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Privacy Policy
Last updated: September 2026
COMHUBAI – a product of Cooper Advertising GmbH
This Privacy Policy explains how Cooper Advertising GmbH processes personal data when you visit the COMHUBAI website, contact us, request a demo, subscribe to newsletters or otherwise interact with us as a website visitor, prospect or business contact.
This Privacy Policy applies to personal data collected by us as controller in connection with the COMHUBAI website and our related marketing and sales activities.
This Privacy Policy does not apply to personal data processed within the COMHUBAI SaaS product on a separate subdomain. The COMHUBAI website is a landing page and marketing website only.
We do not sell personal data.
This Privacy Policy applies to personal data collected by us as controller in connection with the COMHUBAI website and our related marketing and sales activities.
This Privacy Policy does not apply to personal data processed within the COMHUBAI SaaS product on a separate subdomain. The COMHUBAI website is a landing page and marketing website only.
We do not sell personal data.
1. Controller and Contact Details
Controller
Cooper Advertising GmbH
Am Kaiserkai 62
20457 Hamburg
Germany
Email: info@cooper-ads.com
Phone: +49 (0)40 22867932-0
Privacy Contact
Email: datenschutz@cooper-ads.com
Cooper Advertising GmbH
Am Kaiserkai 62
20457 Hamburg
Germany
Email: info@cooper-ads.com
Phone: +49 (0)40 22867932-0
Privacy Contact
Email: datenschutz@cooper-ads.com
2. Scope of this Privacy Policy
This Privacy Policy applies to the following processing activities carried out by us as controller:
This Privacy Policy does not cover processing carried out within the COMHUBAI SaaS product environment on a separate subdomain.
- visiting and using the COMHUBAI website;
- contacting us via website form, email, phone or chat;
- requesting a demo, meeting, sales material or other information about COMHUBAI;
- subscribing to newsletters or other marketing communications;
- receiving direct marketing or business communication from us via email or other communication channels, where legally permitted;
- managing cookies and similar technologies on the website;
- ensuring website security, performance and administration.
This Privacy Policy does not cover processing carried out within the COMHUBAI SaaS product environment on a separate subdomain.
3. Categories of Personal Data We Process
Depending on how you interact with us, we may process the following categories of personal data:
- identification and contact data, such as name, business email address, phone number and company;
- professional data, such as job title, business role, company size and preferred language;
- communication data, such as messages you send us and records of your requests;
- website usage and technical data, such as IP address, browser type, device information, referrer URL, accessed pages, date and time of access, and log data;
- marketing preference data, such as newsletter subscriptions, consent status and communication preferences;
- cookie and tracking data, to the extent permitted based on your cookie choices.
4. Purposes and Legal Bases of Processing
a) Website access and log files
When you visit the COMHUBAI website, your browser automatically transmits certain technical information to our servers.
Categories of data
IP address, browser type and version, operating system, referrer URL, accessed pages, date and time of access, device information and other technical log data.
Purposes
Legal basis
Art. 6(1)(f) GDPR based on our legitimate interests in operating a secure and reliable website.
Storage period
Log data is stored only for as long as necessary for the above purposes and then deleted or anonymised in accordance with our retention practices.
Categories of data
IP address, browser type and version, operating system, referrer URL, accessed pages, date and time of access, device information and other technical log data.
Purposes
- providing the website;
- ensuring security, stability and performance;
- detecting misuse and defending against attacks;
- troubleshooting and system administration.
Legal basis
Art. 6(1)(f) GDPR based on our legitimate interests in operating a secure and reliable website.
Storage period
Log data is stored only for as long as necessary for the above purposes and then deleted or anonymised in accordance with our retention practices.
b) Contact requests and demo requests
If you contact us or request a demo, we process the data you provide to respond to your request and manage the pre-contractual relationship.
Categories of data
Name, business email address, phone number, company, role, preferred language, products or features of interest, message content and any other information you provide.
Purposes
Legal basis
Art. 6(1)(b) GDPR where processing is necessary to take steps at your request prior to entering into a contract, and Art. 6(1)(f) GDPR for related business communication and lead handling.
Storage period
We store this data for as long as necessary to handle your request and any related business relationship, and thereafter only for as long as required by law or necessary to establish, exercise or defend legal claims.
Categories of data
Name, business email address, phone number, company, role, preferred language, products or features of interest, message content and any other information you provide.
Purposes
- responding to your request;
- assessing whether COMHUBAI is a fit for your business;
- scheduling meetings or demos;
- sending requested materials;
- preparing and managing pre-contractual or contractual steps.
Legal basis
Art. 6(1)(b) GDPR where processing is necessary to take steps at your request prior to entering into a contract, and Art. 6(1)(f) GDPR for related business communication and lead handling.
Storage period
We store this data for as long as necessary to handle your request and any related business relationship, and thereafter only for as long as required by law or necessary to establish, exercise or defend legal claims.
c) Newsletter and marketing communications
If you subscribe to our newsletter, request information from us, or otherwise agree to receive marketing communications, we process your contact data and consent information for this purpose.
Categories of data
Name, email address, phone number, company, communication preferences, language, subscription status and consent records.
Purposes
Legal basis
Art. 6(1)(a) GDPR where consent is required.
Where direct marketing to existing business contacts is permitted without separate consent under applicable law, processing may also be based on Art. 6(1)(f) GDPR and applicable marketing rules.
Storage period
We store the data until you withdraw consent, object to processing, or the data is no longer needed for the purpose.
Categories of data
Name, email address, phone number, company, communication preferences, language, subscription status and consent records.
Purposes
- sending newsletters and product updates;
- sending marketing communications about COMHUBAI and related services;
- contacting you for marketing purposes via email, WhatsApp, SMS or RCS where legally permitted;
- documenting and managing your consent and opt-out choices.
Legal basis
Art. 6(1)(a) GDPR where consent is required.
Where direct marketing to existing business contacts is permitted without separate consent under applicable law, processing may also be based on Art. 6(1)(f) GDPR and applicable marketing rules.
Storage period
We store the data until you withdraw consent, object to processing, or the data is no longer needed for the purpose.
d) Cookies and similar technologies
We use cookies and similar technologies on our website. Some are technically necessary for the website to function. Others are only used if and to the extent you provide consent through our consent management tool.
Purposes
Legal basis
Technically necessary cookies and related processing are based on applicable law and, where relevant, Art. 6(1)(f) GDPR. Optional analytics, marketing or similar technologies are used only on the basis of your consent under Art. 6(1)(a) GDPR and any applicable ePrivacy or national cookie rules.
We use a consent management platform to allow you to manage your cookie and tracking choices in a GDPR-compliant manner.
Purposes
- enabling core website functionality;
- maintaining security and technical operation;
- measuring and improving website usage where consent has been provided;
- supporting marketing, conversion measurement and website optimisation where consent has been provided.
Legal basis
Technically necessary cookies and related processing are based on applicable law and, where relevant, Art. 6(1)(f) GDPR. Optional analytics, marketing or similar technologies are used only on the basis of your consent under Art. 6(1)(a) GDPR and any applicable ePrivacy or national cookie rules.
We use a consent management platform to allow you to manage your cookie and tracking choices in a GDPR-compliant manner.
e) Analytics and marketing technologies
We use the following analytics and marketing technologies on the website. None of them is loaded until you consent to the respective service in our consent management tool (Usercentrics). You can change or withdraw your choice at any time via “Change your privacy settings” in the website footer.
Microsoft Clarity
Provider: Microsoft Ireland Operations Limited, One Microsoft Place, Dublin 18, Ireland (parent company Microsoft Corporation, USA). Clarity helps us understand how visitors use the website: it produces heatmaps and recordings of interactions (mouse movements, clicks, scrolling, page navigation) and records which features are used, for example opening the “Try it yourself” chat or reaching a step of the free-trial form. Text you enter into forms and into the chat is masked and is not recorded. Clarity processes device and browser information, a shortened IP address, pages visited, timestamps and interaction data, and sets the cookies _clck and _clsk (up to 12 months). Further information: privacy.microsoft.com/privacystatement.
Meta Pixel and Meta Conversions API
Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, Ireland. We use Meta technologies to measure and optimise advertising on Facebook and Instagram. The Meta Pixel records page views and lead events (demo booked, free trial requested) and sets the cookies _fbp and _fbc (up to 3 months). In addition, we transmit these lead events to Meta from our server (Conversions API), together with your IP address, browser information, the pixel cookie values and, for free-trial requests, your email address and phone number in hashed (pseudonymised) form, so that Meta can attribute the event to an ad and avoid double counting. For the collection and transmission of this data, we and Meta are joint controllers within the meaning of Art. 26 GDPR; the corresponding agreement is available at facebook.com/legal/controller_addendum. Further information: facebook.com/privacy/policy.
LinkedIn Insight Tag
Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The Insight Tag measures conversions from LinkedIn advertising campaigns (demo booked, free trial requested) and provides aggregated insights into the website audience. It processes device and browser information, IP address, pages visited, timestamps and the LinkedIn cookies (including li_fat_id, up to 30 days, and others set by LinkedIn). Further information: linkedin.com/legal/privacy-policy.
The providers named above may process the data as processors on our behalf or, in particular for advertising measurement, as independent or joint controllers, and may transfer data to the USA (see section 6).
Legal basis
Art. 6(1)(a) GDPR and § 25(1) TTDSG (consent). You can withdraw your consent at any time with effect for the future via the consent management tool; the lawfulness of processing before withdrawal is not affected.
Further details about the specific cookies and technologies used, including their storage periods, are made available through our consent management tool.
Microsoft Clarity
Provider: Microsoft Ireland Operations Limited, One Microsoft Place, Dublin 18, Ireland (parent company Microsoft Corporation, USA). Clarity helps us understand how visitors use the website: it produces heatmaps and recordings of interactions (mouse movements, clicks, scrolling, page navigation) and records which features are used, for example opening the “Try it yourself” chat or reaching a step of the free-trial form. Text you enter into forms and into the chat is masked and is not recorded. Clarity processes device and browser information, a shortened IP address, pages visited, timestamps and interaction data, and sets the cookies _clck and _clsk (up to 12 months). Further information: privacy.microsoft.com/privacystatement.
Meta Pixel and Meta Conversions API
Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, Ireland. We use Meta technologies to measure and optimise advertising on Facebook and Instagram. The Meta Pixel records page views and lead events (demo booked, free trial requested) and sets the cookies _fbp and _fbc (up to 3 months). In addition, we transmit these lead events to Meta from our server (Conversions API), together with your IP address, browser information, the pixel cookie values and, for free-trial requests, your email address and phone number in hashed (pseudonymised) form, so that Meta can attribute the event to an ad and avoid double counting. For the collection and transmission of this data, we and Meta are joint controllers within the meaning of Art. 26 GDPR; the corresponding agreement is available at facebook.com/legal/controller_addendum. Further information: facebook.com/privacy/policy.
LinkedIn Insight Tag
Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The Insight Tag measures conversions from LinkedIn advertising campaigns (demo booked, free trial requested) and provides aggregated insights into the website audience. It processes device and browser information, IP address, pages visited, timestamps and the LinkedIn cookies (including li_fat_id, up to 30 days, and others set by LinkedIn). Further information: linkedin.com/legal/privacy-policy.
The providers named above may process the data as processors on our behalf or, in particular for advertising measurement, as independent or joint controllers, and may transfer data to the USA (see section 6).
Legal basis
Art. 6(1)(a) GDPR and § 25(1) TTDSG (consent). You can withdraw your consent at any time with effect for the future via the consent management tool; the lawfulness of processing before withdrawal is not affected.
Further details about the specific cookies and technologies used, including their storage periods, are made available through our consent management tool.
f) Other occasional processing
We may occasionally process personal data for additional website-related purposes, such as event registrations, webinars, downloadable materials or recruitment contact forms. In such cases, we will provide additional privacy information where required.
5. Recipients and Categories of Recipients
We may share personal data with the following categories of recipients where necessary:
Recipients may process personal data on our behalf as processors or, where applicable, as independent controllers.
- hosting and infrastructure providers;
- website, security and IT service providers;
- CRM, sales and marketing tools;
- communication and email delivery providers;
- analytics, consent-management or advertising technology providers, in particular Usercentrics, Microsoft (Clarity), Meta (Pixel and Conversions API) and LinkedIn (Insight Tag), where you have consented;
- professional advisers, such as lawyers, auditors or insurers;
- authorities or courts where legally required.
Recipients may process personal data on our behalf as processors or, where applicable, as independent controllers.
6. International Data Transfers
Apart from the analytics and marketing technologies described in section 4 e), we do not intend to transfer website visitor personal data outside the European Economic Area unless this becomes necessary in connection with selected service providers or tools.
If you consent to Microsoft Clarity, Meta or LinkedIn technologies, the respective provider may transfer personal data to the USA. Microsoft Corporation, Meta Platforms, Inc. and LinkedIn Corporation are certified under the EU-U.S. Data Privacy Framework, for which an adequacy decision of the European Commission exists; in addition, Standard Contractual Clauses are agreed with the providers.
Where personal data is otherwise transferred to recipients outside the European Economic Area, we will ensure that appropriate safeguards are in place, such as an adequacy decision or the use of Standard Contractual Clauses and supplementary measures where required.
You may request further information about the safeguards we use by contacting us at datenschutz@cooper-ads.com.
If you consent to Microsoft Clarity, Meta or LinkedIn technologies, the respective provider may transfer personal data to the USA. Microsoft Corporation, Meta Platforms, Inc. and LinkedIn Corporation are certified under the EU-U.S. Data Privacy Framework, for which an adequacy decision of the European Commission exists; in addition, Standard Contractual Clauses are agreed with the providers.
Where personal data is otherwise transferred to recipients outside the European Economic Area, we will ensure that appropriate safeguards are in place, such as an adequacy decision or the use of Standard Contractual Clauses and supplementary measures where required.
You may request further information about the safeguards we use by contacting us at datenschutz@cooper-ads.com.
7. Data Retention
Unless a shorter or longer retention period is required by law or necessary in the individual case, we retain personal data only for as long as necessary for the relevant purposes, in particular:
- website log data: for a limited period required for security and technical operations;
- contact and demo request data: for the duration of handling the request and the related business relationship, plus any applicable limitation periods;
- newsletter and marketing data: until consent is withdrawn, you object, or the data is no longer needed;
- cookies and tracking data: for the storage periods stated in the consent management tool (currently up to 12 months for Microsoft Clarity, up to 3 months for Meta, up to 30 days for the LinkedIn li_fat_id cookie); server-side conversion events are logged by us for 12 months;
- legal and commercial records: for the duration of applicable statutory retention obligations.
8. Security
We implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.
These measures may include encrypted transmission, access controls, authentication measures, role-based permissions, monitoring, backup procedures and internal privacy and security processes.
These measures may include encrypted transmission, access controls, authentication measures, role-based permissions, monitoring, backup procedures and internal privacy and security processes.
9. Your Rights
Subject to the applicable legal requirements, you have the following rights:
If you wish to exercise your rights, please contact us at datenschutz@cooper-ads.com.
If your personal data is processed for direct marketing purposes, you have the right to object at any time to such processing.
- right of access;
- right to rectification;
- right to erasure;
- right to restriction of processing;
- right to data portability;
- right to object to processing based on legitimate interests;
- right to withdraw consent at any time with effect for the future;
- right to lodge a complaint with a competent supervisory authority.
If you wish to exercise your rights, please contact us at datenschutz@cooper-ads.com.
If your personal data is processed for direct marketing purposes, you have the right to object at any time to such processing.
10. No Obligation to Provide Data
You are generally not legally required to provide personal data when visiting our website. However, certain features, such as contact forms, demo requests or newsletter subscriptions, may not be available without the required information.
11. Automated Decision-Making
We do not use website visitor or prospect data for solely automated decision-making that produces legal effects or similarly significantly affects you within the meaning of Art. 22 GDPR.
12. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our website, our practices or applicable legal requirements.
The latest version will always be made available on this website. Where required, we will provide additional notice of material changes.
If our use of tracking, analytics or marketing technologies changes materially in the future, this Privacy Policy and the related consent settings will be updated accordingly before or at the time such changes become active.
The latest version will always be made available on this website. Where required, we will provide additional notice of material changes.
If our use of tracking, analytics or marketing technologies changes materially in the future, this Privacy Policy and the related consent settings will be updated accordingly before or at the time such changes become active.