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. 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.

7. 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.

8. 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.

9. 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).

10. 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,

Haydnstraße11,
80336 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.

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