- the actions in which we receive data from you
- how we process your data
- to whom we pass on data
- how you can enforce your rights
We secure all transmissions of information with TLS encryption to prevent data from being intercepted during transmission.
I. Contact Details
Controller data of the data processing in Cling and on our website in
the meaning of the General Data Protection Regulation (GDPR) is:
CEO: Andreas Hermann, Peter Romianowski
Phone: +49 30 76583284
Telefax: +49 30 76583339
E-Mail: firstname.lastname@example.org; email@example.com
II. General Information
The provision of Cling and this website requires the processing of various information. The scope of data processing depends on what functions you use.
When visiting our website you are not obliged to provide us with personal data. However, if the provision of this data is technically required for accessing Cling or our site, you will be unable to use our services in case of your refusal.
Neither as a visitor of our website nor of Cling are you subject to any automated decision-making according to Article 22 GDPR.
2. Lawfulness of processing of personal data
The following legal bases apply to the processing of personal data on this website.
|Reason for Data Processing||Legal basis in GDPR||Explanation|
|Performance of a contract or steps prior to entering into a contract||Art. 6 (1) b)||We process your data only to the extent necessary for the exercise and fulfilment of the rights and obligations arising from the user contract based on our terms and conditions.|
|Consent||Art. 6 (1) a)||We process your data if you have expressly consented to the type and scope of data processing. You can revoke your consent at any time with effect for the future. However, this does not affect processing carried out up to this point in time.|
|Legal Obligation||Art. 6 (1) c)||Your data will also be processed where this is necessary to fulfil German or European legal obligations.|
3. Erasure and storage of data
We delete data you stored in Cling at the latest 3 months after you have cancelled your access. Further personal data will be deleted as soon as the legal basis for its processing, such as a legal retention period, expires.
III. Procession of your Data
In order to technically provide Cling and our websites, it is necessary to process certain information. This processing begins when you visit our website as an unregistered visitor. The scope depends on what features of Cling or our website you are using. In the following we would like to explain which data we process depending on the functions used.
When using Cling or our website, your browser sends various information that we need to establish and maintain the connection to our servers. Among the data is your IP address, which we treat as personal data. In addition, the following data is collected:
- Date and time of visit
- URL retrieved (request URL)
- Method, Size, Status, Response Size
- Source/reference from which side you came (referer)
- Browser used (User Agent)
- Remote IP, server IP and request parameters
We store this data in so-called server log files. This data is not combined with any other data about you. The storage of log files including your IP address serves the legitimate interest of providing Cling and our website as well as preventing fraudulent use. Stored log files will be deleted after 30 days at the latest, unless longer storage is necessary, for example to prevent or clarify an attack on our website.
For technical reasons, so-called session and persistent cookies are used. A session cookie is necessary to establish and maintain a connection to our website. When you close your browser, this cookie is automatically deleted and is no longer stored on your hard drive. The persistent cookie we set does not contain any personal data. When you log on to Cling, it merely stores the information that a successful authentication has taken place. You can prevent the storage of cookies in your browser settings. However, in this case Cling can no longer be used while the website can still be used. You can check the storage period of cookies in your browser settings.
3. Content Delivery Networks
In the programming of Cling and our website we use libraries (e.g. jQuery), which facilitate the development. In order to integrate these libraries fast and stable worldwide, we use the Content Delivery Networks (CDN) of MaxCDN by NetDNA, LLC. and Google LLC. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). When you visit Cling or our website, your browser downloads the libraries you need. To do this, your browser connects to the respective CDN, which tells the operator that we are accessing content via your IP address.
The use of CDNs is done in the legitimate interest of a fast and stable
provision of Cling and our website worldwide. More information about the
data protection processes at MaxCDN and Google can be found at:
MaxCDN Legal Information: www.maxcdn.com/legal/#pp
4. Google Web Fonts
To display fonts in Cling and on our website we use so-called Web Fonts by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). When you visit Cling or our website, your browser loads the necessary web fonts to display all texts. To do this, your browser connects to Google, which tells Google you are accessing our content from your IP address.
The use of Google Fonts is in the legitimate interest of a uniform, fast
and appealing presentation of Cling and our website. If your browser
does not support Google Fonts or Web Fonts, a default font is used
instead. You can find more information about Google Web Fonts and data
protection processes at Google at:
Google Web Fonts API: fonts.google.com/
5. Usage analysis and tracking
We want to further improve the usability of Cling and our website. For this reason, we also collect data about your usage behavior with Google (Universal) Analytics and Google Optimize during your visit. Both tools are services from service from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (‘Google’).
In addition to your browser blocking all cookies, you can prevent Google from processing your data by downloading and installing the browser plug-in available at the following link: tools.google.com/dlpage/gaoptout?hl=en
The legal basis of data processing for analysis purposes is our legitimate interest in a statistical evaluation of your user behaviour in order to be able to continuously optimise and better market our website. The data processing for usage analysis takes place during your visit to our website and only up to the time of your effective objection.
Google Analytics is a web analysis service provided by Google. Google collects information about your use of our website (including your IP address) in the USA via a cookie, and stores this information. However, we only use Google Analytics with an anonymisation function in which the IP address is shortened by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area before it is transmitted. Only in exceptional cases will the full IP address be transmitted to Google in the US and only shortened there. Google analyses the information collected and sends us reports on the usage activities on our website and provides us with additional services for this purpose. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.
As an alternative to the browser plug-in or within browsers on mobile devices, you can set an opt-out cookie by clicking on the following link that prevents Google Analytics from collecting data on this website in the future (this opt-out cookie only works in this browser and only for this domain if you delete your cookies in this browser, you must click this link again): Disable Google Analytics
Google Optimize analyses the use of different variants of our website and helps us to improve usability in line with our users’ behaviour on the website. The collected data is anonymous. Google Optimize is integrated in Google Analytics.
6. Live-Chat and e-mail contact
Both when visiting our website and when using Cling, you can contact us at any time via live chat or e-mail. For this, we use the services of Intercom Inc. 55 2nd ST, 4th Floor, San Francisco, CA, 94105, USA ("Intercom"). We will send your name and e-mail address to Intercom. Intercom may supplement this information with other publicly available information about you, such as your address, employer, job title, photos, website addresses and profile information from social networks. You can find more information about the data protection processes of Intercom at: https://www.intercom.com/terms-and-policies#privacy
As an unregistered visitor to our website your data will be kept for 9 months after your inquiry and then automatically deleted. If you are a user of Cling, the data of your inquiry will only be deleted at the end of the user relationship. The legal basis of this processing is our legitimate interest in providing you with a convenient means of communication and contact with us. Insofar as further data processing and analysis of your usage behaviour takes place within the scope of the contact, our legitimate interest is to offer the most suitable assistance possible and to constantly improve our website and Cling.
7. E-Mail notifications
In certain situations (confirmation of registration, invitation when sharing content, changes to content you actively share, etc.) Cling sends automated notifications by e-mail. We use SendGrid, Inc. 1801 California Street, Denver, CO 80202, USA ("SendGrid") to send e-mails. SendGrid will receive your name, your e-mail address and, if required, the titles of your boards. The legal basis for this data processing is the execution of the Cling-user relationship concluded with the registration.
8. Registration and login
To use Cling, you must register user account first. Registration is possible via an existing account with Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google") or on the social media network Facebook of Facebook Inc. 1601 S. California Ave Palo Alto, CA 94304 USA ("Facebook").
If you select one of the two providers you will be redirected to their registration page, where you can log in with your user data. When you register, we store the following information from your profile: your gender, your name and your e-mail address. In addition, your IP address is stored during each login for authentication purposes. Each login to Cling once you have registered is done via your chosen account on Google or Facebook.
The legal basis for this data processing is the execution of the
Cling-user relationship concluded with the registration. For more
information on social media registration, privacy settings and the legal
basis for processing by the social media network, please refer to the
Terms of Service: www.google.com/intl/de/policies/terms/
Terms of Service: www.facebook.com/policies/?ref=pf
9. Cling and Website
We do not operate our own data center, but use the Google Cloud Platform for the provision of Cling and our website, which is one of the most proven secure infrastructures in the business. All of our services are provided from Google's European data center locations and the data you store in Cling does not leave the European Union. The legal basis for this data processing is the execution of the Cling-user relationship concluded with the registration.
IV. Data transfer and transmission
The processing of your personal data in Cling and on our website as described in section “III. Procession of your data" is in part carried out by data processors. These data processors are exclusively employed on the basis of an agreement in accordance with Art. 28 para. 3 GDPR.
In the case of Google, Facebook, SendGrid and Intercom, these data processors are located in a third country outside the European Economic Area. All of these contractors are certified under the “EU-US Privacy Shield” data protection agreement, which guarantees compliance with a European level of data protection.
V. Right to object and right to withdraw consent
If the data processing is based on your consent or our legitimate interest, you have the right to object to the processing or to revoke your consent at any time. Your objection or revocation only has an effect for the future. If the analysis cookies used offer their own technical possibilities for deactivation, this is shown there in each case. You can exercise your right of objection or revocation at any time at: firstname.lastname@example.org or email@example.com If you object to processing on the basis of our legitimate interest, we may nevertheless continue the processing if we can prove compelling reasons worthy of protection for the processing, which outweigh your interests and/or your rights and freedoms.
VI. Rights of data subjects
If your personal data is processed, you are a data subject within the meaning of Art. 4 para. 1 GDPR. As data subject, you have the following rights with regard to your personal data. To exercise these rights, please contact us using the contact details above.
Right of access by the data subject according to Art. 15
You have a right of access concerning your personal data processed by us. This includes the mandatory information set out in Art. 15 GDPR.
Right to rectification according to Art. 16 GDPR
You have the right to request the immediate correction of inaccurate personal data and the completion of incomplete personal data.
Right to erasure according to Art. 17 GDPR
You have the right to request the erasure of your personal data if one of the grounds mentioned in Art. 17 GDPR applies, in particular if there is no longer a legal basis for the processing.
Right to restriction of processing according to Art. 18
You have the right to request the restriction of the processing of your personal data if one of the grounds mentioned in Art. 18 GDPR applies, in particular at your request instead of deleting the data.
Right to data portability according to Art. 20 GDPR
You have the right to request all personal data stored by us about you in a structured, commonly used and machine-readable format or to transmit this data to another controller without obstruction by the controller to whom the personal data was made available.
Right to lodge a complaint with a supervisory authority according
to Art. 77 GDPR
According to Art. 77 GDPR, you have the right to file a complaint with the supervisory authority responsible for you.
Last updated: May 2018