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Tuesday, August 14, 2018

Privacy Policy EU

Last Updated: July 2, 2018

Information about the processing of your data

In accordance with Art. 12 of the General Data Protection Regulation (hereinafter referred to as the GDPR), we are obliged to inform you about the processing of your data when you use our website/application. We take the protection of your personal data very seriously and this privacy policy informs you about the details of the processing of your data and about your legal rights in this regard.

We reserve the right to adapt the privacy policy with future effect, in particular in the event of further development of the website/application, the use of new technologies or changes to the legal bases or the corresponding case law.

We recommend that you read this privacy policy from time to time and take a printout or a copy for your documents.

Definitions

In the following, website means all of the controller’s pages at https://pluto.tv ; application means all of the controller’s applications.

  • personal data means any information relating to an identified or identifiable natural person. A person is identifiable if they can be identified, either directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier or to one or more special features that are an expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person. Personal data is therefore, for example, a person’s name, email address and telephone number, but may also include information about preferences, hobbies and memberships;
  • processing means operations or sets of operations carried out with or without the aid of automated procedures in connection with personal data, such as the collection, recording, organisation, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction;
  • pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data cannot be attributed to an identified or identifiable natural person;
  • consent means any freely given, specific, informed and unambiguous indication of the data subject’s wishes in a particular case by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her; and
  • Google means Google, LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; reachable in the European Union at: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, fax: +353 (1) 436 1001.

Scope

This privacy policy applies to all pages of https://pluto.tv and the linked application;[A1] It does not cover any linked websites of other providers.

Responsible provider/representative of the provider in the European Union (EU)

The following party is responsible for the processing of personal data within the scope of this privacy policy:

Pluto TV EU GmbH
Schwedter Straße 263
10119 Berlin
privacyeu@pluto.tv

Questions about data protection

If you have any questions about data protection with regard to our company or our website/application, you can contact our data protection officer:

Spirit Legal LLP Rechtsanwälte
Attorney-at-law and data protection officer
Peter Hense
Postal address:
Data protection officer
c/o Schwedter Straße 263
10119 Berlin
Contact via encrypted online form: Contact data protection officer

Security

We have taken comprehensive technical and organisational precautions to protect your personal data from unauthorised access, abuse, loss and other external disruption. To this end, we regularly review our security measures and adapt them to current standards.

Your rights

You have the following rights with regard to the personal data concerning you that you can assert against us:

  • right of access (Art. 15 GDPR),
  • right to rectification (Art. 16 GDPR) or erasure (Art. 17 GDPR),
  • right to restriction of processing (Art. 18 GDPR),
  • right to object to processing (Art. 21 GDPR),
  • right to withdraw your consent (Art. 7(3) GDPR),
  • right to receive the data in a structured, commonly used, machine-readable format (‘data portability’) and the right to transfer the data to another controller, if the prerequisites of Art. 20(1) a, b GDPR are fulfilled (Art. 20 GDPR).

You can assert your rights by informing us using the contact details specified above under ‘Responsible provider’ or by contacting the data protection officer designated by us.

You also have the right to lodge a complaint with a data protection supervisory authority about our processing of your personal data (Art. 77 GDPR).

Use of the website/application, access data

In principle, you can use our website/application for purely informational purposes without disclosing your identity. When you access the individual pages of the website/application in this sense, this only results in access data being transferred to our web hosting service so that the website/content in the application can be displayed to you. This is the following data:

  • browser type/browser version
  • operating system used
  • language and version of the browser software
  • hostname of the accessing device
  • IP address
  • website from which the request comes
  • content of the request (specific page)
  • date and time of the server request
  • access status/HTTP status code
  • referrer URL (website visited before)
  • volume of data transferred
  • time zone difference from Greenwich Mean Time (GMT)

Temporary processing of the IP address by the system is necessary to make it technically possible to deliver the website/content in the application to your device. This requires processing of your IP address for the duration of the session. The legal basis of such processing is Art. 6(1) Sentence 1(f) GDPR.

The access data is not used to identify individual users and is not combined with other data sources. The access data is deleted when it is no longer required for achieving the purpose of it processing. In the case of recording the data to provide the website/content of the application, this is the case when you end your visit to the website/application.

IP addresses are stored in log files to ensure the functionality of the website/application. In addition, the data serves us to optimise the website/application and to ensure the security of our information technology systems. No evaluation of the data for marketing purposes takes place in this context either. In principal, data is deleted after seven days at the latest; further processing is possible in individual cases. In this case, the IP address is deleted or so transformed that an assignment of the retrieving client is no longer possible.

The recording of data for the provision of the website/application and the processing of data in log files is an absolute necessity for the operation of the website/application. You may object to the processing. In the event that your objection is justified, we will examine the situation and either stop or adjust the data processing or point out to you the compelling legitimate reasons on the basis of which we will continue processing.

Cookies

In addition to the aforementioned access data, so-called cookies are stored in the internet browser of the device you use to access the website. These are small text files with a sequence of numbers that are stored locally in the cache of the browser used. Cookies do not become part of the device system and cannot execute programs. They serve to make our website/application user-friendly. The use of cookies may be technically necessary or may occur for other purposes (e.g. analysis/evaluation of website/application use).

a) Technically necessary cookies

Some elements of our website/application require that the retrieving browser can be identified even after a page change. This involves processing the following data in the cookies:

  • language settings
  • login information

The user data collected by technically necessary cookies is not processed to create user profiles. We also use session cookies, which store a session ID that can be used to assign various requests from your browser to the shared session. Session cookies are required for using the website/application. In particular, they enable us to recognise the device used when you return to the website/application. If you have an account with us, we use this cookie to recognise you on subsequent visits to the website/application; otherwise you would have to log in again each time you visited. The legal basis of this processing is Art. 6(1) Sentence 1(f) GDPR. We use session cookies to make using our website/application more attractive and effective. Session cookies are deleted as soon as you log out or close your browser.

Most browsers are preset to automatically accept cookies. You can object to the processing of your data by cookies. You can disable or restrict the transfer of cookies by changing the settings in your internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are disabled for our website/application, it may no longer be possible to use the full functionality of the website/application.

b) Technically non-essential cookies

In addition, we also use cookies on the website/application which enable an analysis of users’ surfing behaviour. For example, this involves processing the following data in the cookies:

  • entered search terms
  • frequency of page views
  • use of website/application functions

These cookies are used to make using the website/application more efficient and attractive. The legal basis of this processing is Art. 6(1) Sentence 1(f) GDPR. The technically non-essential cookies are automatically deleted after a specified period, which may vary depending on the cookie.

You can object to the processing of your data by cookies. If you do not wish to use cookies, you have the option of changing your browser settings in order to generally or selectively block the placement of cookies or remove stored cookies. You can also have the corresponding information displayed before a cookie is placed. If you change the browser settings for the use of cookies or disable cookies, the functionality of this website/application may be restricted.

Where we integrate cookies from third-party providers into our website/application, we point this out to you separately below.

c) Flash cookies

HTML5 storage objects are also used, which are stored on the device you use (“Flash cookies”). These process the required data independently of the browser used and do not have an automatic expiry date. The legal basis of this processing is Art. 6(1) Sentence 1(f) GDPR. These cookies are used to make using the website/application more efficient and attractive.

You can object to the processing of your data by cookies. The transfer of Flash cookies cannot be prevented by adjusting your browser settings, but by changing your Flash Player settings. If you do not wish for Flash cookies to be used, please for install an appropriate add-on in the browser you use, e. g. “Better Privacy” for Mozilla Firefox (https://addons.mozilla.org/de/firefox/addon/betterprivacy/).

You can also prevent the use of Flash cookies by opening your browser in ‘private mode’. Furthermore, you can regularly delete cookies and your browser history manually.

*Contacting our company**

When contacting our company, e.g. by email or using the contact form on the website, the personal data provided by you will be processed by us so that we can respond to your enquiry.

In order for us to process enquiries submitted via the contact form on the website or application, it is essential that you provide a name or pseudonym, the type of connection, the usage platform and a valid email address. At the moment when you submit the message to us, the following data will also be processed:

  • IP address
  • date/time of registration

The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR and Art. 6(1) Sentence 1(b) GDPR, if the contact is made with the intention of concluding a contract.

Processing the personal data from the form allows us alone to process the contact you make with us. Where you contact us by email, this also constitutes the necessary legitimate interest in the processing of the data. The other personal data processed during the submission process serves to prevent any misuse of the contact form and to ensure the security of our information technology systems.

The data will not be transmitted to third parties in this context. The data is only processed in order to process the conversation. As soon as processing is no longer necessary, we delete the data generated in this context or, if statutory retention obligations apply, restrict processing of the data.

You have the possibility to object to the processing of your personal data for contact requests at any time. This is the case if processing is not necessary in particular to fulfil a contract with you, which is described by us in the previous description of the functions. In such a case, it may not be possible to continue processing the request. In the event that your objection is justified, we will examine the situation and either stop or adjust the data processing or point out to you the compelling legitimate reasons on the basis of which we will continue processing.

Processing and transmission of personal data for contractual purposes

We process your personal data if and to the extent necessary for the initiation, creation, execution and/or termination of a legal transaction with our company. The legal basis of this results from Art. 6(1) Sentence 1(b) GDPR.

Once the purpose has been achieved (e.g. contract processing), the personal data will be blocked for further processing or erased, unless we are entitled to retain the data for a longer period and process it as required in the respective context on the basis of a consent granted by you (e.g. consent to the processing of your email address for sending promotional emails), a contractual agreement, a statutory authorisation (e.g. authorisation to send direct advertising) or on the basis of justified interests (e.g. retention for asserting claims).

Your personal data will be passed on if

  • it is necessary for the creation, execution or termination of legal transactions with our company (e.g. when transmitting data to a payment service provider/a shipping company to process a contract with you) (Art. 6(1) Sentence 1(b) GDPR), or
  • a subcontractor or party we use to perform our obligations, which we use exclusively within the framework of providing the offers or services requested by you, needs this data (unless you are expressly informed otherwise, such auxiliary parties are only entitled to process the data insofar as this is necessary for the provision of the offer or service), or
  • there is an enforceable official order (Art. 6(1) Sentence 1(c) GDPR) or
  • there is an enforceable court order (Art. 6(1) Sentence 1(c) GDPR) or
  • we are legally obliged to do so (Art. 6(1) Sentence 1(c) GDPR) or
  • the processing is necessary in order to protect the vital interests of the data subject or another natural person (Art. 6(1) Sentence 1(d) GDPR) or
  • we are authorised or even obliged to pursue overriding legitimate interests (Art. 6(1) Sentence 1(f) GDPR).

Your personal data will not be transmitted to other persons, companies or bodies unless you have effectively consented to such transmission. The legal basis of the processing is then Art. 6 (1) Sentence 1(a) GDPR.

Application process

We are pleased that you are interested in us and that you wish to apply or have already applied for a position in our company. In the following, we would like to provide you with information about the processing of your personal data in connection with your application. We process the data necessary for the online application process (name, email address and location) as well as data that you have sent us in connection with your application in order to check your suitability for the position (or any other vacancies within our company) and to carry out the application process.

The legal basis for the processing of your personal data in this application process is primarily Section 26 of the German Federal Data Protection Act (BDSG) as amended on 25 May 2018. It allows the processing of data required in connection with hiring decisions. Should the data be required for the assertion of legal rights after completion of the application process, data may be processed on the basis of the requirements of Art. 6 GDPR, in particular to safeguard legitimate interests pursuant to Art. 6(1)(f) GDPR. In such cases, our interest is in asserting or defending claims.

In the event of a rejection, candidate data will be deleted after 6 months. In the event that you have agreed to further storage of your personal data, we will add your data to our applicant pool. There the data will be deleted after two years. If you are offered a job in the context of the application process, the data from the applicant data system will be transferred to our HR information system.

We use a specialist software provider for the application process. It acts as a service provider for us and may also become aware of your personal data in the context of system maintenance and support. We have concluded what’s known as a data processing agreement with this provider, which ensures that data processing is carried out in a permissible manner.

Upon receipt of your application, your application data will be reviewed by the HR department. Suitable applications are then forwarded internally to the department heads for the respective vacancies. The next steps to be taken are then agreed upon. In principle, only those persons in the company have access to your data who need this for the regular conduct of our application process.

You have the possibility to object to the processing of your data at any time. This is the case if processing is not necessary in particular to fulfil a contract with you, which is described by us in the previous description of the functions. In the event that your objection is justified, we will examine the situation and either stop or adjust the data processing or point out to you the compelling legitimate reasons on the basis of which we will continue processing.

Hosting

We use external hosting services which serve to provide the following services: infrastructure and platform services, computing capacity, storage resources and database services, security and technical maintenance services. This involves processing all data necessary for the operation and use of our website/application.

We use external hosting services for to run of this website/application. By using external hosting services, we aim to make the provision of our website/application efficient and secure. The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR.

The recording of data for the provision and use of the website/application and the processing of data using external web hosting services is an absolute necessity for the operation of the website/application. You may object to the processing. In the event that your objection is justified, we will examine the situation and either stop or adjust the data processing or point out to you the compelling legitimate reasons on the basis of which we will continue processing.

Integration of third-party content

The website/application integrates third-party content such as videos, maps, RSS feeds and graphics from other websites. This integration always requires that the providers of this content (“third-party providers”) perceive the IP addresses of users. This is because without the IP address they would not be able to send the content to the browser of the respective user. As such, the IP address is required to display this content.

We endeavour to only use content from third-party providers who process the IP address solely for delivering the content. We do however have no influence over whether the third-party providers process the IP addresses, e.g. for statistical purposes. If we are aware of such activity, we inform you of this in the following.

Some of the third parties may process data outside the European Union.

You can object by installing a JavaScript blocker such as the browser plug-in NoScript (www.noscript.net) or disabling JavaScript in your browser.

This may however result in functional restrictions on the website.

Google Fonts

We use web fonts provided by Google for the uniform display of fonts. When you retrieve a page, your browser loads the required web fonts into your browser cache in order to display texts and fonts correctly.

For this purpose, the browser you are using must connect to Google’s servers. By doing so, Google becomes aware that our website/application has been accessed via your IP address. Our use of Google Fonts is in the interest of a uniform and visually appealing presentation of our online offers. This constitutes a legitimate interest within the meaning of Art. 6(1) Sentence 1(f) GDPR. We have no knowledge of how long Google stores data and have no way of influencing this.

You can object to the processing by changing your browser settings in such a way that the browser does not support web fonts –although then your device will use a default font.

For more information about Google Fonts, please refer to https://developers.google.com/fonts/faq and Google’s privacy policy: https://www.google.com/policies/privacy/

Services for statistical, analysis and marketing purposes

We use services from third parties for statistical, analysis and marketing purposes. This enables us to offer you a user-friendly, optimised experience when visiting the website/application. The third-party providers use cookies to control their services (see ‘Cookies’ above). Unless otherwise explained below, this does not involve the processing of personal data.

Some of the third-party providers offer users the option of directly objecting to the use of the respective feature, e.g. by placing an opt-out cookie.

If you activate such an opt-out cookie, the third-party provider will no longer process data about your usage behaviour in the future. It is also possible to merely object individually to a partial selection of external services. If you change the browser or device used or delete all cookies, you will be required to set the opt-out cookie again.

Furthermore, you can also object directly to the use of cookies via the opt-out platform of the organisation Bundesverband Digitale Wirtschaft e.V. (BVDW) at http://www.meine-cookies.org/cookies_verwalten/praeferenzmanager.html or via the deactivation page of the Network Advertising Initiative at http://www.networkadvertising.org/choices/. More information about usage-based advertising and opt-out options can also be viewed via the following link: http://www.youronlinechoices.com/de/.

In the following, we inform you about the services from external providers currently in use on our website/application, about the purpose and scope of the respective processing in each case, and about how you can object.

Google Tag Manager

We use Google Tag Manager on our website/application. Google Tag Manager is a solution that allows marketers to manage website/application tags through a single interface. The Tag Manager tool itself (which implements the tags) is a cookieless domain and does not record any personal data. The tool triggers other tags, which in turn may record data. Google Tag Manager does not access this data. If deactivation has occurred at the domain or cookie level, it will remain effective for all tracking tags implemented with Google Tag Manager.

Google Analytics

In order to tailor our website/application perfectly to your interests, we use Google Analytics, a web analytics service from Google. Google Analytics uses ‘cookies’ (see ‘Cookies’ above), which are stored on your device to enable the analysis of how you use the website/application. The information generated in this way about your use of this website/application is transferred to and stored by Google on a server in the USA.

However, if IP anonymisation is activated on this website/application, then within European Union Member States or in other member states of the European Economic Area Google will shorten your IP address before transferring it. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On our behalf, Google will use this information for the purpose of evaluating your use of this website/application, compiling reports for us on website/application activity, and providing us with other services relating to website/application usage and internet usage.

Google will not associate your browser’s IP address transmitted for Google Analytics purposes with any other data held by Google.

This website/application uses Google Analytics with the “_anonymizeIp()” extension. As a result, IP addresses are further processed in abbreviated form, meaning that any association with individual persons can be ruled out. As far as the data collected about you relates to you personally, that relation is therefore excluded immediately and the personal data thus erased without delay.

We use Google Analytics to analyse and regularly improve the use of our website/application. The statistics help us to improve our website/application and make it more interesting for you as a user. For the exceptional cases in which personal data is transferred to the USA, Google has subjected itself to the EU-US Privacy Shield,https://www.privacyshield.gov/EU-US-Framework. The legal basis of the processing by Google Analytics is Art. 6 (1) Sentence 1(f) GDPR. The Analytics cookies are deleted after fourteen months at the latest.

You have the right to object. You can prevent the storage of cookies using the corresponding settings in your browser software; however, we would like to point out that if you do this you may not be able to use the full functionality of this website/application. Furthermore, you can prevent the recording of data generated by the cookie about your use of the website/application (including your IP address) and its processing by Google by downloading and installing the browser plug-in available via the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

For more information about the third-party provider Google, please refer to:

http://www.google.com/analytics/terms/de.html, http://www.google.com/intl/de/analytics/learn/privacy.html,
http://www.google.de/intl/de/policies/privacy.

Nielsen Analytics

This website/application uses Nielsen Analytics, a web analytics services provided by The Nielsen Company (Europe) Sarl, Geneva Business Center, 12, Avenue des Morgines, 1213 Petit Lancy, Switzerland, http://www.nielsen.com/de/de.html: (hereinafter referred to as “Nielsen Analytics”). Nielsen Analytics uses tracking technologies, in particular cookies, which are stored on your device to enable the analysis of how you use the website/application and measure your TV usage. The information generated about your use is processed within the European Union.

The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR. We use Nielsen Analytics for the purposes of evaluating and regularly improving the usage of our website/application. The statistics help us to improve our website/application for you and make it more interesting. We have no knowledge of how long Google stores data and have no way of influencing this. For more information from Nielsen Analytics, please refer to: http://www.nielsen.com/de/de/privacy-policy.html.

You have the right to object to the processing. You can prevent the evaluation performed by Nielsen Analytics by deleting existing cookies and disabling the storage of cookies in your browser. In this case you may not be able to use the full functionality of the website.

Mode Analytics

This website/application uses Mode Analytics, a web analytics service provided by Mode Analytics‚ Inc., 208 Utah St., Suite 400, San Francisco, CA 94103, https://about.modeanalytics.com (hereinafter referred to as “Mode Analytics”). Mode Analytics uses so-called cookies, which are text files stored on your device to enable the analysis of how you use the website/application. The information generated about your use is transferred to and stored by Mode Analytics on a server in the USA. Mode Analytics complies with the data protection provisions of the EU-US Privacy Shield agreement and is certified for the Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR. We use Mode Analytics for the purposes of evaluating and regularly improving the usage of our website/application. The statistics help us to improve our website/application for you and make it more interesting. We have no knowledge of how long Mode Analytics stores data and have no way of influencing this. For more information from Mode Analytics, please refer to: https://about.modeanalytics.com/privacy/.

You have the right to object to the processing. You can prevent the evaluation performed by Mode Analytics by deleting existing cookies and disabling the storage of cookies in your browser. In this case you may not be able to use the full functionality of the website/application.

Looker Analytics

This website/application users Looker Analytics, a web analytics service provided by Looker Data Sciences, Inc., 101 Church Street, 4th Floor, Santa Cruz, CA 95060, https://looker.com (hereinafter referred to as “Looker Analytics”). Looker Analytics uses so-called cookies, which are text files stored on your device to enable the analysis of how you use the website/application. The information generated about your use is transferred to and stored by Looker Analytics on a server in the USA. We have concluded ‘standard contractual clauses’ with Looker Analytics in order to obligate Looker Analytics to maintain an appropriate level of data protection.

The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR. We use Looker Analytics for the purposes of evaluating and regularly improving the usage of our website/application. The statistics help us to improve our website/application for you and make it more interesting. We have no knowledge of how long Looker Analytics data and have no way of influencing this. For more information from Looker Analytics, please refer to: https://looker.com/privacy.

You have the right to object to the processing. You can prevent the evaluation performed by Looker Analytics by deleting existing cookies and disabling the storage of cookies in your browser. In this case you may not be able to use the full functionality of the website.

You can also object via the “About Ads” self-regulation initiative by clicking on the link http://www.aboutads.info/choices; please note that this setting will be erased if you erase your cookies.

Facebook Analytics

To use Facebook Analytics we also use the so-called tracking pixel, provided by Facebook, Inc.
(the provider is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, email: impressum-support@support.facebook.com, data protection information at: https://www.facebook.com/privacy/explanation; hereinafter referred to as “Facebook”) to track your user behaviour. The information obtained by the tracking pixel cookie serves us solely for statistical purposes, is transmitted to us anonymously by Facebook and does not provide any information about the person of the user. Facebook will, however, connect the information to your Facebook account, store and use it for its own promotional purposes in accordance with Facebook’s Privacy Policy, and may also transfer your data to Facebook’s partners. Even if you are not registered with Facebook or have not logged in, it is possible that the provider will obtain and store your IP address and other identifying information.
The processing of your data in this regard is in accordance with Art. 6 (1)(f) GDPR. By using Facebook Analytics, we are pursuing the interest of being able to better evaluate our website/application and improve our range of services. In this case, we do not store any personal data about you. We have no knowledge of how long Facebook stores data and have no way of influencing this.

Logged-in users can disable the Facebook Analytics function at https://www.facebook.com/settings/?tab=ads# in order to exercise their right to object.**
**There are various ways in which you can block the Facebook Analytics function and thus make use of your right to object:

  • by setting your browser software accordingly; in particular, disabling third-party cookies means that you will not receive any ads from third-party providers;
  • by disabling interest-based ads from providers who are part of the “About Ads” self-regulation initiative via the link http://www.aboutads.info/choices; please note that this setting will be erased if you erase your cookies.

For further information about Facebook’s data protection provisions, please refer to the relevant privacy policy at https://de-de.facebook.com/about/privacy/.

Usage-based online advertising

Google DoubleClick

Furthermore, our website/application uses Google’s online marketing tool DoubleClick. DoubleClick uses cookies to display relevant ads to users, improve campaign performance reports, and to prevent a user from seeing the same ads more than once. Google uses a cookie ID – a pseudonymous identification number assigned to your browser –to track which ads are displayed in which browser and can thus prevent them from being displayed more than once. This pseudonym is assigned information about user activities on the website/application. This allows Google and its partner sites to display ads based on previous visits to websites. In addition, DoubleClick can use the cookie ID to record conversions related to ad requests. This happens for example when a user sees a DoubleClick ad and later visits the advertiser’s website with the same browser and buys something there.

The information generated by DoubleClick cookies is transferred to and stored by Google on servers in the USA. Google complies with the data protection provisions of the EU-US Privacy Shield agreement and is certified for the Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The data will only be transferred to third parties within the scope of legal regulations or order processing. According to Google, DoubleClick cookies do not contain any personal information.

Due to the marketing tools used, your browser automatically establishes a direct connection to the Google server. We have no influence on the extent and further processing of the data collected by Google through the use of this tool and therefore inform you according to what we know: By integrating DoubleClick, Google receives the information that you have retrieved the corresponding part of our website/application, or that you have clicked on one of our ads. If you are registered with a Google service, Google can associate the visit with your account. Even if you are not registered with Google or have not logged in, it is possible that the provider will obtain and store your IP address.

The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR. The DoubleClick cookies are deleted after six months at the latest. By using DoubleClick, we are pursuing the interest of showing you ads that may be of interest to you in order to make our website/application more interesting for you.

There are various ways in which you can prevent your participation in this tracking procedure and thus make use of your right to object:

  • by setting your browser software accordingly; in particular, disabling third-party cookies means that you will not receive any ads from third-party providers;
  • by disabling cookies for conversion tracking, by setting your browser in such a way that it blocks cookies from the domain www.googleadservices.com, https://www.google.de/settings/ads; please note that this setting will be erased if you erase your cookies;
  • by disabling interest-based ads from providers who are part of the “About Ads” self-regulation initiative via the link http://www.aboutads.info/choices; please note that this setting will be erased if you erase your cookies;
  • by permanent deactivation in your browser Firefox, Internet Explorer or Google Chrome via the link http://www.google.com/settings/ads/plugin.

For more information about DoubleClick, please refer to: https://www.google.de/doubleclick, http://support.google.com, https://policies.google.com/privacy?hl=de (about privacy at Google in general).

Freewheel

This website/application uses the online advertising service Freewheel, provided by Freewheel Media, Inc., which is headquartered at 231 Second Avenue, San Mateo, CA 94401 in the USA. Here we are pursuing the interest of showing you ads that may be of interest to you in order to make our website/application more interesting for you. This involves collecting statistical information about you, which is processed by our advertising partners. This makes it possible to specifically target internet users with advertising who have already demonstrated an interest in our services and products.

By visiting the website/application, Freewheel receives the information that you have visited our website/application. To this end, Freewheel uses tracking technologies such as web beacons in order to place a cookie on your device. The data mentioned under ‘Access data’ is transmitted. We have no influence on the data collected, and nor are we aware of the full scope of data processing or the storage period. Your data will be transferred to the USA and processed there. Freewheel complies with the data protection provisions of the EU-US Privacy Shield agreement and is certified for the Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

The legal basis of the processing of your data is Art. 6(1) Sentence 1(f) GDPR. We have no knowledge of how long Freewheel stores data and have no way of influencing this. For further information about the purpose and scope of processing and more information about your rights in this regard and how to adjust your settings to protect your privacy, please refer to: http://freewheel.tv/privacy-policy/.

You have the right to object to the processing. You can prevent the evaluation performed by Freewheel by deleting existing cookies and disabling the storage of cookies in your browser. In this case you may not be able to use the full functionality of the website/application.

Roku Advertising

This website/application uses the online advertising service Roku Advertising, provided by Roku, Inc., 150 Winchester Circle, Los Gatos, CA 95032, USA (“Roku”). Here we are pursuing the interest of showing you ads that may be of interest to you in order to make our website/application more interesting for you. This involves collecting statistical information about you, which is processed by our advertising partners. This makes it possible to specifically target internet users with advertising who have already demonstrated an interest in our services and products.

By visiting the website/application, Roku receives the information that you have visited our website/application. To this end, Roku uses tracking technologies such as web beacons to place a cookie on your device. The data mentioned under 'Access data’ is transmitted. We have no influence on the data collected, and nor are we aware of the full scope of data processing or the storage period. Your data will be transferred to the USA and processed there. We have concluded ‘standard contractual clauses’ with Roku in order to obligate Roku to maintain an appropriate level of data protection.

The legal basis of the processing of your data is Art. 6(1) Sentence 1(f) GDPR. We have no knowledge of how long Roku stores data and have no way of influencing this. For further information about the purpose and scope of processing and more information about your rights in this regard and how to adjust your settings to protect your privacy, please refer to: https://docs.roku.com/doc/userprivacypolicy/en-gb.

There are various ways in which you can object to the processing:

  • by activating the ‘do not track’ function in your browser software, as suggested by Roku, https://docs.roku.com/doc/cookiepolicy/en-gb;
  • by setting your browser software accordingly; in particular, disabling third-party cookies means that you will not receive any ads from third-party providers; or
  • by disabling interest-based ads from providers who are part of the “About Ads” self-regulation initiative via the link http://www.aboutads.info/choices; please note that this setting will be erased if you erase your cookies.

Revive Adserver

We also use Revive Adserver, a service provider for advertising and operator of a bidding platform, to deploy usage-based advertising. The operator of the platform is Revive Software and Services BV, a company headquartered in the Netherlands at Jokersvaart 36, 9366 TC Jonkersvaart (hereinafter referred to as “Revive”).

Revive uses cookies to deliver ads that are of relevance to users. For this purpose a cookie ID, which is a pseudonymous identification number, is assigned to your browser. This pseudonymous identifier is assigned information about user activities on our website/application. The data will only be transferred to third parties within the scope of legal regulations or order processing.

Due to the marketing tools used, your browser automatically establishes a direct connection to the Revive server. We have no influence on the extent and further processing of the data collected by Revive through the use of this tool and therefore inform you according to what we know: By integrating the Revive platform, Revive receives the information that you have retrieved the corresponding part of our website/application and that you have clicked on one of our ads, and in this context it records your IP address.

The legal basis of the processing of your data is Art. 6(1) Sentence 1(f) GDPR. By using the Revive platform we are pursuing the interest of showing you ads that may be of interest to you in order to make our website/application more interesting for you. We have no knowledge of how long Revive stores data and have no way of influencing this. For further information about the Revive platform, please refer to https://www.revive-adserver.com/privacy/.

You have the right to object to the processing. You can prevent evaluation and targeted advertising using Revive by deleting existing cookies and disabling the storage of cookies in your browser. In this case you may not be able to use the full functionality of the website/application.

Social network plug-ins

Social network plug-ins are integrated into our website/application. These are provided by the following providers:

The plug-ins can be recognised on our website/application by the aforementioned lettering or by small stylised symbols.

We offer you the possibility to communicate directly with the provider of the plug-in via the button. Only if you click on the marked field and thereby activate it does the plug-in provider receive the information that you have accessed the corresponding page of our website/application. In addition, the data mentioned under ‘Access data’ is transmitted.

In the case of Facebook and Xing, according to the respective providers’ own information, IP addresses in Germany are anonymised immediately after their collection. By activating the plug-in, personal data about you is therefore transferred to the respective plug-in provider and processed there (in the USA in the case of US providers). Since the plug-in provider collects data via cookies in particular, we recommend that before clicking on the greyed-out box you delete all cookies using your browser’s security settings.

We have no influence on the data collected and processing procedures, and nor are we aware of the full scope of data processing, the purposes of processing, or the storage periods. We also have no information about the erasure of the data collected by the plug-in provider.

The plug-in provider stores the data collected about you as usage profiles and processes this for purposes of advertising, market research and/or the demand-oriented design of its website. Such analysis takes place in particular (including for users who are not logged in) to display demand-oriented advertising and to inform other users of the social network about your activities on our website/application.

The legal basis of the use of the plug-ins is Art. 6(1) Sentence 1(f) GDPR. Through the plug-ins we offer you the possibility to interact with social networks and other users, so that we can improve our website/application and make it more interesting for you as a user.

You have the right to object to the creation of these user profiles, although you must contact the respective plug-in provider to exercise this right. There are also various ways in which you can prevent the creation of user profiles and thus make use of your right to object:

  • by setting your browser software accordingly; in particular, disabling third-party cookies means that you will not receive any ads from third-party providers;
  • by disabling interest-based ads from providers who are part of the “About Ads” self-regulation initiative via the link http://www.aboutads.info/choices; please note that this setting will be erased if you erase your cookies.

The data is transferred regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged in with the plug-in provider, the data about you collected by us will be directly assigned to your existing account with that plug-in provider. If you click or tap on the activated button and, for example, share a link to the page, the plug-in provider will also store this information in your user account and share it publicly with your contacts.

After using a social network, we recommend that you log out regularly, especially however before activating the button, as in this way you can avoid being assigned to your profile with the respective plug-in provider.

Copyright by Spirit Legal LLP