Data privacy policy on stroeer.com

We, Ströer SE & Co. KGaA, Ströer-Allee 1, 50999 Cologne (“Ströer,” “we” or “us”), are pleased you are visiting our website on stroeer.com. We and all the entities of the Ströer Group attach the utmost importance to the protection and security of your personal data. This data privacy policy (“Data privacy policy”) explains what information we collect during your visit to our website stroeer.com, how and for what purpose we use this information and with whom we share it. We also explain your rights regarding the processing of your personal data, such as the right of access, rectification, objection and erasure.

We will only use your personal data (“Data”) in accordance with the applicable data protection laws. Where we use your data for purposes other than those stated in this data privacy policy, we will inform you of these purposes and, if necessary, obtain your consent.

The legal basis applied to our data processing can largely be found in the General Data Protection Regulation (“GDPR”), which you can access here. In the following data privacy policy, we also refer to the corresponding legal basis for our processing.

 

1. General

1.1 Who is responsible for using your data?

Ströer is the controller within the meaning of the applicable data protection laws. This means that we are responsible for the use of your data collected by us and are legally obliged to ensure that the necessary measures are taken to protect your data and that your rights are respected.

 

1.2 What data do we collect from you?

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

  • Data on the use of our services

    We collect information about you when you use our services, e.g., when you view an article or video. This relates to the following data:

    • Device-specific information

      We collect device-specific information, such as the model of the hardware you are using, the version of the operating system, unique device identifiers and cellular network information, device event data such as crashes, system activity, hardware settings, browser type, browser language, date and time of your request and referral URL.

    • Your IP address

    • Location-related information

      When you use our services, we may collect and process information about your location. We use various technologies to determine the location, such as IP addresses, GPS and other sensors which provide us with information about nearby devices, WLAN access points or cell phone masts, for example. We only process location data with your consent. You can manage, activate or deactivate the collection of location data in your mobile device settings at any time.

    • Cookies

      When you visit our website, we collect information by using cookies. See 2.1 for details.

  • Surveys, advertising campaigns and competitions

    From time to time we give you the opportunity to participate in surveys or competitions. If you voluntarily participate, we may request and process additional data from you (e.g., your address for the purpose of notifying you if you win as well as your email address and telephone number to ensure that you are notified if you win in the event that you have inadvertently provided an incorrect address, and your date of birth for the purpose of verifying your age). Further use of your data, for example for the purpose of disclosing the winner on our platform, will be made only with your express consent.

  • Newsletter

    If you voluntarily sign up for our newsletter by providing us with your consent, we will record the email address you have provided as well as your first and last name. You can unsubscribe from the newsletter at any time. Simply follow the link to unsubscribe from the newsletter at the end of each message.

  • Data on your social networking services

    Our website offers you the option of using social media buttons. To protect your data, when implementing these buttons we use the “Shariff” solution. This solution allows the buttons to be integrated in the website only as graphics, which contain a link to the corresponding website of the button provider. By clicking on the graphic you will be forwarded to the services of the respective providers. Only then will your data be sent to the respective providers. If you do not click on the graphic, no exchange of information will take place between you and the providers of the social media buttons. Information on the collection and use of your data on the social networks can be found in the respective terms of use of the relevant providers. More information on the Shariff solution can be found here: http://www.heise.de/ct/artikel/Shariff-Social-Media-Buttons-mit-Datenschutz-2467514.html

  • Contract partners, business partners and other interested parties

    Ströer collects from its contractual partners, its business partners and other parties interested in the Ströer Group and its products (e.g., the recipients of our newsletters or other information) the data that is needed to contact the respective contact partner, in particular the names provided to us of the contact partners of our partners, their email addresses and, if applicable, the postal address where we can reach the partner’s contact partner. Where contractual relationships are in place, data relating to the contract partner will also include the partner’s bank account, tax number and, if available, VAT ID.

 

1.3 For what purpose and on what legal basis do we collect your data?

We use your data on the basis of:

  • Your consent pursuant to Art. 6 (1) Sentence 1 lit. a, Art. 7 GDPR

    • To provide information or advice on products, e.g., through our newsletter

  • Our legitimate interests pursuant to Art. 6 (1) Sentence 1 lit. f GDPR

    • To provide, maintain, protect and improve our services, develop new services and to protect ourselves and our users
    • To further improve the security of our IT system for the benefit of all users
    • To communicate with you

  • To perform a contract to which you are party or in order to take steps at your request prior to entering into a contract in accordance with Art. 6 (1) p. 1 lit. b GDPR

    • To allow our services to be used by sharing contributions and interests, preferences and thoughts on our website
    • To resolve any other issues regarding our services and the storage of our communications with you to the extent necessary to resolve the issue

  • Legal obligations pursuant to Art. 6 (1) Sentence 1 lit. f GDPR

    • To comply with applicable laws, regulations or legal proceedings or an enforceable official order
    • To detect, prevent or combat breaches of law where Ströer is legally obliged to do so or third parties have a claim against Ströer in respect of breaches of law.

 

1.4 With whom do we share your data?

We do not share any data with any companies, organizations or persons outside of Ströer other than:

  • With your consent

    We will transmit data to companies, organizations or persons outside of Ströer if we have received your consent to do so.

  • For processing by other controllers

  • We provide data to our partners, other trustworthy companies or persons who process such data on our behalf (e.g., data hosting providers). This is done in accordance with applicable laws and by taking appropriate measures to ensure the protection and confidentiality of your data at all times and, in the event that data is processed on our behalf, on the basis of our instructions. For legal reasons

    We will disclose data to companies, organizations or persons outside of Ströer if we believe in good faith that access to or the use, retention or disclosure of this data is necessary to

    • comply with applicable laws, regulations or legal proceedings or an enforceable official order
    • To prevent or otherwise combat fraud, security shortcomings or technical problems
    • Protect the rights, property or security of Ströer or the public from harm as far as is legally permissible or required

In addition, only our employees have access to your data.

We may disclose non-personal data, i.e., data which cannot be used to determine the identity of a specific person, to the public and our partners, e.g., to other advertisers or related websites. For example, we publish information to show trends in the general use of our services.

 

1.5 Where are your personal data processed?

Your personal data will be processed both within and outside the European Union (“EU”) and the European Economic Area (“EEA”) by us or by the parties referred to in paragraph 1.4. Please note: If your data is transmitted from your home country to another country, the laws in place to protect your data in this country may differ from those in your country (and may provide for a lower level of protection). For example, in non-EEA countries there are other conditions under which law enforcement authorities can access your data than within the EEA. If we transmit your data to a non-EEA country, we will take appropriate measures to ensure an adequate level of data protection (for example, by concluding standard contractual clauses). More information on data transfer to the US can be found specifically under 2.2 (a) Google Analytics.

 

1.6 How long do we keep your data?

We will store your data no longer than is necessary for the fulfillment of the purpose for which it was collected or for as long as we have a legitimate interest in its storage, except where such interests are overridden by your interest in erasure, unless there is a legal basis for longer storage (e.g., under commercial or tax law pursuant to Art. 6 (1) Sentence 1 lit. c GDPR: in the case of such archiving, other access to the data is blocked and the data are deleted and destroyed in accordance with data protection laws after the expiry of the statutory retention periods). We will then delete your data. The respective retention periods are dependent on the underlying purpose and the nature of the data.

In particular, we store

  • Data that we use for personalized advertising (such as your email address when you sign up for our newsletter) for a period of up to 12 months from the last time we contacted you, unless you request prior deletion and there are no statutory storage obligations.

  • Your IP address for a maximum period of two months.

  • Cookies for a period of up to 12 months. In addition, you may delete cookies from your computer at any time. The specific retention periods, which depend on the type of cookie used, can be found under 2.

  • Data from surveys, advertising campaigns or competitions as long as this is required for their implementation and thereafter for a period of 24 months. 

If you object to future advertising emails, we will block your data by crosschecking your name, address and where appropriate the email address in corresponding lists on which we base our advertising measures. This is the only way to ensure that you do not actually receive any more advertising emails.

 

1.7 What rights do you have regarding your data? 

With regard to the processing of your data, you have the right of access, rectification, erasure or restriction of processing, the right to object to processing as well as the right to data portability. 

You have the following rights with regard to the processing of your data:

  • A right to request access to your data from us (Art. 15 GDPR)

  • A right to rectification if your data are incorrect (Art. 16 GDPR) 

  • A right to erasure, (1) where the storage of your data is no longer necessary for the abovementioned purposes, (2) where the storage is based on a consent that you have since revoked and there is no other legal basis for storage by us, (3) where you have objected to direct advertising or profiling conducted by us and we store your data for these purposes, (4) where we have unlawfully processed your data, or (5) where there is a legal obligation to erase (“right to be forgotten,” Art. 17 GDPR),
     
  • A right to restriction of processing, (1) where you have contested the accuracy of your data for the period we need to verify the accuracy of your data, (2) where the processing of your data was unlawful and you oppose the erasure of the personal data and request the restriction of their use instead, or (3) where we no longer need to store your data for the above purposes, but they are required by you for the establishment, exercise or defense of legal claims (Art. 18 GDPR), 

  • A right to data portability with regard to your data which you have provided to us where the processing is based on your consent or a contract with us, i.e., you have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format (Art. 20 GDPR),

  • You have the right to object to processing where we use your data for direct marketing purposes (Art. 21 GDPR). See 1.8 of this data privacy policy for details.

Some of these rights are limited by law. Where we are not able to fulfill these rights, we will inform you accordingly.

 

1.8 Right to withdrawal of consent and right to object pursuant to Art. 7 (3), 21 GDPR

You may object to further use of your data for advertising purposes or revoke consent given (see 1.3, respectively), even if the use of the data is legally permissible without your consent. An informal message to us is sufficient (for contact data see 5.). We will not of course charge you anything for this.

An objection will halt future processing. Any processing prior to the objection will remain unaffected. For information on blocking your data see 1.6 of this data privacy policy.

Our advertising emails (e.g., the newsletter) contain a notice with a link for the simple exercise of your right to object.

2. and 3. of this data privacy policy provide you with specific information on the opt-out for the cookies and similar technologies used by us (e.g., tracking tools).

See 5. “Contact, establishment of your rights” for more information on your rights.

 

2. Cookies and similar technologies

2.1 Cookies

Our web pages use cookies in several places. These cookies serve to make our website more user-friendly and effective. Cookies are small text files that are set on your computer and stored by your browser. Cookies can be used to determine whether communication between your computer and our website has previously taken place. Cookies cannot be assigned to a particular individual and do not contain any personal data. Cookie-generated data is not combined with data from other sources. Cookies do no harm to your computer and do not contain viruses. 

We use different types of cookies:

- Session cookies

Session cookies allow you to store your activities on the website during your browser session. Session cookies are used to enable you to use our website. These cookies are deleted after you close your browser or after you close the website. 

- Tracking cookies

When you visit the website again, tracking cookies (also “persistent cookies”) help your browser, your interests and your user behavior to be identified and the offering to be tailored to your individual needs. The use of these cookies also makes it possible to optimize your use as they register how, when and how often you use the services and on which links you click, allowing trends, stories, advertisements and follower suggestions to be tailored to your needs, for example. Furthermore, tracking cookies allow you to remain logged on to the site without having to re-enter your login data. Tracking cookies will be deleted after 12 months at the latest. In addition, you have the option of manually deleting these cookies via the settings of your browser at any time. 

 

Your rights/objection:

You can of course also make use our offers without cookies. Browsers can be set up in such a way that cookies are generally rejected. You can also delete cookies already set in your browser settings. However, if you do not use cookies, you may no longer be able to use the functions of our website in full.

 

2.2 Similar technologies

a) Notice on the use of Google Analytics

We use the analysis service Google Analytics from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (Google). Google Analytics uses cookies. The information on your use of the website generated by the cookie is transmitted to a Google server in the US and stored there.

Google uses this information, working on our behalf, to analyze the use of the website, generate reports about website activities and provide other services for us related to the use of the website and internet use. These data can be used to create user profiles under pseudonyms.

We have added the code “anonymizeIp” to Google Analytics on our website. This means that the IP address of the users is truncated within the EU or in other Contracting Parties to the Agreement on the European Economic Area. In isolated cases, the full IP address is transferred to a server in the US and truncated there. The IP address transmitted from your browser for use by Google Analytics will not be merged with other data from Google. 

The laws on the protection of personal data in the US may differ from those within the EU and may provide for only a lower level of protection. If personal data is processed by Google Analytics in the US, this will take place on the basis of appropriate measures aimed at ensuring the confidentiality and protection of your data. Google is certified under the Privacy Shield Framework. More information on the Privacy Shield Framework can be found under https://www.privacyshield.gov/welcome.

 

Your rights/objection:

You can prevent cookies from being stored by managing the relevant settings in your browser. You can also prevent data generated by the cookie and related to your use of this website being recorded and processed by Google by downloading and installing the browser plug-in available here: https://tools.google.com/dlpage/gaoptout?hl=en

In this case, the web analytics tool will remain disabled for as long as the Google add-on, for its part, is not deactivated or deleted. Therefore please do not delete the add-on for as long as the web analytics tool is not required. The add-on is set for each browser and for each computer. If you access our website using different browsers or from different computers, you must therefore add the add-on separately for each browser or for each computer. As an alternative to the browser add-on, especially for browsers on mobile end devices, you can also prevent tracking by Google Analytics by clicking on this link: Terminate Google Analytics tracking.

 

b) This creates an opt-out cookie that prevents the future collection of your data upon visiting this website. This opt-out cookie only applies to this browser and only for our website and is stored on your device. If you delete cookies from this browser, you must reset the opt-out cookie accordingly. We also use Google Analytics to evaluate data from DoubleClick cookies and AdWords for statistical purposes, including demographics (e.g., age and gender) and interests. These data cannot be used to determine the identity of a specific person. If you object to this, you can deactivate this at any time using the display settings.

 

c) Server log files

When you visit our website, the provider of the pages stores information in server log files, which your browser automatically transmits to us. This information includes:

IP address (in anonymous form – IP addresses are never stored in full)

- Date and duration of access

- Requested URL link, including parameters in the URL (GET parameters/query string)

- Status code

- Size of the response in bytes

- Referrer URL

- User agent

We do not store this data permanently, but use it only for session recognition and to defend against attacks. The collected data are anonymous and cannot be used to determine the identity of the user.

 

2.3 Embedded YouTube videos

We embed YouTube videos in some of our websites. YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA, is the operator of the corresponding plugin. When you visit a page containing the YouTube plug-in, a connection is established to the YouTube servers and YouTube is informed of the websites visited by you. If you are logged in to your YouTube account, YouTube can associate your browsing behavior with you personally. You can prevent this by logging out of your YouTube account beforehand.

When a YouTube video is launched, the provider sets cookies to collect information about user behavior.

If you have deactivated the saving of cookies for the Google ad program, you will also not have to expect these cookies when watching YouTube videos. However, YouTube stores non-personal user information available in other cookies as well. If you want to prevent this, you must block the storage of cookies in the browser.

More information on data privacy at YouTube can be found in the provider’s data privacy policy under: https://policies.google.com/privacy?hl=en.

 

2.4 Use of Google maps

This website uses Google Maps, which is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, to display maps and generate directions.

By using this website, the user agrees to the collection, processing and use of the data automatically collected and entered by the user by Google, one of its representatives or third parties.

The terms of use for Google Maps can be found under Terms of use for Google Maps. More details can be found in google.de’s data privacy center: Transparency and user choice as well as data protection regulations.

 

3. Contact form

If you have any questions, please contact us by email or using the contact form. To allow us to contact you, please provide us with your voluntary consent. For this purpose, you will need to disclose some personal data (name, zip code, city and email address), which will allow us to associate the inquiry with you and to respond to it. The disclosure of additional data is optional. The information you provide will be stored for the purpose of dealing with the inquiry as well as for possible follow-up questions. After the inquiry sent by you has been dealt with, personal data are deleted.

 

4. White papers

You can obtain various white papers on the Ströer websites. To trigger the dispatch, you will be asked to provide your first and last name, company, and email address. These data are used to contact you by phone, post or email for advertising purposes. The personal data provided are contractual consideration to which we are entitled for the provision of the white paper free of charge. Notwithstanding the above, Ströer grants you the option to revoke the use of your personal data for advertising purposes at all times in the future. To make use of this option, you must send an email to kontakt@stroeer.de and declare your revocation.

 

5. Contact, assertion of your rights

Under the legal conditions, you have an unrestricted right of access, to rectification, to restriction, to objection and to erasure in relation to the processing of your personal data and a right to data portability pursuant to Chapter 3 GDPR. You can assert these rights against the Company free of charge via the email address datenschutz@stroeer.de or via the following contact data:

Ströer SE & Co. KGaA
Datenschutz (data protection)
Ströer Allee 1
50999 Cologne

In addition, Art. 77 GDPR grants you the right to lodge a complaint with a supervisory authority.

Our in-house data protection officer can be reached under:

Ströer SE & Co. KGaA
Datenschutzbeauftragter (Data protection officer)
Ströer Allee 1
50999 Cologne
Email: datenschutzbeauftragter@stroeer.de

 

6. How frequently do we update this data privacy policy?

This privacy policy may be updated from time to time, e.g., to adapt it to new data protection regulations. All changes to this privacy policy will be published on this page. If the changes are significant, we may notify you separately (e.g., by email). This data privacy policy was last updated on [24 May 2018].