PRIVACY POLICY

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COMPANY PRIVACY POLICY

Data Protection Declaration and Consent to Use Data by https://clear-forward.com and https://clear-forward.nl Data protection is a matter of trust and your trust is important to us. We respect your personal space and your privacy. Therefore, protecting personal data and collecting, processing and using them in conformity with the law is an important concern to us. So that you feel safe while visiting one of our web pages, we strictly adhere to legal provisions when we process your data and would like to inform you here about our data collection and use of data. By agreeing to the following data protection declaration, you consent to ClearForward BV (Keizersgracht 676, 1017 ET Amsterdam) collecting, processing and using your personal data by adhering to the data protection laws and the following provisions.

1. Responsible Body

The body responsible for collecting, processing and using your personal data in terms of the Federal data protection laws is ClearForward BV (Keizersgracht 676, 1017 ET Amsterdam). Should you wish to object to ClearForward collecting, processing and using your personal data in accordance with these data protection provisions in total or only to individual measures, you can send your objection by email or letter to the following contacts:

ClearForward BV

Keizersgracht 676

1017 ET Amsterdam

info@clear-forward.com

2. Collecting, Processing and Using Personal Data

We only store and process personal data when you have voluntarily supplied us with it; such as by filling in a contact form. If we collect any other personal data, you will be informed in this privacy policy or on the respective web pages, of the intended purpose of use and, if necessary, asked for your consent to store and process the data. Your personal data will only be disclosed or otherwise transmitted if this is necessary to implement the contract, render our services or you have given your prior consent.

3. Newsletter

For sending the Newsletter we make use of the e-mail address given by you and for this we need your confirmation that, as the owner of the e-mail address, you consent to its receipt (so-called Double Opt-in-Procedure). Should you later decide that you no longer want to receive a newsletter from us, you can object to this at any time without thereby incurring any other costs than the transmission costs in keeping with the basic tariffs. Notification in text form sent by one of the contact options given under point 1 (e.g. email or letter) is sufficient for this purpose. There is, of course, also a cancellation link in every newsletter.

4. Cookies

We use cookies only to make the use of our pages easier for you. Certain pages may store personal data on cookies if you have explicitly agreed to this in advance. In principle, you can also access all the information on our web pages if you have disabled cookies. In case you do not accept cookies, this can lead to a limitation of functionality.

5. Log Files

During every access of our page user data is transmitted by the respective Internet browser and stored in protocol files, the so-called server log files. The datasets stored here contain the following data: date and time of access, name of accessed page, IP address, referrer URL (original URL from which you arrived at the website), the amount of data transmitted, product and version information of the browser used. Subject to possible legal retention obligations, users’ IP addresses are deleted or anonymised after use has been ended. During an anonymisation the IP addresses are changed in such a way that the individual information about personal or material circumstances can no longer be allocated to a certain or to an ascertainable person except with an unreasonably high expense of time, money and manpower.

6. Web Analysis

In order to constantly improve and optimize our offer we make use of so-called tracking technologies. To this end we make use of the services of Google Analytics. Google Analytics is a service from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics makes use of “cookies”, i.e. text files that are stored on your computer and enable an analysis to be made of our offer by Google. The information recorded by the cookies on the use made of our websites (including your IP address) is normally transmitted to a Google server in the USA and stored there. We draw your attention to the fact that on our websites Google Analytics were extended by the code “gat._anonymizeIp();” to ensure an anonymized record of IP addresses (so-called IP masking). At our request, your IP address is therefore recorded by Google solely in shortened form, which ensures anonymization and allows no inferences to be made to your identity. In the event that the IP-anonymize function is activated on this website, your IP address will previously be shortened by Google within the member countries of the European Union or in other contracting states that were party to the agreement on the European Economic Area. Google will make use of the said information to evaluate your use of our websites, to prepare reports on the website activities for us and to provide us with further website-related and Internet-related services. The IP address transferred from your browser by Google Analytics is not brought together by Google with other data collected. Any transfer of this data to a third party by Google is made solely on the basis of statutory regulations or within the framework of order data processing. On no account will Google bring your data together with other data recorded by Google.

By using these websites, you declare that you consent to the processing of the data collected on you by Google and the previously described manner of data processing, as well as the described purpose. You can prevent the storage of the cookies by adjusting your browser-software settings appropriately. In this case, however, we draw your attention to the fact that you may not then be fully able to use all the functions of these websites. You can also prevent the acquisition by Google of the data generated by the cookie and relating to your use of the website (incl. your IP address) as well as its processing by Google in that you download and install the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

7. Safe Data Transmission

Your data is transmitted safely by using encryption. Nevertheless, nobody can guarantee absolute protection. However, we secure our website and other systems with technical and organizational measures against the loss, destruction, access, change or dissemination of your data by unauthorized persons.

8. Right of the Concerned to Receive Information

According to the applicable data protection laws, you have the right to free information regarding the stored data on you as well as the right to correct, block or delete this data.

We take the protection of your data very seriously. In order to ensure that personal data is not given to third parties, please send your request by email or by mail to the following address, clearly stating your identity:

ClearForward BV

Keizersgracht 676

1017 ET Amsterdam

info@clear-forward.com

Data-Protection Statement and Consent to Use of Data www.clear-forward.com and www.clear-forward.nl

Data protection is a matter of trust and your trust is important to us. So that you can feel secure when visiting our websites, we strictly observe the statutory regulations in processing your person-specific data and we would like to inform you here about our data acquisition and data utilization. The following data-protection statement explains to you which data is collected from you on our websites, which parts of this data we process and use and in which way, and to whom you can turn with any concerns or requests.

1. Body Responsible, and Rights of Those Affected

The body responsible for the acquisition, processing and utilization of your person-specific data, in the sense of the Dutch Data Protection Law is ClearForward BV (hereinafter referred to as ClearForward). As the body responsible, ClearForward can be reached by you via the following contact options:

– by post under ClearForward BV, Keizersgracht 676, 1017 ET, Amsterdam

– by e-mail under info@clear-forward.com

You can request, at any time and free of charge, information about your data stored by us, and can exercise your right to correction, blockage or deletion of your data. To this end you can make use of the previously mentioned contact options.

Should you object to the acquisition, processing or utilization of your data by ClearForward in keeping with the stipulations of these data-protection provisions, whether entirely or for individual measures, you can send your objection per e-mail or by letter again using the previously mentioned contact options.

2. Acquisition, Processing and Utilization of Person-Specific Data

Person-specific data describes details relating to the actual or personal relationships of a specific or identifiable natural person. Such details include, for example, your name, your telephone number, your address, and all existing data that you disclose to us during registration and when opening your client account.

2.1 Client accounts

Client Account For each client who registers with us via the [register now] function, we set up a client account, i.e. password-protected, direct access to his or her existing data stored by us. This allows you, amongst other things, to view your already-concluded, still open and recently sent orders, or to manage your personal data.

2.1.1 Setup of the Client Account

The following data must be given during the registration for a client account (obligatory disclosures):

– your forename

– your surname

– your company name

– your (company) address

– your email address

– VAT/TAX ID number

– phone number

– your bank account details

– consent to the check on credit standing and to the data-protection provisions

Your invoice and delivery address need not be given until you order something. For your order we need your correct name, address and payment data. We need your e-mail address so that we can confirm receipt of your order and its dispatch, and so that we can communicate with you in general. We also use your e-mail address to identify you (as a log-in name), when you visit your client account.

2.1.2. Use of the Client Account

You can use your ClearForward client account to log-in to our ClearForward web shop. We will only pass on your data to these services if you log in there. If the services are not those of ClearForward BV, the passing on of data will even then only take place with your consent, which you can give during the respective log-in process.

2.2 Acquisition, Processing and Utilization of Your Person-Specific Data

We collect, store and process your data for the entire processing of your purchase, including any subsequent guarantee claims, for our services, the technical administration, our own marketing purposes (more information on these under point 2.3) and to prevent criminal offences and fraud. Your person-specific data is only passed on to third parties to the extent that this is legally permissible, including the purpose of processing the contract or for invoicing, for marketing or if you have previously consented to this. When processing orders, for example, the service companies used by us (transport companies, logistics companies, banks) are sent the data they require for processing and concluding orders. The data passed on to our service providers in this context may only be used by them for fulfilling their duties.

2.3 Use of Your Data for Advertising Purposes

Apart from the processing of your data for settlement of your purchase at ClearForward, we also use your data for the following purposes: to permanently improve your purchase experience and for making this more client-friendly and individual for you; to communicate with you about your orders, and about certain products or marketing campaigns; and to recommend products or services that might interest you.

To this end we use the information available, such as confirmations of receipts and reading confirmation of e- mails, information on the terminal device used by you, your connection to the Internet, operating system and platform, date and time of the visit to the home page, or products that you have looked at, as well as information that we have received from you (including automatically transferred or generated information). Apart from this we also make use of your order history.

The utilization of your person-specific data for advertising purposes can be objected to at any time, whether all-in-all or as regards individual measures, without any tariffs, other than the transmission costs in keeping with the basic tariffs, being thereby incurred. Notification in text form sent by one of the contact options given under point 1 (e.g. e-mail, fax, letter) is sufficient for this purpose.

2.3.1 Newsletter

For sending the Newsletter we make use of the e-mail address given by you and for this we need your confirmation that, as the owner of the e-mail address, you consent to its receipt.

Should you later decide that you no longer want to receive a newsletter from us, you can object to this at any time without thereby incurring any other costs than the transmission costs in keeping with the basic tariffs. Notification in text form sent by one of the contact options given under point 1 (e.g. email, letter) is sufficient for this purpose. There is, of course, also a cancellation link in every newsletter.

2.3.2 Banner Ads

We also use the data collected during your visit to show you so-called banner ads. These are advertisements which we also use on third sites. It usually involves the use of so-called cookies or pixels. Our aim here is to make the advertising offers more useful and more interesting for you, which is why you will see, in the context of the banner ads, mainly products that you have either already looked at on our site or products that are similar to those already looked at by you (so-called re-targeting). Within the framework of the banner ads we work solely with pseudonymous data; clear-text information relating to your person (e.g. your name or your e-mail address) is not used in the cookies.

You can find more information on cookies, pixels and re-targeting under point 4 and point 7 of this policy statement.

3. Cookies

The acceptance of cookies is not a prerequisite for access to our websites. We draw your attention, however, to the fact that our website and service has only limited functionality, if you do not allow us to place cookies.

What are cookies?

Cookies are small files that are stored on your data carrier and hold certain settings and data for exchange with our system via your browser. Basically, speaking there are 2 different types of cookies: the so-called session cookies, that are deleted as soon as you close your browser; and temporary/permanent cookies, that are stored on your data carriers for a longer period or without limit. This type of storage helps us to design our websites and our offers for you and makes it easier for you to use them in that, for example, certain input from you can be stored so that you are not required to enter this repeatedly.

Which cookies are used by ClearForward?

Most of the cookies used by us are automatically deleted from your hard disk at the end of the browser session (hence the term “session cookies”). Session cookies are needed, for example, to make the shopping-basket function available to you over several pages. In addition to these we also make use of cookies that remain on your hard disk. On a subsequent visit it is then automatically recognized that you have previously visited us, and we know which input and settings you prefer. These temporary or even permanent cookies (lifespan of 1 month to 10 years) are stored on your hard disk and are automatically deleted after the pre-specified period. These cookies in particular serve to make our offer more user-friendly, more effective and more secure. Thanks to these files it is possible, for example, that the site shows you information that has been specially selected to match your interests. The sole purpose of these cookies is to adapt our offer to your client wishes as well as possible and to make surfing with us as comfortable as possible for you.

What data is stored in the cookies?

In the cookies used by ClearForward, only pseudonymous data is stored. On activation of the cookie this is allocated an identification number; an allocation of your person-specific data to this identification number is not undertaken. Your name, your IP address and other such data that might allow the cookie to be traced to you directly are not placed in the cookie. On the basis of the cookie technology we receive only pseudonymized information, relating for example to which of our shop pages have been visited, which products were viewed, etc.

What is on-site targeting?

On the ClearForward websites data is collected on the basis of a cookie technology for optimization of our advertising and of the entire online offer. This data is not used to identify you personally but solely serves the purpose of conducting a pseudonymous evaluation of the use made of the home page. With this technology we can present advertising and/or special offers and services to you, the content of which is based on information obtained from a connection to click-stream analysis (for example, advertising that is based on the fact that during the past few days only sports shoes have been viewed). Our aim here is to make our online offer as attractive for you as possible and to present to you advertising that corresponds to your areas of interest.

Are there also cookies from third-party suppliers (so-called “third-party cookies”)?

ClearForward makes use of a number of web partners who help to make the Internet offer and the websites more interesting for you. This is why, when visiting the websites, the cookies of partner companies are also stored on your hard disk. These cookies are temporary/permanent cookies that are deleted automatically after the pre-specified period. These temporary or even permanent cookies (lifespan of 14 days to 10 years) are stored on your hard disk and delete themselves after the pre-specified period. The cookies of our partner companies also contain solely pseudonymous – mostly even anonymous – data. This relates, for example, to data on which products you have looked at, whether anything was bought, which products were searched for, etc. Here, some of our advertising partners also collect information from the websites on which pages you have previously visited or which products you were interested in, in order to be able to show you advertising that best complies with your interests.

Re-Targeting Our websites make use of so-called re-targeting technologies. We use these technologies to make the Internet offer more interesting for you. This technique allows Internet users who have already shown an interest in our shop and our products to also be provided with suitable advertising on the websites of our partners. We are convinced that the use of personalized, interest-oriented advertising is generally more interesting for the Internet users than advertising that has no such personal content. The use of this advertising approach by our partners is undertaken on the basis of a cookie technology and an analysis of previous utilization behaviour. This form of advertising is completely pseudonymous. On using our sites cookies are deployed and thereby usage data is collected from you, stored and utilized. Your data is furthermore stored in cookies beyond the end of the browser session so that it can, for example, be called up again on your next visits to the websites.

How can you prevent the storage of cookies?

In your browser you can adopt the setting that storage of cookies is only permissible when you agree to it, and thereby prevent the further storage of cookies in the future. If you want to accept only the ClearForward cookies but not the cookies of our service companies and partners, you can select the browser setting [Block third-party cookies]. As a rule, the help function in the menu bar of your web browser will show you how to reject new cookies and how to inactivate old ones.

4. Log Files

With each access to the pages of ClearForward usage data is transmitted by the respective Internet browser and is stored in record files, the so-called server log files. The records stored in this way contain the following data: date and time of the call-up, name of the page called up, IP address, referrer URL (URL of origin, from which you came to the websites), the quantities of data transferred, product information and the version of the browser used. These log file data records are evaluated by us, to help us further improve our offer and the ClearForward shop, as well as to make these more-user-friendly, to detect and correct errors more quickly and to control server capacities. At the same time, we use the log-file data records to defend our ClearForward shop against attacks, e.g. in the context of so-called distributed-denial-of-service attacks, which are intended to block access to our ClearForward shop by overloading it with enquiries.

5. Web Analysis

In order to constantly improve and optimize our offer, we make use of so-called tracking technologies. For this purpose, we enlist the services of Google Analytics.

5.1 Google Analytics

This website makes use of Google (Universal) Analytics, a web-analysis service from Google Inc. (www.google.com). Google (Universal) Analytics deploys methods that make it possible to analyse the use made of the website by you, e.g. the so-called “cookies”, which are text files that are stored on your computer. The information generated on your use of this website is transmitted, as a rule, to a Google server in the USA and stored there. By activating the IP-anonymize function on this website the IP address is shortened, within the member countries of the European Union or in other contracting states that were party to the agreement on the European Economic Area, before further transfer. Only in exceptional cases is the full IP address sent to a Google server in the USA and shortened there. The anonymized IP address transferred by your browser within the framework of Google Analytics is not brought together with other Google data.

You can prevent the acquisition of the data generated by the cookie and relating to your use of the website (incl. your IP address) by Google, as well as its processing by Google, in that you download and install the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

As an alternative to the browser plug-in you can click this link in order to prevent the recording by Google Analytics on this website in the future. In this case an opt-out cookie will be placed in your terminal device. If you delete your cookies you must then click the link again.

6. Re-Targeting and Data Acquisition by Third Parties

We make use of the services of third parties, which set cookies on our sites. These are the following companies:

– Double-click by Google, Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA;

https://www.google.de/intl/en/policies/technologies/ads/

– Fair Marketing, Fair Marketing, Inc. 26310 Oak Ridge Dr. G4 Spring, TX 77380

– Stripe, Stripe, Inc. and its affiliates (collectively “Stripe”)

– MailChimp, is an online marketing platform (the “Services”) operated by The Rocket Science Group LLC, a company headquartered in the State of Georgia in the United States

– EasyRx, EasyRx, LLC, a Georgia limited liability company

– Orchestrate, Orchestrate Orthodontic Technologies. 1747 North Riverside Avenue Rialto, California 92376

– 10Forward BV, 10Forward, Keizersgracht 676, 1017 ET Amsterdam

7. Social Plug-Ins

This Internet presentation makes use of a social plug-in from Facebook (Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA) on several pages only. This plug-in is normally deactivated and therefore sends no data. With a click on the plug-in, or more precisely on the icon [Activate Social Media], you can activate the plug-in. The plug-ins can be deactivated again by clicking in the same place again.

When this plug-in is activated, your browser makes a direct connection to the Facebook servers as soon as you call up a website containing this plug-in. The content of the plug-in is transmitted directly from Facebook to your browser and is integrated by this in the website.

With the activation of the plug-in Facebook is informed that you have called up the corresponding page of our Internet presentation. If you are logged in with the social network, this can assign the visit to your account.

For the purpose and extent of the data acquisition and further processing and utilization of the data by Facebook and your rights in this connection and the setting options for protection of your private sphere, please refer to the data-protection information provided by Facebook: https://www.facebook.com/about/privacy/ .

Even if you are not registered with the social networks, data can be sent to the networks by websites with active social plug-ins. With an active plug-in, with each call-up of the websites a cookie with an identification is set. Since your browser automatically sends this cookie to Facebook every time you connect with a network server, the network could in principle prepare a profile on which websites the user to whom the ID belongs has visited. And it would then indeed be possible to later trace this ID to a specific person – if you were later to register with the network, for example.

8. Safer Data Transfer

Your personal data is securely transferred by us with the help of coding. This naturally also applies to your orders, as well as to the client login. Here we make use of the coding system TLS (Transport Layer Security) or SSL (Secure Socket Layer).

With the help of both technical and organizational measures, moreover, we secure our websites and other systems against loss, destruction, access, alteration and distribution of your data by unauthorized persons.