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Privacy Policy

Feel free to read all of our data policy, but to keep it simple:

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your data is safe with us, we won’t and are not selling it to anyone

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we are using EU servers

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the conversations are recorded in order to improve your experience

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but we do not listen to your calls

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on request, we can delete all of your data

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Intro

In the following, we will inform you about the processing of your personal data by us and the claims and rights to which you are entitled under data protection regulations, in particular the European General Data Protection Regulation (GDPR).

This data protection information explains to you the type, scope and purpose of the processing of personal data by us.

​Personal data within the meaning of the GDPR are all data that can be related to you personally, e.g. B. Name, address, email addresses, user behavior. Which data is processed in detail and how it is used depends largely on the services we use.

​In our data protection information, we use various other terms within the meaning of GDPR. This includes terms such as processing, restriction of processing, profiling, pseudonymisation, person responsible, processor, recipient, third party, consent, supervisory authority and international organization. Art. 4 GDPR you can find the corresponding definitions for these terms.

1. Who is responsible for data processing and who can I contact?

Responsible person:

​Emilia Theye & Celina Messner
Auguststrasse 47
10119 Berlin

2. Which sources and data do we use?

We process personal data that we receive from you when you use our website and, if applicable, our business relationship.

When using the website for purely informational purposes, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server. When you visit our website, we collect the following access data, which is technically necessary for us to display our website to you and to ensure stability and security. The access data includes the IP address, date and time of the request, time zone difference to Greenwich Mean Time (GMT), content of the request (i.e. name of the specific website accessed), access status / HTTP status code, respectively transmitted Amount of data, referrer URL (previously visited page), operating system and its interface, language and version as well as type of browser software, notification of successful access.

We will also receive your personal data if you contact us using the contact form or email. Personal data are e.g. name, address, e-mail, telephone number and, if applicable, the data that you send us as a message (hereinafter referred to as "contact details").

3. What do we process your data for (purpose of processing) and on what legal basis?

We process personal data in accordance with the provisions of the European General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG) for the following purposes and on the basis of the following legal bases:

​Purposes:

1. Insofar as you have given us your consent to the processing of personal data for certain purposes, in particular to establish contact (e.g. via our contact form or by e-mail to process and process the request, send newsletters, address advertising via Telephone, e-mail, SMS etc.), the legality of this processing is given on the basis of your consent.

Consent given can be withdrawn at any time. Please note that the revocation will only take effect in the future. Processing that took place before the revocation is therefore not affected by the revocation. The revocation can be made to the above contact details or to feedback@clareandme.com.

Legal basis: Consent, Art. 6 Para. 1a GDPR

2. When you contact us (using the contact form or email), your details will be processed on the basis of pre-contractual measures, Art. 6 Para , processed.

Legal basis: Implementation of pre-contractual measures at the request of the person, Art. 6 Para. 1b GDPR

3. When you contact us (using the contact form or e-mail) in connection with your application, we process your data in order to check your suitability for the position (or other open positions in our company, if applicable) and to carry out the application process . Your applicant data will be viewed by the HR department upon receipt of your application. Suitable applications are then forwarded internally to the department heads for the respective open position. A decision is then made there about the further course of action. In principle, only those persons in the company have access to your data who need it for the proper flow of our application process.

Legal basis: Establishment of an employment relationship, 26 BDSG and after completion of the application process in the event of rejection to safeguard legitimate interests, Art. 6 Para. 1f GDPR (defense against claims), if necessary, if consent has been given, Art. 6 Para. 1a GDPR

4. We process your access data (see data listed above under point 2) to safeguard our legitimate interests or those of third parties. In particular, we pursue the following legitimate interests:

Legal basis: As part of the balancing of interests to safeguard legitimate interests, Art. 6 Paragraph 1f GDPR

4. Who will get my data?

Within the company, those departments have access to your data that need it to fulfill our contractual, ensuring basic product functionality and legal obligations.

Processors employed by us (Art. 28 GDPR) can also receive data for the above-mentioned purposes. These are companies in the categories of IT services, logistics, printing services, telecommunications, debt collection, advice and consulting, as well as sales and marketing. If we use contract processors to provide our services, we take suitable legal precautions as well as appropriate technical and organizational measures to ensure the protection of personal data in accordance with the relevant legal regulations.

A transfer of data to third parties only takes place within the framework of the legal requirements. We only pass on user data to third parties if this is necessary, for example, on the basis of Art. 6 Paragraph 1 lit. b) GDPR for contractual purposes or on the basis of legitimate interests in accordance with Art. 6 Paragraph 1 lit.f.DS-GVO in an economical and effective operation of our business operations or you have consented to the data transfer. When using the website for informational purposes only, we generally do not pass on any data to third parties.​

5. How long will my data be stored?

For security reasons (e.g. to investigate acts of abuse or fraud), log file information is stored for a maximum of seven days and then deleted (see point 2 above). Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.

If necessary, we process and store your personal data for the duration of our business relationship, which also includes, for example, the initiation and processing of a contract via the contact form or by email.

In the event of rejection, applicant data will be deleted after 6 months. In the event that you have consented to your personal data being stored further, we will transfer your data to our applicant pool. The data will be deleted there if you revoke your consent or after 5 years at the latest. If we fill the advertised position with you, your data will be saved in our personnel management system.

In addition, we are subject to various retention and documentation obligations, which result from the Commercial Code (HGB) and the Tax Code (AO), among others. The periods for storage and documentation specified there are two to ten years.

Finally, the storage period is also assessed according to the statutory limitation periods, which, for example, according to 195 ff. Of the German Civil Code (BGB) can usually be 3 years, but in certain cases also up to thirty years, whereby the regular limitation period is three years.

​6. Will data be transferred to a third country or to an international organization?

A data transfer to third countries (countries outside the European Union - EU) does not take place.

7. What data protection rights do I have?

Every data subject has:

You can also revoke your consent, generally with future effect.

In addition, there is a right of appeal to a data protection supervisory authority (Art. 77 GDPR in conjunction with 19 BDSG). You can find the supervisory authority responsible for you at the Bfdi website.‍

In addition, we would like to point out your right of objection according to Art 21 GDPR:

Information about your right of objection according to Art. 21 GDPR
You have the right, for reasons that arise from your particular situation, to object at any time to the processing of personal data concerning you which is based on Article 6 (1) (e) GDPR (data processing in the public interest) and Article 6 (1) (f) the General Data Protection Regulation (data processing on the basis of a balance of interests) takes place, to lodge an objection; This also applies to profiling based on this provision within the meaning of Article 4 No. 4 GDPR, which we use to evaluate questionnaires or for advertising purposes.

If you object, we will no longer process your personal data, unless we can prove compelling legitimate reasons for the processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or Defense of legal claims.

In individual cases we process your personal data in order to operate direct mail. You have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct mail. If you object to processing for direct marketing purposes, we will no longer process your personal data for these purposes.

The objection can be made informally and there are no costs other than the transmission costs according to the basic tariffs.


If possible, the objection should be sent to:
Email to: feedback@clareandme.com

8. To what extent is there automated decision-making in individual cases, including profiling?

When accessing our website or when contacting us by form or email, we generally do not use fully automated decision-making in accordance with Article 22 GDPR. If we use this procedure in individual cases, we will inform you about this separately, provided this is required by law. We do not process your data automatically with the aim of evaluating certain personal aspects (profiling).

9. Do I have an obligation to provide data?

As part of our website, you must provide the personal data that is required for technical or IT security reasons to use our website. If you do not provide the aforementioned data, you cannot use our website.

When contacting us by form or email, you only need to provide the personal data that is necessary to process your request. Otherwise we cannot process your request.

10. Newsletter

With the following information we will inform you about our newsletter as well as the registration, dispatch and evaluation procedures as well as clarify your rights of objection. If you subscribe to our newsletter, you agree to receive the newsletter and the procedures described.

Newsletter content: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter "newsletter") only on the basis of the consent of the recipient or on the basis of legal permission. If we specifically describe individual newsletters as part of the registration, this description is decisive for the consent of a newsletter customer. If there is no separate description, you will receive information about our products, offers and promotions as well as information about our company in our newsletters.

Double opt-in: The registration for our newsletter takes place in the so-called double opt-in procedure. I.e. after registering for the newsletter, we will send you an email in which we ask you to confirm your registration. This confirmation serves to ensure that only people who also have access to the specified email address register for our newsletter. We log the registrations for the newsletter in order to be able to prove the registration process in accordance with the legal requirements. This includes saving the time of registration and confirmation, as well as the IP address. Changes to your data stored by the newsletter service provider are also logged.

The newsletter is sent via MailChimp, a newsletter distribution platform of the Rocket Science Group, LLC, 675 Ponce De Leon Ave NE # 5000, Atlanta, GA 30308, USA. You can view the data protection provisions of the newsletter service provider here. MailChimp is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with the European level of data protection‍

According to its own information, the newsletter service provider uses the data in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services. However, the newsletter service provider does not use the data of our newsletter recipients to write them down or to pass them on to third parties.

To register for the newsletter, it is sufficient to provide your email address. Optionally, we ask you to give a name so that we can address you personally in the newsletter.

The newsletters contain a so-called web beacon, i.e. a pixel-sized file that is retrieved from the newsletter service provider's server when the newsletter is opened. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, are initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked.

For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our aim nor that of the shipping service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The dispatch of the newsletter and the measurement of success take place on the basis of the consent of the recipient in accordance with Art. 6 Paragraph 1a, Art. 7 GDPR in conjunction with 7 Paragraph 2 No. 3 UWG or on the basis of legal permission in accordance with 7 Paragraph 3 UWG .

The logging of the registration process is based on our legitimate interests in accordance with Article 6 Paragraph 1f GDPR and serves as proof of consent to receive the newsletter.

You can unsubscribe from our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. If the users have only registered for the newsletter and canceled this registration, their personal data will be deleted.

11. Cookies

We use cookies on our website. Cookies are small text files that usually consist of letters and numbers and are stored on the user's computer when certain Internet pages are visited.

Some of these cookies are essential for the functioning of our website, while other cookies help us to improve our website by providing insights into how you use the website.

By default, we only use necessary cookies. Necessary cookies enable the core functionality of our website. The website cannot be displayed correctly without these cookies or individual areas may not function properly. Necessary cookies can only be prevented by making the appropriate settings in your browser.

We only use cookies that are not necessary for the website to function ("non-necessary cookies") if you have given your consent via our cookie banner. You can return to our data protection information at any time and revoke your consent or make changes.

The following additional options exist with regard to cookies:

If you do not want cookies to be stored on your computer, you can deactivate the corresponding option in the system settings of your browser. Saved cookies can be deleted in the system settings of the browser. Please note that deactivating cookies can restrict the functionality of this website.

You can use cookies for website tracking and advertising purposes via the network advertising initiative or the American website or the European web page.

​12. Google Analytics

On the basis of our legitimate interests, i.e. our interest in the analysis and optimization of our website, we use the web analysis service Google Analytics from Google Inc. ("Google"). The web analysis service Google Analytics uses cookies. The information generated by the cookies about the use of our website is usually transmitted to a Google server in the USA and stored there. Google is certified in accordance with the EU-US Privacy Shield Agreement and thus guarantees compliance with European data protection law (https://www.privacyshield.gov).

Google will use this information on our behalf to evaluate the use of our website by our users, to compile reports on the activities within this website and to provide us with other services related to the use of this website . In doing so, pseudonymous usage profiles can be created from the processed data.
We use Google Analytics with activated IP anonymization. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. The full IP address will only be sent to a Google server in the USA and shortened there in exceptional cases.

The IP address transmitted by the user's browser will not be merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; In addition, users can prevent the collection of the cookies generated by the cookie and the transmission to Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link.
Further information on data processing by Google, setting and objection options can be found on the Google website.

13. Social media

You can find us with a presence on social networks and platforms so that we can communicate with you there and inform you about our services. We would like to point out that your data can be processed outside of the European Union and that the data is usually processed there for market research and advertising purposes. Usage profiles can be created from the usage behavior and the resulting interests of the users. These usage profiles can in turn be used, for example, to place advertisements inside and outside the platforms that presumably correspond to the interests of the users. For this purpose, cookies may be stored on the users' computers, in which the usage behavior and the interests of the users are stored. Other data can also be stored in these usage profiles, in particular if the users are members of the respective platforms and are logged in to them.

The processing of the users' personal data takes place on the basis of our legitimate interests in the broadest possible communication with our users in accordance with Art. 6 Para. 1 lit. f GDPR. If the respective social networks obtain consent for the data processing, the legal basis for the processing is Article 6 (1) (a) GDPR. For information about the respective processing and the respective possibilities of objection, we refer to the data protection information of the providers linked below:

Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland)

Facebook pages based on an agreement on the joint processing of personal data - data protection information:

https://www.facebook.com/about/privacy, Opt-Out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com,

Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC& status=Active.

Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) - data protection information / opt-out: http://instagram.com/about/legal/privacy/.

In the case of requests for information and the assertion of user rights, we recommend that these are asserted directly with the providers, as the providers have direct access to the data. Should you still need support, please feel free to use the contact details given above.

This website uses cookies. We use cookies to analyze visits to this website, to optimize content, to personalize advertisements and to be able to offer functions for social media. Data collected about the use of our website can be passed on to our partners for social media, advertising and analysis.

14. App

In order to provide the full service of the app, by using the app you agree that we can contact you over the phone.
To improve our product, we randomly analyze transcripts from calls with Clare & me. Transcripts are only used to improve Clare & me's offering.

We use Adalo, Zapier and Twilio for the current prototype. By downloading the app, you agree to the data protection guidelines of these three third-party providers. To find out more about the Terms of Conditions, go to: https://app.adalo.com/signup/terms,
https://www.twilio.com/legal/tos and https://zapier.com/tos.

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