ClinLife website privacy policy
On this page, we inform you about which personal data is processed when you use this website, ClinLife and its offers, by Clariness GmbH, Schillerstr. 44, 22767 Hamburg, and for what purposes this data is used when you
- visit the ClinLife website (see section 2.1 below)
- complete an online questionnaire (online pre-screening) (see section 2.2 below)
- request participation in a study (see section 3. below)
- consent to being contacted and to the transmission of information outside of a request to participate in a study (section 4.)
- participate in a survey (see section 5.)
- consent to the sending of information on current studies (“newsletter”) (see section 6.)
- use the comment function (see section 7.)
Furthermore, you will be informed about
- the use of cookies and other technologies (see section 8. below)
- the transmission and disclosure of data to other recipients (see section 9. below)
- your rights and the right of withdrawal in detail (see sections 10. and 11. below)
- contact details for the data controller and the data protection officer (see section 12. below)
- contact details for the supervisory authority (see section 13. below)
- the rights of individuals who are not located in the EU (see section 16. below)
Your data will be processed in accordance with the data protection regulations of the current version of Regulation (EU) 2016/679 (General Data Protection Regulation – “GDPR”).
Clariness GmbH will be referred to as “Clariness”. The website ClinLife operated by Clariness will be referred to as “ClinLife”.
1. Who is responsible for processing your data?
The responsible body for processing personal data within the meaning of Article 4 (7) of the GDPR is:
Clariness GmbH, Schillerstraße 44, 22767 Hamburg
Commercial register: Hamburg District Court HRB 108294
Managing director : Michael Stadler
VAT registration number : DE248331129
In order to enable users to request participation in a study via ClinLife (see section 3. below), Clariness works closely with sponsors of clinical studies and the relevant study center(s) at which the respective study is conducted. The aim of requests for study participation is to identify suitable applicants for a study financed by the sponsor.
Notwithstanding the fact that the data collected is never disclosed to the sponsor and that the sponsor never has access to it, the joint interest of the sponsor and Clariness in identifying suitable study participants establishes a joint responsibility (within the meaning of Article 26 of the GDPR) between Clariness and the sponsor. The joint responsibility is limited to the processing that takes place in the context of the request to participate in the study (see section 3 below), with the sponsor's co-responsibility being limited to the sponsor setting the occasion for the collection of user data in the context of a request for a study. Otherwise, Clariness is solely responsible for processing on ClinLife.
Further information is provided on the respective study page as part of the respective study description via a link provided. The user can also request the essential content of the agreements made between Clariness and the sponsor within the framework of joint responsibility (Article 26 (2) sentence 2 GDPR) from Clariness using the contact details provided in section 12. Clariness is solely responsible for the processing of all other processing operations not covered by section 3.
2. Data protection information for visitors to ClinLife
2.1 Provision of ClinLife through Clariness
Each time ClinLife is accessed, the Clariness or hosting provider servers automatically store various data about the accessing system (“server log files”).
2.1.1 Description and scope of data processing
The following data is collected:
- date and time of access to ClinLife
- website from which the user accesses ClinLife (e.g. previous website, hyperlink or similar)
- websites accessed by the user via ClinLife
- the access status (file transferred, file not found)
- the amount of data sent by the user
- the operating system used by the user
- the browser used by the user, including the browser version used
- the internet service provider used by the user
- the IP address that the Internet service provider assigns to the user's computer when connecting to the Internet.
The data is stored temporarily in log files. This data is not stored together with other personal data of the user.
Furthermore, Clariness reserves the right to anonymize the collected data in order to use it for statistical evaluations without personal reference.
2.1.2 Purpose of data processing
Clariness uses the data described in Section 2.1.1 to make ClinLife accessible, to identify and correct any technical problems that may arise, and to prevent and, if necessary, prosecute any misuse of the Clariness service on ClinLife. The processing of data in anonymized form is for statistical purposes and to improve ClinLife.
2.1.3 Duration of storage
The stored data will be deleted or anonymized after 30 days at the latest, i.e. any personal reference will be removed.
2.1.4 Legal basis of data processing
The legal basis for the processing of the user's personal data as described in Section 2.1.1 is Article 6 (1) (f) of the GDPR. Clariness's legitimate interest is that by processing the data, Clariness can make ClinLife accessible to the user and improve the services. Anonymization in advance of statistical evaluations is carried out in order to take into account the principle of data minimization in accordance with Article 5 (1) (c) of the GDPR.
2.1.5 Right of objection and removal
As the collection of data for the provision of ClinLife and the storage of data in log files are absolutely necessary for the operation of ClinLife by Clariness, there is no possibility for the user of ClinLife to object to the processing of the data.
2.2. Data protection information for answering an online questionnaire (hereinafter: "online pre-screening")
2.2.1 What are the aims of online pre-screening?
The data collected during online pre-screening is used to check whether the inclusion criteria for a study have been met based on the information provided by the user. It is not the aim of online pre-screening to make a diagnosis or to replace or influence a specific medical treatment.
2.2.2 What measures are taken to protect confidentiality?
Clariness enriches the data collected from the user with an automatically generated study-related or indication-related internal identifier. This identifier is used to assign the data collected from the user to a specific study or indication (e.g. migraine) and thus to prepare for the check of the fulfillment of the relevant online pre-screening inclusion criteria. Inferences to the person of the user are theoretically possible using the IP address transmitted by the user's browser and thus not completely excluded. However, this is associated with a great deal of technical effort and is by no means intended.
2.2.3 What data is collected?
Which data are collected in individual cases depends on the respective indication or study and the information provided by the user. The online pre-screening is aimed exclusively at querying data that is considered relevant for the online pre-screening decision.
2.2.4 What further processing of the data takes place?
As soon as the user has answered all the questions in the online pre-screening and clicked on the “Next” button, the information provided by the user is analyzed. The user is then informed whether or not he meets the inclusion criteria.
If the online pre-screening shows that the user does not meet the inclusion criteria, the user will receive a message stating that he or she is not suitable for this study. In this case, his or her data will be stored without personal reference and processed only for statistical purposes, as described in Section 2.2.5. below.
If the online pre-screening shows that the user meets the inclusion criteria, he is given the opportunity to select a study center, enter his contact details in the input mask and give his consent to the data processing for the purpose of requesting study participation (see section 3). Otherwise, the user's information will be processed without personal reference for statistical purposes, as described in Section 2.2.5 below.
2.2.5 Processing data for statistical analysis
Clariness processes the data collected from the user without personal reference for statistical evaluations to obtain information about the use of the online pre-screening questionnaire (e.g. to determine dropout rates).
3. Data protection information for inquiries regarding study participation
The request is made when the user voluntarily grants the requested consent (see Section 2.2.4) and, if necessary, provides the additional data requested by Clariness.
3.1 What are the objectives of processing the data in the context of a request to participate in a study?
The purpose of the processing is to establish contact between the study center and the user. The extent of the data processing is based on the consent given by the user. In order to establish contact, it is necessary for Clariness to disclose the user data collected and specified in the consent to the selected study center. Before disclosing this data to the study center, however, it may be useful or even necessary for Clariness to contact the user in order to collect further study-relevant information from the user (e.g. suggestion of another study center, additional inquiries regarding further inclusion/exclusion criteria). Furthermore, Clariness supports the study center selected by the user in contacting the user.
3.2 Storage and deletion of the user's personal data
Clariness stores the user's personal data for the duration specified in the consent or until the consent is revoked. With regard to the handling of data after revocation, please refer to sections 10. and 11.
3.3 Processing of personal data by persons other than Clariness and possibly in a third country?
Apart from the study center and the service providers described in Section 9.1 the user's personal data will not be passed on to other recipients.
3.4 Anonymization of data for statistical analysis
Clariness anonymizes the personal data provided by the user for further processing without personal reference in order to carry out statistical evaluations.
3.5 Miscellaneous
Please refer to sections 10. and 11. for information on the right to revoke consent to data processing and for further information.
3.6 Legal basis for data processing
The legal basis for the data processing described in this section 3 is the consent of the user (Article 9 (2) (a) and Article 6 (1) (a) GDPR). In the event of revocation of consent, the storage of the formerly granted consent together with the revocation, for verification and documentation purposes for a period of up to three years due to legitimate interest in accordance with Article 6 (1) (f) of the GDPR.
The data protection obligations between Clariness and the sponsor are set out in a separate agreement in accordance with Art. 26 of the GDPR. Further details can be found in Section 1 of this data protection declaration and on the respective study page describing the study in question.
4. Data protection information in the event of contact being made and transmission of information outside of a request to participate in a study
Clariness offers users the opportunity to contact them and provide them with information outside of a request to participate in a study. Clariness provides information below about the data processing that takes place in this context.
4.1 What are the objectives of processing the user's data other than the request to participate in the study?
If the user chooses, Clariness provides information about alternative studies and other programs that relate to the indications specified by the user (e.g. events on topics that are potentially relevant to the user, patient surveys).
4.2 How is the data processed?
To fulfill the aforementioned objectives, Clariness uses the user's data to contact the user accordingly. Apart from the service providers described in Section 9.1 the user's data will not be passed on to other recipients.
4.3 Duration of personal data storage
Clariness stores the user's personal data for the fulfillment of the aforementioned purposes until consent is withdrawn. Please refer to sections 10. and 11. regarding the handling of data after consent has been withdrawn.
4.4 Processing of personal data by persons other than Clariness and possibly in a third country?
Please refer to the comments in section 9.
4.5 Miscellaneous
Please refer to sections 10. and 11. for information on the right to revoke consent to data processing and for further information.
4.6 Legal basis for data processing
The legal basis for the data processing described above is the corresponding consent of the user (Article 9 (2) (a) and Article 6 (1) (a) GDPR). In the event of consent being withdrawn, the storage of the previously granted consent together with the withdrawal, for verification and documentation purposes, for a period of up to three years on the basis of a legitimate interest in accordance with Article 6 (1) (f) of the GDPR.
5. Data protection information for participants in a ClinLife survey
Clariness offers the opportunity to participate in surveys (“Survey”) via ClinLife. If a user wishes to participate, they must click the “Yes, I want to participate” button. In this case, they will be redirected to a service provider contracted by Clariness, which will conduct the survey on behalf of Clariness as part of a data processing agreement (see Section 9.1 for details of the contractual relationship between Clariness and the service provider).
The survey is conducted anonymously. No personal data of the user (including IP address or timestamp) is processed in the course of the survey. Otherwise, additional information is provided before data is collected.
6. Data protection information for subscribers to the Clariness newsletter
6.1 Description and scope of data processing for newsletter subscriptions
On ClinLife, there is an option to subscribe to a newsletter from Clariness on selected topics and current studies.
The following additional data is collected:
- E-mail address
- Consent granted for sending information by email about studies and surveys (hereinafter referred to as "Newsletter")
- Topics of interest selected by the user ("subscribed indications", "diagnosis")
- Time of activation of the consent button
- User's IP address
In this context, Clariness checks the e-mail address provided by the user in a so-called double opt-in procedure. This means that after registration, the user receives an email asking for confirmation. This confirmation is necessary so that nobody can register for the newsletter with a third-party email address. The use of the confirmation link is logged in order to be able to prove that the process complies with legal requirements. To do this, it is necessary to store the confirmation time and the IP address. In order to be able to prove a previously given consent, Clariness can store the e-mail address for up to three years after deletion of the user account on the basis of legitimate interests before it is deleted. In this case, storage is only carried out for the purpose of possible defense against claims.
6.2 Newsletter-Tracking
Clariness collects opening rates, click rates, information on “added to spam”, information on “delivered”, information on delivery problems and newsletter unsubscribes. Clariness uses tracking of clicks on links or tracking of opening rates in particular to determine whether the user interacts with the content of the newsletter and to identify potential for improvement. Consent to receive a newsletter also includes the tracking described above. If the user does not want this information to be collected, then he should not subscribe to the newsletter.
6.3 Purpose of data processing
In the case of a newsletter subscription, the data collected from the user is processed (see Section 6.1 above; email address and personalization of content, such as study-related areas of interest / diagnoses named by the user). The newsletter is sent to provide the user with information about studies and surveys in the indications/diagnoses to which he has subscribed. Newsletter tracking is used to evaluate and improve the service.
6.4 Processing of personal data by persons other than Clariness and possibly in a third country?
A service provider is used to send the newsletter e-mails. Please refer to the information in section 9.1.
6.5 Duration of storage
The user has the right to revoke his consent at any time, without affecting the legality of the processing carried out on the basis of the consent until revocation. A corresponding declaration can be made by means of a link within the newsletter; furthermore, the user has the options described in Section 12. for contacting Clariness as the responsible body. In the event of revocation, the user will no longer receive the newsletter. In order to be able to prove a previously given consent, Clariness can store the previous consent to send e-mails for up to three years after the consent has been withdrawn, before it is deleted. In this case, storage is only carried out for the purpose of possible defense against claims.
6.6 Legal basis for the data processing
The sending of newsletters is based on consent within the meaning of Article 6 (1) (a) of the GDPR for the processing of the relevant personal data by the user. In the event of consent being withdrawn, the storage of the previously granted consent together with the withdrawal, for verification and documentation purposes, for a period of up to three years on the basis of a legitimate interest in accordance with Article 6 (1) (f) of the GDPR.
7. Comment function
7.1 Description and scope of data processing
On ClinLife, the user has the option of voluntarily submitting comments in the designated fields. The user's comment, together with the name provided by the user, can be published on ClinLife and on social media. We recommend using first names and not surnames, and not to provide sensitive information, especially regarding health. It is necessary to provide a name and an email address; further information is voluntary. Comments are checked before publication. Clariness reserves the right not to publish comments. The review is to avoid inappropriate content and to monitor adverse events or side effects mentioned in comments. If such events are mentioned, Clariness is obliged to collect and report this information. This report is anonymous and no personal data will be passed on to third parties as part of the report.
7.2 Duration of storage
If the user posts a comment, this will be published and stored for as long as the associated post on ClinLife or on social media is online or until the user has withdrawn their consent and/or requested deletion.
7.3 Miscellaneous
Please refer to sections 10. and 11. for information on the right to revoke consent to data processing and for further information.
7.4 Legal basis for the data processing
The legal basis for the data processing described above is the corresponding consent of the user (Article 6 (1) (a) GDPR). In the event of revocation of consent, the storage of the formerly granted consent together with the revocation, for verification and documentation purposes for a period of up to three years due to legitimate interest under Article 6 (1) (f) GDPR.
7.5 Processing of personal data by persons other than Clariness and possibly in a third country?
Clariness uses the “senja.io” service, which is operated by Senja Proof LTD (https://senja.io/) Apartment 9, 2 Battlebridge Lane, SE1 2HL London, to provide the comment function. When the user uses the comment function, they will be redirected to the Senja Proof LTD website https://senja.io. Clariness has entered into contracts with Senja Proof LTD. (For details of the contractual relationship between Clariness and the service provider, please refer to section 9.1).
8. Cookies and other technologies
8.1 Cookies
8.1.1 General
Cookies are used on ClinLife. Cookies are small text files that are stored in the user's internet browser or by the internet browser on the user's computer system. Cookies are downloaded when the user accesses ClinLife. The cookie contains a characteristic string of characters that enables the browser to be clearly identified when the website is accessed again.
Temporary cookies, also known as “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves the online service and closes his browser. The login status, for example, can be stored in such a cookie. Cookies that remain stored even after the browser has been closed are referred to as “permanent” or “persistent”. This way, for example, a login status can be stored when a user visits the website after several days. Likewise, user interests can be stored in such a cookie, which are used for information purposes. When the website is accessed again from the same device, the cookie is sent back either to the website that created it (first-party cookie) or to another website to which it belongs (third-party cookie). The cookie enables the website to recognize that it has been accessed before with this browser and, among other things, can improve the user experience when it is accessed again. Cookies can customize the content displayed on the website to the personal interests and needs of the user.
Users can decide for themselves whether or not to allow cookies in their browser. Stored cookies can be deleted in the system settings of the browser. The functionality of websites may be limited or even lost if cookies are not allowed.
The first time ClinLife is accessed, the user is informed about the use of cookies via an information banner. Various groups of cookies are used on ClinLife. When the user clicks on Details in the information banner, they will see which cookies Clariness uses on ClinLife and to which group this cookie belongs. If the user does not want a particular cookie or group of cookies to be used, they must make sure that the slider for the corresponding cookie group is set to deselected (gray) before clicking OK to confirm the setting. If the slider is not set to deselect (green), the user consents to Clariness using the cookie group in question. The user has no influence over the use of necessary functional cookies. Cookies are only used on ClinLife after the user has selected the cookie groups.
8.1.2 Cookies used on the ClinLife website
Depending on the consent given, the following types of cookies may be used on ClinLife:
Necessary cookies
Clariness uses cookies that are necessary for the technical functionality of ClinLife, as well as for the detection of errors and security-related anomalies.
The legal basis for the processing of technically necessary cookies is Article 6(1)(f) of the GDPR.
Functional cookies – preferences
Functional cookies enable Clariness to store information that has already been entered (such as user data or language selection) and to offer the user improved, more personalized features on ClinLife.
Functional cookies are only used if the user has consented to their use. The legal basis for the processing is Article 6 (1) (a) of the GDPR. The user has the option at any time to revoke consent given by him, at https://clinlife.us/cookies.
Cookies for Marketing and Statistics
Clariness is committed to the continuous improvement of ClineLife. For this purpose, cookies are used that provide Clariness with overall statistics on the number of visitors, which areas of a page are viewed most often, information on the length of the visit, etc. But web analytics can also be used as a statistical target group tool to evaluate the success of digital communication and marketing measures. These can be installed, for example, by external analysis providers contracted by Clariness.
In order to better adapt the ClinLife service to the interests and needs of users, Clariness evaluates data generated when the user visits ClinLife, provided that the user has consented to the use of cookies for marketing and statistics.
Cookies for marketing as well as cookies for statistics are only used if the user has consented to their use. The legal basis for the processing is Article 6 (1) (a) of the GDPR. The user has the option at any time to revoke the consent they have given under https://clinlife.us/cookies.
An overview of all cookies currently in use, the respective provider, the duration of use and the type can be found under https://clinlife.us/cookies.
The user can view and manage their individual cookie settings under https://clinlife.us/cookies.
8.2 Google Analytics
If you have given your consent, Clariness on ClinLife uses Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter “Google Ireland”). Google Analytics uses cookies. The information generated by the cookies about your use of this website may also be transmitted to and stored by Google LLC, the parent company of Google Ireland, on servers in the United States. The US-based parent company Google LLC is certified under the EU-US Data Privacy Framework; the corresponding certificate can be found here: https://www.dataprivacyframework.gov/list. Any data transfers to Google LLC in the United States are thus covered by the corresponding adequacy decision of the EU Commission in accordance with Article 45 (3) of the GDPR. The EU Commission has published the adequacy decision here: https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.
The legal basis for this is your consent in accordance with Article 6 (1) (a) of the GDPR. We expressly reserve the right to resort to other legal bases.
On behalf of Clariness, Google Ireland will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage. Pseudonymous user profiles may be created from the processed data.
You can revoke your consent to the use of Google Analytics at any time via the cookie settings on the website. Furthermore, you can also technically prevent the storage and use of cookies by making the appropriate browser settings or using browser add-ons. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the further processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
Further information about data use by Google, settings and objection options can be found on the Google websites under the following links:
• https://policies.google.com/technologies/partner-sites?hl=en (“How Google uses data when you use our partners' sites or apps”),
• https://www.google.com/policies/technologies/ads (“Data use for advertising purposes”),
• https://www.google.de/settings/ads (“Manage information Google uses to show you advertising”).
8.3 Google Ads / Google Marketing Platform
We use the remarketing or “similar target groups” function in Google Ads/Google Marketing Platform from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter “Google Ireland”) on our website to optimize our offers. Google Ireland uses cookie/tracking technologies that are stored on your device to enable an analysis of your use of our website and to display ads for products or services that may interest you. According to Google Ireland, the cookies used for this purpose do not contain any personal information. If you are registered with a Google service and logged in, Google Ireland can assign your visit to our website to your account. Even if you are not registered with Google, it is possible that Google Ireland will find out your IP address and use it to create and store usage profiles about you.
The information generated by the cookie/tracking technologies about the user's use of this website may also be transmitted to and stored by Google LLC, the parent company of Google Ireland, on servers in the United States. Google LLC, a US-based parent company, is certified under the EU-US Data Privacy Framework; the corresponding certificate can be found here: https://www.dataprivacyframework.gov/list. Any data transfers to Google LLC in the USA are thus covered by the corresponding adequacy decision of the EU Commission in accordance with Article 45 (3) GDPR. The EU Commission has published the adequacy decision here: https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en. You can revoke your consent at any time via the cookie settings on our website. Furthermore, you can also technically prevent the storage and use of cookies by making the appropriate browser settings or browser add-ons. In addition, you can disable interest-based advertising on Google by clicking on the following link: http://www.google.com/settings/ads/plugin.
Further information on data processing by Google can be found here:
• https://policies.google.com/privacy?hl=en and
• https://policies.google.com/technologies/ads and
• https://marketingplatform.google.com/about/enterprise/.
8.4 Facebook-Pixel and Meta Conversions API
We use services provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland (hereinafter “Meta Ireland”), such as the Facebook pixel, for retargeting/remarketing purposes on this website.When you visit our website and provided you have given us your consent to do so, the Facebook pixel will establish a direct connection between your browser and the Meta server. This enables Meta Ireland to receive information that you have visited our website and allows us to make our F acebook activities more effective and, for example, to display posts or ads only to visitors to our website. In addition, the Facebook pixel allows us to analyze the use of this website and to display ads for content and offers that may interest you. The collected data is only transmitted to Meta Ireland in encrypted form and is anonymous to us, i.e. we cannot see the personal data of individual users.
When you visit our website and provided you have given us your consent to do so, a connection is established between our website and Meta via the Meta Conversions API (Application Programming Interface) to enable the direct transmission of marketing data and website events. This helps us to improve our marketing measures and optimize advertising campaigns. As part of the use of the Meta Conversions API, various events are recorded that are triggered by user actions on our website. These events include, for example, page views, filling out forms or other interactions on the website.
The information generated may also be transmitted to and stored by servers of Meta Platforms, Inc., the parent company of Meta Ireland, in the United States. The US-based parent company Meta Platforms, Inc. is certified under the EU-US Data Privacy Framework; the corresponding certificate can be found here: https://www.dataprivacyframework.gov/list. Any data transfers to Meta Platforms, Inc. in the USA are thus covered by the corresponding adequacy decision of the EU Commission pursuant to Article 45 (3) of the GDPR. The EU Commission has published the adequacy decision here: https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.
You can revoke your consent at any time via the cookie settings on our website. Furthermore, you can also technically prevent the storage and use of cookies by making the appropriate browser settings or browser add-ons.
Further information on the type, scope, purposes, legal basis and options for objecting to data processing by Meta Ireland, as well as your settings options for protecting your privacy, can be found in the data protection declaration of Meta Ireland at https://www.facebook.com/about/privacy/.
9. Transfer and disclosure of personal data to other recipients and, where applicable, processing in a third country
9.1.
Within the Clariness organization, user data is only received by those departments that need it to fulfill the corresponding purpose and legal obligations. Service providers (telecommunications and IT service providers) contracted by Clariness may also receive data for these purposes. This concerns, for example, cases in which Clariness is supported in data processing by service providers employed and contracted by Clariness (so-called contract processors). Said service providers are contracted, for example, to provide server capacity or to host questionnaires for Clariness.
The legal basis for the aforementioned transfer of personal data is Article 6 (1) (f) of the GDPR. Clariness's legitimate interest is to provide and improve the service.
9.2 Clarity may also disclose personal data to third parties:
9.2.1. With the user's consent, data will be passed on to the study center selected by the user so that the study center can contact the user regarding their request to participate in the study and process the request further. The legal basis is Article 6 (1) (a) of the GDPR in conjunction with Article 9 (2) (a) of the GDPR.
9.2.2. If there is an enforceable or final court or official order for disclosure and/or transfer of data to third parties, or if Clariness is obliged to disclose and/or transfer data to third parties due to a legal obligation even without such an order. The legal basis is Article 6 (1) (c) and (f) of the GDPR. Clariness's legitimate interest lies in the fulfillment of sovereign claims.
9.2.3. If the disclosure and/or transfer is necessary to prevent misuse of the Internet offer or individual services – in particular, a violation of the terms and conditions of use – in a legally permissible manner. The legal basis is Article 6 (1) (f) of the GDPR. Our legitimate interest lies in the detection and prosecution of abusive behavior.
9.3
Clariness will not transfer personal data to third parties without the express consent of the user except in the cases described in this data protection declaration. The legal basis for the transfer of personal data in the case of express consent is Article 6 paragraph 1 letter a) of the GDPR.
9.4 Processing of data in a third country?
Although Clariness takes care to only commission service providers that are based and have their servers in a country of the European Union or the European Economic Area, there is a possibility that the user's personal data may be passed on to the parent company of the respective service provider based in a third country (i.e. in a country that is neither a member of the European Union nor the European Economic Area). Not all third countries have a level of data protection recognized by the European Commission as adequate. Clariness therefore takes care to conclude contracts that also provide for appropriate safeguards in the event of transfers to third countries in accordance with Article 46 (2) of the GDPR (e.g. standard contractual clauses or binding corporate rules); in addition, Clariness takes additional technical and/or organizational measures to the extent necessary to maintain appropriate protection of personal data.
The user can obtain a copy of the regulations made in this regard by using the contact details of the responsible body under Section 12. below.
10. User Rights
The user has the following rights. Their assertion will be processed immediately and will not result to any disadvantages for the user.
Right of access (Article 15 of the GDPR):
The user can – without owing a fee for this – request information from Clariness about which personal data is processed, from which data source it originates and for which purpose(s) the data is processed and – as well as relevant – to which recipient or categories of recipients the data is transmitted. Requests for information received electronically will be answered electronically.
Right to object (Article 21 of the GDPR):
The user can object to the processing of his data for reasons arising from his particular situation, insofar as the data processing is based on the legitimate interests of Clariness or a third party (Article 6 (1) (f) of the GDPR) and in cases where the data processing is in the public interest (Article 6 (1) (e) of the GDPR). If the user objects, Clariness will no longer process the personal data unless Clariness can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the user, or for the establishment, exercise or defense of legal claims.
Insofar as Clariness processes personal data in order to provide targeted information about the range of services offered by Clariness (hereinafter referred to as “advertising purposes”), the user has the right to object at any time to the processing of personal data concerning him for this purpose. In the event of an objection to processing for advertising purposes, Clariness will no longer process the user's personal data for these purposes.
Right to data portability (Article 20 of the GDPR):
The user has the right to request the disclosure of the personal data that he or she has provided to Clariness in a structured, common, machine-readable format, provided that the processing of the data is based on the user's consent (Article 6 (1) (a) GDPR) or the processing is carried out to fulfill a contract concluded with the user or to carry out pre-contractual measures (Article 6 (1) (b) of the GDPR).
Right to rectification (Article 16 of the GDPR):
If personal data is incorrect or incomplete, you can request that it be corrected or completed. Furthermore, a correction triggers an obligation on the part of Clariness to notify all recipients to whom the incorrect data has been passed of the correction, provided that this is not exceptionally impossible or involves a disproportionate effort.
Right to deletion (Article 17 of the GDPR):
The user can request the immediate deletion of their data if (i) the purpose of the data processing has ceased to apply due to the passage of time or for other reasons, (ii) the processing is based on the user's consent and this has been withdrawn, (iii) the user has objected to the processing and further processing must cease as a result, or (iv) the legal basis for processing the data is missing or has ceased to apply. However, Clariness must observe existing retention obligations and legitimate interests that preclude deletion.
Right to restriction of processing (Article 18 of the GDPR):
The processing of personal data is to be restricted (i) as long as Clariness is checking the disputed accuracy of the data, (ii) the processing was unlawful from the outset, but an objection to deletion has been received from the user, (iii) after the purpose has been achieved, if the user still needs the data to assert legal claims, and (iv) while an objection from the user is being checked. During the period of restricted processing, Clariness will only process the data (i) with the user's consent or (ii) to assert, exercise or defend legal claims or (iii) to protect the rights of another person or for reasons of important public interest.
Right of appeal (Article 77 GDPR in conjunction with Section 19 FDPA):
The user has the right to contact a regulatory authority with complaints.
Right to withdraw consent under data protection law (Article 7(3) of the GDPR):
The user has the right to revoke at any time any consent given to Clariness to process personal data. Further information can be found in section 11. below.
11. The right of withdrawal of the user
Any consent is voluntary!
The user can revoke his consent to the processing of his data at any time without giving reasons, in whole or in part. The revocation - even if limited to certain data - may result in the user no longer being able to use certain Clariness services.
A revocation always only refers to the future processing of the user's data. Data processing that has already taken place cannot be undone.
To revoke your consent, please contact: [email protected]
In the event of withdrawal, the personal data stored on the basis of the consent will be deleted.
After a revocation, data processing will only continue if Clariness can base the (future) processing on a legal basis other than consent. A possible legal basis for this is the fulfillment of a legal obligation in accordance with Article 6 (1) (c) of the GDPR, which is the case, for example, if Clariness has to fulfill corresponding legal obligations (e.g. under commercial or tax law) or regulatory requirements. Another legal basis for continuing data processing is the protection of legitimate interests (Article 6 (1) (f) of the GDPR) in particular for the assertion of legal claims and defense in legal disputes. Thus, the previously granted consent together with the revocation is stored for verification and documentation purposes for a period of up to three years due to legitimate interest in accordance with Article 6 (1) (f) of the GDPR. Nevertheless, the data will not be processed to protect legitimate interests as long as and to the extent that Clariness can recognize indications that predominant interests worthy of protection oppose the processing. Before any processing of personal data to protect legitimate interests, the opposing interests worthy of protection are therefore examined in the context of an objectified consideration.
12. Contact details of the responsible party, contact details of the data protection officer
The contact details of the responsible body are:
Clariness GmbH
Schillerstraße 44
22767 Hamburg
Telephone: +49 (40) 298 678 00
Telefax: +49 (40) 298 678 09
E-Mail: [email protected]
The contact details of the data protection officer of the responsible body are:
Clariness GmbH
c/o Herold Unternehmensberatung GmbH
Mein Datenschutzbeauftragter.de
Hafenstraße 1a, 23568 Lübeck
The rights set out in sections 10. and 11. can be asserted, and general questions and suggestions regarding data protection can be submitted, to both the responsible body and its data protection officer using the contact details provided above.
13. Contact details for the relevant regulatory authority
The Hamburg Commissioner for Data Protection and Freedom of Information (HmbBfDI) is the competent supervisory authority. It monitors compliance with data protection law in the non-public sector in Hamburg. The user has the opportunity to contact the supervisory authority at any time.
The contact details are:
Free and Hanseatic City of Hamburg
The Hamburg Commissioner for Data Protection and Freedom of Information
Thomas Fuchs
Ludwig-Erhard-Strasse 22
20459 Hamburg
Tel.: 040 / 428 54 – 4040
Fax: 040 / 428 54 – 4000
E-Mail: [email protected]
14. Links to other websites
This data protection declaration does not extend to other providers if the website contains links to other websites. ClinLife has no influence over whether their operators comply with data protection regulations and therefore does not accept any responsibility for the accuracy, timeliness and completeness of the information provided therein.
15. Amendment of the data protection declaration
Clariness reserves the right to amend this data protection declaration as necessary to reflect changes in factual or legal conditions with effect for the future.
16. Information for individuals not within the EU
Clariness is a company headquartered in Germany/EU. Clariness must therefore comply with the requirements of the GDPR, which means that the “ClinLife website privacy policy”
applies to all users of the ClinLife website. Since ClinLife also addresses users who are not in the EU, the data protection law of the place where the user is located may also apply.
Additional information on data protection that applies at the user's location will, where applicable, be provided on the respective country-specific ClinLife website at the end of this section of the respective “ClinLife website privacy Policy” in the respective language.
For California residents
The following provisions expressly apply only if the user is a California resident and the processing of personal data falls under the California Consumer Privacy Act (CCPA). The “Data protection information ClinLife website" provided above also applies to California residents. Additionally, Clariness informs:
- Clariness does not sell or share personal information or use or disclose sensitive consumer information for any purpose other than those stated above, without the consumer's consent or as permitted or required by applicable law.
- The consumer has the right to withdraw the consent to the use of personal data at any time with effect for the future (see section 11.).
- Cookies for marketing as well as cookies for statistics are only used if the consumer has consented to their use. The consumer can exercise his right of refusal (see section 7.) The consumer has the option at any time to revoke any consent they have given at
Clariness does not “sell” or “share” personal information of consumers Clariness knows to be under the age of 16.
To assert California consumer rights, please submit a request to:
Clariness GmbH
Schillerstraße 44
22767 Hamburg
Telephone: +49 (40) 298 678 00
Telefax: +49 (40) 298 678 09
e-mail: [email protected]
When submitting a request, please describe your relationship with us and your request in sufficient detail for us to properly understand, evaluate and respond to it. We will need to verify your identity before we can process your request. This may require us to request further personal data from you. We will only use personal data provided in connection with a consumer rights request to verify and respond to the request. In accordance with applicable law, you may be entitled to submit a request through an authorized representative. If you wish to appoint an agent to exercise your rights and choices on your behalf, please provide proof that the agent otherwise has valid written authorization to submit requests to exercise your rights on your behalf. In certain circumstances, we may refuse a request to exercise the rights described above, in particular if we are unable to verify your identity. If we are unable to comply with all or part of your request, we will explain the reasons for refusing the request.
Current status as of: January 2025