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Introduction
This Privacy Policy aims to inform you about how we, Mative Media GmbH, process your personal data (hereafter also referred to as “data”) in connection with our services, especially on our websites, in mobile applications, and within external online presences, such as our social media profiles (collectively referred to as “Online Services”). The terms used in this policy are intended to be gender-neutral.
Effective Date: January 1, 2021
Contents
Introduction
Responsible Entity
Overview of Data Processing
Legal Basis for Processing
Security Measures
Transmission and Disclosure of Personal Data
Data Processing in Third Countries
Use of Cookies
Online Services and Web Hosting
Social Media Presence
Plugins and Embedded Functions and Content
Deletion of Data
Modification and Update of the Privacy Policy
Rights of Data Subjects
Definitions
Responsible Entity
Mative Media GmbH
Neue Burg 2
20457 Hamburg,
Germany
Phone: +49 40 285 475 68
Email: info@mative.de
Register Court: Hamburg | Commercial Register Number: HRB 165745
VAT ID: DE 339363853
Managing Director: Alper Bugra Temur, Tom Becker
Overview of Data Processing
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of Processed Data:
Inventory data (e.g., names, addresses).
Content data (e.g., text input, photographs, videos).
Contact data (e.g., email, phone numbers).
Meta/communication data (e.g., device information, IP addresses).
Usage data (e.g., websites visited, interest in content, access times).
Categories of Data Subjects:
Users (e.g., website visitors, users of online services).
Purposes of Processing:
Provision of our online services and usability.
Response to contact inquiries and communication.
Marketing, advertising, and market research.
Security measures.
Legal Basis for Processing
We process personal data in accordance with the provisions of the General Data Protection Regulation (GDPR), based on the following legal grounds:
Consent (Article 6 (1) (a) GDPR): The data subject has given consent to the processing of their personal data for one or more specific purposes.
Legitimate interests (Article 6 (1) (f) GDPR): Processing is necessary for the purposes of the legitimate interests pursued by the controller 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.
In addition to the GDPR, national data protection regulations may apply in your or our country of residence or domicile.
Security Measures
We take appropriate technical and organizational measures to ensure a level of security appropriate to the risk, according to the legal requirements, taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing as well as the varying likelihood and severity for the rights and freedoms of natural persons.
Transmission and Disclosure of Personal Data
In the course of our processing of personal data, it may happen that the data is transferred to other places, companies, legally independent organizational units, or persons, or that it is disclosed to them. Recipients of these data may include, for example, payment institutions within the context of payment transactions, service providers tasked with IT tasks, or providers of services and content integrated into a website. In such cases, we comply with the legal requirements and conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.
Data Processing in Third Countries
If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to other persons, bodies, or companies, this only takes place in accordance with the legal requirements.
Subject to express consent or transfer required by contract or law, we process or let the data be processed only in third countries with a recognized level of data protection, which includes US processors certified under the “Privacy Shield,” or on the basis of special guarantees, such as contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications, or binding internal data protection regulations (Article 44 to 49 GDPR, Information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).
Use of Cookies
Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after their visit within an online service. The stored information may include, for instance, the language settings on a website, the login status, a shopping cart, or the location where a video was watched. We also include in this definition other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”).
The following types and functions of cookies are distinguished:
Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their browser.
Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for range measurement or marketing purposes can be stored in such a cookie.
First-party cookies: First-party cookies are set by ourselves.
Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
Necessary (also: essential or absolutely necessary) cookies: Cookies can be necessary for the operation of a website (e.g., to save logins or other user inputs or for security reasons).
Statistics, marketing, and personalization cookies: Furthermore, cookies are usually also used in the context of range measurement as well as when a user’s interests or behavior (e.g., viewing certain content, using functions, etc.) are stored on individual websites in a user profile. Such profiles are used, for example, to display content to users that corresponds to their potential interests. This process is also referred to as “tracking”, i.e., following the potential interests of users. Insofar as we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or in the context of obtaining consent.
Provision of the Online Offer and Webhosting
To provide our online offer securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers they manage) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space, and database services, as well as security services and technical maintenance services.
The data processed in the context of providing the hosting offer may include all information concerning the users of our online offer, which is generated in the course of use and communication. This regularly includes the IP address necessary to be able to deliver the contents of online offers to browsers, and all within our online offer or of websites made entries.
Collection of Access Data and Log Files: We ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). Server log files can include the address and name of the accessed web pages and files, date and time of access, transferred data volumes, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), and usually IP addresses and the requesting provider.
The server log files can be used for security purposes, e.g., to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the load of the servers and their stability.
Processed Data Types: Content data (e.g., text input, photographs, videos), Usage data (e.g., websites visited, interest in content, access times), Meta/communication data (e.g., device information, IP addresses).
Data Subjects: Users (e.g., website visitors, users of online services).
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Presence in Social Networks (Social Media)
We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may pose risks to users because, for example, the enforcement of users’ rights could be made more difficult. Regarding US providers certified under the Privacy Shield or offering comparable guarantees of a secure level of data protection, we would like to point out that they commit themselves to complying with the data protection standards of the EU.
Furthermore, user data is usually processed for market research and advertising purposes. For example, user profiles can be created based on the user behavior and the resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements inside and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies containing the behavior and interests of the users are stored on the computers of the users. Furthermore, data can also be stored in the usage profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective processing forms and the opt-out options, we refer to the privacy statements and information provided by the operators of the respective networks.
Also, in the case of requests for information and the assertion of data subject rights, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, then you can contact us.
Processed Data Types: Inventory data (e.g., names, addresses), Contact data (e.g., email, phone numbers), Content data (e.g., text input, photographs, videos), Usage data (e.g., websites visited, interest in content, access times), Meta/communication data (e.g., device information, IP addresses).
Data Subjects: Users (e.g., website visitors, users of online services).
Purposes of Processing: Contact requests and communication, Tracking (e.g., interest/behavioral profiling, use of cookies), Remarketing, Reach Measurement (e.g., access statistics, recognition of returning visitors).
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Services Used and Service Providers:
Instagram: Social network; Service provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.
Facebook: Social network; Service provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Privacy Shield (ensuring level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-Out: Settings for advertisements: https://www.facebook.com/settings?tab=ads; Additional information on data protection: Agreement on joint processing of personal data on Facebook pages: https://www.facebook.com/legal/terms/page_controller_addendum, Privacy notices for Facebook pages: https://www.facebook.com/legal/terms/information_about_page_insights_data.
Plugins and Embedded Functions and Content
We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These can be, for example, graphics, videos, social media buttons, and contributions (hereinafter uniformly referred to as “content”).
The integration always presupposes that the third-party providers of this content process the IP address of the users, since they could not send the content to their browsers without the IP address. The IP address is therefore required for the presentation of this content or functions. We strive to use only those contents whose respective providers use the IP address only for the delivery of the contents. Third-party providers can also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user’s device and contain, among other things, technical information about the browser and operating system, referring websites, visiting time, and other information about the use of our online offer, as well as be linked to such information from other sources.
Notes on Legal Bases: If we ask the users for their consent to the use of third-party providers, the legal basis of the processing of data is consent. Otherwise, the users’ data is processed on the basis of our legitimate interests (i.e., interest in efficient, economic, and recipient-friendly services). In this regard, we also refer you to the information on the use of cookies in this privacy policy.
Processed Data Types: Usage data (e.g., websites visited, interest in content, access times), Meta/communication data (e.g., device information, IP addresses).
Data Subjects: Users (e.g., website visitors, users of online services).
Purposes of Processing: Provision of our online offer and user-friendliness, Contractual services, and service.
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Services Used and Service Providers:
Google Fonts: We integrate the fonts (“Google Fonts”) of the provider Google, whereby the users’ data is used solely for the purpose of displaying the fonts in the users’ browser. The integration is based on our legitimate interests in a technically secure, maintenance-free, and efficient use of fonts, their uniform presentation, and taking into account possible licensing restrictions for their integration. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
Deletion of Data
The data processed by us is deleted in accordance with the legal requirements as soon as their consent allowed for processing is revoked or other permissions no longer apply (e.g., if the purpose of processing this data has ceased to apply or they are not required for the purpose).
If the data is not deleted because they are required for other and legally permissible purposes, their processing is restricted to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons or whose storage is necessary for the establishment, exercise, or defense of legal claims or to protect the rights of another natural or legal person.
Further information on the deletion of personal data can also be found in the individual data protection notes in this privacy policy.
Changes and Updates to the Privacy Policy
We ask you to regularly inform yourself about the contents of our privacy policy. We adapt the privacy policy as soon as the changes in the data processing carried out by us make it necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g., consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses can change over time and please check the information before contacting us.
Rights of Data Subjects
As data subjects, you have various rights under the GDPR, which arise in particular from Articles 15 to 18 and 21 of the GDPR:
Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data which is based on Art. 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this applies to profiling to the extent that it is related to such direct marketing.
Right to withdraw consent: You have the right to withdraw consent at any time.
Right of access: You have the right to request confirmation as to whether the data in question is being processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
Right to rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the correction of the incorrect data concerning you.
Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that relevant data be erased immediately, or, alternatively, to demand a restriction of the processing of the data in accordance with the statutory provisions.
Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common, and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
Furthermore, according to legal requirements, you have the right to file a complaint with the competent supervisory authority.
Definitions
This section provides you with an overview of the terms used in this privacy policy. Many of the terms are drawn from the law and defined mainly in Article 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily for understanding. The terms are sorted alphabetically.
Personal data: “Personal data” means 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 (e.g., cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
Processing: “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, whether it be collecting, evaluating, storing, transmitting, or deleting.
Controller: “Controller” means 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.