WAGAWIN – WEBSITE PRIVACY POLICY

1. An overview of data protection

GENERAL

The following gives a simple overview of what happens to your personal information when you visit our website. Personal information is any data with which you could be personally identified. Detailed information on the subject of data protection can be found in our privacy policy found below.

Data collection on our website
Who is responsible for the data collection on this website?

The data collected on this website are processed by Wagawin GmbH who is responsible for this website. The contact details can be found in the website’s imprint.

How do we collect your data?

Some data are collected when you provide it to us. This could, for example, be data you enter on a contact or registration form. Other data are collected automatically by our IT systems when you visit the website. These data are primarily technical data such as the browser and operating system you are using or when you accessed the page. These data are collected automatically as soon as you enter our website.

What do we use your data for?

Part of the data is collected to ensure the proper functioning of the website. Other data can be used to analyze how visitors use the site.

What rights do you have regarding your data?

You always have the right to request information about your stored data, its origin, its recipients, and the purpose of its collection at no charge. You also have the right to request that it be corrected, blocked, or deleted. You can contact us at any time using the address given in the legal notice if you have further questions about the issue of privacy and data protection. You may also, of course, file a complaint with the competent regulatory authorities.

Analytics and third-party tools

When visiting our website, statistical analyses may be made of your surfing behavior. This happens primarily using cookies and analytics. The analysis of your surfing behavior is usually anonymous, i.e. we will not be able to identify you from this data. You can object to this analysis or prevent it by not using certain tools. Detailed information can be found in the following privacy policy.

You can object to this analysis. We will inform you below about how to exercise your options in this regard.

2. General information and mandatory information

Data protection

The operators of this website take the protection of your personal data very seriously. We treat your personal data as confidential and in accordance with the statutory data protection regulations and this privacy policy.

If you use this website, various pieces of personal data will be collected. Personal information is any data with which you could be personally identified. This privacy policy explains what information we collect and what we use it for. It also explains how and for what purpose this happens.

Please note that data transmitted via the internet (e.g. via email communication) may be subject to security breaches. Complete protection of your data from third-party access is not possible.

Notice concerning the party responsible for this website

The party responsible for processing data on this website is:

Wagawin GmbH, represented by its managing directors Nicolas Leonhardt und Andreas Merold,
Possartstraße 6
D-81679 München
Telephone: +49 (0) 89 62 42 21 00
E-Mail: privacy@wagawin.com

The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (names, email addresses, etc.).

Revocation of your consent to the processing of your data

Many data processing operations are only possible with your express consent. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.

Right to file complaints with regulatory authorities

If there has been a breach of data protection legislation, the person affected may file a complaint with the competent regulatory authorities. The competent regulatory authority for us is:

Bayerisches Landesamt für Datenschutzaufsicht
Promenade 27 (Schloss)
91522 Ansbach (Germany)

Telephone: +49 (0) 981 53 1300
Fax: +49 (0) 981 53 98 1300
Contact: poststelle@lda.bayern.de

Right to data portability

You have the right to have data which we process based on your consent or in fulfillment of a contract automatically delivered to yourself or to a third party in a standard, machine-readable format. If you require the direct transfer of data to another responsible party, this will only be done to the extent technically feasible.

Information, blocking, deletion

As permitted by law, you have the right to be provided at any time with information free of charge about any of your personal data that is stored as well as its origin, the recipient and the purpose for which it has been processed. You also have the right to have this data corrected, blocked or deleted. You can contact us at any time using the address given in our legal notice if you have further questions on the topic of personal data.

Right to object

You have the right to object at any time to processing of personal data which is based on legitimate interests (Art. 6 I f) GDPR according to Art. 21 GDPR. You further have the right to restriction of processing according to Art. 18 GDPR.

Opposition to promotional emails

We hereby expressly prohibit the use of contact data published in the context of website legal notice requirements with regard to sending promotional and informational materials not expressly requested. The website operator reserves the right to take specific legal action if unsolicited advertising material, such as email spam, is received.

3. Data collection on our website
Cookies

Some of our web pages use cookies. Cookies do not harm your computer and do not contain any viruses. Cookies help make our website more user-friendly, efficient, and secure. Cookies are small text files that are stored on your computer and saved by your browser.
Most of the cookies we use are so-called “session cookies.” They are automatically deleted after your visit. Other cookies remain in your device’s memory until you delete them. These cookies make it possible to recognize your browser when you next visit the site.
You can configure your browser to inform you about the use of cookies so that you can decide on a case-by-case basis whether to accept or reject a cookie. Alternatively, your browser can be configured to automatically accept cookies under certain conditions or to always reject them, or to automatically delete cookies when closing your browser. Disabling cookies may limit the functionality of this website.
Cookies which are necessary to allow electronic communications or to provide certain functions you wish to use (such as the shopping cart) are stored pursuant to (Art. 6 I f) GDPR. We have a legitimate interest in the storage of cookies to ensure an optimized service provided free of technical errors. If other cookies (such as those used to analyze your surfing behavior) are also stored, they will be treated separately in this privacy policy.

Server log files

We automatically collect and stores information that your browser automatically transmits to us in “server log files”. These are:

  • Browser type and browser version
  • Operating system used
  • Referrer URL
  • Host name of the accessing computer
  • Time of the server request
  • IP address

These data will not be combined with data from other sources. The basis for data processing is (Art. 6 I f) GDPR, which allows the processing of data to fulfill a contract or for measures preliminary to a contract.

Contact form

Should you send us questions via the contact form, we will collect the data entered on the form, including the contact details you provide, to answer your question and any follow-up questions. We do not share this information without your permission.

If you contact us via the contact form, the following data must be entered:

  • Name and / or company name
  • E-Mail-Address
  • Country
  • Telephone number
  • Text message

The use of the contact form requires the acceptance of these privacy policy rules.

We will, therefore, process any data you enter onto the contact form only with your consent per Art. 6 I a) GDPR. You may revoke your consent at any time. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.

We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Any mandatory statutory provisions, especially those regarding mandatory data retention periods, remain unaffected by this provision.

Registration on this website

You can register on our website in order to access functions with respect to image processing offered on our website. For the registration, you must push the “Register now” button and enter the following data:

  • First Name
  • Family name
  • Company name
  • Telephone number
  • E-Mail-Address
  • Country
  • Password

After successful registration you are able to login on our website with your username and password in order to use our services.

The input data will only be used for the purpose of using the respective site or service for which you have registered. The mandatory information requested during registration must be provided in full. Otherwise, we will reject your registration.

A successful registration requires the acceptance of these privacy policy rules. To inform you about important changes such as those within the scope of our site or technical changes, we will use the email address specified during registration.

We will process the data provided during registration only based on your consent per Art. 6 I a) GDPR. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.

We will continue to store the data collected during registration for as long as you remain registered on our website. Statutory retention periods remain unaffected.

Processing of data (customer and contract data)

We collect, process, and use personal data only insofar as it is necessary to establish, or modify legal relationships with us (master data). This is done based on Art. 6 I b) GDPR, which allows the processing of data to fulfill a contract or for measures preliminary to a contract. We collect, process and use your personal data when accessing our website (usage data) only to the extent required to enable you to access our service or to bill you for the same.

Collected customer data shall be deleted after completion of the order or termination of the business relationship. Legal retention periods remain unaffected.

Data transferred when signing up for services and digital content

We transmit personally identifiable data to third parties only to the extent required to fulfill the terms of your contract with us. Your data will not be transmitted for any other purpose unless you have given your express permission to do so. Your data will not be disclosed to third parties for advertising purposes without your express consent. The basis for data processing is Art. 6 I b) GDPR, which allows the processing of data to fulfill a contract or for measures preliminary to a contract.

Facebook Pixel

Our website uses Facebook Pixel, a remarketing service provided by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (hereinafter referred to as “Facebook”), to better and more accurately display relevant advertisements to you.

A Facebook pixel allows us to understand whether you complete certain actions on our website after you have viewed or clicked on one of our display/video ads on Facebook or another Facebook platform. Using the data from your interaction, we can then subsequently present you with targeted advertising.

The information generated by the pixel is transferred by Facebook to a server in the USA for evaluation and stored there. If you have a Facebook account, the information associated with Facebook Pixel can also be added to your Facebook account.

Facebook has EU-U.S. Privacy Shield certification (which can be viewed at this link), so that an adequate level of data protection is ensured when your personal data are processed in the USA.

The legal basis for this processing is your consent (Art. 6(1)(1a) GDPR).

You can find more information about Facebook’s privacy policy at: https://www.facebook.com/policy.php

Google Floodlight Pixel

Our website uses Google Floodlight Pixel, a remarketing service provided by Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland (hereinafter referred to as “Google”), to better and more accurately display relevant advertisements to you.

A Google Floodlight pixel enables us to understand whether you complete certain actions on our website after viewing or clicking on one of our display/video ads on Google or another Google platform. Using the data from your interaction, we can then subsequently present you with targeted advertising.

The information generated by the pixel is transferred by Google to a server in the USA for evaluation and stored there. If you have a Google account, the information associated with Google Floodlight Pixel can also be added to your Google account.

Google has EU-U.S. Privacy Shield certification (which can be viewed at this link), so that an adequate level of data protection is ensured when your personal data are processed in the USA.

The legal basis for this processing is your consent (Art. 6 (1)(1a) GDPR).

You can find further information on privacy here: https://support.google.com/displayvideo/answer/9028179?hl=en

Linkedin conversation-tracking (linkedin-corporation)

LinkedIn Conversion Tracking is a LinkedIn Corporation analytics service that links data from the LinkedIn advertising network to actions taken through this application.

Personal data processed: Cookie; Usage data.

Processing location: United States of America – Privacy policy –Privacy Shield member.

Matomo

Our website uses Matomo, an analysis software for the statistical evaluation of visitor traffic. Matomo uses cookies that enable an analysis of your use of the website. The IP address is made anonymous immediately after processing and before it is stored.

The legal basis for this processing is Art. 6(1)(1f) GDPR, because the evaluation of the data traffic on our website to increase your user experience and for the general optimization of the website is in our legitimate interest.

You can prevent this evaluation by deleting existing cookies and deactivating the storage of cookies in your web browser’s settings.

Please note that the evaluation of your user behavior is only deactivated for as long as you do not delete the Matomo deactivation cookie in your browser.

4. Social media
Relevant Legal Grounds

Below you will find the legal grounds of the General Data Protection Regulation (GDPR) that form the basis for the way in which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may also apply in your and our country of residence and business.

National Data Protection Regulations in Germany: In addition to the data protection provisions of the General Data Protection Regulation, national regulations also apply for the protection of data in Germany. One of the most prominent of these is the law aimed at protecting against the misuse of personal data during data processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special provisions covering the right to information, the right to erasure, the right to objection, the processing of special categories of data, processing for other purposes, data transfer, as well as automated decision-making including profiling. Furthermore, it regulates data processing for the purposes of employment (Section 26 BDSG), especially with regard to hiring, carrying out, or terminating contracts of employment as well as employees’ consent. Also, state data protection legislations may apply in individual federal states.

Rights of Data Subjects

As a data subject within the meaning of the GDPR, you enjoy various rights, in particular those arising from Articles 15 to 18 and 21 GDPR:

  • Right of objection: You have the right to lodge an objection at any time for reasons arising from your specific situation against the processing of personal data relating to you based on Article 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. If personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to processing of the personal data relating to you for the purpose of such marketing; this also 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 that you have already given at any time.
  • Right to information: You are entitled to request confirmation as to whether relevant data are processed and to information about these data as well as to additional information and a copy of the data in accordance with statutory provisions.
  • Right to rectification: You are entitled to request the completion of the data relating to you or the rectification of inaccurate data relating to you in accordance with statutory provisions.
  • Right to erasure and restriction of processing: In accordance with statutory provisions, you are entitled to request that data relating to you be immediately erased or, as an alternative, that the processing of your data be restricted in accordance with statutory provisions (“blocking”).
  • Right to data portability: You have the right to request to receive the personal data relating to you that you provided to us, in a structured, commonly used, and machine-readable format, or to request transmission of those data to another controller in accordance with statutory provisions.
  • Complaint to a supervisory authority: Furthermore, you have the right in accordance with statutory provisions to lodge a complaint with a supervisory authority, especially in the Member State of your usual place of residence, place of work or place of the alleged breach, if you think that the processing of the personal data relating to you breaches the GDPR.
Presence in Social Networks

Wagawin GmbH maintains an online presence in social networks in order to communicate with users active there or to provide information about us there.
We wish to point out that users’ data may be processed outside the European Union (EU). This may result in risks for users, as, for example, this may make it difficult for them to assert their rights. We also wish to point out that US providers certified under the EU-US Privacy Shield or who offer similar guarantees of a secure level of data protection thereby undertake to comply with the data protection standards of the EU.

Furthermore, user data in social networks are generally processed for market research and advertising purposes. This may result in the creation of usage profiles based on user behavior and user interests derived from this. The usage profiles may in turn be used, for example, to place advertisements within or outside of the networks that are likely to match the interests of users. To this end, cookies are generally saved on user devices that store user behavior and interests. Furthermore, data may also be stored in usage profiles independently of the user devices (in particular when users are members of the platforms in question and are logged in there). We would direct you to the data privacy statements and information of the operators of the networks in question for a more detailed description of the relevant forms of processing and the options to object (opt-outs).
We would also point out that any requests for information and the claims to assert data subject rights should be best addressed to the providers themselves. Only the providers have access to the relevant user data and are able to take corresponding measures directly and provide information. However, if you still require assistance, you can contact datenschutz@wagawin.com.

  • Types of data processed: Master data (e.g. names, addresses), contact details (e.g. e-mail addresses, phone numbers), content data (e.g. text input, photographs, video clips), 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. interests-/behavior-based profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of repeat visitors).
  • Legal grounds: Legitimate interests (Article 6 (1) (f) GDPR).
Services Used and their Providers:
Changes and Updates to Our Data Privacy Statement

Wagawin GmbH would ask you to stay up to date about the content of our data privacy statement on a regular basis. We amend our data privacy statement whenever changes to the data processing that we perform make this necessary. We will inform you as soon as such changes require your cooperation (e.g. consent) or necessitate some other form of personal notification.

5. Automated e-mail-services

We use Amazon Simple e-mail services (Amazon SES) in order to send automated e-mails, i.e. after successful registration. This service is a cloud-based service to send automated e-mails. Amazon SES is a service of Amazon Web Services Inc. with head offices in Seattle (United States of America). This company is certified under the US privacy-shield. For more information see https://aws.amazon.com/de/privacy/?nc1=f_pr. We have entered into a data processing agreement with Amazon Web Services Inc.

WAGAWIN – PRODUCT PRIVACY POLICY

1. Introduction

Wagawin GmbH (“Wagawin”, “we”, “us”) respects your privacy and we are responsible for taking care of it. This privacy policy will tell you about your relationship with us. We therefore ask you to read them carefully. This privacy statement is intended for end users of Wagawin’s advertising services, called “LivingAds”.

Why you should read this privacy statement:

Many website operators and app developers make their content available free of charge. But of course they also have to pay their bills. That’s why they broadcast advertisements to you. We help to place advertisements on websites and in apps. As you know, advertising is often annoying and boring. That’s why we create interactive advertising and try to show you the advertising that is interesting for you.

To accomplish this, however, we need some information about you that the Data Protection Act (DS-GVO) classifies as personal data. If we store personal data about you, this is only an identification number or a cookie that is stored in your browser. We will never be able to find out your name, birthday or address and therefore will not store it. Your personal data will only be processed by us if this is necessary to fulfil the contract, if we or the third party have a legitimate interest in the processing or if you have given your consent.

To ensure that your are well informed about your privacy rights we want

  • To inform you about the way in which we use your personal data
  • To ensure that you understand what information we collect, what we do with it, and most importantly, do not do with it
  • To show us responsible for the protection of your data and rights within the framework of this privacy statement /li>
2. Our service called “LivingAds“

Wagawin provides advertising & marketing services for our Advertiser clients (“Advertisers”). When it comes to mobile advertising, we think interaction matters. Therefore we provide ad formats, called LivingAds, that allow users to interact with advertising content. Our service helps our advertisers’ ads to generate higher awareness and higher performance as we show ads to users that are interacting with advertising content. Furthermore, we aim to make advertising more useful and relevant to users by showing ads that are best tied to their specific interests. Our platform uses interaction data, as well as other data described below, to help Advertisers provide ads to you that are more relevant to you.

3. What personal data we collect

Publishers can choose how to receive LivingAds. No matter if publishers use our SDK or API or provide their traffic programmatically, we collect device and browser information for the purpose described below. This is technical information about the device or browser you use to access the Advertiser’s website. For example, your device’s IP address, cookie string data, operating system, and (in the case of mobile devices) your device type and mobile device’s unique identifier such as the Apple IDFA or Google Advertising ID. Knowing this basic information, we collect certain data about the ads we served (or attempted to serve) to you. It includes things like how many times an ad has been served to you, what page the ad appeared on, and whether you clicked on or interacted with the ad.

4. How we process the personal data we collect

We use this data to help our Advertisers identify and serve ads to you that are more relevant to you. We also use this data to operate, improve and enhance our services including enhancing the data points we or our Advertising Partners have about a particular user, browser, or device to serve the most relevant ads to you and, in turn, improve performance of an Advertiser’s ad campaigns. Specifically, we use this data for:

  • Re-Targeting: Selecting ads that are more likely to be relevant to you based on the interests previously associated with your device and the time of day you may be most interested in viewing these specific ads
  • Frequency capping: Making sure that you don’t see the same ad too many times
  • Sequencing: If you are being served a sequence of ads, making sure we show you the right ad next in the sequence
  • Attribution: Monitoring when, where, and at what price we served certain ads on behalf of an Advertiser so that we can measure our influence on the marketing result of the Advertiser’s campaigns and overall marketing strategy
  • Reporting: Providing Advertisers insights into how their ads are performing and gain insights into their customers. Reporting may include ad metrics such as impressions, interactions, clicks, and conversions (however the Advertiser may define a “conversion,” for example, a sale or a white paper download).
  • Fraud Detection: By using the ad metrics mentioned above, we focus on real users and dismiss fraudulant traffic
  • Maintenance: The maintenance of the system and the ongoing operations.
5. Management of Cookies and Ad IDs

If you wish to return your browser to a cookie-free state for this domain, find your browser in the list below and follow the instructions. Once complete, your browser will have no cookies from this domain and you can re-attempt some of the tests for the demos.

  • Google Chrome: https://support.google.com/accounts/answer/32050?co=GENIE.Platform%3DDesktop&hl=en
  • Firefox: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
  • Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
  • Internet Explorer Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
  • Safari (Mobile): https://support.apple.com/en-us/HT201265
  • Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac

Depending on your operating system, manage your Ad IDs as follows:

  • GAID (Android): https://support.google.com/ads/answer/2662922?hl=en
  • IDFA (iOS): https://support.apple.com/en-us/HT205223

By reseting your GAID/IDFA or removing all cookies of the domain *.wagawin.com, we cannot match you data with your device anymore.

6. Opt out possibility

You can also object to the processing of your data by Wagawin via the following link: https://de.wagawin.com/web/optout

7. Sharing of personal data

We may share your personal data with our subcontractors to track conversions (e.g. app installs).

Information on how you have interacted with a particular ad is only given to third parties by us if we or the third party have a legitimate interest in passing it on or if you have given your consent.

When we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of Wagawin, we share your data with the responsible authority.

We store all personal data of EU citizens on servers within the European Union. In the selection of data centers we ensure that country-specific data protection laws are fulfilled.

8. Retention of personal data

We store user data for the purpose of the bullets stated in section 4 and may save such data for longer period for invoicing, reporting, discrepancy reasons and to prevent fraud, but in any case, for no longer than 12 months.

After this time or at the time you wish your data to be removed (see section 10) we employ measures to delete it. Personal data collected for other purposes is held no longer than necessary for our business purposes but is anonymized. For example, we retain anonymized impression and click data to ensure we can meet auditing requirements related to services provided or to meet legal requirements.

9. Security

We apply technical, administrative and organizational security measures to protect the data we collect against accidental or unlawful destruction and loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against other unlawful forms of processing.

10. Data Subject Requests for Data Access or Deletion

Article 15 and 17 of the GDPR provides data subjects with the right to access and/or delete personal data that is related to him/her or is about him/her. Wagawin will cooperate with its partners (i.e. Publishers) to help them to fully comply with any access and/or deletion request of a data subject and shall provide its partners with the requested information or confirmation of deletion of such information, as soon as possible.

The GDPR gives you specific rights to your personal data we process; these rights include obtaining copies of it, requesting changes to it, restricting the processing of it, deleting it, or receiving it in a common electronic format so it can be moved to another controller. To exercise your rights, just contact us on the address stated in section 11.

In case that we process your data based on our legitimate interests pursuant to art. 6 para. 1 letter f GDPR, you can contradict the future processing of your data for other purposes not being based on legitimate interest. You also have the right to desire only a limitation of the processing based on certain purposes (art. 18 GDPR).

11. Note on the responsible body

The responsible body for data processing on this website is:

Wagawin GmbH,

represented by its managing directors Nicolas Leonhardt und Andreas Merold,

Possartstraße 6
D-81679 München

Telephone: +49 (0) 89 62 42 21 00
E-Mail: privacy@wagawin.com

The responsible body is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (names, email addresses, etc.).

In the event of violations of data protection laws, you have the right to lodge a complaint with the Bayerisches Landesamt für Datenschutzaufsicht.