Data Privacy Policy

1. General

1.1. We, the Seeding Alliance GmbH (hereinafter: SAG), Ströer-Allee 1, 50999 Cologne, Germany are pleased that you are visiting www.seeding-alliance.de (hereinafter: “our website”).

1.2. SAG offers services in the area of online advertising technologies both for operators of websites and apps (hereinafter “Publisher”), for advertisers and advertising agencies (hereinafter “Advertisers”). The services and advertising technologies listed here are provided via the following subdomains. The contents of this data protection declaration also apply to these domains: b.nativendo.de, b2.nativendo.de, d.nativendo.de, d2.nativendo.de, t.nativendo.de, t2.nativendo.de, c.nativendo.de, s.nativendo.de.

1.3. This data protection policy is addressed to the visitors (hereinafter “users”) of digital offers of our customers from the publisher sector and to our business partners and customers, their employees (hereinafter “partners”) as well as to the simple visitors to our website.

1.4. The legal basis on which we base our data processing can be found in the General Data Protection Regulation (“GDPR”), which you can access here (https://dsgvo-gesetz.de). In the data protection policy presented below, we refer to the corresponding legal basis for our processing.

1.5. We have set designed our data privacy policy in such way that everyone can get a quick overview why the personal data is being processed. Personal Data is the information from which a person can be clearly identified, either directly or by linking it to other data, e.g. name or email address. We will process your personal data (hereinafter also “your data” or “user data”) only in accordance with applicable data protection law. If we process your data for purposes other than those stated in this privacy policy, we will inform you about these purposes separately in advance and, where necessary, obtain your consent.

1.6. Please read the following data protection policy carefully. This policy is divided into individual subsections. If you have any questions or comments about this data protection policy, you can contact us at any time via e-mail which was given in point 2.4.

1.7. Our data protection policy may be changed from time to time, e.g. in order to adapt it to new data protection regulations. We will publish any changes to the data protection information on this page.

2. Controller, data protection officer, assertion of your legal rights

2.1. Seeding Alliance GmbH is the controller for the processing of your data as described in this privacy policy. For certain processing operations, we are jointly responsible with the publishers of the digital offers you visit, as well as the vendors used by them and, if applicable, the advertisers who play (have played) advertisements in the digital offers of the publishers (so-called joint responsibility; see more on this in section 5).  

2.2. Please find the contact details of the publishers in the imprint of the digital offers you visit. You can find the contact details of the respective vendors in the consent management platforms (hereinafter “CMPs”) of these digital offerings. You can obtain contact details of the advertisers from us upon request.

2.3. Where we are solely responsible for certain processing operations or the processing of certain categories of data, we have indicated this accordingly. However, the majority of the processing operations described in this policy are carried out under joint responsibility.

2.4. If you have any questions or comments about this privacy policy or about data protection in general, please contact:

Seeding Alliance GmbH
Ströer-Allee 1
50999 Cologne
Germany

Mail: datenschutz@seeding-alliance.de

If you have any questions about the processing of your personal data or about exercising your rights under the GDPR, you can consult our data protection officer. You can contact our company data protection officer at:

Ströer Digital Media GmbH
Platz der Einheit 1
60327 Frankfurt am Main
Germany

Data protection Officer: datenschutzbeauftragter-sa@stroeer.de

The supervisory authority responsible for SAG can be reached as follows:

Die Landesbeauftragte für den Datenschutz Nordrhein-Westfalen
Kavalleriestr. 2-4
40213 Düsseldorf
Germany
Mail: poststelle@ldi.nrw.de
Telephone: +49 211 / 38424-0
Fax: +49 211 / 38424-999

3. Your rights regarding your data

3.1. You have the following rights in relation to the processing of your data:

(a) A right of access to your data (Art. 15 GDPR). This includes, first of all, information about whether we process your personal data. If this is the case, you have the right to be informed about the data processed and additionally about:

• the purposes of the processing;
• the categories of data processed;
• the recipients of the data;
• the applicable data protection safeguards if the data is transferred to recipients outside the European Union;
• the storage period;
• your legal rights regarding data protection;
• the origin of the data and the existence of automated decision-making.

You also have the right to be provided with a copy of your personal data, provided that this does not affect the rights of third parties..

(b) A right to rectification if your data is inaccurate or to completion if your data is incomplete (Art. 16 GDPR), if this is necessary to achieve the purpose of the processing.

(c) A right to erasure (1) if processing of your data is no longer necessary for the aforementioned purposes, (2) if the processing is based on consent that you have revoked in the meantime and there is no other legal basis for processing by us, (3) if you have objected to processing carried out by us and – in the case of objection on personal grounds – there are no overriding legitimate grounds for the processing, (4) if we have processed your data unlawfully, or (5) if there is a legal obligation to erase it (so-called “right to be forgotten”, or “right to be informed”). “Right to be forgotten”, Art. 17 GDPR)

(d) A right to restriction of processing (1) if you dispute the accuracy of your data for the period we need to verify the accuracy, (2) if the processing of your data was unlawful and you wish to have the processing restricted instead of erased, (3) if storage by us is no longer necessary for the aforementioned purposes, (4) if you have objected to processing carried out by us which is based on our legitimate interests, as long as it has not yet been determined whether our legitimate interests outweigh your rights (Art. 18 GDPR).

(e) A right to data portability with regard to your data that you have provided to us, if the processing is based on your consent or a contract with us, i.e. you can request the data you have provided to us in a structured, common and machine-readable format to be transferred to you or to a third party (Art. 20 GDPR)

(f) A right to object to processing, please also see the detailed information under point “Rights of objection according to Art. 21 GDPR”.

These rights are partly restricted by law. If we are unable to fulfil these rights, we will notify you.

We reserve the right not to process requests that are unreasonably frequent or that are received without appropriate proof of identity. We will inform you of this in writing.

If you are of the opinion that the data processing does not comply with data protection regulations, in particular the General Data Protection Regulation and the Federal Data Protection Act, you can lodge a complaint with a data protection supervisory authority. In particular, you can contact the supervisory authority at your place of residence, at your place of work or at the place of the suspected data protection violation. This does not exclude any further legal remedies, e.g. before the courts.

3.2. Your rights to object according to Art. 21 GDPR

• Right to object to direct advertising

You can object to further use of your data for advertising purposes, even if the use of the data is legally permissible without your consent.

• Right to object on personal grounds

You have the right to object to the processing of your data by us on grounds relating to your particular situation, insofar as this is based on our legitimate interests. We will then stop processing your data unless we can demonstrate compelling legitimate grounds for further processing that override your rights, or the processing serves to assert, exercise or defend legal claims.

In order to assert your objection, it is sufficient to send us an informal message (contact details: datenschutz@seeding-alliance.de see under point: “Controller, data protection officer, assertion of your rights”). Please note that with regard to data processing in joint responsibility, we are generally not able to identify you by name or e-mail address. To exercise your right to object, you should therefore contact the publishers of the digital offers you visit or ideally change your settings directly in the CMP of the digital offers you visit.

An objection does not trigger any costs for you and has no negative consequences for you. The lawfulness of the processing of your data prior to your objection remains unaffected in this case.

3.3. To exercise your above rights, please click on this link: https://stroeer-requests.my.onetrust.com/webform/5223f5cf-ed85-4b3d-a37c-2f49312cbd78/a10bc38c-e5af-46ed-bfbc-4fa27ba0cd89

4. Place of data processing

We will not store your data for longer than is necessary to fulfil the purpose for which it was collected, unless there is a legal basis for further processing. In the case of such archiving, the data will be blocked from other access and deleted and destroyed in accordance with data protection law after the statutory retention periods have expired. The respective retention periods depend on the underlying purpose and the type of personal data.

As the data controller, we process your data ourselves exclusively within the European Union (“EU”). However, your data will be processed both within and outside the EU and the European Economic Area (hereinafter “EEA”) by the recipients described in section 5 and in point 6.7. Please note: If your data is transferred from your home country to another country, the laws protecting your data there may differ from those in your country (and may only provide a lower level of protection). If we transfer your data to a country outside the EEA, we will take appropriate measures to ensure an adequate level of data protection, for example by concluding so-called standard contractual clauses (Art. 46 of the GDPR) or by obtaining your explicit consent (Art. 49 (1) sentence 1 lit. a of the GDPR).

You have the right to receive a copy of the specifically agreed regulations to ensure the appropriate level of data protection. Please use the information in the section “Controller, data protection officer, assertion of your rights”.

5. Special information on processing by Seeding Alliance – visitors of digital offers provided by SAG as a service provide

5.1. Business model of Seeding-Alliance GmbH

Through the use of our online advertising technology, we enable the display of advertising (e.g. in the form of native advertising) on the basis of data that is collected/processed when you visit the digital offerings of publishers. For this purpose, cookies and similar technologies are set by other companies (so-called vendors) in the digital offerings of the publishers – exclusively with your consent. These allow the vendors to collect and transmit your data (pseudonymous cookie ID, IP address) to other vendors within an anonymous environment (so-called cookie matching process). The purpose of this cookie matching process is to combine information from different digital offers in order to enable the most accurate possible display of advertising on this basis. Under no circumstances will data such as name, address or e-mail address be stored in the cookies.

You can find more information on this and on the vendors in the data protection notices of the digital offers you visit and in the consent management platforms used there (hereinafter “CMPs”).

In order to provide the highest level of transparency for you as a user, the publishers use vendors who participate in the Transparency & Consent Framework (hereinafter “TCF”) of IAB Europe and have submitted to its specifications and guidelines for data processing under joint responsibility via their CMPs. Via the CMPs of the digital offers of the publishers, you have the possibility to give informed consent to the processing of your data individually or collectively for case groups defined by the TCF and to revoke this consent at any time with effect for the future. You can also object to the processing of your data if it is based on legitimate interests.

An overview of your setting options and information, the purposes and involved vendors within the scope of data processing in joint responsibility can be found at any time in the CMPs of the digital offers you visit.

You can also find out more about the TCF on the IAB Europe website: iabeurope.eu.

5.2. Auction of advertising space by SAG

SAG auctions advertising space from publishers to connected sales platforms.  For this purpose, SAG can use the collected user data to pre-filter relevant target groups.

SAG makes certain user data available to the purchasing platforms so that they can make a purchasing decision for the respective advertising space for their advertisers (so-called bid requests). In particular, SAG takes the cookie ID assigned by SAG for this purpose and establishes an assignment to the respective purchasing platforms, which in turn is made available in the bid request in order to identify already known end devices of users (so-called cookie matching process). 

Based on the user data provided, the purchasing platforms make a purchasing decision for the advertisers for the respective advertising space and submit a bid for this (so-called bid response). SAG delivers the advertising media of the highest bidder on the respective advertising space.

5.3. Information about Cookies  

As explained at the beginning, our business model is based on the placement of user-based advertising on the Publisher’s websites through the use of cookies and similar technologies (hereinafter collectively referred to as “cookies”). The data collection and processing necessary for this takes place on the Publisher’s websites under joint responsibility in accordance with Art. 26 GDPR. We jointly process data collected when visiting digital offers of the Publisher for the purpose of targeting advertising to specific groups (e.g. as banner advertising). For this purpose, we integrate scripts into the websites of the publishers, which technically enable the vendors – exclusively with your consent (within the meaning of Section 25 (1) of the Telecommunications-Telemedia Data Protection Act (german: TTDSG) – to set cookies in the end devices of the users and thus to collect data about the usage behaviour of the users of such digital offers. This data is usually compiled downstream by the vendors in so-called target group segments.

Cookies are small text files that enable your browser to be recognised and that are sent to your computer or mobile device. Under no circumstances will data such as name, address or e-mail address be stored in the cookies.

Of course, you can also use the digital offers of the publishers without cookies. You can set your browser to generally reject cookies without our involvement or the involvement of the publishers. You can also delete cookies that have already been set in your browser settings.

You can find more information about the purposes and the vendors who use cookies in the digital offers you visit in the CMP of the respective publisher.

5.4. Processing of your data

For certain processing operations, we are jointly responsible with the publishers of the digital offers visited by you as well as the vendors used by them and, if applicable, the advertisers who play (have played) advertisements in the digital offers of the publishers (so-called joint responsibility). For the contact details of the publishers, please refer to the imprint of the digital offerings you visit.

You can find the contact details of the respective vendors in the consent management platforms (CMPs) of these digital offerings. Where we are solely responsible for certain processing operations or the processing of certain categories of data, we have indicated this accordingly. However, the majority of the processing operations described in this notice are carried out under joint responsibility.

5.5. Processing operations under joint responsibility; central contact point

The processing operations for which we are jointly responsible with the other controllers include the following:

• Collection of your data on the publishers’ digital offers you visit using cookies and other technologies;
• Transmission of your data (pseudonymous cookie ID, IP address) within an anonymous environment (so-called cookie matching process);
• Auction of advertising space by SAG;
• Display of advertising in the digital offers you visit.

The acquisition of so-called segment data and the formation of target group segments by the various advertisers is not carried out under joint responsibility.

You can find more information on data processing under joint responsibility by the publishers in the data protection notices of the digital services you visit. You can find more detailed information on data processing under joint responsibility by the other vendors in their data protection notices, which you can access from the CMP of the digital offer you are visiting.

In order to exercise your rights as a data subject, you can either contact us (our contact details can be found above), assert them directly against the publishers of the digital offers you visit or contact the vendors named in the respective CMP. The joint controllers have also agreed that the publisher will act as the central point of contact for the exercise of data subjects’ rights against all joint controllers.

5.6. Which of your data do we process and from which sources does this data originate?

In connection with the display of advertising, we process the following data in joint responsibility, which relate to you as a user of digital offers of the publishers:

• HTTP data

When you call up a digital offer, certain information is collected for technical reasons by the browser used on your end device or the respective app via the so-called Hypertext Transfer Protocol (Secure) (HTTP(S)), for example your IP address, type and version of your Internet browser, operating system used, language used, the page called up, the previously visited page (referrer URL), date and time of the call;

• Device-related data

When a digital offer is accessed via a mobile device, the so-called IFA (Identifier for Advertisers) of the mobile device may be read. The IFA is an identification number of a mobile end device which enables the end device to be identified for advertising purposes.

• Location-related information

The approximate location of your end device can be determined from the HTTP data (the postcode district is determined).

• Cookie data

If you use a digital offer, cookies and other technologies (hereinafter collectively “cookies”) may be stored in the browser on your end device for the purpose of targeting advertising. Cookies are tiny text files. The next time you visit the digital offer, the cookies can be read from your browser.

The cookies are used for this purpose exclusively with your consent based on TTDSG Section 25 para. 1 in conjunction with GDPR Art. 6 para. 1 a. Under no circumstances will data such as name, address, e-mail address or IP address be stored in the cookies.

5.7. Self-regulation according to TCF 2.2

Practicable data protection for the benefit of users with regard to usage-based online advertising is important to SAG. Beyond the legal requirements and the strict pseudonymisation of the collected data, we therefore follow the self-regulatory requirements of the IAB Europe Framework.

Information on the IAB Transparency and Consent Framework (TCF 2.2)

SAG is a registered vendor in the Transparency and Consent Framework (also known as TCF 2.2) of the International Advertising Bureau Europe (IAB). Cookies are set on some partner sites for the processing of advertising campaigns.

5.8. Purposes of processing (according to TCF) and legal basis

Your data will be processed for the following purposes and on the following legal basis.

We process your data primarily for the overriding purpose of selling and purchasing digital advertising for the most targeted purchase and sale of advertising placements (sole and joint responsibility). The purposes pursued in detail and the associated legal bases (legitimate interest, Art. 6 para. 1 sentence 1 lit. f DSGVO or consent, Art. 6 para. 1 sentence 1 lit. a or § 25 para.1 TTDSG; Art. 7 DSGVO) are listed in the following table:

	Purpose of the processing (according to TCF 2.0)	legal basis
a)	To store and/or retrieve information on a device (use of cookies):   For the processing purposes indicated to you, cookies, device identifiers or other information may be stored on or retrieved from your device.	Consent (within the meaning of Section 25 (1) TTDSG)
b)	Use limited data to select advertising:   Advertising presented to you on the service which we use can be based on limited data, such as the website or app you are using, your non-precise location, your device type or which content you are (or have been) interacting with (for example, to limit the number of times an ad is presented to you).	Consent or legitimate interest
c)	Create profiles for personalised advertising:   Information about your activity on the service which we use (such as forms you submit, content you look at) can be stored and combined with other information about you (for example, information from your previous activity on this service and other websites or apps) or similar users. This is then used to build or improve a profile about you (that might include possible interests and personal aspects). Your profile can be used (also later) to present advertising that appears more relevant based on your possible interests by this and other entities.	Consent
d)	Use profiles to select personalised advertising:   Advertising presented to you on the service which we use can be based on your advertising profiles, which can reflect your activity on this service or other websites or apps (like the forms you submit, content you look at), possible interests and personal aspects.	Consent
e)	Create profiles to personalise content:   Information about your activity on the service which we use (for instance, forms you submit, non-advertising content you look at) can be stored and combined with other information about you (such as your previous activity on this service or other websites or apps) or similar users. This is then used to build or improve a profile about you (which might for example include possible interests and personal aspects). Your profile can be used (also later) to present content that appears more relevant based on your possible interests, such as by adapting the order in which content is shown to you, so that it is even easier for you to find content that matches your interests.	Consent
f)	Use profiles to select personalised content:   Content presented to you on this service can be based on your content personalisation profiles, which can reflect your activity on this or other services (for instance, the forms you submit, content you look at), possible interests and personal aspects, such as by adapting the order in which content is shown to you, so that it is even easier for you to find (non-advertising) content that matches your interests.	Consent
g)	Measure advertising performance:   Information regarding which advertising is presented to you and how you interact with it can be used to determine how well an advert has worked for you or other users and whether the goals of the advertising were reached. For instance, whether you saw an ad, whether you clicked on it, whether it led you to buy a product or visit a website, etc. This is very helpful to understand the relevance of advertising campaigns.	Consent or legitimate interest
h)	Measure content performance:   Information regarding which content is presented to you and how you interact with it can be used to determine whether the (non-advertising) content e.g. reached its intended audience and matched your interests. For instance, whether you read an article, watch a video, listen to a podcast or look at a product description, how long you spent on this service and the web pages you visit etc.. This is very helpful to understand the relevance of (non-advertising) content that is shown to you.	Consent or legitimate interest
i)	Understand audiences through statistics or combinations of data from different sources:   Reports can be generated based on the combination of data sets (like user profiles, statistics, market research, analytics data) regarding your interactions and those of other users with advertising or (non-advertising) content to identify common characteristics (for instance, to determine which target audiences are more receptive to an ad campaign or to certain contents).	Consent or legitimate interest
j)	Develop and improve services:   Information about your activity on the service which we use, such as your interaction with ads or content, can be very helpful to improve products and services and to build new products and services based on user interactions, the type of audience, etc. This specific purpose does not include the development or improvement of user profiles and identifiers.	Consent or legitimate interest
k)	Ensure security, prevent and detect fraud, and fix errors:   Your data can be used to monitor for and prevent unusual and possibly fraudulent activity (for example, regarding advertising, ad clicks by bots), and ensure systems and processes work properly and securely. It can also be used to correct any problems you, the publisher or the advertiser may encounter in the delivery of content and ads and in your interaction with them.	Legitimate interest
l)	Deliver and present advertising and content:   Certain information (like an IP address or device capabilities) is used to ensure the technical compatibility of the content or advertising, and to facilitate the transmission of the content or ad. to your device.	Legitimate interest
m)	Use precise geolocation data:   With your acceptance, your precise location (within a radius of less than 500 metres) may be used in support of the purposes explained in this notice.	Consent

6. Visitors to our website, business partners and customers as well as their employees

6.1. The processing of your data

Depending on the information you provide to us, we collect the following categories of data:

Professional contact and organisational data such as surname, first name, gender, address, email address, telephone number, mobile phone number, area, department, responsibilities or participation in sales events, order or contract data such as products purchased, services provided, date of contract or pre-contract stage, prices, payment and delivery information or special requests Billing or banking data such as payment history, balance sheets, credit reference agency data or account details. No special categories of data (Art. 9 para. 1 GDPR) are processed.

6.2. For what purposes and on what legal basis are your data processed.

Your data will be processed for the following purposes and on the basis of the following legal grounds (sole and joint responsibility):

6.2.1. on the basis of our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR

• To provide, maintain, protect and improve our services, to develop new services and to protect us and our business partners and customers;

• to further improve the security of our IT system for the benefit of all business partners and customers;

• to detect or prevent technical problems;

• to protect rights affecting our property or safety, the property or safety of business partners and customers, or the public, to the extent permitted and required by law;
• to assert, exercise or defend legal claims;
• to provide you with relevant information about the Stroeer Group company and services including customer service and marketing activities, unless you have objected to the use of your data for these services;
• in the context of customer administration and support

6.2.2. Due to legal obligations pursuant to Art. 6 para. 1 sentence 1 lit. c GDPR

• for the fulfilment of and compliance with applicable laws, regulations, legal proceedings or enforceable official orders that are binding;
• for the detection, prevention or combating of legal infringements, insofar as SAG is legally obliged to do so or third parties have a legal claim against SAG;
• for the detection, prevention or rectification of security defects or technical problems.

6.2.3. For the execution of the contract in accordance with Art. 6 Para. 1 lit. b GDPR

• for the establishment, content or amendment of the contractual relationship with the respective customer;
• for the provision of our services, i.e. the fulfilment of our contracts.

6.2.4. on the basis of your consent to the processing for one or more specific purposes pursuant to Art. 6 Para. 1 Sentence 1 lit. a GDPR

• for the processing of your personal data in relation to the personalised creation of the newsletter;
• for regular dispatch to the e-mail address you have provided;
• for marketing purposes and customer contact;
• to offer you customised content, for example, to provide you with personalised advertising.

6.3. Passing on your data

Within our company, your data will be passed on to those departments or group units that need it to fulfil our contractual and legal obligations or in the context of processing and implementing our legitimate interests.

Your data will only be passed on to other offices:

6.3.1. For legal reasons:

We will disclose your information to other companies, organisations or individuals when necessary to comply with applicable laws or regulations, such as to comply with legal process, or to comply with a binding governmental order, to enforce contractual agreements, including investigation of potential violations, to detect, prevent, or otherwise address fraud, security or technical issues, or to protect against harm to our property, other rights or safety, the property or safety of our users or the public, as permitted or required by law.

In the aforementioned cases, your data may also be disclosed to authorities, courts, lawyers, auditors and tax advisors as necessary.

6.3.2. For processing by other bodies (on our behalf):

These are trustworthy companies that we commission with the processing of data within the framework provided by law and that process the data according to our instructions (so-called processors). This is done in accordance with applicable law, as well as appropriate confidentiality and security measures that enable us to ensure the protection of your data at all times. In this case, SAG remains responsible for the protection of your data. We engage companies in the following areas in particular: IT, sales, marketing, finance, consulting, customer service, human resources, logistics, printing. Beyond that, only our employees have access to your data. Data that has no personal reference, i.e. data that cannot be associated with your person (e.g. completely anonymised data), may be passed on to third parties.

6.3.3. Information on the use of Google Analytics on Seeding-Alliance.de

We use the Google Analytics service provided by Google Inc, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (Google). Google Analytics uses cookies (see our CMP on our website). The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. Google will use this information on our behalf for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage. Pseudonymous usage profiles can be created from the processed data.

We have added the code “anonymizeIP” to Google Analytics on our website. This means that the IP address of the user is shortened within the EU or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. You can prevent the storage of cookies by selecting the appropriate setting in your browser. You can also prevent the collection of data generated by the cookie and related to your use of this website by Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

6.3.4. Use of Youtube

Our website uses the provider YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066, USA, represented by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, for the integration of videos. Normally, when you access a page with embedded videos, your IP address is sent to YouTube and cookies are installed on your computer. However, we have embedded our YouTube videos with the extended data protection mode (in this case, YouTube still contacts Google’s Double Klick service, but according to Google’s privacy policy, personal data is not evaluated). This means that YouTube no longer stores any information about visitors unless you watch the video. If you click on the video, your IP address is transmitted to YouTube and YouTube learns that you have watched the video. If you are logged in to YouTube, this information is also assigned to your user account (you can prevent this by logging out of YouTube before viewing the video).

We have no knowledge of and no influence on the possible collection and use of your data by YouTube. You can find more information in YouTube’s privacy policy at http://www.google.de/intl/de/policies/privacy/.

6.4. Data processing log data, cookies, tools and plugins on this website

When you access our website, your browser sends certain technical data to us in order to enable a connection of your terminal device to our server and the retrieval of our page.

We process the following categories of personal data:

IP address (this is anonymised immediately after collection),
Date and time of the page request,
URLs called up from our sub-pages,
Referral URL (URL of the page from which you came to our site),
http status code (e.g. successful page request),
Browser language settings,
operating system, browser type, model of the end device.

6.5. Marketing and Newsletter

We process your data in accordance with the statutory provisions for our own marketing purposes.

You can object to the processing of your data for advertising purposes at any time by sending a short written message to datenschutz@seeding-alliance.de or revoke your consent without incurring any costs other than the transmission costs according to the basic rates.

If you object to the use of your data, your contact address will not be used for advertising purposes. We would like to point out that in exceptional cases, advertising material may still be sent even after receipt of your objection. This is due to technical reasons and does not mean that we will not implement your objection.

The legal basis for this is § 7 para. 3 of Act against unfair competition (german: UWG) as well as Art. 6 para. 1 lit. f) EU GDPR. Our interest in addressing advertising in a needs-based manner is to be regarded as justified within the meaning of the aforementioned provision.

• We only pass on your data to business partners for the dispatch of advertising material if the partner is committed to our data protection standards.

On our website you can subscribe to our newsletters. In our newsletters, we provide information about our current products and services, invite you to our events and give you an overview of interesting articles (e.g. blog entries) and relevant topics. We usually need your e-mail address for registration.

The registration for our newsletters is carried out in the so-called double opt-in procedure. After entering your e-mail address on our website (1st step), we will send you a confirmation link in the first e-mail. After calling up this link (2nd step), you will receive our regular newsletter. This procedure serves to confirm that the e-mail address has not been entered into our newsletter distribution list by unauthorised persons. If the confirmation link is not called up within a certain period of time, the newsletter will not be sent.

If you have subscribed to a newsletter, you will also find a corresponding link at the end of the newsletter. Alternatively, you can unsubscribe using this link. If no legal retention periods are relevant for your personal data (e.g. from a contractual relationship with us), we will remove you from the respective newsletter distribution list immediately after receiving your unsubscription.

The processing of your personal data serves the personalised creation of the newsletter as well as the regular dispatch to the e-mail address you have provided. The legal basis for the processing is your consent (Art. 6 para. 1 lit. a) GDPR).

6.6. Your contact to us

We offer a separate form on our website to quickly contact us and to arrange an appointment for a free demo. In doing so, we process the data you provide in the forms, including free text (content of the message). If certain categories of data are not absolutely necessary for processing your enquiry, but are helpful for further personalising our response (e.g. the function in your company) or for contacting you by alternative means (e.g. by telephone), we mark such fields as “voluntary”. The legal basis for data processing is your consent (Art. 6 para. 1 lit. a) GDPR). If we need the data you provide for the preparation or fulfilment of a contract with you, the legal basis is Art. 6 para. 1 lit. b) GDPR.

Of course, you can also contact us by e-mail at any time. If you send us a message to an email address provided on our website, the legal basis for data processing is our legitimate interest in processing your request (Art. 6 para. 1 lit. f) GDPR).

Please note that the e-mails are generally not sent fully encrypted. This means that – despite extensive technical security precautions – there is a risk of unauthorised access to the email content by third parties, e.g. during transmission.

6.7. Further categories of data and recipients

The offer on our website and in our presences in social media is not designed to process special categories of personal data within the meaning of Art. 9 GDPR, e.g. information on health, origin or religion. As a rule, we therefore do not process such special categories of data unless they are provided to us on our own initiative, e.g. in a contact form (Art. 9(2)(a) GDPR).

If we involve external service providers who come into contact with the personal data provided to us, they will usually act for us as so-called processors. This means that we conclude a contract with them for commissioned processing in accordance with Art. 28 GDPR, on the basis of which they are obliged to use the data exclusively in accordance with our specifications. We select our service providers carefully and oblige them to maintain confidentiality. We may use external service providers for web analysis and newsletter distribution, for example.

If personal data is required for the preparation or implementation of a legal dispute or action against legal violations, it may also be processed to the extent necessary for this purpose (e.g. forwarding to lawyers). In this case, the legal basis for data processing is the exercise of our legitimate interest in legal action (Section 24 (1) No. 2 Federal Data Protection Act (german: BDSG), Art. 6 (1) lit. f) GDPR).

In addition, personal data may also be transmitted to competent state authorities (e.g. for the purpose of criminal prosecution) due to legal obligation, enforceable official order or court decision (Art. 6 para. 1 lit. c) GDPR).

6.8. Job applications

In this section, we would like to inform you about the extent to which we process your personal data when you contact us via our career portal and submit an application form.

We collect and process the following personal data from you during the application process:

• Applicant master data (first name, last name, title, e-mail address, telephone number, residence, gender, nationality),
• qualification data (covering letter, letter of motivation, curriculum vitae, previous activities, professional qualifications and skills),
• voluntary information, such as an application photo, details of severely disabled status or other information that you voluntarily provide or upload in your application,
• additional questions depending on the job advertisement in question (e.g. nationality, salary expectations),
• the communication between you and us as well as comments and evaluations written about you in the course of your application process.
• The specific scope of data processing in the application process depends on the position to be filled. If, for example, the position involves increased financial responsibility, we may request additional documents for a decision, e.g. an extract from the Federal Central Register (certificate of good conduct) limited to relevant entries. If such additional data collection is necessary for the application process, we will inform you separately and explain the reasons why we need to collect the relevant data categories.

The legal basis for data processing is Section Artikel 6 (1) b GDPR.. The processing serves the preparation, conclusion and implementation of an employment contract, for which a review and evaluation of the application documents by the internal departments responsible at our company is necessary.

We use SmartRecruiters GmbH as an external service provider for the application process. SmartRecruiters GmbH, Wilhelmstr. 118, 10963 Berlin (hereinafter “SmartRecruiters”), operates an e-recruiting system (hereinafter “career portal”) on which we can place job adverts and receive and manage applications.The Ströer career site is the central platform for our applicant management within the Ströer group of companies. The careers site can be accessed via the following link: (https://karriere.stroeer.com/de/)

When you use our career portal, your personal data is recorded directly in the e-recruiting system. In the case of a postal or e-mail application, your data can also be transferred to the e-recruiting system of our career portal. All relevant information on data processing in the context of an application can be found under the link https://karriere.stroeer.com/de/datenschutzhinweise to the data protection information of the Ströer careers site.

Recipients

We forward your application documents internally to the departments responsible for this at our company. These are primarily the personnel department and the management of the respective department. In addition, applications may also be forwarded to the works council so that it can fulfil its statutory duties (e.g. approval of a recruitment).

Applicant pool

You can also give your consent for your data to be included in our applicant pool. We will then store your application documents for a period of 1 year.

If a suitable position is identified within the Group, your application documents may also be forwarded to the following Ströer Group companies for review and further contact: Ambient-TV Sales & Services GmbH / Asam Betriebs- GmbH / ASAMBEAUTY GmbH / Avedo II GmbH / Avedo Essen GmbH / Avedo Gelsenkirchen GmbH / Avedo Köln GmbH / Avedo Leipzig GmbH / Avedo Leipzig West GmbH / Avedo München GmbH / Avedo Rostock GmbH / blowUp Media GmbH / Business Advertising GmbH / Content Fleet GmbH / DSA Schuldisplay GmbH / DSM Deutsche Städte Medien GmbH / DSM Krefeld Außenwerbung GmbH / DSMDecaux GmbH / ECE flatmedia GmbH / Edgar Ambient Media Group GmbH / Fahrgastfernsehen Hamburg GmbH / grapevine marketing GmbH / Hamburger Verk. Mittel Werbung GmbH / Infoscreen GmbH / kajomi GmbH / M. Asam GmbH / Nachsendeauftrag DE Online GmbH / Neo Advertising GmbH / Omnea GmbH / OPS Online Post Service GmbH / Optimise IT GmbH / Outsite Media GmbH / Permodo GmbH / PosterSelect Media- Agentur für Aussenwerbung GmbH / Ranger Marketing & Vertriebs GmbH / RegioHelden GmbH / Sales Holding GmbH / Seeding Alliance GmbH / Service Planet GmbH / SIGN YOU mediascreen GmbH / Statista GmbH / StayFriends GmbH / Ströer Content Group GmbH / Ströer DERG Media GmbH / Ströer Content Group Sales GmbH / Ströer Deutsche Städte Medien GmbH / Ströer Dialog Group GmbH / / Ströer Digital Media GmbH / Ströer Digital Publishing GmbH / Ströer media brands GmbH / Ströer Media Deutschland GmbH / Ströer News Publishing GmbH / Ströer Next Publishing GmbH / Ströer Sales & Services GmbH / Ströer Sales Group GmbH / Ströer SE & Co. KGaA / Ströer Social Publishing GmbH / Ströer SSP GmbH / SuperM&N UG / Yieldlove GmbH

The legal basis for data processing in this case is your consent (Art. 6 para. 1 lit. a) GDPR), which also includes any special categories of personal data, insofar as you have specified these in your application documents (Art. 9 para. 2 lit. a) GDPR). You can revoke your consent to the inclusion of your application documents in our applicant pool at any time for the future.

This data protection notice was last updated at 22.11.2023