General Data Protection Regulation Policy

Updated June, 2018

Cooliance Data Protection Policy Your privacy and trust are extremely important to Cooliance, and we place a high value on the protection and security of your data.  In the  ‘Cooliance Data Protection Policy,’ we will explain the data collection process used when you visit www.cooliance.com,  and how we use it.  We also provide guidance on how you can protect your data under the auspices of the EU General  Data Protection Regulation.

I. Responsible person
This website is operated by Cooliance, 60 Alhambra Rd, Warwick, Rhode Island 02892, USA , which acts as the “responsible person” within the meaning of the EU General Data Protection Regulation (from now on “GDPR”).

Cooliance has not appointed a data protection officer, because this is not necessary to comply with the statutory requirements.
However, inquiries about data protection and the processing of your personal data can be sent to the following email address, and we will handle them per the statutory provisions:  dataprotection@cooliance.com

II. Data processing, Purpose of processing, Duration of storage
This section describes the data categories we use as well as the purposes we aim to achieve through the use of the data. Information on the length of time for which various kinds of data are stored is provided where possible.

Every time this website is accessed, access data is saved in a log file known as the visitor log. The data record saved in this regard contains the following information:

  • IP Address
  • URL accessed on the Cooliance web site
  • Time
  • Bandwidth used during the transaction
  • Referring URL
  • Web browser used to view the Cooliance website
  • The operating system of the device used to view the Cooliance website
  • Country of origin

We only analyze these log files in the event of misuse of our website. We reserve the right to subsequently examine the log files of users against whom a concrete suspicion exists of having used our website illegally and/or in breach of contract. In general, it is not possible for us to associate this data with a specific person. If such association is possible, however, we only use such data in cases for which a corresponding legal basis exists (weighing of interests in the individual case).

If you have agreed to receive a newsletter, we use your name and email address to deliver such a newsletter. This data is used for as long as you are subscribed to the respective newsletter.

You can revoke at any time any consent you have provided for processing of your personal data. You can send notice of revocation in writing or via email to  dataprotection@cooliance.com

III. Data recipients and recipient categories
In connection with operating this website, the following service providers have been engaged by Cooliance: Website hosting provider: GoDaddy. Aside from GoDaddy, other service providers may be engaged in connection with providing this website in the future.

IV. General principles for the processing of personal data

  1. Without limitation, we comply with all statutory data protection regulations.
    The data protection directives of the European Union and the national laws derived from them apply to the storage, processing, and use of personal data. The legal basis for processing the respective personal data is evident from the foregoing.
  2. Personal data is not sold, given over, rented out or otherwise disclosed to third parties in any manner without your consent.
    We will not make third parties aware of your personal data for advertising or marketing purposes or otherwise, give it to third parties unless this is necessary in order to execute the performance owed to you or without your express permission.

In some cases, personal data may be made available to external service providers if they offer sufficient guarantees that data will be used legally and securely, and they contractually undertake to comply with the principles and statutory provisions described in this Data Protection Policy.

Within the scope of corporate restructuring or mergers, we reserve the right to transfer personal data to other companies, provided they also undertake to comply with the principles of conduct described here and are domiciled either within the European Union or a third state with an appropriate level of data protection.

In the future, Cooliance may use Social Networking,  and If you decide to use these social networking functions offered in our online presence, personal data will be forwarded to the respective external social network providers. See Section 4, below, for detailed information on this topic.

Furthermore we reserve the right to forward personal data to third parties if we are compelled to do so by operation of law, judgment handed down by a court of competent jurisdiction or administrative order issued by the competent supervisory authority; or if, as a result of actions or omissions on your part, we are forced to have our rights, property, and assets protected by the competent supervisory authorities or have said rights, etc. enforced on our behalf.

3. The data we collect is limited to necessary and expedient information.
When we collect personal data, we always explain to you the purposes for which we process the data.
In individual cases, we collect personal data only to the extent necessary to achieve these purposes. If personal data is no longer required for our use, it is deleted.

V. Your rights in relation to the data used
If and insofar as we use personal data relating to you, you have the following rights in relation to such data:

  • Right of access (Art. 15 GDPR):
    You can demand information at any time as to whether personal data relating to you is being processed by us and if so, to demand that we inform you of the specific information, as well as the purposes of its processing, the origin of the data, any recipients to whom the data has been transmitted and the length of time that such data has been stored by us.
  • Right to correction (Art. 16 GDPR):
    If you become aware that personal data relating to you is incorrect, you can demand the correction of such data at any time. Insofar as you consider data to be incomplete, you can also demand that any missing data be added.
  • Right to erasure (Art. 17 GDPR):
    If you believe that the processing of your personal data is no longer necessary or that such use is occurring without a sufficient legal basis or is illegal for other reasons, you can demand the erasure of this data.
  • Right to restriction of processing (Art. 18 GDPR):
    Instead of erasure, you can also demand that data processing be restricted if data is being processed illegally. In particular, you can also demand such restriction of data processing if you dispute the correctness of the data or have filed an objection against an instance of data processing.
  • Right to data portability (Art. 20 GDPR):
    With regard to the personal data that you have created yourself and which is used on the basis of a contract or consent, you can demand that this data be provided to you in a structured, common and machine-readable format. You can also demand that this data be sent directly to another responsible person.
  • Right to object (Art. 21 GDPR):
    If in your special situation there are reasons that make it illegal to process personal data relating to you, which we are processing on the basis of a weighing of interests, you have the right to object to such data usage. Insofar as your personal data is processed for direct advertising, you also have a right to object.
  • Right to lodge a complaint with a supervisory authority (Art 77 GDPR):
    If you believe that your rights in relation to personal data relating to you have been infringed, you have the right to lodge a complaint with a supervisory authority. In particular, you can do so with the supervisory authority that is responsible for your place of residence, place of work or the place of suspected infringement. The  European Data Protection Supervisor is located at Rue Wiertz 60, B-1047 Brussels: email edps@epds.europa.eu

If you have questions about your rights in relation to your personal data or want something clarified, you can contact us at any time at the following email address: dataprotection@cooliance.com

V. Processing of data by social networks
In the future, this website may social media plugins of various social networks. These plugins are functions of the respective social network that enable you to share content from our website with your contacts in the social networks or to recommend this content, for example. The social media plugins will be recognized by the logo of the respective social network.

The following social media plugins from the following social network operators may be used:

  • Twitter: Twitter Inc., Folsom St., Suite 600, San Francisco, CA 94107, USA
  • LinkedIn: LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA
  • YouTube: YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066, USA

Social media plugins with the exception of YouTube are deactivated by default, which means that simply accessing the Cooliance website does not result in any data being transferred to the social network providers. If you want to use the functionality of the respective social network and therefore activate an initially deactivated social media plugin, you are expressly consenting for data to be transferred to the social network operator from that time forward. We have no influence on the scope of data collected in this way by the providers of social networks.

To our knowledge, the following data is transferred:

  • IP address
  • User identification, if you are logged into the respective service
  • Previously visited page (referrer), if you followed a link
  • Type of browser and browser settings
  • installed plugins like Adobe® Flash® or Adobe® Reader®
  • URL of the page on which the social media plugin is integrated
  • The date and time of the visit
  • Technical data relating to the operating system
  • Location-specific information
  • Cookies

Through the integration of the plugin, the operators of the social networks receive the information that you accessed the respective pages of our online presence. If you are at the same time logged in to a social network, the operator can associate these page views with your account on the respective social network. If you then go on to interact with the social media plugins, e.g., clicking the Facebook “Like” button, that information is also transmitted to the respective social network. Even if you are not a member of any said social networks, it is possible that via the social plugin they may become aware of your IP address and store it. For details about the purpose and scope of data processing, collection and use by the social networks used by us and your rights and setting options in this regard, please consult the privacy policies of the social networks:

  • Twitter: www.twitter.com/privacy
  • LinkedIn: http://www.linkedin.com/legal/privacy-policy
  • YouTube: https://policies.google.com/privacy

If desired you can permanently activate the plugins of one or more social media providers. In this case, whenever you access a page, data is always transmitted to the social network provider. You can deactivate certain or all social media plugins at any time. Moreover, you may be able to render data transmission to social media networks technically impossible. To do so, please adjust the security settings in your web browser, for instructions on how to do so, please consult the “Help” section in your web browser.

VI. Cookies
We use cookies on our website in order to enable the use of certain website functions, analyze user activity on our website and offer certain third-party services.

Cookies are small text files stored on your computer. Most of the cookies we use are deleted from your hard drive at the end of your browser session (“session cookies”). Other cookies remain on your computer and enable us to recognize your computer on your next visit (“persistent cookies”). In addition, cookies placed by third party providers are used on our website.

You can prevent the saving of cookies by selecting the appropriate browser setting. Please note, however, that if you do so, some functions of this website may not be fully available.

If you do not wish to have cookies stored on your computer, please deactivate the storing of cookies in your browser for our website or configure your browser so that cookies in general are not stored on your computer. You can also delete previously saved cookies using your browser.

Deactivating the use of cookies may also require that a persistent cookie be saved on your computer. If you delete this cookie at a later time, you have to deactivate cookies again.
The following categories of cookies are used on our website:

I. Session cookies
To facilitate browsing on our website, we place a session ID (“session identifier”) that is associated with each visitor when they start using our website. This session ID allows our server to identify you and/or your computer/browser as the same visitor, even if your IP address has changed. This session ID makes it possible to associate multiple related requests by a user with a single session. The session ID cookie is only valid until the end of a session. When you close your browser, it is automatically deleted.

II. Persistent cookies Google Analytics
This website uses Google Analytics, a web analytics service of Google Inc. (“Google”). Google Analytics also uses cookies that make it possible to analyze how you use the website, among other things. The information generated by these cookies is usually transmitted to a Google server in the US and stored there. Google uses this information on behalf of the operator of this website to analyze your use of the website, to compile reports about website activities and to render other services for the website operator related to use of the website and internet. These reports and services are used to continuously improve the offerings of this website.

You can prevent the saving of cookies by selecting the appropriate browser setting. Please note, however, that if you do so, some functions of this website may not be fully available.

Moreover, you can prevent the collection by Google of the data generated by these cookies and the data related to your use of the website (incl. your IP address) as well as the processing of this data by Google; to do so, click the following link, and download and install the Google plugin available for your browser: https://tools.google.com/. Additional plugins of this sort are also available from other providers, depending on the browser used.

In light of the discussion around the use of complete IP addresses in analytic tools, we wish to note that this website uses Google Analytics with the “anonymizeIp()” extension and as such, the IP addresses are only processed in truncated form in order exclude direct association with a person. Your IP address is therefore truncated by Google within European Union member states and other signatories to the Treaty on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the US and truncated there. The IP address supplied by your browser within the scope of Google Analytics is not combined with other Google data.

III. Third party cookies
Services by third party providers are also integrated within the framework of our website. With regard to these services, however, processing of personal data performed by the providers listed below falls outside the scope of responsibility of the provider of this website.

a. Google Maps
Some pages of this website use Google Maps to depict interactive maps and generate directions. Google Maps is a map service of Google Inc., 1600 Amphitheater Parkway, Mountain View, California 94043, USA. Through the use of Google Maps, information about the use of this website, including your IP address and the (origin) address entered for the route planning function, is transmitted to Google in the US.
If you access a web page on our online presence that contains Google Maps, your browser establishes a direct connection with Google servers. The map content is directly transmitted by Google to your browser, which integrates it into the website. We, therefore, have no influence on the scope of data collected by Google in this manner.
To our knowledge, this includes the following data, at a minimum:

  • The date and time of the visit to the respective website
  • Internet address or URL of the accessed website
  • IP address
  • (Origin) address entered for route planning

We have no influence on the further processing and use of the data by Google, and therefore, we cannot assume any responsibility in this regard.

If you do not want Google to collect, process or use data about you via our website, you can deactivate JavaScript in your browser settings. In this case, however, you cannot use the map function. For the purpose and scope of data collection and the further processing and use of the data by Google as well as your rights in this regard and settings options to protect your private sphere, please consult the Google privacy policy: https://policies.google.com/privacy?hl=en-gb&gl=en.

b. YouTube
Some pages of this website integrate YouTube videos or provide links to YouTube videos. YouTube is a video service of YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA, represented by Google Inc. YouTube uses cookies to collect information about the use of the videos. The Google privacy also applies to YouTube and is available at https://policies.google.com/privacy?hl=en-gb&gl=en.

VII. Links to other websites
Our website contains hyperlinks to the websites of other providers. If you click on one of them, you will be directed from our website directly to the website of the other provider. This is evident from the change in URL in the address bar of your browser. We cannot assume any responsibility for the confidential handling of your data by such providers since we have no influence on the compliance of the other providers with data protection provisions. For information about how your personal data is handled by these providers, please consult their websites directly.

IX. Security measures to protect your data
To protect your data, we take special technical and organizational security measures, which are reviewed and adapted to technological process on a regular basis.

Please note, however, that due to the structure of the internet, it is possible that data protection and data security rules will not be observed by other persons or institutions outside our scope of responsibility.


VIIII. Amendment of data protection provisions
Since amendments to legislation or changes in our internal company processes may make it necessary to amend our data protection provisions, we reserve the right to do so, and we ask that you read this data protection policy regularly.