Privacy Policy

 

1. General Provisions

1.1. This privacy policy (hereinafter – “Privacy Policy”) of the company Colobridge GmbH operating under the laws of Germany, located at the address: Scharfe La

1.1. This privacy policy (hereinafter – “Privacy Policy”) of the company Colobridge GmbH operating under the laws of Germany, located at the address: Scharfe Lanke 109-131, 13595, Berlin, Germany (hereinafter “Colobridge” “we”, “us”, or “our”) describes as to how we might collect, store, use and/or share (“process”) your personal information when you use the services provided by us under the mark “Beinf” (“Services”) or communicate with us to conclude the agreement, such as you:

  • visit our website at [website address], or any other our website that links to this Privacy Policy;

  • engage with us in other related ways: (i) through our Services; (ii) when you interact with us by means other than the website, for example, in person, by telephone, or e-mail; and (iii) from our customers, distributors, suppliers, vendors, and other business partners (collectively referred to as “Business Partners”).

1.2. Depending on the context, “you” shall mean End Customer, End User, Representative or Visitor:

  • When you directly use our Services as natural person (e.g., as independent entrepreneur) for your commercial activity, we refer to you as an “End User”.

  • When you do business with, or otherwise transact with our Business Partners but are not directly doing business with Colobridge, we refer to you as an “End Customer”.

  • When you are acting on behalf of an existing or potential Business Partner (e.g. you are a director of a company, contact person or any other authorized representative), we refer to you as a “Representative”.

  • When you visit our site or otherwise communicate with Colobridge, we refer to you as a “Visitor” (e.g. you send Colobridge a message asking for more information because you are considering being a user of our Services).

1.3. This Privacy Policy summarizes what personal information we may collect, how we may use this information, and other important topics relating to your privacy and data protection.

1.4. It is our policy to comply with all applicable privacy and data protection laws. This commitment reflects the value we place on earning and keeping the trust of our customers, Business Partners and others who share their personal information with us.

1.5. To the extent required by applicable law, whenever Colobridge collects personal information, we will:

  • provide timely and appropriate notice to you about our data practices;

  • collect your personal information only for specified and legitimate purposes. The information we collect will be relevant, adequate and not excessive for the purposes for which it is collected;

  • process your personal information in a manner consistent with the purposes for which it was originally collected or to which you have subsequently consented;

  • take commercially reasonable steps to ensure that your personal information is reliable for its intended use, accurate, complete, and, where necessary, kept up-to-date;

  • not use your personal information for direct marketing purposes without giving you an opportunity to “opt-out”;

  • take appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country, including transfers within Colobridge.

nke 109-131, 13595, Berlin, Germany (hereinafter “Colobridge” “we”, “us”, or “our”) describes as to how we might collect, store, use and/or share (“process”) your personal information when you use the services provided by us under the mark “Beinf” (“Services”) or communicate with us to conclude the agreement, such as you:

  • visit our website at [website address], or any other our website that links to this Privacy Policy;

  • engage with us in other related ways: (i) through our Services; (ii) when you interact with us by means other than the website, for example, in person, by telephone, or e-mail; and (iii) from our customers, distributors, suppliers, vendors, and other business partners (collectively referred to as “Business Partners”).

2. What personal information do we process?

2.1. We collect personal information that you as the Visitor or End User voluntary provide to us when you visit our website, express an interest in obtaining information about us or our products and Services, communicates with us in order to conclude an agreement or otherwise when you contact us.

2.2. Colobridge as a data processor can also process personal data of End Customers or Representatives received from our Business Partners in order to provide our Services to them. Such processing of personal data will be governed by this Privacy Policy and the agreement with our Business Partner being your data controller.

2.3. The personal information that we process depends on the context of your interaction with us or with our Business Partner, the Services, the choices you make, and the products and features you use. Colobridge collects the following types of personal information:

2.3.1. Information you provide.  Colobridge collects personal information that End Users and Visitors provide us, which may include:​

  • contact information, such as your name, company name, job title, address, e-mail address, and phone number;

  • additional information about you to help us get to know you better, such as your professional associations and registration numbers, information about how you use our products; 

  • comments, questions, requests and orders you may make;

  • log-in information, including, if applicable, social media account information for login purposes;

  • information about your preferences, such as your preferred methods of communication and product types in which you are interested.

2.3.2. Information automatically collected from your device.​

  • Device and browser information. Colobridge may collect technical information about your device, such as device type, browser type, IP address, operating system, and device identifier. Colobridge collects this information automatically from your device and web browser through cookies and similar technologies.

  • Information about how you interact with us. We may collect technical data about your usage of our website and how you interact with our digital advertisements and promotions, such as content viewed or downloaded, features used, links clicked, promotional emails opened, and dates and times of interactions. Colobridge collects this information using cookies and similar technologies.

  • Cookies and Similar Technologies. A "cookie" is a file of information placed on your device when you visit a website. Cookies and similar technologies can enhance your user experience by saving your preferences, personalizing your online experience, holding items in your shopping cart, and sometimes providing you with advertising which is tailored to your interests.

Certain countries require your consent to the use of cookies when you visit our website. If you access the website for one of these countries, you will be presented with information regarding your options, including the option to accept or reject certain categories of cookies. 

2.3.3. Information from Business Partners and other third parties.

Colobridge may receive the personal data of End Customers and Representatives from Business Partners or collect such personal data on behalf of our Business Partners in order to conclude and perform our transaction with Business Partner. When we are acting as a Business Partner’s service provider (including as data processor), we will process personal data in accordance with the terms of our agreement with the Business Partner and the Business Partner’s lawful instructions. Business Partners are responsible for making sure that their End Customer’s and Representatives privacy rights are respected, including ensuring appropriate disclosures about data collection and use that happens in connection with their services. If you are an End Customer or Representative of our Business Partner (e.g., a purchaser of a products or services at the Business Partner’s site), please refer to the privacy policy or notice of the Business Partner for information regarding the Business Partner’s privacy practices, choices and controls, or contact the Business Partner directly.

 

2.4. Colobridge as a data controller does not collect or process any sensitive information.

 

3. How Colobridge uses and shares your personal data?

3.1. Colobridge may use your personal information to:

3.1.1. Develop and manage our relationships with you and our Business Partners. This may include: (i) delivering services or carrying out transactions that End Users or our Business Partners have requested; (ii) providing information about Colobridge products, Services, and transactions, and advertisements, that may be of interest to you; (iii) providing you and our Business Partners a more consistent experience in interacting with Colobridge or with Business Partners, including by learning more about you and how you use and interact with websites, products, and services; and (iv) planning, managing, and performing under our contractual relationships you or with our Business Partners.

3.1.2. Communicate with you or your company. This may include: (i) informing you of Colobridge products, services, and promotional activities that may be of interest to you or your company; (ii) providing information about relevant products, services, and transactions, including, for example, pricing information, technical data, invoice, or information about product or service improvements; (iii) responding to questions or inquiries that you make; and (iv) inviting you to participate in, or informing you of the results of, customer satisfaction or market research surveys.

3.1.3. Provide and improve our websites, products, and services. This may include: (i) customizing them to your preferences or interests, making them more compatible with your technology, or otherwise making them easier to use; (ii) maintaining the security of and otherwise protecting them; and (iii) and developing new sites, products and Services of Colobridge.

3.1.4. Address legal issues. This may include: (i) complying with our obligations set forth by law (e.g. keeping certain business records for minimum retention periods; tax payments; accounting issues etc); (ii) establishing, exercising, or defending legal claims; (iii) complying with laws, regulations, court decisions, or other legal process; (iv) detecting, preventing, and responding to fraud, intellectual property infringement, violation of our contracts or agreements, violations of law, or other misuse of our sites, products or services; and (v) protecting Colobridge’s rights or property, or yours or others’ health, safety, welfare, rights, or property.

3.2. Colobridge may also use your personal information for other uses consistent with the context in which the information was collected or received or with your consent.

3.3. Colobridge may anonymize or aggregate any of the information we collect and use it for any purpose, including for research and product-development purposes. Such information will not identify you individually and shall not be treated as personal data.

3.4. Colobridge shall not disclose your personal information except as follows:

3.4.1. We can share your personal data with our service provider or subcontractors in order to receive services which are required for provision of our Services to you or to our Business Partners. These service providers or subcontractors are required to use the personal information we share with them only to perform services on our behalf and to treat your personal information in compliance with all applicable privacy and data protection laws.

3.4.2. Colobridge may share your information with your permission or at your request.

3.4.3. We may share your personal data with third parties in order to comply with our legal or contractual obligations, e.g. upon request of empowered state authorities, for making payments or for tax purposes etc, or in order to protect our rights, legal interests or property.

3.4.4. Colobridge as a service provider (including as data processor) may share personal information of End Customers or Representatives according to lawful instructions of the Business Partner as indicated in the agreement between us and our Business Partner. For more information in this respect please see the Business Partner’s privacy policy.

3.4.5. Colobridge may share your personal information with other our entities, including those in different countries. When we do so, these other Colobridge entities will use your information in a manner consistent with this Policy, and all applicable privacy and data protection laws.

3.5. Colobridge may share anonymized or aggregated information internally and with third parties for any purpose. Such information will not identify you individually and shall not be considered as your personal data.

 

4. Security and term of retention

4.1. We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of your personal data. We maintain organizational, technical and administrative measures designed to protect personal data covered by this policy against unauthorized access, destruction, loss, alteration or misuse. Personal data is only accessed by a limited number of personnel who need access to the information to perform their duties.

4.2. Personal information of End Users, Visitors and Representatives will generally be stored in our databases or databases maintained by our service providers. Many of these databases are stored on servers located in Germany, the USA as well as on cloud services, including but not limited to Google Cloud. The storage of the personal data of End Customers depends on the agreement with respective Business Partner and lawful instruction of Business Partner being your data controller.

4.3. Colobridge takes appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country, including transfers within Colobridge. For transfers to third countries, we have entered into Standard Contractual Clauses, approved by the European Commission, to ensure an adequate level of protection for the transfer of your Personal Data to those entities outside the EEA.

4.4. Although we use security measures to help protect your personal information against unauthorized disclosure, misuse, or alteration, as is the case with all computer networks linked to the Internet, we cannot guarantee the security of information provided over the Internet and will not be responsible for breaches of security beyond our reasonable control.

4.5. How long we keep your personal information will vary and will depend on the purpose and use of information collected. There are legal requirements that we keep some types of data for specific periods. Otherwise, we will retain it for no longer than is necessary for the purposes for which the data was collected.

4.6. To determine the period for which your personal data will be retained in accordance with this Policy, Colobridge considers the following criteria:

  • any applicable legal requirements to retain data for a certain period of time; 

  • any retention obligations related to actual or potential litigation or government investigations;

  • any retention requirements in relevant agreements with our Business Partners;

  • achieving goals and purposes for which the data have been collected;

  • date of your or your Company’s last interaction with Colobridge;

  • the sensitivity of the data.

 

5. Legal basis for processing of personal information

5.1. The lawful basis for processing of your personal data will depend on the purposes of the processing.

5.2. Contractual or pre-contractual business relationships.

Where we process personal data of Visitors or End Users in relation to a contract, or a potential contract, with you, the lawful basis is that the processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract.

5.3. Legitimate business interests. 

Where allowed under applicable law, we rely on our legitimate business interests to process your personal data. The following list sets out the business purposes for which we have a legitimate interest in processing your data:

  • providing, improving, and promoting our sites, products, and Services;

  • manage, operate and improve the performance of our sites and Services by understanding their effectiveness and optimizing our digital assets;

  • communicating with current and potential customers, other Business Partners, and their individual points of contact;

  • analyze and advertise our Services;

  • conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business;

  • sharing information within the Colobridge group, as well as with service providers and other third parties;

  • maintaining the safety and security of our products, services and employees, including fraud protection.

5.4. Personal data processing consent.

We will also use consent as the legal basis where we deem appropriate or to the extent required by applicable law, for example, before we collect precise location data from your device. We can also process your personal data based on your consent, if any other legal basis cannot be applicable to the purposes of processing.

When we process data based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn.

5.5. Processing because Colobridge is under a legal obligation to do so.

 Colobridge may have the obligations set forth by applicable laws and for performance of such obligations the processing of your data may be required.  Examples of situations in which Colobridge must processes personal data to comply with its legal obligations include:

  • payment of taxes and other government levies;

  • providing your personal data to law enforcement agencies and other governmental bodies when required by applicable laws;

  • retaining business records (including accounting or tax records) required to be retained by applicable laws;

  • complying with court decisions or other legal processes etc.

 

6. Your rights as a data subject

6.1. Depending on your location and subject to applicable laws, you as a data subject may have the right related to processing of your personal data. According to the laws of European Union you have the following rights which are adhered to by Colobridge:

6.1.1. Right of access. You have the right to ask Colobridge to confirm whether we process your personal data. If we do, you have the right to request access to your personal data that we process and the following information:

  • the purposes of the processing;

  • the categories of personal data we process;

  • the recipients or categories of recipients of your personal data; 

  • the envisaged retention period of the data where possible, or the criteria we use to determine the retention period;

  • your right to request rectification or erasure of your personal data, or restriction of the processing of such data;

  • your right to file a complaint with a supervisory authority;

  • if we have not collected the data from you, any information we have available about the source of the data;

  • whether we use your personal data to make any automated decisions that have legal or other similar significant effects on you.

You may review, correct and update personal information you provide to us by writing to us at:

Colobridge GmbH

Scharfe Lanke 109-131

13595, Berlin, Germany

6.1.2. Right to rectification. You have the right to obtain from Colobridge without undue delay the rectification of your inaccurate personal data. Taking into account the purposes of the processing, the you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

6.1.3. Right to erasure. The right to erasure is also called the “right to be forgotten.” You may ask Colobridge to delete your personal data. Please note that this right not absolute. Pursuant to the laws, Colobridge is required to delete your personal data upon your request only in the following circumstances: 

  • your personal data is no longer necessary for the purposes for which we collected or processed them;

  • if Colobridge processes your personal data on the basis of consent, you withdraw your consent, and no other legal ground exists for us to continue processing your personal data;

  • if Colobridge processes your personal data for its legitimate business interests, you object to the processing, and there are no overriding legitimate grounds for us to continue processing your personal data;

  • if Colobridge has processed your personal data unlawfully; or 

  • he personal data must be erased to comply with a legal obligation under European Union or Member State law to which Colobridge is subject.

We are not required to erase your personal data to the extent that Colobridge needs to process them to:​

  • exercise its right of freedom of expression and information;

  • comply with a legal obligation under European Union or Member State law to which Colobridge is subject; or

  • to establish, exercise, or defend a legal claim.

6.1.4. Right to restriction of processing. You have the right to request that Colobridge restrict the processing your personal data in the following circumstances:​

  • for the period of time Colobridge needs to verify the accuracy of your personal data when you contest its accuracy;

  • when the processing of your personal data is unlawful and you oppose the erasure of the data, and instead request that we restrict the use of the data; 

  • when Colobridge no longer needs your personal data for the purposes of processing, but you need the data to establish, exercise, or defend a legal claim; or

  • or the period of time Colobridge needs to verify if it has compelling legitimate grounds for processing that override your interests, rights, and freedoms when you object to the processing of your personal data for Colobridge’s legitimate business interests.

6.1.5. Right to data portability. You have the right to receive personal data which you provided to Colobridge when:​

  • the processing of the data is based on your consent or is necessary for the performance of a contract between you and Colobridge;

  • processing of your personal data is carried out by automated means; and

  • complying with your request will not adversely affect the rights and freedoms of others.

6.1.6. Right to object. You have the right to object to processing of your personal data by Colobridge when such data are proceed based on the legitimate business interests of Colobridge. We will no longer process your personal data unless Colobridge demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. 
​If Colobridge processes your personal data for direct marketing purposes, you have the right to object to this processing. If you exercise this right, Colobridge will stop processing your personal data for direct marketing purposes.

6.1.7. Right to lodge a complaint with a supervisory authority. Colobridge will use its best efforts to address and settle any requests or complaints brought to its attention. In addition, you have the right to approach the competent data protection authority with requests or complaints. This can be the supervisory authority in the country or federal state where you live. The overall competent supervisory authority for Colobridge in Europe is:

Berlin Commissioner for Data Protection and Freedom of Information (BlnBDI)

Friedrichstr. 219, 10969 Berlin

Telephone: +49 30 13889-0

Fax: +49 30 2155050

E-Mail: 

 

7. Changes to this Privacy Policy

7.1. We may change this Privacy Policy from time to time to reflect new services, changes in our privacy practices or relevant laws. The “Last updated” legend at the top of this Privacy Policy indicates when this Policy was last revised. 

7.2. Changes to this Privacy Policy will be posted on this site, along with information on any material changes. Colobridge reserves the right to update or modify this Privacy Policy at any time and without prior notice. Any modifications will apply only to the personal information we collect after the posting.