar' section on Hotjar's help page.

17. Newsletter and use of "MailChimp"​

Automated emails and the newsletter are sent via "MailChimp“, a newsletter service provider of the US provider The Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000 Atlanta, Georgia 30308, USA. The email addresses of contacts for automated emails, subscribers to our newsletter, and other personal data described in the context of this statement are stored on MailChimp's servers in the USA.

MailChimp will only process your personal data on our behalf for sending and evaluating the newsletters based on an order processing agreement.

Furthermore, MailChimp may, according to its own information, use this data to improve its own services. In this case, MailChimp is exclusively responsible for processing your personal data. For more information about data protection at MailChimp, please visit https://www.intuit.com/privacy/statement/.

Our automated emails, as well as the newsletter, contain a so-called "web beacon", i.e., a pixel-sized file that is retrieved from MailChimp's server when the automated emails and the newsletter are opened. As part of this retrieval, technical information (such as information about the browser and your system, your IP address, and the time of the retrieval, as well as the determination of whether and when the automated emails and the newsletter are opened and which links are clicked) is collected to technically improve the service.

18. Data protection contact​

The responsible entity for data processing as defined by Art. 4 GDPR is
anynines GmbH Science Park 2 66123 Saarbrücken Germany
Phone: +49 (0)681 – 30964190
Mail: mail@anynines.com

Statutory representative
Dipl.-Inf.(FH) Julian Fischer Science Park 2 66123 Saarbrücken Germany
Phone: +49 (0)681 - 30964190
Mail: mail@anynines.com

Data protection manager
Sicoda GmbH Peter Mühlemeier Rochusstraße 198 53123 Bonn Germany
Phone: +49 (0)228 - 28614060
Mail: dataprivacy@anynines.com

Contact Us
If you have any questions about this Privacy Policy, please contact us at: support@klutch.io.