This policy has three parts:
- Part A – Website clamio.de: what happens when you visit this website or send us an email. Here we are the controller.
- Part B – Clamio platform: for users of the portals and the Driver app and for everyone whose data is processed there. For most data the company that uses Clamio is the controller. For some data we ourselves are the controller (B5).
- Part C – Your rights: applies to both parts.
Part A – Website clamio.de
A1 Controller and contact
The controller within the meaning of the General Data Protection Regulation (GDPR) is:
NG Guard Technology GmbH
Poggenkamp 20
22399 Hamburg
Germany
represented by its Managing Director Abdelmounaim Fares
Email: see imprint
Please use the same address for questions about data protection.
We have not appointed a data protection officer.
A2 At a glance
| What | Which data | What for | Legal basis | How long |
|---|---|---|---|---|
| Opening a page | IP address, time, address requested, technical details of the browser | Delivering the website | Art. 6(1)(f) GDPR | only for the duration of delivery; no access logs |
| Email to us | Your email address, content of your message | Answering the message | Art. 6(1)(f) GDPR | 12 months after the last contact |
| Remembering settings | Your privacy choice, your light/dark choice | Remembering the choice | Section 25(2) no. 2 TDDDG | until you delete them in the browser |
| Google Analytics 4 (Provider: Google Ireland Limited) | see A11 | web analytics | consent (Section 25(1) TDDDG, Art. 6(1)(a) GDPR); Third country: USA (EU-US Data Privacy Framework) | 14 months, cookies at most 2 years |
We use technically necessary storage. We use Google Analytics for statistics only with your consent (see “Web analytics with Google Analytics”). We do not use advertising services.
A3 Provision of the website
We run this website with a hosting provider with data centres in the EU.
- Storage location of the files: the website’s files are stored in data centres in the EU.
- Delivery: the pages are sent to your browser via a content delivery network. The content delivery network has servers at many locations. Your request is usually answered from a location near you. This location may also be outside the EU (see A9).
- Encryption: the connection is always encrypted (HTTPS).
When a page is opened, the hosting provider processes your IP address, date and time, the address requested and technical details of your browser. Without this data the page cannot be sent to your device. We do not store access logs with IP addresses. The content delivery network processes your IP address only briefly for delivery.
Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is to provide the website securely, quickly and reliably.
Processor: We use a hosting provider with data centres in the EU (processing on our behalf under Art. 28 GDPR). The data processing agreement with the standard contractual clauses is part of the hosting provider’s service terms.
A4 Protecting the website against attacks and misuse
Will be added once the contact form sends data.
A5 Enquiries via our forms
The forms on this website do not currently send any data.
A6 Contact by email
If you write us an email, we process your email address, your name if given, and the content of your message in order to answer you.
Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is to answer enquiries. If you write to us as a sole trader about a contract with you yourself, the legal basis is Art. 6(1)(b) GDPR.
Storage period: we delete enquiries that do not lead to a contract 12 months after the last contact. If a contract is concluded, the periods in B5 apply.
A7 Storage in your browser
This website only stores what is technically necessary, for example your choice in the cookie banner. It places exactly two entries in your browser’s local storage (localStorage):
| Entry | Contents | When | Purpose |
|---|---|---|---|
clamio-einwilligung-v2 | Version of the choice, time, categories chosen | when you make a choice in the “Privacy settings” window | Remembering your choice so that the window does not appear every time a page is opened |
clamio-theme | “light” or “dark” | only if you switch the display yourself; otherwise the page follows your device’s setting | Remembering the display you chose |
Both entries stay on your device. They remain stored until you delete them in your browser. You can change your privacy choice at any time via “Cookie settings” at the bottom of every page.
Legal basis: Section 25(2) no. 2 of the German Telecommunications Digital Services Data Protection Act (TDDDG). The entries are strictly necessary for us to provide the function you requested: remembering your choice or your display.
Google Analytics cookies are only set after your consent. Without your consent, no third-party service is involved. With your consent to “Statistics”, Google Analytics is involved.
A8 Analytics only with consent, no advertising
Web analytics only takes place with your consent. Details are given in the section “Web analytics with Google Analytics”. Without consent, no analytics service is loaded. Fonts and images are served from our own server. Only if you consent to “Statistics” is an additional script loaded from Google (Google Analytics). We do not embed content from other providers (such as videos, maps or fonts from third-party servers).
A9 Transfers to countries outside the EU
The website’s files are stored in data centres in the EU.
Delivery runs, by contrast, at the hosting provider’s locations in several countries, including outside the EU, namely in: USA, Canada, Israel. Your IP address and the technical details of your request (see A3) are processed at the location that answers your request. This is usually a location near you; we cannot determine in the individual case which location it is.
The transfer is based on:
- USA: the European Commission’s adequacy decision on the EU-US Data Privacy Framework (Art. 45 GDPR). The hosting provider’s US parent company is certified under it. In addition, the European Commission’s standard contractual clauses apply (Art. 46(2)(c) GDPR).
- Canada and Israel: adequacy decisions of the European Commission (Art. 45 GDPR).
The European Commission’s standard contractual clauses are available at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj. The hosting provider has incorporated them into its data processing agreement.
See also A11.
A10 No automated decisions
On this website we make no decisions that are based solely on automated processing and that produce legal effects concerning you or similarly significantly affect you (Art. 22 GDPR).
A11 Web analytics with Google Analytics
If you consent to the “Statistics” category in the cookie settings, we use Google Analytics 4. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).
Purpose: We want to understand how visitors use our website, for example which pages are viewed and whether a demo request is submitted, so that we can improve the website.
Data processed: Google Analytics sets cookies and records information about your device and browser, the pages viewed, date and time, your approximate location (country, city) and whether a demo request was submitted. Google Analytics 4 does not store your IP address. We have switched off Google signals and ad personalisation.
Legal basis: Your consent under Section 25(1) TDDDG and Art. 6(1)(a) GDPR. Without your consent, Google Analytics is not loaded.
Transfers to third countries: Data may be transferred to Google LLC in the USA. Google LLC is certified under the EU-US Data Privacy Framework, for which an adequacy decision of the European Commission exists (Art. 45 GDPR).
Retention: Data is deleted in Google Analytics after 14 months. The cookies expire after 2 years at the latest.
Withdrawal: You can withdraw your consent at any time with effect for the future via the “Cookie settings” link at the bottom of every page.
Part B – Clamio platform (portals and Driver app)
This part applies to the Clamio platform, with which companies (for example fleets) handle claims, breakdowns, defects and violations with all parties involved. Portal, Driver app and emails from Clamio refer to this page for data protection. Part B therefore also informs all users of the platform.
B1 Who is responsible?
For the data that a company processes in Clamio, that company is the controller, for example the fleet that uses Clamio. NG Guard Technology GmbH processes this data only on behalf of and on the instructions of that company, as a processor under Art. 28 GDPR.
If a company processes data in Clamio on behalf of its own customers, we are to that extent a sub-processor.
For some data we ourselves are the controller, above all for the secure operation of the platform and for the contract with our customers. This data is described in B5.
B2 What does that mean for you?
Do you use Clamio via your employer, your fleet or a client, or do you appear in a case, for example as a driver, other party to an accident or witness? Then the following applies to the data in the cases:
- You receive the privacy information from that company.
- Please address questions about your data and requests, for example for access or deletion, to that company.
- If such a request reaches us directly, we forward it to the company without delay.
B3 Which data is processed on behalf of customers
Depending on how the company uses Clamio, in particular:
- master data of persons (name, function, organisation, contact details),
- driver data (driving licence data including photos of the driving licence, vehicle assignment, personnel number),
- vehicle data relating to persons (number plate, vehicle identification number, mileage),
- claim, breakdown and defect data (course of events, photos, expert reports, cost estimates, details of witnesses and other parties to an accident),
- location data (place of a report),
- details of traffic violations,
- contract, billing and bank data,
- communication content (messages, emails, SMS),
- user, device and log data (accounts, roles, change logs, app and device identifiers).
Which data is processed in the individual case is determined by the company that is the controller.
B4 Where the data is processed
The platform’s data is stored with a hosting provider in data centres in the EU. We provide our customers with the current list of our sub-processors together with the data processing agreement.
Delivery to your device: the files of the portal interface and public images (logos of organisations, brand images, profile pictures) are sent to your device via a content delivery network and cached there for up to one day, at most one year. Your IP address and technical details of the request are processed at the location that answers your request. These locations are also outside the EU, in particular in North America and in Israel. The same bases apply to the transfer as for the website (see A9): for the USA the adequacy decision on the EU-US Data Privacy Framework, and additionally, and for other countries without an adequacy decision, the standard contractual clauses.
Damage photos and documents do not run via the content delivery network. They are stored non-publicly in data centres in the EU and can only be retrieved via signed links that expire after 120 seconds. The platform’s interface does not cache any requests.
B5 Where we ourselves are the controller for the platform
For the following purposes NG Guard Technology GmbH processes data in connection with the platform as the controller. This concerns all users of the platform, including drivers.
| Purpose | Which data | Legal basis | How long |
|---|---|---|---|
| Operation and security of the platform: sign-in, protection against misuse, finding and fixing errors | Access and role data, technical logs, performance data and error reports, app and device identifiers | Art. 6(1)(f) GDPR; our legitimate interest is a secure and functioning platform | Technical logs 30 days |
| Anonymisation of customer data to improve the platform, including automated functions such as damage detection. Images are redacted beforehand for this purpose, for example number plates and persons. | Customer data that is anonymised | Anonymisation is carried out on the customer’s instructions under the data processing agreement. Anonymised data does not allow either the customer or a person to be identified. | Anonymised data is not deleted. |
| Contract with our customers: contact persons, contract administration, billing | Name, function and business contact details of the contact persons; contract and invoice data | Art. 6(1)(f) GDPR for contact persons at companies (for sole traders point (b)); Art. 6(1)(c) GDPR for statutory retention obligations | Contact persons: until the end of the business relationship; commercial and tax records 6 or 10 years (Section 257 HGB, Section 147 AO); billing statuses without personal data 10 years |
| Proof of acceptance of general terms and conditions and terms of use | who, when, which version | Art. 6(1)(f) GDPR; our legitimate interest is proof of the contractual basis | 3 years after the end of the contract or the end of use |
Recipients: Hosting provider with data centres in the EU (processing on our behalf under Art. 28 GDPR), see B4. We do not pass on usage data and anonymised data in a form that allows conclusions to be drawn about the customer or about natural persons.
Part C – Your rights (for Part A and Part B)
C1 Your rights
You have the right to
- access to your data (Art. 15 GDPR),
- rectification of inaccurate data (Art. 16 GDPR),
- erasure (Art. 17 GDPR),
- restriction of processing (Art. 18 GDPR),
- data portability (Art. 20 GDPR).
If you have given consent, you can withdraw it at any time with effect for the future (Art. 7(3) GDPR). Until withdrawal the processing remains lawful.
For the website and for the data in B5, contact NG Guard Technology GmbH, Poggenkamp 20, 22399 Hamburg (email: see imprint). For data in the cases on the platform, contact the company that provides Clamio for you (see B2).
C2 Right to object
If we process your data on the basis of our legitimate interest (Art. 6(1)(f) GDPR), you can object at any time on grounds relating to your particular situation (Art. 21(1) GDPR). We will then no longer process the data unless we can demonstrate compelling legitimate grounds that override your interests, or the processing serves the establishment, exercise or defence of legal claims.
C3 Right to lodge a complaint
You can lodge a complaint with a data protection supervisory authority, in particular in the member state of your habitual residence, your place of work or the place of the alleged infringement (Art. 77 GDPR). The authority responsible for us is:
The Hamburg Commissioner for Data Protection and Freedom of Information (Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit)
Ludwig-Erhard-Straße 22
20459 Hamburg
Email: mailbox@datenschutz.hamburg.de
C4 Changes to this policy
We adapt this policy when the website, the platform or the legal situation changes. The version published here at the time applies.
Last updated: 15 November 2026