Privacy Policy

The responsible entity for the purposes of data protection (the controller) is Clover Environmental Solutions Ltd, Units 8 & 9 First Quarter, Blenheim Road, Epsom, KT19 9QN, United Kingdom.

Although Clover Environmental Solutions Ltd is operating this Website, information collected and processed on this site may be shared with other European legal entities in the Clover Imaging Group (hereafter referred to as “CIG EMEA”) in adherence with the European General Data Protection Regulation GDPR. Please see section (5.3) Data Processing within the Group for details. In the following, “we”, “us” or "our" refers to the legal entities of the CIG EMEA company group.

Your privacy is important to us and we respect your privacy rights. This Privacy Policy sets out the basis for processing any personal data we collect from you or that you provide to us. The collection, processing and use of your personal data is governed by applicable legislation, in particular the GDPR and applicable national laws.

Our current Privacy Policy is dated 13.05.2018. We reserve the right to adapt the data protection policy to changed laws and regulations at any time. Please keep up to date with changes to the Privacy Policy by clicking on the relevant link from our website.

Please read the Privacy Policy carefully. If you do not want to agree to this Privacy Policy, you should not use the Website nor provide any personal data to us.

In our Privacy Policy we use terms and definitions of the GDPR, in particular Art. 4 GDPR. In pursuit of this regulation we are “controller” of personal data, you are the “data subject”. Information that directly or indirectly relates to you is “personal data”. For the purpose of this Privacy Policy “your data” is the data that directly or indirectly relates to you as a natural person, such as name, address, telephone number, your email address, your company and further details, which you fill into forms of our web portal.

Of course you can visit our web sites without providing any personal data to us. However, when using our web portal, data is automatically collected and processed, which cannot identify you individually. Please refer to the sections

  • “Web Service Logfiles”
  • “Cookies”
  • “Web Analysis Tool Google Analytics”
in this privacy policy.

You can contact Clover Environmental Solutions Ltd.’s data protection officer at

GDPR-UK@ceseurope.com

(1) Automatic Collection, Processing and Use of Personal Data of Unregistered and Registered Users

(1.1) Web Service Log Files

When you access the pages of our website with your browser, the server logs the data required for the operation of a web service in the log files: the name of your browser, the name of your internet service provider, the IP address of your PC, the address [of] the site from which you accessed our website, the name of your operating system, the web pages you visit, and the date and duration of your visit. This data is temporarily stored in the log files and then automatically deleted. The purpose of the storage is to analyze the possible activities leading to malfunctions as well as to detect, prevent and investigate cyber-attacks (e.g. distributed denial of service (DDoS) Attacks, hacking attacked, identity misuse).

(1.2) Cookies

Our website uses cookies. These are small files that the web server transfers to your PC. These files are used to track your way through the pages of our website or to accept an order.

Cookies are distinguished on the one hand according to the duration of their storage. Session cookies are automatically deleted when you close their browser. A session cookie can serve to manage an order form or record which services are of particular interest. Permanent cookies, on the other hand, remain stored on your PC. A permanent cookie can be read again on the next visit of our website. To prevent this, you can delete the permanent cookie after visiting our website.

On the other hand, cookies are differentiated according to their origin. So-called first-party cookies always come from the website, which is indicated in the address bar of your browser. Third-party cookies are from websites that you have not directly accessed, but which have been linked to images or advertisements on the site of the first provider. Your browser can tell you which sources are stored on your PC.

(1.2.1) Our Use of Cookies

According to the European Cookie Policy, consent is required to set permanent cookies that serve purposes other than ensuring the correct communication with the web server. If you make no objection, we assume that by continuing to use our website, you consent to our use of cookies described here.

In as far as your browser permits, our web server uses the following permanent Google Analytics cookies (please see section 1.3 of this policy for further details about Google Analytics):

  • _ga is used to distinguish users and expires after 2 years.
  • _gat is used to throttle the request rate and expires after 2 minutes.
  • _utma is a Google Analytics cookie used to distinguish users and sessions, and expires after 2 years.
  • _utmb is a used to determine new sessions/visits, and expires after 30 minutes.
  • _utmz stores the traffic source and shows how the user reached the website, and expires after 6 months.
  • _utmt is used to throttle the request rate, and expires after 10 minutes.

Possibility of Objection

Most browsers are set to accept cookies. To disable this, please change the appropriate settings of your browser. If your browser does not allow cookies, you may not be able to use all pages of our Internet site without problems.

(1.2.2) How Can I Disable Cookies?

You can customize your browser settings to turn off all cookies, turn off third-party cookies, or allow temporary cookies only. Please refer to the help pages of your browser for the settings you need to make.

(1.3) Web Analysis Tool Google Analytics

On legal grounds of legitimate interest in continuous improvement of our web services, this website uses Google Analytics, a web analytics service provided by Google, Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses so-called “cookies”, text files which are stored on your computer and which allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is generally transferred to a Google server in the USA and stored there.

On our websites, IP anonymization is activated, which means that your IP address will be shortened by Google prior to transmission to the USA. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and abbreviated there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity, and to provide other services related to website usage and internet usage against the website operator.

The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. You can prevent cookies from being saved by setting your browser software accordingly. This may result in impairment of the functionality of our websites. Deleting permanent cookies after visiting our websites does not result in any impairment.

Possibility of Objection

In addition, you may prevent Google’s processing of the data (including your IP address) generated by the cookie and your use of the website (including your IP address) as well as the processing of this data by Google by using the browser plugin http://tools.google.com/dlpage/gaoptout?hl=en Download and install.

An alternative to the browser add-on or within browsers on mobile devices, please click this link to prevent Google Analytics collection within this site in the future. An opt-out cookie is stored on your device. If you delete your cookies, you must click this link again.

For more information on Google’s Terms of Service and Privacy, please visit http://www.google.com/analytics/terms/en.html or https://www.google.com/intl/en/policies/.

(2) Our Processing of Personal Data of Customers and Suppliers

We collect data of natural persons on our web portal or contact form, who are contacting us or who belong to, or represent a company that is in a business relationship with us. We may also collect personal data directly from you by telephone and email. This data includes your name, the name and address of your company, your business contact data including email and telephone, and your job title. The legal ground for processing your data is our legitimate interest in communicating with you as a representative of your company, as well as the legitimate interest of your company in establishing the communication with us. Your contrary interests may outweigh our legitimate interest, e.g. after you have left your company.

Of course, as a data subject you have rights under data privacy law, e.g. the right to withdraw consent, the right of access to your data, and several other rights. Please refer to section

(5.5) Your rights relating to your personal data.

For the purpose of performing a contract we process your company’s data in our CRM and in the planning, manufacturing, logistics and financial modules of our ERP. Depending on your role and responsibility in your company, this data may include the above mentioned personal data, which directly relates to you as a person. However, the purpose of the processing does not relate to you as an individual but to your company, as our business partner. Data protection regulations do not apply to business data that does not relate to a natural person.

Mobile Phone Trade in – Registration on our Web portal

Clover Environmental Solutions Ltd provides a mobile phone trade-in service to companies who sell mobile phones. These companies are not affiliated with us. When you enter personal details onto the mobile phone supplier’s trade-in web portal, managed by Clover Environmental Solutions Ltd / Clover Wireless in order to receive a quote to trade-in your mobile phone, your personal details are used on the legal ground of fulfilling a contract. The personal data includes your name and email address. If you decide to trade in your used mobile phone, you are also required to provide your mobile phone IMEI number, address, phone number and driver’s license.

The personal data is required:

  • to provide you with the current trade-in value of your used mobile phone.
  • to send a quote to your email address, with your unique order number.
  • for the company you are trading the phone in with to check the IMEI number against police records to confirm if the phone has been stolen.
  • to confirm you are the owner of the phone.
  • to fulfil your order.
  • to analyse the popularity of this service.

Your personal data may be used by the mobile phone company you are trading in your phone with to complete your order with them. We do not retain your personal data for any other purposes, other than to fulfil your contract.

Mobile Phone Data Wiping

If you trade in or send us your used mobile phone, you may have personal data stored on your phone. it is your responsibility to wipe any personal data from the phone before sending it to us, by performing a ‘factory reset’. Instructions on how to perform a factory reset are available from your phone provider, and also available on the web portal you have used to trade in the phone.

All phones received at our company premises are further data wiped using an automated software solution which exceeds the requirements of HMGIS5 Baseline (UK), DoD 5220.22-M (USA) and VISTR (Germany).

(3) Newsletter

As a rule, you receive an electronic newsletter because you have requested it explicitly. When you request a newsletter, we will store your consent and its time stamp.

If we are not sure about the ordering party, we will use the so-called "double-opt-in" procedure before the newsletter is sent, which means that we will only send you a newsletter by e-mail, that you have subscribed to. For this purpose, we will send you a notification e-mail and ask you to confirm by clicking on a link contained in this e-mail that you would like to receive our newsletter.

Possibility of Objection

You can revoke this consent or unsubscribe at any time. The easiest way to do this is to click on the corresponding link in our newsletter or in the email including the information on the special offers. You can also advise us that you wish to object or unsubscribe by using the contact form.

(4) Contact Form

When you enter your details into a contact form, they will be sent to the department you have selected, along with your optional message, as an e-mail.

If your query relates to a potential order, your data will be stored in our CRM and will be used by us and other companies of CIG EMEA on legal grounds of performing a contract, for purposes of customer relationship management, and processing your requests and orders. On legal grounds of improving our business relationship, your data will be used for marketing as well. Please see section (5.3) Data Processing within the Group for details.

We may also use your data to provide you with information and special offers by e-mail or electronic newsletter. If required by applicable law, we will obtain your express consent prior to sending such communications to you. You may at any time object to this use through the contact form on our website.

(5) Further Explanations Regarding Data Protection

(5.1) Data Controller

The data controller identified at the beginning of this Privacy Policy is solely responsible for our own websites but not for sites of partner companies that may be linked to our website.

(5.2) Related Pages and other Websites

The respective partner company is responsible for data protection on linked pages. If you access linked pages, please refer to the information on the legal notice and the privacy policy of the linked websites. The same applies if this website is linked to other websites of any third party.

(5.3) Data Processing Within the Group

While customers and business partners may view the CIG EMEA Group as one company, it actually consists of several legal entities that are committed to collect, process and use your information in adherence with the same set of obligations under European data protection provisions. Depending on your business location or the type of business that you doing with CIG EMEA, your data may be used and processed by any of the following EMEA CIG legal entities for the purposes listed:

CLOVER IMAGING GROUP EMEA
Clover Portugal, Lda
Rua do Galhano, No 11
Varziela, Arvore
4480-089 Vila do Conde
Portugal
 Central data processing for CIG EMEA;
Group web portal;
Customer relationship management;
Order management
Clover Wireless, Unipessoal, Lda
Rua do Galhano, No 11
Varziela, Arvore
4480-089 Vila do Conde
Portugal 		Customer relationship management;
Order management
Clover Germany GmbH
In den Wolfsmatten Geb. 142
D-77955 Ettenheim
Germany 		Customer relationship management;
Order management
Clover Environmental Solutions GmbH
In den Wolfsmatten Geb. 142
D-77955 Ettenheim
Germany
 Customer relationship management;
Order management
Clover Serbia d.o.o.
Rade Končara 1
21131 Petrovaradin
Serbia
 Centralized data processing for CIG EMEA;
Group customer service;
Order management;
Webshop
Clover Dataproducts of Ireland Ltd
39/40 Upper Mount St.
Dublin 2.
Ireland
 Customer relationship management;
Order management
Clover Environmental Solutions Ltd
Unit 8 & 9 First Quarter
Blenheim Road
Epsom
Surrey KT19 9QN
United Kingdom
 Customer relationship management;
Order management;
Web portal

Under data protection law, any European CIG legal entity may assume a role of controller of your personal data (“Joint Controllership”). Data protection agreements warrant that protection and security of your personal data are maintained at the level required by EU law, even if processed and used outside the European Economic Area.

The above mentioned “Joint Controllership” is applicable to data stored in the jointly used CRM of the CIG EMEA company group and to the processing of data in our web shop.

For order management purposes each single company is a sole controller under data protection laws of all data that are required for performing contracts with their customers and suppliers, including the processing of financial data.

Our customer care department will forward your request to the respective CIG legal entity that is serving your business.

(5.4) Disclosure of Personal Data

We do not disclose your personal data to other third parties outside the CIG EMEA Group without your consent, except that we disclose such information when disclosure is necessary to comply with or is permitted by any applicable law, or in response to any judicial or administrative request. However, we may communicate or otherwise disclose your personal data in connection with the sale of all or a portion of our business to a third party. This data may be used by such third party for purposes of providing services to you.

(5.5) Your rights relating to your personal data

As a data subject you may exercise your rights under data privacy at any company of the CIG EMEA group.

You have the right of access to your personal data (Art. 15 GDPR). You may have your data rectified in pursuit of Art. 16 GDPR, or on specific grounds have them erased according to Art. 17 GDPR. In accordance with Art. 18 GDPR you have the right to restriction of processing, and on grounds relating to your particular situation, you additionally have the right (in pursuit of Art. 21 GDPR) to object to the processing of your data generally or in parts. For data that you have provided to a company of the CIG EMEA group, you have the right to receive it in a commonly used and machine-readable format. You have the right to withdraw your consent to the processing of your data at any time, with future effect. That means that your withdrawal can only effect future processing. Consequently, past processing remains in compliance with data protection stipulations.

You have a general right to object to any CIG EMEA group company’s processing of your contact and address data for direct marketing purposes, unless you have specifically requested this.

Please use our contact form to exercise your rights, or contact us at GDPR-UK@ceseurope.com

If you are a user in the D-A-CH region, you may contact the data protection officer appointed by Clover Germany GmbH, Reinhard M. Novak, by using the contact form or imprint information on his web site http://www.dsb-ext.com.

You have the right to lodge a complaint to a supervisory authority.

Should you decide to delete your data, you understand that we will not be in a position to provide you with all or part of the services offered through the website and you may not be able to use all or part of the functionalities of the website.