When and how we collect and handle your personal data

When you visit our websites

• Cookies
  • Some of our sites use cookies to enhance User experience, for statistics, and marketing purposes. Only strictly necessary cookies will be set until we get your explicit permission to use other cookies. To see a full list of cookies that we use on each Site, please view our cookie declaration found in the footer of each of the pages listed above.
• Visitor statistics
  • We collect anonymous visitor data to better understand how our visitors interact with our web page.

When you download our content

We have made available white papers, customer cases, and other content on certain parts of our websites that you can download. To be able to download our content, we require your contact details, company name, your role, and additional information so that we can:

• Send you the requested content
• Add your email address to our company newsletter, to which you can unsubscribe at any time by clicking the unsubscribe link at the bottom of the emails.
• Follow up with you, directly, at a later stage.

When you register for our events & webinars

In some cases, to register for our events and webinars, we require your contact details. Apart from the necessary communications, such as event reminders, governed by the terms and conditions of the tools that we are using, we also collect your information to:

• Subscribe your email address to our company newsletter, to which you can unsubscribe at any time by clicking the unsubscribe link at the bottom of the emails.
• Subscribe your email address to notifications about upcoming events and/or webinars, to which you can unsubscribe at any time by clicking the unsubscribe link at the bottom of the emails.
• Be able to follow up with you directly, at a later stage.

When you request a quote, callback or fill out other forms to get in touch with us

When you fill out other types of forms on our web pages, that specifically reference this privacy policy, we may require your contact details, company name, your role, and additional information so that we can:

• Fulfil the purpose of the form (send in your questions, "show an interest in", Subscribe to etc)
• Add your email address to our company newsletter, to which you can unsubscribe at any time by clicking the unsubscribe link at the bottom of the emails.
• Follow up with you, directly, at a later stage.

When using our forms we add a secret token that's unique to each submission. This is only used to hinder spambots.

When you contact customer service

• We require your e-mail address to respond to your requests.

When you sign up for an account

• We collect your e-mail address to be able to create your account and provide your credentials to Cleura Cloud Management Panel.

Why we collect your data

Cleura AB collects and uses personal data for the following purposes:

• To personalize user experience
  We use information in the aggregate to understand how our Users, as a group, use the services and resources provided on our Site.

• To improve our Site
  We use the feedback you provide to improve our products and services.

• To deliver requested material(s)
  When a User requests to download our whitepapers, customer cases, or other content, we need your email address to deliver the content.

• To send marketing emails
  To send Users information they agreed to receive about topics we think will be of interest to them.

• For direct communications
  To be able to follow up directly with Users who have downloaded our content and/or participated in our events, to inform about, sell, and promote our products and services.

• For advertising purposes
  By visiting our web sites, third parties will place cookies on your browser for targeted advertising purposes. Our cookie declaration details which cookies we use and what they store.

How we protect your information

We adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal information, username, password, transaction information, and data stored on our Site. Sensitive and private data exchange between the Site and its Users happens over an SSL secured communication channel and is encrypted and protected with digital signatures.

Sharing your personal information

We do not sell, trade, or rent Users’ personal data to others. We share generic aggregated demographic information, not linked to any personal data, regarding visitors and users with our business partners, trusted affiliates, and advertisers for the purposes outlined above. We use third-party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We will share your information with these third parties for the limited purposes outlined above.

Subprocessors and countries your data will be sent to

Cleura AB uses certain sub-processors and subcontractors to provide you with our services and information connected to our services and company. A subprocessor is a third party data processor engaged by us that provides our service with various functions. We make sure that there are formal agreements in place to keep your personal data safe. Cleura is a global company, and your personal data may be transferred across international borders. When we send your data to countries with different data protection laws, we make sure they are transferred with an adequate protection level. In light of the invalidation of Privacy Shield, and the subsequent lack of clear, legal, mechanisms to transfer your personal data to the U.S., and our inability to ensure that your data is transferred and processed with an adequate level of protection, we apply a warning to inform our attendees that international data transfers will occur.

Specific cases

Third-party websites

Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors, and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. Also, these sites or services, including their content and links, may always be changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites that link to our Site, is subject to that website’s own terms and policies.

Information related to Cleura's processing as a controller when delivering services

When Cleura provides Services to Customers, Cleura is a controller of some processing of personal data.

Cleura needs to use the following types of personal data to provide the Services:

• Billing information
• Technical contact information regarding the services
• Customer master account
• Logs from Cleura Cloud Management Portal and API user accounts

The Customer can avoid Cleura processing some personal data in the form of contact information by providing information which is not connected to a unique individual. For instance, the Customer can provide a group e-mail address such as finance@yourdomain.com instead of a personal e-mail address for receiving billing information.

Billing information

The Customer must provide billing information with a working e-mail address and a physical address. The billing information the Customer provides may contain personal data.

Billing data that is being collected and processed by Cleura:

• E-mail address
• Contact name
• Contact address
• Payment verification hash (if you pay with a credit card)

The purpose of the processing, billing

• To request and receive payment for the consumed Services.
• To be compliant with legal requirements regarding corporate accounting.

Legal basis, billing

• Legitimate interest, consisting of Cleura’s and the Customer’s respective interest in providing and using the Services.
• Legal obligation, specifically corporate accounting regulations.

Nature of the processing

Billing data is sent in connection with invoicing and payment. It is also retained after payment, so that Cleura is able to prove that the company’s accounting is in order and that applicable taxes have been paid.

Retention period

Billing information, including invoicing data, is stored a number of years in compliance with Swedish accounting practices.

Technical contact information regarding the services

The Customer must provide at least one working e-mail address to receive notifications, information, and alerts regarding services used by the Customer.

Technical contact data processed by Cleura:

• E-mail address.
• E-mails containing alerts and information related to the Services.
• Information about which recipients have received which e-mails.

The purpose of the processing, technical contact information, is to inform the Customer of:

• Potential security breaches
• Updates and changed to the general terms and conditions
• Relevant changes in the technical and organisational security measures
• Upcoming maintenance windows
• Potential service disruptions
• News and updates regarding Cleura’s services

Legal basis, technical contact information

• Legitimate interest, consisting of Cleura’s and the Customer’s respective interest in providing and receiving a high quality service.
• Legal obligation, consisting of GDPR requirements regarding technical and organisational measures to protect data processed by the Customer.

Nature of the processing

Cleura sends e-mails containing the relevant information to the recipient e-mail address.

Retention period

Information is stored for a period of time regarding which recipients have been sent which e-mails.

Customer master account

Cleura must create a master account for each Customer, which other details regarding the customer are tied to, and which the customer can use to create Cleura Cloud Management Portal and API user accounts.

Customer master account data used by Cleura:

• Account user-id.
• Account user e-mail address.
• Name of the Customer’s master account user.

The purpose of the processing, master account

In order to provide the Services to the Customer, Cleura must create a master account for each Customer, which other details regarding the customer are tied to, and which the customer can use to create Cleura Cloud Management Portal and API user accounts.

Legal basis

Legitimate interest, consisting of Cleura’s and the Customer’s respective interest in providing and using the Services.

Nature of the processing

Cleura creates the master account in its IT system. The Customer uses the master account to manage administrative affairs related to its business relationship with Cleura, and to create Cleura Cloud Management Portal and API user accounts.

Retention period

Cleura keeps the master account for at least as long as the Services are provided to the Customer.

Logs from Cleura Cloud Management Portal and API user accounts

Cleura keeps logs of actions taken using Cleura Cloud Management Portal user accounts and API user accounts.

Logging data used by Cleura:

• Which Cleura Cloud Management Portal user accounts and API user accounts are used.
• What actions each account performs.
• At what time.

The purpose of the processing, logging

To ensure Cleura is providing the Services according to the Agreement and its legal obligations, by executing commands as instructed by the Customer.

Legal basis

• Legitimate interest, consisting of Cleura’s and the Customer’s respective interest in providing and receiving a high quality and secure service.
• Legal obligation, consisting of GDPR requirements regarding technical and organisational measures to properly process data according to instructions given by the Customer.

Nature of the processing

Logs of actions are automatically recorded and sent to a master log, where they are saved.

Retention period

Cleura keeps the logs for at least as long as the Services are provided to the Customer.

Changes to this privacy policy

Cleura AB has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal data we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Your acceptance of these terms

By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting us

If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this Site, please contact us at:

Cleura AB  
Blekingegatan 1 SE-37157  
Karlskrona
SWEDEN
dpo@cleura.com

This document was last updated on May 24, 2023