1. General Information
We, Virtual Minds GmbH, a ProSiebenSat.1 Group company, offer technologies that help advertisers and digital platform operators display targeted digital ads or generate revenue through website displays. We provide various products, each serving different commercial purposes, which are outlined in section 3.1 of this Privacy Policy.
This Privacy Policy aims to give you clear and simple information about our technology, services, and the related processing of personal data. We understand that our activities can be complex, so we are available to answer any additional questions you may have at https://virtualminds.com/contact/ or via email at data.privacy@virtualminds.com.
2. Contact
Controller for data collection and processing:
Virtual Minds GmbH
Ellen-Gottlieb-Straße 16
79106 Freiburg im Breisgau
Germany
You can reach our data protection officer:
Rechtsanwalt Daniel Raimer
Law firm Daniel Raimer
Ernst-Gnoß-Straße 22
40219 Düsseldorf
Germany
Phone: +49 211 4167 4600
office@kanzlei-raimer.com
3. Information Relating To The Collection And Processing Of Data By Our Products
3.1 What products do we offer?
Our platform includes products that enable our customers to display or show target group-specific or user-oriented advertising. Advertisers use various factors, such as the advertising environment or the assumed interests and preferences of users, to decide which ads are displayed, when, and on which end device. Our technologies allow content to be displayed in a wide variety of digital environments, including websites, mobile applications, and HBBTV inventory. If not defined in more detail, we summarize these environments as “Digital Offers.” It is important for us and our customers to display advertising that is as relevant as possible. Depending on the type of customer, we offer access to the following products on our platform
Active Agent (DSP)
Under the name “Active Agent,” we offer advertisers and agency clients the opportunity to purchase advertising inventory, address target groups, and manage and optimize advertising campaigns using demand-side platform (DSP) technology. Active Agent customers are primarily companies that want to advertise their products and services in Digital Offers. We enable our customers to efficiently participate in auctions for advertising space offered by third parties, book these spaces, and display digital advertising content on Digital Offers.
Adition (AdServer)
We offer publishers under the name “Adition” an ad server technology for marketing their own Digital Offers. An ad server is a system that enables the management and delivery of online advertising. It manages the placement of ads on websites and measures the success of advertising campaigns. The Adition ad server also enables the hosting, display, and curation of ads. Additionally, the Adition technology allows customers to analyse interactions with their own website and use this data to select appropriate advertising measures if necessary.
The Adex (DMP)
The “The Adex” Data Management Platform (DMP) supports advertisers, digital service providers, and data partners in managing data for the creation and addressing of target groups for the delivery of advertising or content. We help our customers understand which of their offers are of interest to which users, in order to improve these offers and gather information. This information allows our customers to address potential users in a target group-oriented and relevant manner through our platform or other DSP, SSP, and ad server partners.
Yieldlab (SSP)
The “Yieldlab” Sell Side Platform (SSP) is our technology for operators of Digital Offers that helps them manage, optimize, and sell their advertising inventory to advertisers. We enable our Yieldlab customers to offer their digital advertising space to various DSPs (see 2.3) through real-time auctions and provide the necessary technology for this. Publishers and marketers can use the platform to control the sale of advertising inventory and view analyses of their sales.
In this Privacy Policy, we explain our data processing in a standardized manner for all our products. If there are differences between the products in specific points, we will highlight these at the relevant section
3.2 How do we collect data?
We summarise the data collection processes described below under the term “Tracking Technologies.” Our customers will inform you about the use of Tracking Technologies within the scope of joint controllership and, where necessary for specific purposes, obtain your explicit consent to their use.
We offer our customers the technical capability to collect data for use in our products. Our customers integrate Tracking Technologies provided by us, such as web beacons, tracking pixels, tags, JavaScript functions, SDKs, or API calls, as additional code in their Digital Offers. For example, this integration can forward campaign-related, user-generated, inventory-relevant data to the various products on our platform. Additionally, these technologies allow us to recognize the internet application of your device via the Digital Offer on which one of our products is integrated during a visit or advertising contact by using an identifier..
If the Digital Offers are accessed through a browser as an internet application, a random ID is generated by our Tracking Technology and stored in a cookie. Cookies are small text files stored in your browser on your device, enabling us to identify this browser. Cookies generated by our products can only be read and used by us.
If you view content on your mobile device via an app as an internet application, we use the SDK to access the Mobile Advertisement ID (MAID) as an identifier provided by the operating system of your device. This unique ID is assigned to your device and is used to identify it.
Some customers also provide us with other identifiers via the various digital services, which are obtained from pseudonymized email addresses, for example, or provided by ID providers. Such pseudonymized IDs make it possible to identify a pseudonymized user but do not allow us to draw any conclusions about the initial data (e.g., the email address).
When working with providers of comparable or complementary services, it is advantageous if all parties involved agree on which browser, device, or user the information relates to. For this reason, we match our identifiers obtained from the use of Tracking Technologies with those of our partners as part of a synchronization process (“Cookie Matching” / “ID Matching”).
3.3 What data do we collect?
We collect the following data about you for all our products:
Internet Connection Information
When you view online content on your device or watch digital ads, we may collect information about your internet connection. This includes details about your internet service provider and the type of connection you are using, such as broadband, Wi-Fi, or mobile network. In particular, the IP address is also recorded..
Location Information
If you view digital content or advertising material on a mobile device, we can collect your exact location if you have activated the corresponding function on your phone. Regardless of whether you are using a mobile or stationary device, we can determine your approximate location or postcode area.
Device Information
When you view digital content or advertising material on your device, we may collect information about your device. This includes details such as the type of device (e.g., smartphone, tablet, laptop), the operating system (e.g., iOS, Android, Windows), and other technical characteristics such as the screen size.
Cookies And Other Identifiers
We can set and read cookies on your device as described above and access other advertising identifiers provided by mobile operating system manufacturers (IDFA or AAID).
Internet Application Information
If you use a specific application (e.g., app, browser, HBBTV), we may collect information about the software you use. This includes details such as the name of the app or browser, the version, and possibly also information about the settings or extensions you have activated. Information about how your browser handles cookies is also collected.
Contents In Internet Application
When you use content in an application, we may collect information about the type of content you view or interact with. This includes information about the type of content, such as news, videos, music, games, or TV programs.
Behavioural Information In The Internet Application
When you use applications or browsers, we may collect information about your behavior in them. This includes details such as the content you view or interact with, like clicks, engagement, or the duration of your use.
Information On Advertising Media Displayed
When you see advertising material, we may collect information about the ads you see. This includes information about the type of ad, the advertiser, the content of the ad, and possibly your current or previous interactions with the ad, such as clicks or views.
Information About The Data Collection Decisions You Have Made
We also receive information about whether you have been informed about processing operations or whether you have consented to them. Additionally, we receive information on whether you have partially or completely objected to the processing and/or whether you want your cookie to no longer be used in the future.
Information About You As A User
With your express consent, we may receive pseudonymized data or information relating to you as a user from our customers and partners. This may include personal information such as age, gender, demographic characteristics, purchasing behavior, interests, or an allocation of the user to third-party target groups.
At no time do we collect sensitive or critical data that allows direct, clear, and immediate identification of the user or automatic assignment of the user to categories such as race, religion, or health status. In particular, we do not collect your name, email address, or home or work addresses. When forming target groups based on the individual data collected, the target group is based on probabilistic probabilities and broad assumptions. These assumptions may or may not apply to you—this typically applies to such a large group of users that it is not possible to trace them back to an individual.
3.4 What this Privacy Policy does not cover
Many website operators (Publishers) work with several companies to enrich their offerings with online advertising. Like us, many of these providers rely on the use of Tracking Technologies (see section 3.2 above). This means, for example, that several cookies from different providers may be stored on your device when you visit a website. In some cases, this happens when you access the website, and in other cases, only when you interact with an advertising medium. This Privacy Policy only applies to processing carried out by us and the Tracking Technologies we use.
If you would like to receive more detailed information about the other companies involved by the website operator and their processing, please contact them directly. If the website operator supports the IAB TCF (see section 3.11 below), you will also receive much of this information via the CMP used by the website operator (see also section 3.11 below).
3.5 Why we use your information and on what legal basis
We use the data described above for the purposes and products listed below based on the legal bases outlined. In some cases, our customers have a choice of legal bases. You will find the designation of the respective legal basis in the CMP and/or the Privacy Policy of the Publisher that uses our products.
3.5.1 Processing purposes
In our products, we use the data specified below and defined above for the purposes listed below under the applicable legal bases.
Store and/or access information on a device
We may store or read the following information on your device to recognize it each time it connects to an app or website:
This is done for one or more of the processing purposes listed below.
Most of the processing purposes explained are based on storing or accessing information on your device when you use an app or visit a website. For example, it may be necessary for a provider or website operator to store a cookie on your device when you first visit a website in order to recognize it on your next visits (by retrieving this cookie each time).
We always use the legal basis “consent” for our products.
Use limited data to select advertising
Advertising presented to you may be based on specific data. We may process the following information for this purpose:
A car manufacturer wants to advertise its electric vehicles to environmentally conscious users who live in the city after work. The ad is displayed to users whose approximate location indicates that they are in an urban area on a page with similar content (e.g., an article on climate protection measures) after 6:30 pm.
The Adex (DMP) and Yieldlab (SSP) use the legal basis “consent.” For Adition (AdServer) and Active Agent (DSP), we allow our customers to choose between “consent” and “legitimate interest” as the legal basis.
Create profiles for personalised advertising
Information about your activities (such as forms you submit or content you view) may be stored and combined with other Information About You As A User (e.g., information from your previous activity on this Digital Offering and other websites or apps) or similar users. This is then used to create or supplement a profile about you (which may include, for example, possible interests and personal characteristics). Your profile may (also later) be used to enable us and other companies to present you with ads that are likely to be more relevant to you based on your potential interests.
We may use the following information for this purpose:
If you read several articles about the best bicycle accessories on the market, this information can be used to create a profile about your interest in bicycle accessories. Such a profile can be used or improved at a later date on the same or another website or app to show you ads for a specific brand of bicycle accessories. If you are also looking at a configurator for a vehicle on a luxury car manufacturer’s website, this information may be combined with your interest in bicycles to refine your profile and lead to the assumption that you are interested in luxury bicycle equipment.
We use the legal basis “consent” for all our products
Use profiles to select personalised advertising
Advertising presented to you may be based on your advertising profiles, which may reflect your activities on a customer’s Digital Offerings or other customers’ websites or apps (such as forms you submit or content you view), possible interests, and personal characteristics. We may process the following information for this purpose:
An online retailer wants to advertise a limited sale on running shoes. They want to target ads to users who have previously viewed running shoes in their mobile app. Tracking Technologies can be used to determine whether you have used the mobile app to search for running shoes in the past and to show you the relevant ads in the app.
At no time do we generate a unique digital “fingerprint” ID (“fingerprinting”) from various data points about the user’s device or browser (such as screen resolution, installed fonts, time zone, and browser plugins), over which you as the user would no longer have any control.
We use the legal basis “consent” for all our products.
Measure advertising performance
Information about which ads are presented to you and how you interact with them can be used to determine how much an ad has appealed to you or other users and whether the objectives of the advertising campaign have been achieved. The information includes, for example, whether you viewed an ad, clicked on it, were encouraged to buy a product or visit a website, etc. This information is helpful in determining the relevance of advertising campaigns. We may process the following information for this purpose:
You are one of the few people who have clicked on an ad in the app about a discount on the occasion of a special event (e.g., “International Day of Recognition”) of an online gift shop. The app operator would like to receive statistics on how often a certain ad within the app, particularly the ad for a special event (e.g., “International Day of Recognition”), was viewed or clicked on by you and other users. This helps the app operator and its partners (such as agencies) optimize the placement of ads.
The Adex (DMP) and Yieldlab (SSP) use the legal basis “consent.” For Adition (AdServer) and Active Agent (DSP), we allow the collecting customers to choose between “consent” and “legitimate interest” as the legal basis.
Use limited data to select content
Content presented to you may be based on specific data. We may process the following information for this purpose:
A travel magazine has published an article on its website about the new online courses offered by a language school to enhance the traveling experience abroad. The travel school’s blog posts are inserted directly at the bottom of the page and selected based on your approximate location (e.g., blog posts with the syllabus for the course of a language that is not the language of your country).
The Adex (DMP) uses the legal basis “consent.” Adition (AdServer), Active Agent (DSP), and Yieldlab (SSP) do not use the data for this processing purpose.
Create profiles to personalise Content
Information about your activities (such as completed forms or non-promotional content viewed) may be stored and combined with other Information About You As A User (such as your previous activity on this content or other websites or apps) or similar users. This is then used to create or supplement a profile about you (this may include, for example, possible interests and personal characteristics). Your profile may be used (including at a later date) to show you content that is likely to be more relevant to you based on your potential interests, for example, by changing the order in which content is shown to you to make it even easier for you to find content that matches your interests.
We may process the following information for this purpose:
You read several articles on a social media platform about how to build a tree house. This information can be added to a profile to record your interest in content about outdoor activities and do-it-yourself instructions (with the aim of enabling the personalization of content so that you are presented with more blog posts and articles about tree houses and wooden cabins in the future, for example).
The Adex (DMP) uses the legal basis “consent.” Adition (AdServer), Active Agent (DSP), and Yieldlab (SSP) do not use the data for this processing purpose.
Use profiles to select personalised Content
Content presented to you may be based on your content profiles, which may reflect your activities on this or other content (such as forms you submit or content you view), possible interests, and personal aspects. This can be used, for example, to customize the order in which content is displayed to you, making it easier for you to find non-advertising content that matches your interests. We may process the following information for this purpose:
You read articles about vegetarian food on a social media platform and then use the cooking app of a company that is independent of the platform. The profile created about you on the social media platform is used to present you with vegetarian recipes on the home page of the cookery app.
The Adex (DMP) uses the legal basis “consent”. Adition (AdServer), Active Agent (DSP) and Yieldlab (SSP) do not use the data for this processing purpose.
Measure content Performance
Information about what ads you are presented with and how you interact with them can be used to determine whether non-advertising content has reached the intended audience and matched your interests. This includes, for example, information about whether you have read a particular article, watched a particular video, listened to a particular podcast, or looked at a particular product description, how much time you have spent with the customer, and the websites you have visited. This information helps to determine the relevance of non-advertising content that is displayed to you. We may process the following information for this purpose:
You were presented with a video about fashion trends, but you and several other users cancelled it after 30 seconds. This information is used to evaluate the appropriate length of future videos on fashion trends.
The Adex (DMP) uses the legal basis “consent”. Adition (AdServer), Active Agent (DSP) and Yieldlab (SSP) do not use the data for this processing purpose.
Understand audiences through statistics or combinations of data from different Sources
Based on the combination of data sets (such as user profiles, statistics, market research, analytics data), reports may be generated about your interactions and those of other users with advertising or non-advertising content in order to identify common characteristics (e.g., to determine which target groups are receptive to an advertising campaign or to certain content). We may process the following information for this purpose:
The owner of an online bookstore wants to analyze how many visitors have visited his website without buying anything, or how many have visited the website to buy the latest celebrity biography of the month, as well as the average age of visitors and how many of them are male or female, broken down by category. Data about your navigation on the website and your personal characteristics is then used and combined with other such data to create these statistics.
The Adex (DMP) uses the legal basis “consent.” For Adition (AdServer) and Active Agent (DSP), we allow the collecting customers to choose between “consent” and “legitimate interest” as the legal basis. Yieldlab (SSP) does not use the data for this processing purpose.
Develop and improve Services
Information about your activities, such as your interaction with ads or content, can help to improve products and offers and to develop new products and offers based on user interactions, the type of target group, etc. This processing purpose does not include the development, enhancement, or improvement of user profiles and identifiers. We may process the following information for this purpose:
A technology platform that works with a social media provider sees growth in the number of users of its mobile app and recognizes, based on user profiles, that many of them are logging in via mobile connections. The platform uses a new ad delivery technology that is optimized for mobile devices and requires low bandwidth to improve the loading speed of ads.
The Adex (DMP) and Yieldlab (SSP) use the legal basis “consent.” For Adition (AdServer) and Active Agent (DSP), we allow the collecting customers to choose between “consent” and “legitimate interest” as the legal basis.
Save and communicate privacy choices
The choices you make regarding the listed purposes and entities on the Digital Offerings are made available to us in the form of digital signals (strings) and stored by us. This is necessary to enable both our products and the entities concerned to honor these decisions. We use the following information for this purpose:
If you visit a website and have the choice to consent or not to the use of profiling for personalized advertising or content, your decision will be stored and made available to the advertising providers or other partners involved so that the advertising or content displayed to you respects this decision.
We uniformly use the legal basis “legitimate interest” for our products.
Ensure security, prevent and detect fraud, and fix errors
Your data may be used to monitor and prevent unusual and potentially fraudulent activity (for example, advertising, ad clicks by bots) and to ensure that systems and processes function properly and securely. The data may also be used to resolve problems that you, the website or app operator, or the advertiser may have in delivering content and ads and in your interaction with them. We may process the following information for this purpose:
An advertising intermediary provides ads from different advertisers to its network of partner websites and apps. The advertising intermediary notices a sharp increase in clicks on ads from a particular advertiser. He analyses the data regarding the source of the clicks and finds out that 80% of the clicks come from bots and not from humans.
We uniformly use the legal basis “legitimate interest” for our products.
Deliver and present advertising and Content
Certain information (such as IP address or end device functions) is used to ensure the technical compatibility of the content or advertising and to enable the content or advertising to be transmitted to your end device. We use the following information for this purpose:
When you click on a link in an article, you are usually redirected to another page or another part of the article. To this end, 1°) your browser sends a request to a server linked to the website, 2°) the server responds to the request (“here is the article you requested”) using technical information contained by default in the request sent by your terminal in order to properly display the information/images that are part of the article you requested. Technically, such an exchange of information is necessary to provide the content that is displayed on your screen.
We uniformly use the legal basis “legitimate interest” for our products.
3.5.2 Supporting functions
Supporting functions allow the processing purposes to be carried out and applied and are based on the legal bases of the respective processing purposes.
Match and combine data from other data sources
Information about your activities may be matched and combined with other information about you from different sources (e.g., your activities on another Digital Offering, your use of an in-store loyalty card, or your responses to a survey) to support the purposes described. We use these functions for our products on the legal basis of the respective processing purposes.
Link different devices
To support the purposes described above, it can be determined whether it is likely that your device is connected to other devices belonging to you or your household (e.g., because you are connected to the same digital service on both your mobile phone and your computer or because you use the same internet connection on both devices). We use these functions for our products on the legal basis of the respective processing purposes..
Identify devices based on information transmitted automatically
Your end device can be differentiated to support the purposes explained with the help of information that it automatically transmits when accessing the internet (e.g., the IP address of your internet connection or the type of browser you use). We use these functions for our products on the legal basis of the respective processing purposes..
Use precise geolocation data
We can enable our customers to use precise geolocation data for your device. Precise here means that your location can be accurate to within a few meters. This information is used to show you ads that are particularly relevant to you based on your location. If the precise Location Information is used for activities other than a temporary and immediate conversion into non-precise Location Information or for the detection of fraudulent activities, this requires separate confirmation from yo
Active Agent (DSP), Adition (AdServer), and Yieldlab (SSP) use these functions on the legal basis of the respective processing purposes. The Adex (DMP) does not use this function.
3.6 Who do we share your information with?
Sharing within the Virtual Minds platform
Within the Virtual Minds platform, various types of information can be exchanged between the products to create a comprehensive picture of you: This includes data that DSP and AdServer customers have about you, such as user accounts or previous visits and purchases on their websites, as well as data collected about your age, gender, and surfing behaviour. The merging of this data is subject to the legal restrictions described above. It is neither intended nor possible, for example, to pass on precise Location Information from the Adition AdServer to The Adex DMP for the purpose of user profiling.
Disclosure to third parties
We may pass on your personal data to third parties. The data will only be passed on if we have received your consent to do so or if we can rely on our legitimate interests.
We share your data and identifiers with partner companies that hold additional information about users or market this information for third parties, as well as with technology providers and companies that wish to purchase advertising space. These partners and third parties use the data to show you targeted advertising or to analyse the effectiveness of advertising measures. Before we pass on your data, we ensure that this transfer is legally permissible.
If the disclosure is legally permissible, we use the additional data to make informed decisions about advertising placements and to optimize the advertising content accordingly. This data can be used both to enrich information for advertising placements and to improve advertising efficiency.
In addition, our customers who show a binding interest in specific advertising spaces may use the data to analyze and improve their own advertising measures, but only in the context of our platform and without passing it on to other third parties.
A detailed list of the technology providers we work with can be found at this link. For information on these and other partner companies, as well as for additional information on data processing, you can use our contact address data.privacy@virtualminds.com.
Joint controllership
We are a service provider, so we work with partners to process data. This also includes those partners on whose websites or mobile applications we collect data using the Cookies described above. With some of these partners, we are joint controllers within the meaning of data protection law (Art. 26 GDPR). This joint controllership generally relates to the collection and transmission of data to us. We will be happy to send you a current list of those partners with whom we are jointly responsible on request
We and our partners have shared certain tasks and activities within the framework of joint controllership. The division is as follows: We provide the partner with a technical solution (here tag), which the partner integrates into its offers. This tag enables the collection of the data described in more detail above. We also support the partner, in particular in the processing of enquiries from data subjects.
Our partner is responsible for obtaining consent and/or implementing transparency requirements in relation to you. They pass this information on to us in order to communicate the scope and permissibility of the data processing. This also includes information about our cooperation in the partner’s privacy policy.
In particular, each of the parties will ensure that the necessary data security is in place. Both we and our partner will also fulfil our reporting and notification obligations individually, but will support and inform each other to the extent necessary.
You can exercise your rights as a data subject as described below (see section 3.10) both against us and against our partner. We and our partner are liable for any processing that does not comply with the provisions of the GDPR in accordance with Art. 82 GDPR.
Do you have any further questions on the subject of joint controllership? We will be happy to provide you with further information on our cooperation with certain partners.
Other disclosure
We may also disclose your information to governmental authorities, courts, or third parties if such disclosure is necessary or appropriate for the establishment, exercise, or defence of our claims, interests, or rights, or to protect the vital interests of the data subject or another natural person.
We may also disclose your data to an acquirer or potential acquirer of our company or parts of our company, insofar as your data is connected to the part to be acquired and insofar as this is necessary to enable the acquirer to assess our company or the part of the company concerned. In the event of an acquisition, we may also transfer your data to the acquirer
3.7 How long do we store your data
Technical log files that are created during the transfer of data are automatically deleted after 3 days at the latest. The cookies used by us and stored in your browser generally have a duration of 90 days. If the cookie on your device is recognized by us again within this period, the term is extended by a further 90 days. If we do not recognize your identifier again for 90 days, the cookie will be automatically removed from your browser.
We do not store the data associated with the cookie or other identifiers in our systems for longer than is necessary for the purpose for which they were collected, unless we are authorized or obliged by law to continue to store them.
In principle, all personal data is deleted after 90 days at the latest, in many cases after just one month. This means that at no time do we have information about an identifier that is older than 90 days, even if the identifier was first generated more than 90 days ago.
Aggregated data that no longer has any reference to an identifier is stored for a maximum of 5 years and includes reports on the performance figures of campaigns, contact counts, fraud detection, and similar.
3.8 Transfer of your data abroad
We are based in Germany and our servers are also located there. However, some of our partners and customers are based outside the European Union. If we transfer your data to a partner or customer based outside the European Union, we ensure that secure processing with an appropriate level of protection takes place in this case too. For this purpose, we make use of legally provided and permissible measures, such as the submission of an adequacy decision of the European Commission (cf. Art. 45(1) GDPR) for the third country concerned; the use of the European Standard Contractual Clauses (cf. Art. 46(2)(c) GDPR); or other effective safeguards provided for in the GDPR.
3.9 Your rights
It is important to us that you do not lose control over the handling of your data. Under the GDPR, you have the rights listed here. We would like to point out that we may need your cooperation in order to identify you and respond to your request to assert your rights (Art. 11 (2) GDPR). In particular, we need your respective identifier for the respective product for which you wish to assert your rights and a completed form for proof of identity. You can find more information on both at this link . (Link auf Recht auf Auskunft & Vergessen)
Your Right
Explanation
Right of access (Art. 15 GDPR)
You have the right to obtain confirmation from us as to whether we are processing your personal data. If this is the case, you have a right to information about this data and, if necessary, further information.
Right to object (Art. 21 GDPR)
You can object to the further processing of your data at any time.
Right to rectification (Art. 16 GDPR)*
You can request that we correct the personal data stored about you.
Right to erasure (Art. 17 GDPR)
Under certain circumstances, you have the right to demand that we delete your personal data.
Right to restriction of processing (Art. 18 GDPR)*
Under certain circumstances, you also have the right to demand a restriction of processing.
Right to data portability (Art. 20 GDPR)
If the requirements of Art. 20 GDPR are met, you have the right to receive from us a structured, commonly used and machine-readable version of the personal data concerning you.
Right to lodge a complaint regarding our processing of your personal data with a data protection supervisory authority (Art. 77 GDPR)
Right to lodge a complaint regarding our processing of your personal data with a data protection supervisory authority (Art. 77 GDPR)
Right to withdraw your consent
You can withdraw your consent to the processing of your data at any time. Further information about your options can be found in section 4 below. In section 4.2 you will also find information on how to opt out.
* Please note that we do not receive and store any directly identifiable information relating to named individuals. The information we collect is grouped and stored exclusively on the basis of pseudonymous identifiers. Therefore, the exercise of the rights to correction or amendment is precluded by the actual possibility of allocation in our products. In the event of a request for restriction, correction, or amendment, we will instead delete the indirectly personal data, if we can assign it to your request, in consultation with you.
3.10 Switzerland: Country-Specific Provisions
In addition to the provisions listed above, the following applies to Switzerland:
All references to the GDPR are replaced by the corresponding provisions of the Swiss Federal Act on Data Protection in its current version.
Personal data is processed in Denmark, Germany, France, Ireland, Italy, Canada, the Netherlands, Norway, Poland, Romania, Sweden, Switzerland, Singapore, Slovakia, Slovenia, Spain, the UK, the USA, and Cyprus.
If we also share your personal data with partners in the third countries Canada, Singapore, the UK, or the USA, we will secure this transfer, where required by law, by concluding Standard Contractual Clauses with the data recipients or another legally permissible instrument for transfer protection.
3.11 What is the IAB Transparency and Consent Framework (IAB TCF)?
We participate in the IAB TCF, a standard for transparency obligations and consent in online advertising. Companies in the IAB TCF undertake to comply with higher standards than the GDPR. Our products (Adition, Active Agent, Yieldlab, Adex) are registered as vendors. You can find more information here: https://iabeurope.eu/transparency-consent-framework/. We recommend our customers to register as well. If you use the services of a company registered in the IAB TCF, you benefit from transparency and control over your data. The IAB TCF (version 2.2) enables data subjects to understand which processing activities are authorized based on their choices. You have complete freedom of choice over the use of your data and can exclude individual recipients or restrict purposes, except in the case of security-relevant processes.
Our customer is responsible for obtaining your consent and transparency requirements and passes this information on to us in order to communicate the data processing. This is usually done by means of a mechanism in the Internet Application used, which only enables access to content after you have given your consent via a banner. The IAB Transparency and Consent Framework (IAB TCF) serves as the standard for these consent banners, also known as the Consent Management Platform (CMP), and ensures your data protection and compliance with legal regulations.
We have also committed ourselves to this standard with our products and are verified vendors as defined by the IAB TCF and have the following vendor IDs:
Using the IAB TCF ensures that your consent or refusal is documented and forwarded. You can use the CMP to specify which data may be processed for which purposes. Your settings are taken into account on every visit, unless you have deleted your Cookies or they have expired. You can adjust or revoke your decisions at any time via the CMP.
Our customers and partners offer you the greatest possible freedom of choice, which applies to all Digital Content. Your choice may vary depending on the website operator. Digital content providers that do not yet use the IAB TCF and a CMP still offer control options for data processing. The exact structure may vary, so we recommend consulting the Privacy Policy of the respective customer or partner.
4. Your Options
It is important to us to enable you to make an informed decision about the use of your data. Here is an overview of your options. If you delete the cookies on your device or update the Mobile Advertising ID (MAID), your choices will be lost. You can choose again as soon as a new cookie is set. These choices do not mean that you will no longer see ads, but the ads you see may be less relevant to you..
4.1 Use of the CMP or the settings on the website
Your data is collected when you visit websites or use apps. Websites that participate in the IAB TCF offer detailed options for influencing data processing. They often use a CMP that clearly shows you your options (see 3.11).
With the CMP, you can generally consent to the processing or reject it. You can also make more granular decisions and select each purpose and recipient separately. The CMP recognizes you by the cookie, unless it has been deleted or has expired. If you choose, the CMP will ensure that this information is forwarded.
We and the Publishers (website operators) want to offer you the greatest possible freedom of choice. These options apply to every website but may vary depending on the website operator.
4.2 Use of our opt-out option
Irrespective of the Publishers, you can also object directly to the processing of your data by us. This option is also linked to the cookie. You can make these settings for our products at the following links:
Adition (AdServer)
Active Agent (DSP)
Yieldlab (SSP)
The Adex (DMP)
Your advantage: This choice then applies to all our services for the respective product for all our customers. However, it only applies to our processing activities and has no further effect. This choice does not apply to other contractual partners of the Publisher and its partners.
4.3 Deletion or blocking of cookie IDs
While we have defined the term Cookie broadly elsewhere in this document, here we are referring to cookies in the technical sense. These explanations therefore only apply if you use a browser and cannot be transferred to the use of apps. Furthermore, these explanations refer to third-party cookies, i.e., cookies that do not originate from the website operator. Many browsers already offer you options for handling cookies automatically. They often offer the following options:
The browser you are using may offer additional or different options. To make it as easy as possible for you to use these functions, we have compiled links here to the corresponding instructions and help for the most commonly used browsers:
However, as mentioned above, deleting cookies will result in a new cookie being set when you visit a website again, for which the previous options do not apply. If you want to prevent this completely, you can block cookies.
4.4 Mobile Advertising ID (MAID)
Unlike websites, advertising displayed in programmes (apps) on mobile phones uses the so-called MAID to identify the device. This MAID is a unique identifier that is stored on your device and linked by apps. Its use and purpose also correspond to a cookie.
You can prohibit the use of MAID for advertising purposes altogether via the operating system of your mobile phone. If you use an Apple device, MAID will only be used anyway with your separate consent, which can be revoked at any time.
For devices running the Apple operating system, you can find this information under Settings, then under Privacy, then under Advertising. There you have the option to restrict or reset ad tracking.
On a device running the Android operating system, you can usually find these settings under “Settings”, then under “Google” and then “Advertising”.
Right to information
Website privacy policy
Revocation of consent (Opt-Out)
