We participate in the „IAB Europe Transparency & Consent Framework” an adhere to its specifications and guidelines. In connection with our cookie-based processes we use the consent management platform (“CMP”) with the identification number 318.
1. Who are we? (Controller)
2. Why do we process your personal data and what is the legal basis for processing?
Personal Data is any information relating to an identified or identifiable natural person. Processing personal data means that we for ex-ample collect, store, use transfer or delete personal data. We process your personal data for the following purposes and based on the listed legal basis. In case data processing is based on legiti-mate interests we describe our legitimate interests for processing.
General purposes for processing:
Nr. Purpose Legal Basis including where applicable description of legitimate interests
1 Providing the Online Content, including in particular
• enabling the use of the Online Content;
• providing a contact form as well as answering submitted re-quests performance of a contract
2 Conducting sweepstakes in accordance with the respective terms & conditions. performance of a contract
3 Sending e-mail newsletters regarding our offers (without registration) legitimate interests (direct marketing, as long as direct marketing is in accordance with data protection, telecommunication and competition regulations)
4 Sending push notifications consent
5 Providing login via third parties (single sign-on-service). performance of a contract
6 Providing login via 7Pass. performance of a contract
7 Determination and eventual blocking of users that have installed so-called adblockers and thus are blocking advertising legitimate interests (providing our online con-tent partially or fully financed with advertising only to users that do not block advertising)
8 Information security: identifying disruptions and ensuring system se-curity including detecting and tracking unauthorized access and at-tempts to access our web servers. compliance with our legal obligation to ensure data security as well as legitimate interests (elimination disruptions, ensuring system secu-rity and detection and tracking of unauthorized access and attempts to access)
9 Compliance with statutory retention periods or other statutory obliga-tions (eg in connection with audits) compliance with our legal obligations, in par-ticular in connection with storing certain infor-mation and with audits; legitimate interests (creating the conditions for legal compliance)
10 Preservation and defense of our rights. legitimate interests (preservation and defense of our rights)
11 Sale of all or part of our business operations legitimate interests (transferring customer data to the acquirer in connection with the sale of our business operations; as a rule, this presup-poses that the users have agreed to a transfer of the contract or have not objected to a trans-fer after receiving adequate information)
Please note your right to object regarding data processing for the purpose of direct marketing and for personal reasons respectively (see sections “Your right to object to direct marketing” and “Your right to object due to personal reasons”.
1 Selection of simple ads. Ads can be displayed based on content you are seeing, the application you are using and your approximate loca-tion or device type. legitimate interests (Display of ads that are as interesting as possible for our users and there-fore provide added value to them) or consent (according to the legal bases stated in our CMP)
2 Creation of a personal ad profile. A profile of your interests can be created to display relevant personalized ads. consent
3 Selection of personalized ads. Personalized ads can be displayed based on the created profile. consent
4 Creation of a personalized content profile. A profile of you and your interests can be created to display relevant personalized ads. consent
5 Selection of personalized content. Personalized content can be dis-played based on the created profile. consent
6 Measure ad performance. The performance and effectiveness of ads you see or interact with may be measured. legitimate interests (efficient display and in-voicing of ads or consent (according to the legal bases stated in our cmp)
7 Measure content performance. The performance and effectiveness of content you see or interact with may be measured. legitimate interests (display of content that is as interesting as possible for our users and therefore provide added value to them) or consent (according to the legal bases stated in our CMP)
8 Use of market research to gain insights into target groups. Market research may be used to learn more about the audiences that use services or applications and view ads. legitimate interests (better understanding of audiences and optimization of the content) or consent (according to the legal bases stated in our CMP)
9 Product development and improvement. Your data may be used to improve existing systems or software and develop new products. legitimate interests (development and im-provement of our content)
10 Ensure security, prevent fraud, and fix bugs. Your data may be used to identify and prevent fraudulent activity and to ensure that systems and processes function properly and securely. legitimate interests (ensuring security, pre-venting fraud or fixing bugs)
11 provide ads or content technically. Your device can receive and send information necessary to allow you to view and use content and ads. performance of a contract (display of content) or legitimate interests (display of ads)
12 Select personalized content to merge with offline data sources. Data from offline data sources may be merged with data from your online activities to be used for one or more processing purposes or special processing purposes and vice versa. consent
13 Link different devices. For use for one or more processing purposes, it can be detected whether different devices belong to you or your household. consent
14 Receive and use automatically sent device properties for identifica-tion. Your device can be distinguished from other devices based on information it sends automatically, such as IP address or browser type. consent
15 Use accurate location. Your location can be used for on or more processing purposes meaning your location may be detected up to a few meters. consent
16 Actively query device properties for identification. Your device can be detected by querying its specific characteristics. consent
3. Who receives your personal data and why?
Transfer of data to third parties
Your personal data is generally only transferred to third parties if necessary for the performance of a contract, if covered by legitimate in-terests of us or third parties, you consented to the transfer or if necessary to comply with a legal obligation.
We may disclose personal data to third parties in particular
• if we are obliged to do so by law or by enforceable administrative or judicial order in the individual case;
• in connection with legal disputes (transfer to courts or our lawyers) or audits (transfer to auditors);
• in connection with possible criminal offences (transfer to the competent investigative authorities);
• in case of a sale of our business operations (transfer to the acquirer).
If data may be transferred to third parties on a regular basis this is explained separately in this privacy notice. In case the transfer is based on your consent this explanation will be given when obtaining your consent. Transfer of data to service providers
We reserve the right to use service providers when collecting or processing personal data. Service Providers will receive only personal data required for their respective service from us. For example, your e-mail address may be transferred to a service provider in order to deliver our newsletter. We may also task service providers with providing server capacity. Service providers are generally processor and as such may only process personal data of users of the Online Content in accordance with our instructions.
Insofar as service providers have not been named explicitly, we use the following categories of service providers:
• IT-Services (technical support): Germany, France, Bulgaria, Albania, Austria
• IT-Services (hosting): Germany, USA, Austria
• IT-Services (push notifications): Germany
• Customer support (e-mail, phone): Germany, Austria
4. When to we transfer data to countries not part of the European Economic Area?
We may transfer personal data to third parties or processors that have their main office in a Non-EEA-Country. In this case prior to the transfer we ensure that either there is an adequate level of data protection (eg by means of an adequacy decision by the European Commission for the respective country pursuant to Art 45 GDPR or by concluding so-called standard contractual clauses sanctioned by the European Commission pursuant to Art 46 GDPR) or the user has consented to the transfer.
These are third parties or processors in the following countries: USA You may request a list of the recipients in third countries or a copy of the relevant concluded measures to safeguard an adequate level of data protection. Please see Section Contact for our contact details.
5. Who long do we store data?
We store your data as long as necessary for providing our Online Content and other content in connection with it or as long as we have a legitimate interest in further storage. In all other cases, we will delete your personal data except for such data, which we must store in or-der to comply with legal (eg tax or commercial) retention periods (eg invoices). We restrict access to data subject to a retention period until the expiry of the period.
Specifically, the following retention periods apply to personal data processed in the context of this Online Content:
• Log-files: 7 to 20 days
• Consent to newsletter: until user revokes consent/unsubscribes
Please find more information on retention periods of cookies and ad-identifiers in the respective policies or our CMP.
6. Are you required to provide personal data?
In principle, you are not required to provide us with your personal data. However, the use of certain services of this Online Content may require processing of your personal data, eg registration or participation in sweepstakes. In such cases we will indicate the requirement accordingly. Mandatory information is regularly marked with an *. If you do not wish to provide us with the necessary data, you may not be able to use the respective services.
Each time you use the Online Content certain information is automatically transmitted to us from your device and stored for 7 to 20 days for the purpose of determining faults and for security reasons (eg to investigate attempted attacks). After this period the data will be de-leted. However, where further retention of log-files is necessary for evidence purposes the log-files will not be deleted until the final clari-fication of the respective incident and may eventually be transferred to investigating authorities.
The log-files contain in particular the following information:
• IP-address (internet protocol address) of the device accessing the Online Content;
• internet address of the website referring to the online content (so-called origin or referring url);
• name of the service provider used to access the Online Content;
• name of retrieved files or information;
• date and time as well as duration of the access;
• amount of data transferred;
• operating system and information on the used device; and
• http-status-code (eg “request successful” or “requested file not found”).
Log-files will also be used for analytical purposes.
8. Cookies, ad-identifiers and similar technologies
For information regarding cookies, advertising identifiers and similar technologies used in this Online Content, please refer to our respec-tive policies and our CMP. Insofar as personal data is processed in connection these technologies, you will find detailed information on the respective purposes. Information on how to object to such processing can also be found in the relevant policies.
9. Share features
Your mobile device offers you the possibility to share content from the Online Content with third parties (eg via email, SMS or via social networks). We have no influence on the processing of data connected eg by social network providers. The respective third party provid-ers are responsible for such features.
10. Registration/Login via 7Pass
You can sign up for this Online Content using your 7Pass account. Responsible for providing the 7Pass account is ProSiebenSat.1 Digi-tal Data GmbH, Medienallee 4, 85774 Unterföhring, Germany ("PSDD").
7Pass is designed to provide users with uniform credentials for various mobile services. For more information about 7Pass, please see the 7Pass FAQ.
11. Sign in Services (Login via third party providers)
Registration/Login via Facebook (Facebook-Login)
We offer the possibility to register or sign in via your Facebook account. If you use this, we will receive the data required for registration or signing in from Facebook (eg e-mail address, name).
Registration/Login via Google
We offer the possibility to register or sign in via your Google Account. If you use this, we will receive the data required for registration or signing in from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google") (eg email address, name).
Registration/Login via NetID
We offer the possibility to register or sign in via your NetID account. If you use this, we will receive the data required for registration or signing in from European netID Foundation, Elgendorfer Str. 57, 56410 Montabaur (“NetID”) (eg e-mail address, name).
We offer you the possibility to subscribe to a newsletter. You may revoke your consent at any time. For more information, see the sec-tion “Your Right to Revoke Consent”.
13. Your rights (rights of data subjects)
How can you excercise your rights? Please use the information in the section “Contact” to exercise your rights. Please make sure that we can clearly identify you.
Alternatively, you may use the settings options in your user account to correct the data provided at the time of registration or for your ad-vertising objection. You may also use the "Unsubscribe" link at the end of each email. Your settings regarding cookies and/or ad-identifiers and the data processing based on them may be customized at any time in our re-spective policies or our CMP.
Your rights to information and correction You have the right to request confirmation that we are your processing personal data and to request information regarding your personal data processed by us. If your data is incorrect or incomplete, you have the right to request correction or completion of your personal da-ta. If we have transferred your data to third parties, we will inform these third parties of the correction to the extent required by law.
Your right to deletion
You have the right to request deletion of your personal data where the statutory requirements are fulfilled. This is in particular the case if
• your personal data is no longer necessary for the purpose the data was collected;
• the processing was solely based on your consent which you have revoked;
• you objected to the processing for marketing purposes (“objection to marketing”);
• you have objected to processing based on legitimate interests due to personal reasons and we are not able to provide overriding legitimate interests for the processing; • your personal data is processed unlawfully; or
• your personal data must be deleted to adhere with statutory requirements.
If we have transferred your data to third parties, we will inform these third parties of the deletion to the extent required by law. Please note that your right of deletion can be subject to restrictions. For example, we do not need to or may not delete any data that we have to store due to statutory retention periods. Data that we need to assert, exercise or defend legal claims are also excluded from your right of deletion.
Your right to restrict processing
You have the right to request restriction of processing where the statutory requirements are fulfilled This is in particular the case if
• you contest the accuracy of your personal data until we had the chance to evaluate the accuracy;
• processing is unlawful and you request restriction instead of deletion (see above);
• we no longer require your personal data for the initial purpose, but you may need them to assert, exercise or defend your legal claims;
• you objected due to personal reasons, until it is clarified whether we have overriding legitimate interests.
Where the right to restrict processing exists, we mark the data concerned to ensure that it is only processed within the narrow limits that apply to such restricted data (in particular to defend legal claims or with your consent).
Your right to data portability
You have the right to receive your personal data given to us for the performance of a contract or based on your consent in a transferable format. In this case, you may also request that we transfer this data directly to a third party, insofar as this is technically feasible.
Your right to revoke consent
If you have given us your consent to processing your data, you have the right to revoke given consent at any time in our CMP with ef-fect for the future. The legality of the processing of your data until the revocation remains unaffected.
Your right to object to direct marketing
You also have the right to object to the processing of your personal data for marketing purposes at any time. Please note that for or-ganizational reasons, there may be an overlap between your objection and the use of your data as part of an already ongoing cam-paign.
Your right to object due to personal reasons
You have the right to object to the processing of your personal data based on our legitimate interests for reasons arising from your particular situation. We will then cease processing your data unless we can prove, in accordance with the legal requirements, compel-ling reasons worthy of protection for further processing, which override your rights.
Your right to file a complaint with a data protection authority
You have the right to file a complaint with a data protection authority. You can in particular contact the data protection authority compe-tent for your place of residence or where data protection laws have been infringed. Alternatively, you can contact the data protection au-thority competent for us.
For inquiries and feedback regarding data protection we and our Data Protection Manager are readily available via e-mail (email@example.com) at any time.
You can further contact us as follows:
ProSiebenSat.1 PULS 4 GmbH
Media Quarter Marx 3.3
Maria Jacobi Gasse 1
Telefon: +43 / 1 / 368 77 66 – 0
Telefax: +43 / 1 / 368 77 66 - 199