PRIVACY POLICY
EU/EEA Residents appendix
The General Data Protection Regulation EU 2016/679 (hereinafter GDPR) shall beapplicable to residents and users of the website in the European Union (EU) andEuropean Economic Area (EEA). Below you will find additional information required
as per applicable data protection legislation.
1. Description of data processing and cookies
When you visit our website, we might collect and process your personal data for
the following purposes and legal grounds:
PURPOSELEGAL GROUND

Process and respond to your requests
when you reach us via our contactforms.

(Pre)contractual or legitimate interest,
Art. 6(1)(b) and 6(1)(f) GDPR
respectively.

Improve website performance andbrowsing experience.

Legitimate interest, Art. 6(1)(f) GDPR

Display content on our website
including videos

Consent or legitimate interest, Art.
6(1)(a) and 6(1)(f) GDPR respectively

Maintain the security of our website

legitimate interest, Art. 6(1)(f) GDPR

Analyze site usage and enhance sitenavigation

Consent or legitimate interest, Art.
6(1)(a) and 6(1)(f) GDPR respectively

Marketing purposes

Consent or legitimate interest, Art.
6(1)(a) and 6(1)(f) GDPR respectively

Share information with advertisingpartners

Consent, Art. 6(1)(a) GDPR

When you use our website, we may use cookies and similar technologies. Ourcookie banner and cookie policy show you the list of the cookies we use, including
their provider, purpose, description and other relevant information. You can adjust
your preferences and withdraw your consent at any time in the pop up on the left
side of the page. See the Cookie Policy (Cookies Policy - Clever Leaves) for more
information.

Clever Leaves • Privacy Policy for https://cleverleaves.com/ • May 202312. Data retention
Unless we have provided you with specific information about the retention of yourpersonal data, we retain your data as long as is necessary to fulfill the purposes forwhich it has been collected. Data no longer required will be deleted.
3. Social links
On our website, we place social media buttons (such as LinkedIn and Twitter) in theform of links. We only display a button and do not integrate any social media
plugins. This means that personal data from you will only be transferred to thesocial media provider if you click on the button.
If you are already logged into the social media service, when you click on therespective social media button, the social media service may also use this data toidentify your username and, possibly, even your real name.
We have no control over the extent, nature and purpose of such data processing
by the social media service. Please note that the social media service might use thisdata to create pseudonymised and even individualised user profiles.
You can find further information about how social media providers use your dataon the privacy policies provided on their respective social media platforms.
4. Google Products
4.1. Google Analytics
We use the web analysis tool “Google Analytics” to design our websites according
to your needs. Google Analytics creates usage profiles based on pseudonyms. For
this purpose, permanent cookies are stored on your end device and read out by us.
In this way, we are able to recognize returning visitors and count them as such.
Within the framework of Google Analytics, Google Ireland Limited and Google LLC(United States) support us. The data processing can therefore also take placeoutside the EU or EEA. With regard to Google LLC, no adequate level of dataprotection can be assumed due to the processing in the United States. There is arisk that authorities may access the data for security and monitoring purposes
without you being informed or having the right to appeal. Please take this into
account if you decide to give your consent to our use of Google Analytics.
If you wish to withdraw your consent, you can change your cookies preferences in
the pop up on the left side of the page.

Clever Leaves • Privacy Policy for https://cleverleaves.com/ • May 20232

4.2. Google reCAPTCHA
In order to fulfill our legitimate interest to protect the security and integrity of ourwebsite, we utilize Google reCAPTCHA. This service is designed to identify andprevent automated software (bots) from engaging in abusive activities on our site,
such as spamming or creating false accounts.
In order to determine whether a user is a human or a bot, Google reCAPTCHA
analyzes various data such as IP address, the amount of time spent on the website,and mouse movements made by the user. This data is sent to Google, where it maybe stored and analyzed.
It's important to note that this service may involve transferring your personal data
to Google servers located in the United States, a country that does not offer thesame level of data protection as the European Economic Area. You are free to not
click on the reCAPTCHA box, however, that may limit your possibility to use thecontact form.
5. Contact form
You are welcome to reach us via our contact form. In order to use our contact form,
we ask you to provide the following information: your name, email, field of interest,and subject. Furthermore, you can decide for yourself whether you would like toprovide us with further information (e.g., in the message text box). This information
is provided voluntarily and is not required for contacting us. We process your details
on the basis of your consent.
Your data will only be processed to answer your request. We will delete your data
if they are no longer required and there are no legal obligations to retain them.
You can revoke your consent to the processing of your voluntarily stated
information at any time. To do so, please use the email address provided in thesection “Data protection requests” of this policy.
6. Transfer to Third Parties
Clever Leaves may share your personal data with:• Our contractors and suppliers, including those who provide us withinformation technology services, such as hosting and technical support;• our professional advisors and auditors;• our business partners;• regulators, governments and legal authorities, when required by theapplicable regulation.

Clever Leaves • Privacy Policy for https://cleverleaves.com/ • May 2023

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When we share your personal data with our service providers, the transfer falls
under the scope of a data processing agreement which obliges our service providers
to follow our strict instructions and comply with contractual obligations.
The personal data that we collect may be processed by Clever Leaves affiliatedcompanies and trusted third parties. In some cases, we may transfer personal data
to third countries outside the EU. Some of the countries to which your personal
data is transferred may not offer an adequate level of protection equivalent to theprotection offered by the laws in the EU. In such cases, to ensure that your personal
data remains protected when it is transferred outside of the EU, we make sure thatappropriate measures are implemented, including our intragroup agreement, orStandard Contractual Clauses issued by the European Commission.
Our business partners, such as Google, may transfer your data to countries(including the United States) in which data protection laws do not offer an adequatelevel of protection. When data are transferred to such countries, the authorities
may have access to the data, without any legal recourse being available. In suchcases, we ask you for your consent to perform this transfer based on Art. 49.1 (a)GDPR. If you wish to withdraw your consent, you can change your cookies
preferences at any time in the pop up on the left side of the page.
7. Your rights as a data subject
According to Art. 12-22 GDPR, you may have the right to:
••
•
•
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access your data as well as receive a copy of your data;
rectification and erasure;restriction of processing;data portability;
object, if the data is processed pursuant to the legitimate interests of CleverLeaves;• lodge a complaint with a supervisory authority if you believe that theprocessing of your personal data infringes applicable data protection
regulations.
8. Data protection requests
Questions or comments regarding your rights as a data subject should be submitted
to Clever Leaves by e-mail at info@cleverleaves.com.

Clever Leaves • Privacy Policy for https://cleverleaves.com/ • May 20234