Data Protection
Table of Contents
1. General Information
2. Controller, Data Protection Officer, Exercising Your Rights
3. Your Rights Regarding Your Data
4. Location and Duration of Data Processing
5. Specific Information on Processing by SAG
5.1. SAG’s Business Model
5.2. Auctioning of Advertising Spaces by SAG
5.3. Information on Cookies and Similar Technologies
5.4. Processing of Your Data
5.5. Joint Processing Responsibility; Central Contact Point
5.6. Which Data Do We Process and What Are Their Sources
5.7. Self-Regulation According to TCF 2.2
5.8. Processing Purposes (According to TCF) and Legal Basis
6. Visitors to Our Website, Business Partners, and Customers as well as Their Employees
6.1. Processing of Your Data
6.2. For What Purpose and on What Legal Basis Is Your Data Processed
6.3. Sharing Your Data Within Group Entities
6.4. Data Processing: Log Data, Cookies, Tools, and Plugins on This Website
6.5. Marketing and Newsletters
6.6. Contacting Us
6.7. Additional Data Categories and Recipients
6.8. Job Applications
7. Social Media
8. Detailed Information on the Processing of Customer Contact Data Under Joint Responsibility with the Companies of the Ströer Group
Privacy Notice
1. General Information
1.1. We, Seeding Alliance GmbH (hereinafter referred to as “SAG”), located at Ströer-Allee 1, 50999 Cologne, Germany, are pleased to welcome you to www.seeding-alliance.de (hereinafter referred to as “our website”).
1.2. SAG offers services in the field of online advertising technologies, catering to both website and app operators (hereinafter referred to as “publishers”) as well as advertisers and advertising agencies (hereinafter referred to as “advertisers”). The services and advertising technologies listed here are provided via the following subdomains. The content of this privacy notice also applies 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 privacy notice is directed at visitors (hereinafter referred to as “users”) of digital offerings from our customers in the publisher segment, as well as at our business partners, clients, and their employees (hereinafter referred to as “partners”), as well as the simple visitors to our website.
1.4. The legal basis we rely on for data processing can be found in the General Data Protection Regulation (GDPR), which you can access, for example, at https://dsgvo-gesetz.de . In the following privacy notice, we refer to the relevant legal bases for our processing activities.
1.5. Our goal is to present our privacy notice in a way that allows everyone to quickly understand the purposes for which we process personal data. Personal data refers to information that can uniquely identify an individual, either directly or through linkage with other data, such as a name or email address. We will process your personal data (hereinafter also referred to as “your data” or “user data”) only in accordance with applicable data protection laws. If we process your data for purposes other than those specified in this privacy notice, we will inform you about these purposes in advance and request your consent where necessary.
1.6. Please read the following privacy information carefully. It is divided into individual subsections. If you have any questions or comments regarding this privacy notice, you can contact us at any time via the email address provided in Section 2.4.
1.7. Our privacy notice may be updated from time to time, for example, to comply with new data protection regulations. Any changes to the privacy notice will be published on this page.
2. Controller, Data Protection Officer, Exercising Your Rights
2.1. Seeding Alliance GmbH is the data controller responsible for the processing of your data as described in this privacy notice. For certain processing activities, we share joint responsibility with the publishers of the digital offerings you visit, as well as with the vendors used by these publishers and, where applicable, the advertisers that display (or have displayed) advertisements within the publishers’ digital offerings (referred to as “joint controllership”; see more details in Section 5).
2.2. You can find the contact details of the publishers in the legal notice (“Impressum”) of the digital offerings you visit. Contact details of specific vendors can be found in the Consent Management Platforms (hereinafter referred to as “CMPs”) of these digital offerings. Contact details of advertisers are available upon request.
2.3. Where we are solely responsible for specific processing activities or for processing specific categories of data, we explicitly indicate this responsibility. However, the majority of the processing activities described in this notice occur under joint controllership.
2.4. If you have any questions or comments regarding this privacy notice or about data protection in general, please contact:
Seeding Alliance GmbH
Ströer-Allee 1
50999 Cologne (Köln), Germany
Email: datenschutz@seeding-alliance.com
If you have questions regarding the processing of your personal data or wish to exercise your rights under the GDPR, you may consult our Data Protection Officer. You can reach our appointed Data Protection Officer at:
Ströer Digital Media GmbH
Platz der Einheit 1
60327 Frankfurt am Main, Germany
Data Protection Officer email: datenschutzbeauftragter-sa@stroeer.de
For matters concerning SAG, the lead supervisory authority can be reached as follows:
The State Data Protection Authority of North Rhine-Westphalia
Kavalleriestr. 2-4
40213 Düsseldorf, Germany
Email: poststelle@ldi.nrw.de
Phone: +49 211 / 38424-0
Fax: +49 211 / 38424-999
3. Your Rights Regarding Your Data
3.1. Regarding the processing of your data, you have the following rights:
(a) Right of access: You have the right to request information about your data from us (Art. 15 GDPR). This includes preliminary information about whether we process your personal data. If this is the case, you have the right to receive details about:
The purposes of the processing;
The categories of processed data;
The recipients of the data;
The applicable data protection safeguards in the event of data transfers to recipients outside the European Union;
The retention period of your data;
Your statutory rights regarding data protection;
The origin of the data and whether automated decision-making is involved.
Additionally, you have the right to obtain a copy of your personal data, provided this does not adversely affect the rights of others.
(b) Right to rectification: If your data is incorrect, you have the right to request its correction. If your data is incomplete, you can request its completion, provided this is necessary to achieve the purpose of processing (Art. 16 GDPR).
(c) Right to erasure (right to be forgotten): You have the right to request the deletion of your data (Art. 17 GDPR) if:
The processing of your data is no longer necessary for the stated purposes;
The processing is based on your previously granted consent, which you have now withdrawn, and no other legal basis for the processing exists;
You have objected to processing conducted by us, and in the case of objections based on personal reasons, there are no overriding legitimate grounds for the processing;
We have unlawfully processed your data; or
Legal obligations require the data to be erased.
(d) Right to restriction of processing (Art. 18 GDPR): You can request the restriction of processing in the following cases:
If you contest the accuracy of your data, for the period we require to verify its accuracy;
If the processing of your data was unlawful, but you oppose erasure and request restricted processing instead;
If we no longer need your data for the stated purposes but you require it to establish, exercise, or defend legal claims;
If you have objected to processing based on our legitimate interests, and it is not yet clear whether our legitimate interests outweigh your rights.
(e) Right to data portability: You have the right to receive the data you have provided to us in a structured, commonly used, and machine-readable format, and to transmit those data to another controller. This applies where processing is based on your consent or a contract with us (Art. 20 GDPR).
(f) Right to object to processing: Please refer to the detailed information provided in Section “Your Right to Object Pursuant to Art. 21 GDPR.”
In cases where our processing is based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out based on the consent before its withdrawal (Art. 7(3) GDPR).
These rights are partially restricted by law. If we are unable to fulfill such rights, we will inform you of this.
We reserve the right to refuse requests that are unreasonably frequent or lack adequate proof of identity. You will be informed of this in writing.
If you believe that data processing does not comply with data protection regulations, especially the GDPR or German Data Protection Act, you have the right to file a complaint with a data protection supervisory authority. You can contact the supervisory authority in your place of residence, workplace, or the location of the alleged privacy violation. Exercise of further legal remedies, such as court proceedings, is not excluded by this process.
3.2. Your Right to Object under Article 21 GDPR
Right to object to direct marketing:
You have the right to object to the use of your data for advertising purposes at any time, even if this use is legally permissible without your consent.
Right to object for personal reasons:
You have the right to object to the processing of your data based on reasons related to your particular situation if the processing is based on our legitimate interests. In this case, we will stop processing your data unless we can demonstrate compelling legitimate grounds for processing that outweigh your rights, or if the processing is necessary for the establishment, exercise, or defense of legal claims.
To exercise your right to object, a simple informal request to us is sufficient. Please contact us at datenschutz@seeding-alliance.com (see Section “Controller, Data Protection Officer, Exercising Your Rights”). Please note that, in cases of joint data controllership, we are generally unable to identify you based on your name or email address. To exercise your right to object, you should contact the publishers of the digital offerings you visit or adjust your settings directly in the CMPs of the digital offerings you visit.
Exercising your right to object is free of charge and will not result in any negative consequences for you. The lawfulness of any data processing carried out prior to your objection remains unaffected.
3.3. To exercise the aforementioned rights, please use the following link:
https://stroeer-requests.my.onetrust.com/webform/5223f5cf-ed85-4b3d-a37c-2f49312cbd78/a10bc38c-e5af-46ed-bfbc-4fa27ba0cd89
4. Location and Duration of Data Processing
We will not store your data for longer than is necessary to fulfill the respective purposes 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 further access and will be securely deleted and destroyed in accordance with data protection regulations once the applicable retention periods have expired. The specific retention periods depend on the underlying purpose and the type of personal data involved.
As the data controller, we only process your data within the European Union (“EU”). However, the recipients described in Section 5 and in Subsection 6.7 may process your data both within and outside the EU and the European Economic Area (hereinafter referred to as “EEA”).
Please note: If your data is transferred from your country of residence to another country, the data protection laws of that country may differ from those of your own, and they may not provide the same 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. This may include, for example, entering into so-called Standard Contractual Clauses (Art. 46 GDPR) or obtaining your explicit consent (Art. 49 (1)(a) GDPR).
You have the right to request a copy of the specific provisions ensuring an adequate level of data protection. To do so, please refer to the contact details provided in the section “Controller, Data Protection Officer, Exercising Your Rights.
5. Specific Information on Data Processing by Seeding Alliance – Visitors to Digital Offerings Provided by SAG
5.1. Business Model of Seeding Alliance GmbH
Through the use of our online advertising technology, we enable the display of ads (e.g., in the form of native advertising) based on data collected and processed during visits to publishers’ digital offerings. For this purpose, other companies (so-called vendors) place cookies and similar technologies on the publisher’s digital offering — but only 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 (the so-called cookie matching or ID matching process). The purpose of this cookie matching process is to combine information from different digital offerings to enable the most precise ad delivery possible. Under no circumstances will cookies store data such as your name, address, or email address.
For more detailed information regarding this and the vendors involved, please refer to the privacy policies of the digital offerings you visit and the consent management platforms (hereinafter referred to as “CMPs”) used on those sites.
To ensure maximum transparency for you as a user, publishers—in cases involving joint responsibility for data processing—use CMP vendors who participate in the Transparency & Consent Framework (hereinafter referred to as “TCF”) of IAB Europe and adhere to its specifications and guidelines. Through the CMPs of publishers’ digital offerings, you have the opportunity to grant or withdraw informed consent for TCF-defined processing purposes either individually or collectively at any time, for future processing. You may also object to the processing of your data where it is based on legitimate interests.
A comprehensive overview of your settings, purposes, and vendors involved in joint data processing is always available in the CMPs of the digital offerings you visit.
Additionally, you can learn more about the TCF on the IAB Europe website: https://iabeurope.eu/ .
5.2. Auctioning of Advertising Spaces by SAG
SAG facilitates the auctioning of publishers’ advertising spaces to affiliated sales platforms. SAG may use collected user data to pre-filter relevant target groups.
SAG provides certain user data to purchasing platforms to enable them to decide whether to purchase the respective ad space on behalf of their advertisers (so-called bid requests). In particular, SAG allocates a cookie ID and links it to the respective purchasing platforms, making this cookie ID available in the bid request to identify already known user devices (referred to as the cookie matching process).
On the basis of the provided user data, purchasing platforms make purchasing decisions on behalf of advertisers for the respective ad spaces and submit bids (so-called bid responses). SAG then delivers advertisements from the highest bidding advertiser on the respective ad space.
5.3. Information on Cookies and Similar Technologies
As previously described, our business model for delivering user-driven ads on publishers’ sites relies on the use of cookies and similar technologies (hereinafter collectively referred to as “cookies”). The necessary data collection and processing for this takes place on the publishers’ websites under joint responsibility in accordance with Article 26 GDPR.
Together, we process data collected during visits to publishers’ digital offerings to serve advertisements targeted to specific audiences (e.g., banner ads). For this purpose, we embed scripts on the publishers’ websites to enable vendors to technically set cookies and similar technologies on users’ devices and collect usage data related to those digital offerings — but only with your consent (as defined by §25(1) TDDDG). This data is typically later aggregated by vendors into so-called audience segments.
Cookies are small text files that enable your browser to be recognized and are sent to your computer or mobile device. Under no circumstances are data such as names, addresses, or email addresses stored in cookies.
Of course, you can access publishers’ digital offerings without cookies. You can configure your browser to reject cookies entirely, or you can delete cookies from your browser settings at any time.
For more detailed information on the purposes and vendors using cookies in the digital offerings you visit, please refer to the CMP of the respective publisher.
5.4. Processing of Your Data
For certain processing activities, we share responsibility with the publishers of the digital offerings you visit as well as the vendors they use and, where applicable, the advertisers who display ads in the publishers’ digital offerings (so-called joint responsibility).
The contact details of the publishers can be found in the legal notice (“Impressum”) of the digital offerings you visit. The contact details of specific vendors can be found in the CMPs of these digital offerings.
Where we are solely responsible for specific processing activities or data categories, we explicitly indicate this in our privacy notices. However, the majority of the processing described herein occurs under joint responsibility.
5.5. Jointly Responsible Processing Operations and Central Contact Point
The processing operations for which we share joint responsibility with other controllers include the following:
Collection of your data on the publishers’ digital offerings you visit using cookies and similar technologies;
Transmission of your data (pseudonymous cookie ID, IP address) within an anonymous environment (the so-called cookie matching process);
Auctioning of advertising spaces by SAG;
Displaying advertising on the digital offerings you visit.
The procurement of so-called segment data and the creation of audience segments by the various advertisers, however, occur outside the scope of joint responsibility.
For more information on data processing under joint responsibility by publishers, please refer to the privacy policies of the digital offerings you visit. For additional details on joint responsibility processing by other vendors, refer to their respective privacy policies, accessible through the CMP of the relevant digital offering.
To exercise your rights as a data subject, you can either contact us (our contact details are provided above), address the publishers of the digital offerings you visit directly, or contact the vendors listed in the respective CMP. The jointly responsible parties have further agreed that publishers will act as the central contact point for exercising the data rights of individuals with respect to all jointly responsible parties.
5.6. What Data Do We Process and From Which Sources Are These Data Obtained?
In the context of serving advertisements, we process the following data jointly with publishers that relates to you as a user of their digital offerings:
HTTP Data: When you access a digital offering, your device’s browser or app automatically transmits certain technical information via the Hypertext Transfer Protocol (Secure) (HTTP(S)), such as your IP address, browser type and version, operating system, language, the accessed webpage, the previously visited webpage (referrer URL), and the date and time of access.
Device Data: When accessing a digital offering via a mobile device, the Identifier for Advertisers (IFA) of the mobile device may be retrieved. The IFA is an ID that enables advertiser-related identification of the device.
Location Data: From the HTTP data, the approximate location of your device can be determined (e.g., postal code region).
Cookie Data and Similar Technologies: Cookies may be stored in your device’s browser to provide targeted advertisements. These cookies are used only with your consent under §25(1) TDDDSG in conjunction with Art. 6(1)(a) GDPR. Under no circumstances are your name, address, email address, or IP address stored in these cookies.
5.7. Self-Regulation under TCF 2.2
SAG is committed to ensuring user-friendly data protection in relation to usage-based online advertising. Beyond strict pseudonymization of collected data and legal requirements, we adhere to the self-regulation principles of the IAB Europe Framework.
Information on the IAB Transparency and Consent Framework (TCF 2.2 or later):
SAG is a registered vendor under the Transparency and Consent Framework (TCF 2.2 or later), as developed by the International Advertising Bureau (IAB) Europe. On some partner sites, cookies are set to manage advertising campaigns.
5.8. Purposes of Processing (in accordance with TCF) and Legal Basis
Your data is processed for the following purposes and based on the following legal grounds.
We primarily process your data for the overarching purpose of selling and purchasing digital advertising for the most targeted buying and selling of ad placements (under sole and joint responsibility). The specific purposes pursued and their associated legal bases (legitimate interest, Art. 6(1)(f) GDPR, or consent, Art. 6(1) (a) GDPR in conjunction with § 25(1) TTDG; Art. 7 GDPR) are listed in the table below:
Data Processing Purposes According to TCF 2.2
| Purpose | Legal Basis | Data Categories | |
| P1 | Storing and/or accessing information on a device | Consent (per § 25(1) TDDDG in conjunction with Art. 6(1)(a) GDPR) | Cookie ID / Advertising ID |
| P2 | Use of limited data to select advertising | Legitimate interest (to make ads more relevant and ensure monetization) or consent | IP address, User-Agent string, HTTP data (URL) |
| P3 | Creating profiles for personalized advertising | Consent | IP address, User-Agent string, HTTP data (URL), Cookie ID / Advertising ID (not linked to user account) |
| P4 | Using profiles to select personalized advertising | Consent | IP address, User-Agent string, HTTP data (URL), Cookie ID / Advertising ID (not linked to user account) |
| P5 | Creating profiles to personalize content | Consent | IP address, User-Agent string, HTTP data (URL), Cookie ID / Advertising ID (not linked to user account) |
| P6 | Using profiles to select personalized content | Consent | IP address, User-Agent string, HTTP data (URL), Cookie ID / Advertising ID (not linked to user account) |
| P7 | Measuring ad performance | Consent or legitimate interest (to assess advertising success and quality factors) | IP address, User-Agent string, HTTP data (URL), Cookie ID / Advertising ID (not linked to user account) |
| P8 | Measuring content performance | Consent or legitimate interest (to assess content success and qualitative aspects) | IP address, User-Agent string, HTTP data (URL), Cookie ID / Advertising ID (not linked to user account) |
| P9 | Audience insights through statistics or data combinations | Consent or legitimate interest (to better understand target audiences and optimize offerings) | IP address, User-Agent string, HTTP data (URL), Cookie ID / Advertising ID (not linked to user account) |
| P10 | Developing and improving products and services | Consent or legitimate interest (to optimize and develop attractive advertising products) | IP address, User-Agent string, HTTP data (URL), Cookie ID / Advertising ID (not linked to user account) |
| SP1 | : Ensure security, fraud prevention, and troubleshooting | Legitimate interest (to ensure smooth and secure operation of digital services) | IP address |
| SP2 | Delivering content and ads | Legitimate interest (to enable communication and technical delivery of content/ads) | IP address |
| SP3 | Storing and sharing your privacy preferences | Legitimate interest (to comply with privacy regulations and user rights) | Consent string |
6. Visitors to Our Website, Business Partners, and Customers, as well as Their Employees
6.1. Processing of Your Data
Depending on the information you provide to us, we process the following categories of data:
Professional contact and organizational data, such as name, first name, gender, address, email address, phone number, mobile number, department, responsibilities, or participation in sales events;
Order or contract-related data, such as purchased products or services, date of contract conclusion or pre-contractual stage, prices, payment and delivery information, or special requests;
Billing or banking data, such as payment behavior, balances, credit reports, or account information.
We do not process any special categories of personal data within the meaning of Article 9(1) GDPR.
6.2. For What Purpose and on What Legal Basis Are Your Data Processed
Your data is processed for the following purposes and based on the following legal grounds, either under sole or joint responsibility:
6.2.1. Based on Our Legitimate Interests (Article 6(1)(1)(f) GDPR):
To provide, maintain, protect, and improve our services; to develop new services; and to protect both ourselves, our business partners, and customers;
To further enhance the security of our IT systems for the benefit of all business partners and customers;
To detect or prevent technical issues;
To protect rights, property, or safety belonging to us, our business partners and customers, or the public, as permitted or required by law;
To establish, exercise, or defend legal claims;
To send you relevant information about Ströer Group and its services, including customer support and marketing activities, unless you have objected to the usage of your data for these services;
For customer management and support.
6.2.2. Based on Legal Obligations (Article 6(1)(1)(c) GDPR):
To comply with or fulfill applicable laws, regulations, legal processes, or enforceable governmental orders;
To detect, prevent, or combat violations of the law when SAG is legally required to do so or third parties have a legal claim against SAG;
To detect, prevent, or rectify security deficiencies or technical problems.
6.2.3. For Contract Execution (Article 6(1)(1)(b) GDPR):
To establish, structure, or modify a contractual relationship with any specific customer;
To deliver our services as part of contract fulfillment.
6.2.4. Based on Your Consent for One or More Specific Purposes (Article 6(1)(1)(a) GDPR):
For the processing of your personal data in relation to creating a personalized newsletter;
For regularly sending newsletters to the email address you provided;
For marketing purposes and customer engagement;
To offer you tailored content, such as personalized advertising.
6.3. Sharing of Your Data Within Corporate Entities
Within our company, only departments or corporate entities that require access to your data to fulfill our contractual and legal obligations or to pursue our legitimate interests will receive your data.
We only share your data with other entities under the following circumstances:
6.3.1. For Legal Reasons
We will share your data with other companies, organizations, or individuals if it is necessary to:
Comply with applicable laws or regulations, such as legal processes or enforceable governmental orders;
Enforce contractual arrangements, including investigating potential violations;
Detect, prevent, or address fraud, security deficiencies, or technical issues;
Protect the rights, property, or safety of Ströer, its users, or the public, as permitted or required by law.
In such cases, your data may also be shared with authorities, courts, attorneys, auditors, and tax consultants if necessary.
6.3.2. For Processing by Other Entities (on Our Behalf)
We may share your data with trusted companies that process data on our behalf in accordance with legal provisions and based on our instructions (so-called processors). This occurs in compliance with applicable laws and under suitable confidentiality and security measures to ensure the protection of your data. SAG remains responsible for safeguarding your data in such cases. Service providers may include entities in areas such as IT, sales, marketing, finance, consulting, customer support, human resources, logistics, and printing.
Additionally, only our employees have access to your data. Non-personalized data (such as fully anonymized data, which cannot be linked to your identity) may be shared with third parties.
6.3.3. Note on the Use of Google Analytics on Seeding-Alliance.de
We use the Google Analytics analysis service from Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses cookies. The information generated by these cookies about your use of the website is transmitted to and stored on a Google server in the USA. Google will use this information on our behalf to analyze your use of the website, compile reports on website activity, and provide additional services related to website and internet usage. Pseudonymous user profiles may be created based on the processed data.
We have integrated Google Analytics on our website with the “anonymizeIP” code. This means that users’ IP addresses are truncated within the EU or other signatory states of the EEA Agreement before being transmitted to Google’s servers. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. The IP address transmitted by your browser in connection with Google Analytics will not be merged with other Google data.
You can prevent the storage of cookies with a corresponding setting in your browser. You can also prevent the collection of data generated by cookies related to your use of this website and their processing by Google through the following browser plugin: http://tools.google.com/dlpage/gaoptout?hl=de .
6.3.4. Use of YouTube
Our website integrates videos through the provider YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066, USA, represented by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Normally, when you visit a page with embedded videos, your IP address is sent to YouTube, and cookies are installed on your computer. However, we have integrated YouTube videos with enhanced privacy mode. This means YouTube still contacts DoubleClick, a Google service, but per Google’s privacy policy, personal data is not analyzed. YouTube does not save information about visitors unless they watch the video.
If you click on a video, your IP address will be transmitted to YouTube, which will record that you have viewed the video. If you’re logged into YouTube, this information is linked to your YouTube account (you can avoid this by logging out before watching the video).
We have no knowledge of or influence over YouTube’s subsequent collection and use of your data. For more information, see YouTube’s privacy policy: http://www.google.de/intl/de/policies/privacy .
6.4. Log Data, Cookies, Tools and Plugins Processed on This Website
When you access our website, your browser sends technical data to enable communication between your device and our server for accessing our pages. We process the following categories of personal data:
IP address (immediately anonymized upon collection);
Date and time of page access;
Accessed URLs of our subpages;
Referral URL (the URL from which you reached our site);
HTTP status code (e.g., successful page access);
Language settings in your browser;
Operating system, browser type, and device model.
6.5. Marketing and Newsletter
We process your data in accordance with legal regulations for our own marketing purposes.
You can object to the processing of your data for promotional purposes or withdraw your consent at any time by sending a brief written notice to datenschutz@seeding-alliance.com . This will not incur any charges beyond the standard transfer costs at basic rates.
If you object to the use of your data, the contact details you provided will be excluded from further promotional processing. Please note that in exceptional cases, you may still receive promotional materials after your objection is submitted. This is due to technical processing and does not mean your objection has not been implemented.
The legal basis for this processing is both § 7(3) UWG and Art. 6(1)(f) GDPR. Our legitimate interest in addressing advertising to meet demand is considered justified within the meaning of the aforementioned regulations.
We only share your data with business partners for sending promotional materials if the partner adheres to our data protection standards.
Newsletter Subscription
On our website, you can subscribe to our newsletter. In our newsletters, we provide updates on our current products and services, invite you to our events, and share interesting articles (e.g., blog posts) and relevant topics. This information may also be used for advertising purposes. Typically, your email address is required for registration.
The newsletter subscription follows the so-called double opt-in procedure. After entering your email address on our website (Step 1), we will send you a confirmation email with a verification link. When you click this link (Step 2), you will receive our regular newsletter. This process ensures that unauthorized individuals cannot subscribe to our newsletter distribution list using your email address. If the link is not clicked within a specific time frame, the newsletter will not be sent.
If you have subscribed to a newsletter, a dedicated unsubscribe link is included at the end of each newsletter. Alternatively, you can unsubscribe here . If no legal retention periods apply to your personal data (e.g., due to an existing contractual relationship with us), we will promptly remove you from the respective newsletter distribution list upon receiving your request to unsubscribe.
The processing of your personal data is for the purpose of creating a personalized newsletter and regularly sending it to the email address you provided. The legal basis for this processing is your consent (Art. 6(1)(a) GDPR).
6.6. Contacting Us
On our website, we provide a specific form to quickly get in touch with us or schedule an appointment for a free demo. In this process, we process the information you enter into the form, including free-text content (e.g., details of your message).
If specific data is not absolutely necessary to respond to your inquiry but helps us personalize our response (e.g., your role in the company) or allows for alternative contact methods (e.g., phone), we will label such fields as “optional.”
The legal basis for processing this data is your consent (Art. 6(1)(a) GDPR). If the information you provide is required to prepare or fulfill a contract with you, the legal basis is Art. 6(1)(b) GDPR.
You can also contact us anytime via email. If you send a message to one of the email addresses listed on our website, the legal basis for data processing is our legitimate interest in handling your request (Art. 6(1)(f) GDPR).
Please note that emails are generally not fully encrypted during transmission. Despite extensive technical measures, there is a risk of unauthorized third-party access to email content.
6.7. Additional Data Categories and Recipients
The content on our website and our social media presence is not designed to process special categories of personal data within the meaning of Article 9 GDPR (e.g., health information, origin, or religion). Typically, we do not process such data unless provided voluntarily by you, such as in a contact form (Article 9(2)(a) GDPR).
If we hire external service providers who may come into contact with your personal data, they usually act as so-called processors on our behalf. This means we sign a data processing agreement with them under Article 28 GDPR, which obliges them to use the data exclusively as instructed by us.
We engage processors in the following areas:
IT
Sales
Marketing
Finance
Insurance
Business consulting
Tax consulting
Auditing
Customer service
Human resources
Logistics
Printing
Use and Sharing by Partners
Our partners are obligated to use your data exclusively for agreed-upon purposes and are prohibited from using or sharing it for their own purposes or with third parties. Access to your data is limited to employees who require it to fulfill their responsibilities (need-to-know principle).
If personal data is required to prepare or pursue litigation or to address legal violations, it may be processed accordingly (e.g., sharing with attorneys). The legal basis for this is our legitimate interest in legal action (§ 24(1) No. 2 BDSG, Art. 6(1)(f) GDPR).
In addition, personal data may also be transferred to relevant state authorities (e.g., for law enforcement purposes) due to legal obligations, enforceable administrative orders, or court decisions (Art. 6(1)(c) GDPR).
6.8. Applications
If you apply via our career page and submit an application form, we process your personal data as follows:
Use of an External Service Provider:
We use the SmartRecruiters GmbH service, Wilhelmstr. 118, 10963 Berlin (“SmartRecruiters”), for application management. SmartRecruiters operates an e-recruiting system (“Career Portal”), through which we post job ads and manage applications.
Career Page Usage:
The Ströer career page is our central platform for applicant management across the Ströer Group. You can access the career page at the following link: https://karriere.stroeer.com/de/datenschutzhinweise
Collection and Transmission of Your Data:
When using our Career Portal, your personal data is recorded directly in the e-recruiting system. If you apply by post or email, your application data may also be transferred to the e-recruiting system in our Career Portal.
Further Information: Detailed information on data processing as part of your application can be found in the privacy notices on our career page: https://karriere.stroeer.com/de/datenschutzhinweise
7. Social Media
General Information
You can find us on various social media platforms where we maintain an active presence. Our goal is to provide you with a wide range of information and engage with you on topics that may be important to you. In addition to the individual providers of the social networks, we also collect and process personal user data on our profile pages.
On this website, we provide links to our profiles in social networks using icons or graphics representing each network. These simply link to our profile page and no data is transmitted to the social network operators when our website is accessed. Data is only transmitted when you actively follow the link to one of our social media profiles.
Depending on the operator of the respective network, the following categories of data may be processed:
IP address
Date and time of access
Pages visited in the social network
Referral URL (website from which the user arrived at the social network)
URLs of internal and external pages accessed from the social network
Device type (desktop, smartphone, tablet)
User’s language settings
User’s region
When you visit our social media profiles, the social network operator can set cookies on your device, regardless of whether you have an account on the platform or are logged in. Cookies are data packets that assign a specific identifier to the user’s device. Cookies are mainly used to display personalized advertising to visitors of the social networks, including on our profile pages.
For example, this occurs when users see ads from the network’s advertising partners on the social media platform based on websites the user has previously visited. Cookies also enable the compilation of statistics about the use of the respective profile page (e.g., number of page views, target audience analysis).
If we receive such statistical analyses from the social network operator, the data is anonymized beforehand so that it is impossible for us to associate it with individual users. However, if you are logged into the social network, the operator may associate your visit to our profile with your user account on their platform. To avoid your data being directly linked to your user account, simply log out of the social network before following the link to our profile.
We have no control over what data is collected or transmitted by the social network operator, to whom the operator sends the data, or how long the operator stores the data. For further information, please refer to the relevant social network’s privacy policy.
We maintain our social media presence to inform you about our offers and services and to provide an additional means of contact. The legal basis for this processing is our legitimate interest in public relations activities (Art. 6(1)(f) GDPR). The legal basis for the use of social media plugins, such as “Share” buttons, is your consent (Art. 6(1)(a) GDPR).
Public posts you make (e.g., on our timeline) will remain published on our profiles unless you explicitly request their removal or delete them yourself.
We reserve the right to delete illegal content published on our profile pages, such as copyright infringements or statements that are relevant under criminal law. Additionally, we may store usernames and comments deleted due to violations of our netiquette for the purpose of providing evidence in legal disputes, up to the applicable statutory limitation period.
In accordance with the ruling of the European Court of Justice, we are jointly responsible with the operator of the respective social network for compliance with data protection regulations as they pertain to operating our profile pages. Within this framework, the social network operator provides the associated IT infrastructure and manages the social network’s website. The operator also serves as the primary contact point for processing requests concerning your data on the social network (e.g., access or deletion requests). For data processing inquiries related to social networks, we recommend contacting the respective network operator directly, as they are the only ones with full access to your user data.
We maintain profiles on the following social networks:
When you access our Facebook fan page, Facebook Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, D02 X525, Ireland, collects, stores, and processes your personal data in accordance with Facebook’s Privacy Policy. You can view the privacy policy here: https://de-de.facebook.com/policy.php
Through the “Facebook Insights” feature, Facebook also provides us with the following anonymized (statistical) data to measure the performance and optimize our Facebook presence:
Predefined interactions on our fan page (conversions)
Timestamps
User’s country/city
HTTP status codes
Age groups, gender
Previously visited website (so-called referral URL)
User’s device
Facebook user ID (if logged in)
For the processing of Insights data, Facebook and we share joint responsibility, with Facebook assuming primary responsibility. This includes the processing of data and the implementation of user rights. Therefore, please contact Facebook directly for all claims under the GDPR regarding the processing of Insights data. We will forward any relevant inquiries we receive to Facebook. For more details: www.facebook.com/legal/terms/page_controller_addendum .
Further information on Facebook Insights is available here:
https://analytics.facebook.com/features/list#automated_insights
YouTube
When you access our YouTube channel, personal data is collected and processed by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, D04 E5W5, Ireland (“Google”), as the operator of YouTube, in accordance with Google’s Privacy Policy. You can find their privacy policy here: https://policies.google.com/privacy?hl=de
Using YouTube Analytics, we can perform specific statistical evaluations to optimize our channel. These include details about popular videos (e.g., user viewing time, video rankings), target audiences (e.g., countries, language settings, age, activity times), and channel reach (e.g., where users were redirected from) or impressions (e.g., how many users viewed a particular ad).
User-specific insights or access to individual profiles are not possible for us. For more information on YouTube’s Analytics features, visit: https://support.google.com/youtube/answer/9002587?hl=de
Other Social Networks
LinkedIn: Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. Privacy Policy: https://www.linkedin.com/legal/privacy-policy ; Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out .
Xing: Provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung .
Instagram: Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. Privacy Policy: https://privacycenter.instagram.com/policy/?entry_point=ig_help_center_data_policy_redirect .
X (formerly Twitter): Provider: Twitter International Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland. Privacy Policy: https://x.com/de/privacy .
For data access requests or the assertion of data subject rights, it is generally most effective to contact the respective social network provider directly. Only the platform operators have full access to user data and can take immediate action. However, if you need additional support, you are welcome to contact us.
8. Detailed Information on the Processing of Customer Contact Data under Joint Responsibility with the Companies of the Ströer Group
Seeding Alliance, as part of the Ströer Group, exchanges customer contact data with other Ströer Group companies (hereinafter referred to as “our Group Companies”). All participating companies are contractually bound by a separate data protection agreement regarding joint controllership (Article 26 GDPR). They are also restricted in their processing of your data to the purposes stated in this privacy notice.
You can find a list of the participating companies involved in the joint use of customer contact data here:
https://www.stroeer.de/gesellschaftsuebergreifende-nutzung-von-kontaktdaten/
Your data may be processed by our Group Companies for the following processing purposes:
- Management of the opt-in process
- Processing of business contact data in the CRM system and potentially other related systems
- Promotional communication
- Processing of inquiries and preparation of offers
- Initiation and execution of contracts
- Creation of contact reports
- Documentation of the business customer relationship
- Invitation management
- Creation of creditor & debtor records
- Management of the opt-out process
- Purposes and Legal Bases of the Joint Data Processing by Our Group Companies
| Purpose | Legal Basis |
| Promotional communication | Consent pursuant to Art. 6(1)(a) GDPR |
| Invitation to and execution of events | Consent / Legitimate interest (Art. 6(1)(a) / Art. 6(1)(f) GDPR) |
| Invitation to market research activities | Consent (Art. 6(1)(a) GDPR) / Legitimate interest (Art. 6(1)(f) GDPR |
| Promotional communication to existing customers | Legitimate interest (Art. 6(1)(f) GDPR in conjunction with § 7(3) UWG) |
| Measurement/analysis of open and click rates | Consent (Art. 6(1)(a) GDPR) |
| Customer support / Handling data subject requests | Legitimate interest (Art. 6(1)(f) GDPR) |
If you have any questions regarding the aforementioned joint processing, or if you wish to exercise your rights under the GDPR (in relation to this joint processing), please refer to the section Controller, Data Protection Officer, and Exercising Your Rights of this privacy notice (Section 2). Alternatively, you can contact the respective Group Company directly. The contact details can be found in the privacy notice of the relevant Group Company.
This privacy notice was last updated on February 26, 2025.