Legal
Privacy Policy

Effective date: January 1, 2020

The controlex GmbH offers with GroupLotse a virtual group assistant for digitizing decision-making processes of groups, which can be used via various third-party services (collectively the “Service”) and websites, especially www.grouplotse.com (the “Website”).. As you use the Service and interact with the Websites, GroupLotse collects and processes information from and about you in order to provide you with access to the Service, enhance your experience while using the Service, and interact with you. This Privacy Policy (the “Policy”) describes how GroupLotse collects, uses, and discloses information collected through the Service and Websites, and what choices you have with respect to such information. The first section below explains which privacy terms are applicable to you depending on what type of user you are.

References to “GroupLotse” throughout the Policy mean the GroupLotse entity that acts as the data controller or data processor of your information, as explained in more detail below. If you do not agree with this Policy, do not access or use the Service, Websites, or any other part of GroupLotse’s business.

If you have any questions about this Privacy Policy, please contact GroupLotse at: controlex GmbH – GroupLotse, Philosophenweg 31-33, 47051 Duisburg, Germany or by emailing us at privacy@grouplotse.com.

This Privacy Policy contains the following sections:

I. What Type of User am I and What Privacy Terms are Applicable to Me?

II. Privacy Terms for Subscribers

III. Privacy Terms for Free Users

IV. Privacy Terms for Site Visitors

V. Additional Privacy Terms for All Users

VI. GroupLotse Contact Info

I. What Type of User am I and Which Privacy Terms Are Applicable to Me?

GroupLotse has three different types of users depending on the GroupLotse products used. Please see the bullets below to determine which type of user you are, and then click the internal link to visit the privacy terms applicable to you. It is possible that you may use GroupLotse in different ways. If so, please review all applicable privacy terms. Also, don’t forget to review Section E, which contains privacy terms applicable to all users.

Subscribers

We call users who use the Service as part of any tier of a paid GroupLotse subscription plan “Subscribers.” The Service features and functionalities available to Subscribers are determined by the specific terms agreed to between GroupLotse and the organization (e.g., your employer or another entity or person, called the “Customer”) that entered into a separate agreement that governs delivery, access, and use of the Service (for purpose of this Policy, the “Customer Agreement”). The Customer controls its instance of the Service and is the data controller of the information collected through the Service about group- and channel member, and GroupLotse is a data processor of such information. To go directly to the terms applicable to Subscribers, please click here.

Free Users

We call users who use a non-paid version of the Service “Free Users.” While Free Users can access and use the Service, they have access to a more limited set of Service features and functionality than Subscribers. GroupLotse is the data controller of the information collected through the Service about Free Users. To go directly to the terms applicable to Free Users, please click here.

Site Visitors

We call users of the Websites “Site Visitors.” Site Visitors can be individuals who are simply browsing the Websites but who do not use the GroupLotse Service; or, Site Visitors can be Free Users or Subscribers who visit the Websites to seek additional information about GroupLotse. GroupLotse is the data controller of the information collected through the Website about Site Visitors. To go directly to the terms applicable to Site Visitors please click here.

II. Privacy Terms for Subscribers

A. Overview

Section II of this Policy applies only to Subscribers. If you are a Subscriber, the “Customer Agreement” governs the collection and processing of information collected by GroupLotse, including all associated messages, attachments, files, tasks, projects and project names, team names, channels, conversations, and other content submitted through the Service. In the event of a conflict between this Privacy Policy and the Customer Agreement, the Customer Agreement governs. If you are a Subscriber located in the European Union, please note that the you are the data controller with respect to the processing of your group or channel content pursuant to the EU General Data Protection Regulation (“GDPR”). When processing group or workspace Content of EU data subjects governed by the Customer Agreement, GroupLotse is the data processor, meaning that we collect and process such information solely on behalf of the Customer.

B. Collection and Use of Subscriber Information

This section explains the information we collect from Subscribers. We do not require Subscribers to provide us with information. However, certain information, such as account log-in data, is required to provide you with access to the Service, and other information may be collected automatically as you use the Service.

1. Group and Channel Content
Workspace Content is collected, used, and shared by GroupLotse in accordance with the Customer’s instructions, including any applicable terms in the Customer Agreement, or as required by applicable law. The Customer, and not GroupLotse, determines its own, internal policies regarding access, modification, deletion, sharing, and retention of Group- and Channel Content which may apply to your use of the Service. For example, a Customer may provide or remove access to messages of an IoT device, enable or disable third party integrations.

2. Account Information
To set up your GroupLotse account, you as the Customer will provide us with the following information about you: username and telephone number. If you submit payment information in connection with your use of the Service, we utilize a third party processing company to collect payment information, including your credit card number and billing address. In such circumstances, the third party service provider, and not GroupLotse, stores your payment information on our behalf.

3. Service Usage Information
As you use the Service, we collect information about how you use and interact with the Service (“Service Usage Information”). Such information includes: Metadata – when you interact with the Service, metadata is generated that provides high-level (non-content) information about the way you work with the Service. For example, we may log the number of groups or channels you work in; the number of actions you have triggerd; the features and embedded Service content you interact with; the types of files you share; and what, if any, third party services and integrations you use. We do not have access to any data you share in a group or a channel outside the GroupLotse service.

4. Other Informations
You may provide us with information when you interact with us in other ways, such as when you submit requests or questions to us via forms or email (e.g., support forms, sales forms, user research participation forms); information you provide in connection with GroupLotse beta testing and requests for customer support or technical assistance (collectively, “Other Information”).

5. Information Collected from Third Party Integrations
If you choose to use or connect to third-party integrations (e.g. Slack, Microsoft Teams, Telegram, IFTTT) through the Service such third parties may allow us to have access to and store additional information about your interaction with those services as it relates to your use of the Service. If you initiate these connections, you also understand that we will share information about you that is required to enable your use of the third-party integration through the Service. If you do not wish to have this information shared, do not initiate these connections. By enabling these connections, you authorize us to connect and access the information provided through these connections, and you understand that the privacy policies of these third parties govern such connections.

Our GroupLotse service is enabled by Microsoft Bot Framework. The Microsoft Bot Framework is a set of web-services that enable intelligent services and connections using conversation channels you authorize. As a service provider, Microsoft will transmit content you provide to our service in order to enable the service. For more information about Microsoft privacy policies please see their privacy statement here . In addition, your interactions with this service are also subject to the conversational channel’s applicable terms of use, privacy and data collection policies. To report abuse when using a bot that uses the Microsoft Bot Framework to Microsoft, please visit the Microsoft Bot Framework website and use the “Report Abuse” link in the menu to contact Microsoft.

We use in general only the minimum data requirements which are necessary for the third-party integration.

C. How Does GroupLotse Use Subscriber Information?

This section explains how GroupLotse uses information collected from Subscribers.

1. GroupLotse may view and use Content collected from and about Subscribers only as necessary:

• To maintain, provide and improve the Service

• To prevent or address technical or security issues and resolve support requests

• To investigate when we have a good faith belief, or have received a complaint alleging, that Content is in violation of the Customer Agreement or our User Terms of Service

• As otherwise set forth in our Customer Agreement or as expressly permitted in writing by the Customer

2. Account Information, Service Usage Information, Information from Third Party Integrations, and Other Information. GroupLotse May Use These Categories of Information Collected from and about Subscribers to:

• Maintain, provide, and improve the Service

• Respond to your requests for information

• Prevent or address technical or security issues and resolve support requests

• Investigate in good faith alleged violations of our User Terms of Service

• Help us better understand user interests and needs, and customize the Service for our users

• Engage in analysis, research, and reports regarding use of the Service

• Protect the Service and our users

• Communicate with you via email and through the Service about important notices and updates regarding the Service, such as to inform you about changes in the Service, our service offerings, and important services-related notices, such as about security and fraud. Because these communications are an important part of the Service, you may not opt out of them.

• In accordance with applicable legal obligations, communicate with you about promotions, offers, and news about GroupLotse. You have the ability to unsubscribe from such promotional communications.

• Provide cross-device management of your account. For example, we may locate or try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), or work with service providers that do this, in order to save your preferences across devices and analyze usage of the Service.

D. Sharing of Subscriber Information

In accordance with the applicable Customer Agreement, we may share the information we collect from Subscribers as follows:

1. Affiliates and Subsidiaries: We may share the information we collect within the GroupLotse family of companies.

2. Service Providers: We may provide access to or share your information with select third parties that use the information only to perform services on our behalf. These third parties provide a variety of services to us, including without limitation sales, marketing, provision of content and features, analytics, data storage, security, fraud prevention, and other services.

3. Business Transactions: If the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the service can continue to operate. In such case, your information would remain subject to the promises and commitments contained in this Policy until such time as the acquiring party modifies it. If such transfer is subject to additional mandatory restrictions under applicable laws, GroupLotse will comply with such restrictions.

4. Consistent with your settings within the Service. Please note that the Group and/or Channel Content you submit through the Service may be viewable by other users in your Groups or Channels.

E. Aggregate De-Identified Data

We may aggregate and/or de-identify information collected through the Service so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and analytics, and may also share such data with any third parties, including partners, affiliates, services providers, and others

F. Combined Information

We may combine the information that we collect through the Service with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Policy and the Customer Agreement.

G. Data Retention

We will retain your information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law, or where the Customer Agreement requires or permits specific retention or deletion periods.

H. Data Subject Rights

Please contact your Group or Channel administrator(s) to exercise any data subject rights you have under applicable local laws, including your ability to access, delete, rectify, transfer, or object under the GDPR.

III. Privacy Terms for Free Users

A. Overview

Section III of this Policy applies only to Free Users of the Service. If you are a Free User located in the European Union, GroupLotse is the data controller with respect to the processing of your personal data pursuant to the GDPR.

B. Collection and Use of Free User Information

This section explains how we collect, process, and use the information collected from Free Users. We do not require Free Users to provide us with information. However, certain information, such as account log-in data, is required to provide you with access to the Service, and other information may be collected automatically as discussed below.

1. Information You Provide to GroupLotse.
GroupLotse collects the following information submitted directly through the Service by Free Users:

• The messages, attachments, files, tasks, groups, channels, actions, and other content submitted through the Service (collectively, the “Workspace Content”), files and attachments are only stored until the forwarding to third-party integration services (Slack, Microsoft Teams, Telegram);

• Information you provide as part of your account registration with GroupLotse, which may include yourtelephone number, username and password (collectively, the “Account Information”); and

• Information you provide in other interactions with us, such as requests or questions you submit to us via forms or email (e.g., support forms, sales forms, user research participation forms), information you provide in connection with GroupLotse sweepstakes, contests, or research studies in which you choose to participate; beta testing; and requests for customer support and technical assistance (collectively, “Other Information”).

2. Service Usage Information.
As you use the Service, we collect a variety of information about how you use and interact with the Service (“Service Usage Information”). Such information includes:

• Metadata – when you interact with the Service, metadata is generated that provides high-level (non-content) information about the way you work in your Workspace. For example, we may log the number of Groups and Channels you work in; the number of tasks to which you are assigned; the features and embedded Service content you interact with; the types of files you share; and what, if any, third party services and integrations you use. We do not have access to any data you share in a group or a channel outside the GroupLotse service.

3. Information Collected from Third Party Integrations.
If you choose to use or connect to third-party integrations (e.g., Slack, Telegram, Microoft Teams, IFTTT) through the Service, such third parties may allow us to have access to and store additional information about your interaction with those services as it relates to your use of the Service. Moreover, if you initiate these connections, you also understand that we will share information about you that is required to enable your use of the third-party integration through the Service. If you do not wish to have this information shared, do not initiate these connections. By enabling these connections, you authorize us to connect and access the information provided through these connections, and you understand that the privacy policies of these third parties govern such connections.

Our GroupLotse service is enabled by Microsoft Bot Framework. The Microsoft Bot Framework is a set of web-services that enable intelligent services and connections using conversation channels you authorize. As a service provider, Microsoft will transmit content you provide to our service in order to enable the service. For more information about Microsoft privacy policies please see their privacy statement here. In addition, your interactions with this service are also subject to the conversational channel’s applicable terms of use, privacy and data collection policies. To report abuse when using a bot that uses the Microsoft Bot Framework to Microsoft, please visit the Microsoft Bot Framework website and use the “Report Abuse” link in the menu to contact Microsoft.

We use in general only the minimum data requirements which are necessary for the third-party integration..

4. Information Collected from Other Third Parties.
GroupLotse may receive additional information about you, such as demographic information, from affiliates under common ownership and control, and from third parties, such as business partners, marketers, researchers, analysts, and other parties that we may use to supplement the information that we collect directly from you.

C. Use of Free User Information

GroupLotse may use the information collected from Free Users to:

1. Maintain, provide, and improve the Service

2. Respond to your requests for information

3. Prevent or address technical or security issues and resolve support requests

4. Investigate in good faith alleged violations of our User Terms of Service

5. Help us better understand user interests and needs, and customize the Service for our users

6. Engage in analysis, research, and reports regarding use of the Service

7. Protect the Service and our users

8. Schutz des Service und unserer Nutzer

9. Communicate with you via email or through the Service about important notices and updates regarding the Service, such as to inform you about changes in the Service, our service offerings, and important services-related notices, such as about security and fraud. Because these communications are an important part of the Service, you may not opt out of them.

10. In accordance with applicable legal obligations, communicate with you about promotions, offers, and news about GroupLotse. You have the ability to unsubscribe from such promotional communications.

11. Provide cross-device management of your account. For example, we may locate or try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), or work with service providers that do this, in order to save your preferences across devices and analyze usage of the Service.

D. Legal Bases for Use of Your Information

If you are located in the EU, please note that the legal bases under the EU General Data Protection Regulation (“GDPR”) for using the information we collect through your use of the Service as a Free User are as follows:

1. Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with the User Terms of Service which you accept by using the Service.

2. Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our Service; operate our Service; prevent fraud, analyze use of and improve our Service, and for similar purposes).

3. Where use of your information is necessary to comply with a legal obligation.

4. Where we have your consent to process data in a certain way.

E. Sharing of Free User Information

We share the information we collect through the Service about Free Users with the following:

1. Affiliates and Subsidiaries.
We may share the information we collect within the GroupLotse family of companies.

2. Service Providers.
We may provide access to or share your information with select third parties that use the information only to perform services on our behalf. These third parties provide a variety of services to us, including without limitation sales, marketing, provision of content and features, advertising, analytics, research, data storage, security, fraud prevention, and other services.

3. Business Transfers.
If the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the Websites can continue to operate. In such case, your information would remain subject to the promises and commitments contained in this Policy until such time as this Policy is updated or amended by the acquiring party upon notice to you. If such transfer is subject to additional mandatory restrictions under applicable laws, GroupLotse will comply with such restrictions.

4. Consent.
We may also disclose your information to third parties with your consent to do so.

5. Consistent with your settings within the Service.
Please note that the Group and Channel Content you submit through the Service may be viewable by other users in your those Groups and Channels, depending on the specific settings you have selected.

F. Aggregate De-Identified Data

We may aggregate and/or de-identify information collected through the Service so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, and/or others.

G. Combined Information

For the purposes discussed in this Policy, we may combine the information that we collect through the Service with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Policy.

H. Data Retention

We will retain your information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

I. Data Subject Rights

Local legal requirements (such as those in the EU) may afford you additional rights. If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “GroupLotse Contact Info” section below at any time. Your local laws (such as those in the EU) may permit you to request that we:

1. provide access to and/or a copy of certain information we hold about you

2. prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling)

3. update information which is out of date or incorrect

4. delete certain information which we are holding about you

5. restrict the way that we process and disclose certain of your information

6. transfer your information to a third party provider of services

7. revoke your consent for the processing of your information

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

IV. Privacy Terms for Site Visitors

A. Overview

Section IV of this Policy applies only to Site Visitors. If you visit the Websites, regardless of whether you are also a user of the Service, the following rules apply to you. To eliminate any confusion, please note that the terms in this section apply only to use of GroupLotse’s Websites, not to use of the Service. If you are a Site Visitor located in the European Union, GroupLotse is the data controller with respect to the processing of your personal data pursuant to the EU General Data Protection Regulation (“GDPR”).

B. Collection and Use of Site Visitor Information

1. Information Collected from Site Visitors
When you use the Websites, we collect the following information about you:

• Contact Information – if you submit a request for information or a question through the Websites, you may be asked to provide us with basic information including your name, email address, phone number, and postal address. We will also keep records of the communication, the question/request you raised, and how it was resolved. If you choose to participate in an GroupLotse sweepstakes, contest, or research study offered through the Websites, we will also collect basic contact information from you in connection with such activity.

• Websites Usage Information – as you browse the Websites, we and our service providers (which are third party companies that work on our behalf to provide and enhance the Websites) use a variety of technologies, including cookies and similar tools, to assist in collecting information about how you use the Websites. For example, our servers automatically record certain information in server logs. These server logs may include information such as your web request, IP address, browser type and settings, referring / exit pages and URLs, number of clicks and how you interact with links on the Websites, domain names, landing pages, pages viewed, mobile carrier, mobile device identifiers and information about the device you are using to access the Websites, date and time stamp information and other such information.

• Location Information – we collect and process general information about the location of the device from which you are accessing the Service (e.g., approximate geographic location inferred from an IP address).

2. Cookies and Similar Technologies
To collect the Websites Usage Information discussed above, we and our service providers use Internet server logs, cookies, tags, SDKs, tracking pixels, and other similar tracking technologies. A web server log is a file where website activity is stored. An SDK is a section of code that we embed in our applications and software to allow third parties to collect information about how users interact with the Websites. A cookie is a small text file that is placed on your computer or mobile device when you visit a site, that enables us to: (i) recognize your computer and login session; (ii) store your preferences and settings; (iii) understand which pages of the Websites you have visited; (iv), enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform analytics; and (vi) assist with security and administrative functions. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, email open rates, measure popularity of the Websites and associated advertising, and to access user cookies. As we adopt additional technologies, we may also gather information through other methods. Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari).

3. Use of Information Collected from Site Visitors
We use the information collected from Site Visitors for a variety of purposes including to:

• Maintain, provide, and improve the Websites and the Service.

• Respond to your requests for information.

• In accordance with applicable legal obligations, communicate with you about promotions, offers, and news about GroupLotse. You have the ability to unsubscribe from such promotional communications.

• Prevent or address technical or security issues.

• Investigate in good faith alleged violations of our User Terms of Service

• Help us better understand Site Visitor interests and needs, and customize the advertising and content you see on the Websites.

• Engage in analysis and research regarding use of the Websites and the Service.

C. Legal Bases

If you are located in the EU, please note that the legal bases under the GDPR for using the information we collect through your use of the Websites as a Site Visitor are as follows:

1. Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with the User Terms of Service which you accept by browsing the Websites)

2. Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our Websites; operate our Websites; prevent fraud, analyze use of and improve our Websites, and for similar purposes).

3. Where use of your information is necessary to comply with a legal obligation.

4. Where we have your consent to process data in a certain way

D. Aggregate/De-Identified Data

We may aggregate and/or de-identify information collected through the Websites so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, and/or others.

E. Combined Information

You agree that, for the purposes discussed in this Policy, we may combine the information that we collect through the Websites with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Policy. If, however, the collection of any information about you is governed by a Customer Agreement, information will only be combined and used in accordance with such Customer Agreement and the sections of this Policy applicable to Subscribers.

F. Website Analytics and Advertising

1. Website Analytics
We may use third-party web analytics services on our Websites to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

2. Notice Concerning Do Not Track (DNT)
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our Websites for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals. To learn more about Do Not Track, you can do so here.

G. Sharing of Site Visitor Information

We share the information we collect through the Websites with the following:

1. Affiliates and Subsidiaries.
We may share the information we collect within the GroupLotse family of companies.

2. Service Providers.
We may provide access to or share your information with select third parties that use the information only to perform services on our behalf. These third parties provide a variety of services to us, including without limitation sales, marketing, provision of content and features, advertising, analytics, research, data storage, security, fraud prevention, and other services.

3. Business Transfers.
If the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the Websites can continue to operate. In such case, your information would remain subject to the promises and commitments contained in this Policy until such time as this Policy is updated or amended by the acquiring party upon notice to you. If such transfer is subject to additional mandatory restrictions under applicable laws, GroupLotse will comply with such restrictions.

4. Public Forums.
The Websites makes it possible for you to upload and share comments or feedback publicly with other users, such as on the GroupLotse community forum. Any information that you submit through such public features is not confidential, and GroupLotse may use it for any purpose (e.g. GroupLotse marketing materials). Any information you post openly in these ways will be available to the public at large and potentially accessible through third-party search engines. Such information can be read, collected and/or used by other users, and it could be used to send you unsolicited messages. Accordingly, please take care when using these features of the Websites.

5. Consent.
We may also disclose your information to third parties with your consent to do so.

H. Retention of Your Information

We will retain your information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

I. Data Subject Rights

Local legal requirements (such as those in the EU) may afford you additional rights. If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “GroupLotse Contact Info” section below at any time. Your local laws (such as those in the EU) may permit you to request that we:

1. provide access to and/or a copy of certain information we hold about you

2. prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling)

3. update information which is out of date or incorrect

4. delete certain information which we are holding about you

5. restrict the way that we process and disclose certain of your information

6. transfer your information to a third party provider of services

7. revoke your consent for the processing of your information

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

J. Third Party Links And Services

The Websites may contain links to third-party websites and functionalities. If you choose to use these third party services, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function. Because these third-party websites and services are not operated by GroupLotse, GroupLotse is not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third party websites or services, and not this Policy. We urge you to read the privacy and security policies of these third-parties.

V. Additional Privacy Terms for All Users

The following additional information about GroupLotse’s privacy practices apply to all users of GroupLotse (Subscribers, Free Users, and Site Visitors).

A. Changes to Our Privacy Policy

We reserve the right to amend this Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Service or Websites, or advances in technology. We will make the revised Policy accessible through the Service and Websites, so you should review the Policy periodically. If we make a material change to the Policy, we will comply with applicable legal requirements regarding providing you with notice and/or consent.

B. How We Protect Your Information

GroupLotse takes technical and organizational measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure, and thus we cannot ensure or warrant the security of that information.

C. Marketing Practices and Choices

If you receive email from us, we may use certain analytics tools, such as clear GIFs, to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns. You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us at the “GroupLotse Contact Info” section below. In commercial email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as permitted by this Policy or as required by applicable law. For example, you may not opt out of certain operational or service-related emails, such as those reflecting our relationship or transactions with you.

VI. GroupLotse Contact Information

controlex GmbH – GroupLotse
Philosophenweg 31-33
47051 Duisburg
Germany

If you wish to contact us or have any questions about or complaints in relation to this Policy, please contact us at: privacy@grouplotse.com