This document aims to represent the overall approach adopted by ShowHeroes in order to guarantee an adequate level of protection of the personal data to carry out a treatment in compliance with the relevant legislation, in particular with EU Regulation n.2016/679 (hereinafter “GDPR”), concerning the protection of individuals with regard to the processing of Personal Data as well as the free circulation of such Data, and in accordance with the country-specific data protection regulations applicable to ShowHeroes.
The data provided will be processed according to the principles of lawfulness, correctness and transparency and the protection of confidentiality and rights.
The use of the Internet pages of ShowHeroes, its video-player widgets (when used as a video content player) and other products is possible without any indication of personal data.
However, the processing of personal data may become necessary if a data subject wants to use special enterprise services via our website, video-player widgets (when used to monetise inventory) or any of our other products. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.
As a Data Controller, ShowHeroes has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website.
Without user consent, ShowHeroes does not track any personal data in its video player widgets, which are integrated on countless partner websites. In particular, cookies are not set there without the necessary consent, and user data (including IP addresses or device IDs) are not stored in such a way that a user can be identified again at a later point in time.
ShowHeroes video player widgets also support various consent management platforms (CMPs) to protect the privacy wishes of every user with regard to affiliated advertising partners. See: https://iabtechlab.com/standards/gdpr-transparency-and-consent-framework/.
In this document, we use, inter alia, the following terms:
a) Personal data: any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject: any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
c) Controller/ Data Controller: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
d) Data Protection Officer: the natural or legal person who ensures that the company or organization is correctly protecting individuals’ personal data according to current legislation.
e) Processor: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
f) Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
g) Recipient: a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of that data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
h) Consent of the data subject: any freely given, specific, informed and unambiguous indication of the data subject’s wishes 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.
i) Restriction of processing: the marking of stored personal data with the aim of limiting their processing in the future.
j) Profiling: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
k) Pseudonymisation: the processing of personal data in such a manner that the personal data can no longer be aributed 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 organizational measures to ensure that the personal data are not aributed to an identified or identifiable natural person.
l) Third party: a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
2. Data Controller and Data Protection Officer
10115 Berlin – Germany
Data Protection Officer (“DPO”):
Carlos de las Cuevas Otero
3. Collection of general data and information
The website of ShowHeroes collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files.
The Data that may be collected are the following:
a. browser types and versions used;
b. operating system used by the accessing system;
c. website from which an accessing system reaches our website (so-called referrers);
e. date and time of access to the Internet site;
f. an Internet protocol address (IP address);
g. Internet service provider of the accessing system;
h. any other similar data and information that may be used in the event of attacks on our information technology systems.
The purposes of the processing are the following:
4. Legal basis of the processing
The legal basis for the processing of personal data is explained as follows:
– the legitimate interest of ShowHeroes entities: it consists of carrying out our business in favor of the well-being of all our employees and the shareholders.
– the performance of the contract between the SH Entity and the Partner, to ensure that ShowHeroes can provide the Services required under the Contract, to ensure that the Partner can access ShowHeroes’ platforms and websites;
– the compliance with legal requirements;
– your consent, which you can express through the Consent Management Platform (“CMP”) of our Publisher Partners, or even revoke at a later date.
In case of lack of consent, we will not be able to optimize the advertising services addressed to you on the basis of the information acquired by us through our cookies. In any case, if you do not wish to be tracked by our systems, you can click on the following opt-out link.
According to Article 6 of the GDPR, processing shall be lawful only if and to the extent that at least one of the following applies:
a. you have given consent to the processing of your personal data for one or more specific purposes;
b. processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract: for example, when processing operations are necessary for the supply of goods or to provide any other service. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services;
c. processing is necessary for compliance with a legal obligation to which the controller is subject and for which processing personal data is required, such as for the fulfillment of tax obligations;
d. processing is necessary in order to protect your vital interests or the ones of another natural person: for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party.
e. processing operations which are not covered by any of the above mentioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
You can find further information in the following link:
5. Processing methods
The data will be processed using electronic tools suitable for guaranteeing security, in relation to the purposes for which they were collected, as well as to avoid unauthorized access by third parties and, in any case, in compliance with the provisions of national and European legislation.
In no case we use the data collected by us or by other third parties to determine your personal identity, and all data is processed anonymously. In particular, we use randomized user identification strings that are anonymous by design. IP addresses processed for technical delivery will be salted by the user agent string and stored in a hashed format, preventing any possibility of reconstruction.
6. Subjects of data processing and communication
The data are processed only with electronic tools, in a totally automated way and, for the most part, without human intermediation. Therefore, our employees and collaborators will never access the content of your personal data obtained through cookies. Some of our employees and collaborators, appointed by us as authorized personnel and / or data processors and / or system administrators, may carry out maintenance operations on the computer systems that host the data, without ever being able to access their actual content.
Each browser has different procedures for managing settings. You can get specific instructions through the links below.
Internet Explorer: https://windows.microsoft.com/it-it/windows7/block-enable-or-allow-cookies
Google Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en
Mozilla Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
Apple Safari: https://www.apple.com/legal/privacy/it/cookies/
8. Provision of personal data as statutory or contractual requirement – Requirement necessary to enter into a contract – Obligation of the data subject to provide the personal data – Possible consequences of failure to provide such data
The provision of personal data can be partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject should contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
9. Your Rights
We inform you of the possibility of exercising at any time the rights that are recognized by GDPR and data protection laws, reported as follows:
a. Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact the mailbox firstname.lastname@example.org and fill in this form: https://docs.google.com/forms/d/1jEbYzdxQapClLAe4fWibkN8sAtvu-RXiQSPHy-BjASE/edit with the details of him or her enquiry.
b. Right of access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
– the purposes of the processing;
– the categories of personal data concerned;
– the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
– where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
– the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
– the existence of the right to lodge a complaint with a supervisory authority (Privacy Guarantor);
– where the personal data are not collected from the data subject, any available information as to their source;
– the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
– Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
– If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact the mailbox email@example.com and fill in this form: https://docs.google.com/forms/d/1jEbYzdxQapClLAe4fWibkN8sAtvu-RXiQSPHy-BjASE/edit with the details of him or her enquiry.
c. Right to rectification
According to Article 16 of the GDPR, each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact the mailbox firstname.lastname@example.org and fill in this form: https://docs.google.com/forms/d/1jEbYzdxQapClLAe4fWibkN8sAtvu-RXiQSPHy-BjASE/edit with the details of him or her enquiry.
d. Right to erasure (right to be forgotten)
Each data subject shall have the right granted by Article 17 of the GDPR to obtain the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
– the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
– the data subject withdraws consent to which the processing is based according to point (a) of Article 6.1 of the GDPR, point (a) of Article 9.2 of the GDPR, and where there is no other legal ground for the processing;
– the data subject objects to the processing pursuant to Article 21 of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21 of the GDPR;
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The personal data have been collected in relation to the offer of information society services referred to in Article 8.1 of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by ShowHeroes, he/she may, at any time, contact any employee of the controller. The controller shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17.1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. If a data subject wishes to exercise this right to erasure, he or she may, at any time, contact the mailbox email@example.com and fill in this form: https://docs.google.com/forms/d/1jEbYzdxQapClLAe4fWibkN8sAtvu-RXiQSPHy-BjASE/edit with the details of him or her enquiry.
e. Right to obtain the portability of your data, according to Article 20 of the GDPR
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmied directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact the mailbox firstname.lastname@example.org and fill in this form: https://docs.google.com/forms/d/1jEbYzdxQapClLAe4fWibkN8sAtvu-RXiQSPHy-BjASE/edit with the details of him or her enquiry.
f. Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact the mailbox email@example.com and fill in this form: https://docs.google.com/forms/d/1jEbYzdxQapClLAe4fWibkN8sAtvu-RXiQSPHy-BjASE/edit with the details of him or her enquiry.
g. Right to oppose data processing, according to the Article 21 of the GDPR
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
ShowHeroes shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.
If ShowHeroes processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to ShowHeroes to the processing for direct marketing purposes, ShowHeroes will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by ShowHeroes for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
h. Right to oppose an automated decision-making process relating to natural persons, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, ShowHeroes shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, and the data subject may contact the mailbox firstname.lastname@example.org and fill in this form: https://docs.google.com/forms/d/1jEbYzdxQapClLAe4fWibkN8sAtvu-RXiQSPHy-BjASE/edit with the details of him or her enquiry.
Any request can be addressed to:
address: ShowHeroes SE – Data Privacy Officer, Brunnenstraße, 154 – 10115 Berlin
10. Registration on the Website
The data subject has the possibility to register on the ShowHeroes website with the indication of personal data. Which personal data are transmied to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.
By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.
The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees are available to the data subject in this respect as contact persons.
11. Subscription to our newsletter
On the website of ShowHeroes users are given the opportunity to subscribe to our enterprise’s newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.
ShowHeroes informs its customers and business partners regularly by means of a newsletter about enterprise offers.
The enterprise’s newsletter may only be received by the data subject if:
a. the data subject has a valid e-mail address and
b. the data subject registers for the newsletter shipping. A confirmation email will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation email is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.
During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by email, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter.
The newsletter of ShowHeroes contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such emails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, ShowHeroes may see if and when an email was opened by a data subject, and which links in the email were called up by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even beer to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller.
ShowHeroes automatically regards a withdrawal from the receipt of the newsletter as a revocation.
13. Contact possibility via the website
The website of ShowHeroes contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address).
If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
14. Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
15. Data protection provisions about the application and use of the following Services:
– Google Analytics (with anonymization function)
On the websites of ShowHeroes Group, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
For web analytics through Google Analytics the controller uses the application “_gat. _anonymizeIp”. By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.
The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits to our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
Further information and the applicable data protection provisions of Google may be retrieved on the following links: https://www.google.com/intl/en/policies/privacy/ and http://www.google.com/analytics/terms/us.html.
Google Analytics is further explained under the following Link https://www.google.com/analytics/.
The controller has integrated components of the LinkedIn Corporation on this website. LinkedIn is a web-based social network that enables users with existing business contacts to connect and to make new business contacts. Over 400 million registered people in more than 200 countries use LinkedIn. Thus, LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.
With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a LinkedIn component (LinkedIn plug-in) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding LinkedIn component of LinkedIn. Further information about the LinkedIn plug-in may be accessed under https://developer.linkedin.com/plugins. During the course of this technical procedure, LinkedIn gains knowledge of what specific sub-page of our website was visited by the data subject.
If the data subject is logged in at the same time on LinkedIn, LinkedIn detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-page of our Internet page was visited by the data subject. This information is collected through the LinkedIn component and associated with the respective LinkedIn account of the data subject. If the data subject clicks on one of the LinkedIn buttons integrated on our website, then LinkedIn assigns this information to the personal LinkedIn user account of the data subject and stores the personal data.
LinkedIn receives information via the LinkedIn component that the data subject has visited our website, provided that the data subject is logged in at LinkedIn at the time of the call-up to our website. This occurs regardless of whether the person clicks on the LinkedIn button or not. If such a transmission of information to LinkedIn is not desirable for the data subject, then he or she may prevent this by logging off from their LinkedIn account before a call-up to our website is made. LinkedIn provides under https://www.linkedin.com/psettings/guest-controls the possibility to unsubscribe from e-mail messages, SMS messages and targeted ads, as well as the ability to manage ad settings. LinkedIn also uses affiliates such as Eire, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame.
The setting of such cookies may be denied under https://www.linkedin.com/legal/cookie-policy.
Into its products, the controller has integrated components of DoubleClick by Google. DoubleClick is a trademark of Google, under which predominantly special online marketing solutions are marketed to advertising agencies and publishers.
The operating company of DoubleClick by Google is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.
DoubleClick by Google transmits data to the DoubleClick server with each impression, clicks, or other activity. Each of these data transfers triggers a cookie request to the data subject’s browser. If the browser accepts this request, DoubleClick uses a cookie on the information technology system of the data subject. The definition of cookies is explained above. The purpose of the cookie is the optimization and display of advertising. The cookie is used, inter alia, to display and place user-relevant advertising as well as to create or improve reports on advertising campaigns. Furthermore, the cookie serves to avoid multiple displays of the same advertisement.
DoubleClick uses a cookie ID that is required to execute the technical process. For example, the cookie ID is required to display an advertisement in a browser. DoubleClick may also use the Cookie ID to record which advertisements have already been displayed in a browser in order to avoid duplications.
It is also possible for DoubleClick to track conversions through the cookie ID. For instance, conversions are captured when a user has previously been shown a DoubleClick advertising ad, and he or she subsequently makes a purchase on the advertiser’s website using the same Internet browser. A cookie from DoubleClick does not contain any personal data. However, a DoubleClick cookie may contain additional campaign IDs. A campaign ID is used to identify campaigns that the user has already been in contact with.
With each call-up to one of the individual pages of this website, which is operated by the controller and on which a DoubleClick component was integrated, the Internet browser on the information technology system of the data subject is automatically prompted by the respective DoubleClick component to send data for the purpose of online advertising and billing of commissions to Google. During the course of this technical procedure, Google gains knowledge of any data that Google may use to create commission calculations. Google may, inter alia, understand that the data subject has clicked on certain links on our website.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google may be deleted at any time via a web browser or other software programs.
Further information and the applicable data protection provisions of DoubleClick may be retrieved under DoubleClick by Google https://www.google.com/intl/en/policies/.
– Marketing relationships with [m]PLATFORM
Into its products, the controller has integrated components of [m]PLATFORM by GroupM. [m]PLATFORM is a trademark of GroupM, which GroupM agencies use for their clients, to help them to understand the advertising that the clients deliver online (e.g. what sites it was delivered on, who saw it and whether or not anyone interacted with it) and to improve the effectiveness of that advertising. It also helps them to try to deliver advertising to consumers who are more likely to be interested in their products and services.
The operating company of [m]PLATFORM by GroupM is GroupM UK Limited, 40 The Strand, London WC2N 5RW, United Kingdom.
The Platform is designed to collect and/or use information about the type of web pages that individuals visit and about interactions that they have with Sites and with our clients’ advertisements. It also collects information that identifies the browsers and devices of the individuals who have viewed its clients’ advertising. This information includes the following categories of data:
– Technical Identifiers: Cookie IDs, Mobile Advertising IDs, [m]PLATFORM’s “[mP]ID” proxy identifier for the above IDs;
– Additional Technical Information: IP Address and data derived from it, browser data, connection type, geolocation;
– Online Activity Information: sites and pages viewed, referrers, date and time of an activity, frequency of visits, search terms, interactions with an advertisement;
Further information and the applicable data protection provisions of [m]PLATFORM are available at https://www.groupm.com/mplatform-privacy-notice-eu/. To opt out of data collection via cookies from [m]PLATFORM please click here: https://www.groupm.com/groupm-privacy-notice-opt-out-confirmation/.
Other Services with the related personal data collected and the purposes pursued:
Google Tag Manager: we collect Usage Data to tag Management.
Mailchimp: we collect email addresses, first name and last name.
Mailing list or newsletter: we collect email address, first name and last name, website.
Mandrill: we collect email address and Usage data.
Further information about Personal Data:
Navegg’s “Your Profile”
Navegg’s “Edit your data”
16. Data storage
‘The data will be kept only for the time necessary to achieve the purpose for which they were collected. However, it is understood that if there is finally revocation of the consent of the interested party and / or in the event that, for any reason, the retention of personal data of the same is not further justified on the basis of evaluations carried out that take into account the principles of necessity, proportionality, adequacy and relevance of the processing, the Data Controller will in any case proceed without delay to the cancellation or anonymization of the data.
For more information on the principles underlying the aforementioned conservation choices, the Data Controller may be contacted in the manner referred to in point 9 above.
17. Changes or updates
The constant evolution of our services may lead to changes in the characteristics of the processing of your personal data described so far.
Consequently, this document may undergo changes and additions over time, which may also be necessary in relation to new regulatory interventions on the protection of personal data.
We therefore invite you to periodically check the contents: where possible, we will try to inform you promptly about the changes made and their consequences.
In any case, the updated version of the privacy information will be published on this page.