Privacy Policy for Online Advertising
Privacy Policy for Online Advertising by VIVALU GmbH
This is the privacy policy for online advertising by VIVALU GmbH. The privacy policy for our website www.vivalu.com can be found here: vivalu.com/privacy-policy
As part of our business activities, we carry out user-centred online marketing measures for our clients. The technology used by VIVALU GmbH on behalf of its clients optimises advertising measures through the use of data that, as a rule, does not have any personal reference (anonymous & pseudonymised data). VIVALU GmbH will not attempt under any circumstances to assign the data available to it to a specific person.
1. Definitions
The privacy policy of VIVALU GmbH is based on the terms used by the European legislators when adopting the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easily readable and understandable for both the public and our customers and business partners. For the terms used, such as “personal data” or “processing”, we refer to the definitions in Article 4 of the GDPR.
2. Name and Address of the Controller
The controller within the meaning of the GDPR, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:
VIVALU GmbH
Zollhof 6
40221 Düsseldorf
Germany
Phone: +49 211 7817520
Email: datenschutz@vivalu.com
Website: www.vivalu.com
3. Name and Address of the Data Protection Officer
The Data Protection Officer of the controller is:
Kia Zolfaghari
VIVALU GmbH
Zollhof 6
40221 Düsseldorf
Phone: +49 211 78175212
Email: kzo@vivalu.com
Website: www.vivalu.com
Any data subject may contact our Data Protection Officer at any time with all questions and suggestions regarding data protection.
4. Information on Usage-Based Online Advertising
As a company, we have voluntarily submitted to the self-regulation of the German Data Protection Council for Online Advertising (DDOW). This concerns the responsible handling of data for advertising targeting with regard to transparency, usage and objection possibilities.
The self-regulatory code valid for us for third parties can be viewed at the following link: meine-cookies.org/DDOW
We optimise the control of advertising for the products and services of our clients through the anonymous collection and processing of your usage behaviour. For this purpose, a cookie is stored on your device.
4. Cookies
Cookies are small text files that are placed and stored on a computer system via an internet browser and that enable users to be recognised. By using cookies, VIVALU GmbH can offer the users of this website targeted online advertising that would not be possible without the setting of cookies. Cookies are not used to identify a user. VIVALU GmbH will in no case attempt to assign the data available to it to a specific person.
You may object to the setting of cookies by VIVALU GmbH for this browser here: VIVALU OptOut
Furthermore, the setting of cookies by VIVALU GmbH can be prevented by configuring the internet browser used and thus permanently objecting to the setting of cookies. Cookies that have already been set can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our website may be fully usable.
Further information on the subject of cookies is provided by the German Association for the Digital Economy. There you can set individual preferences for the acceptance of cookies in addition to general information on cookies and the subject of data protection: meine-cookies.org
5. Type and Purpose of the Data Collected
The technologies used exclusively collect anonymised and pseudonymised data. Among other things, the following data may be retrieved: which websites were accessed, the time of access, information about the user’s end device, which advertising media have already been viewed or clicked, duration of stay on websites and webshops, etc.
The purpose of data collection is the implementation of online marketing measures such as display advertising. Data collection and processing are therefore carried out on behalf of the respective client. With the help of the collected data, relevant advertisements can be made available to a user.
VIVALU does not collect or use any data that could be used to deliver advertising to children who have not yet reached the age of 13.
6. Additional Data from Third Parties
In order to meet our objective of reducing wastage in advertising delivery, we may use audience data. These data are made available to us by third parties in the form of pseudonymous profiles. VIVALU uses exclusively data from certified providers.
7. Technology Partners
Our technology partners are also committed to active protection of consumer data and follow the applicable guidelines for the industry. They have also reviewed and updated the guidelines and procedures used to ensure the security and protection of personal data. Please refer to the respective privacy policies of the partners mentioned for their handling of data.
MediaMath (DSP) – MediaMath is a global provider of digital advertising media and data management technology. Data is activated, processes are automated and advertising interactions across all addressable media channels are optimised with the proprietary platform TerminalOne™ of MediaMath. As an active member of industry associations, MediaMath continuously deals with consumer privacy guidelines in connection with interest-based advertising.
Detailed information can be found in the privacy policy of MediaMath: mediamath.com/de/datenschutzrichtlinie
AppNexus (DSP) – AppNexus has created a technical platform with which our clients can buy, sell and offer online advertising, including interest-based advertising, usually via real-time bidding.
Detailed information can be found in the privacy policy of AppNexus: appnexus.com/platform-privacy-policy
Adform (DSP) – The Adform platform allows advertisers to buy digital ad space and publishers to sell their ad space. Furthermore, Adform offers tools to manage, buy and sell data to ensure that ads are served to users likely to be interested in a particular ad. Adform does not collect or allow its clients to use data on the platform that on its own identifies a person, such as name, address, telephone number, email address or government ID.
Detailed information can be found in the privacy policy of Adform: site.adform.com/platform-privacy
TabMo (DSP) – TabMo SAS is a marketing services company focused on mobile applications and the mobile web market. TabMo collects information about visited mobile apps and websites to build interest segments and make ads more relevant without collecting data that enables personal identification.
Detailed information can be found in the privacy policy of TabMo: tabmo.io/services
The Trade Desk (DSP) – The Trade Desk provides a demand-side platform (DSP) known in the industry. It enables advertisers and their agencies to manage digital ad campaigns across many channels such as websites, apps, audio, and video. Data collected are used to ensure relevant ads and to measure and report on their effectiveness. The data on our platform is pseudonymised, meaning it does not directly identify individuals.
Detailed information can be found in the privacy policy of The Trade Desk: thetradedesk.com/general/privacy
Google Ads – Google Ads is an online advertising service that allows advertisers to place ads in Google search results and in the Google advertising network.
Detailed information can be found in the privacy policy of GoogleAds: policies.google.com
Google Display & Video 360 – Display & Video 360 is the evolution and consolidation of DoubleClick Bid Manager, Campaign Manager, Studio and Audience Center and belongs to the Google Marketing Platform. Data are transmitted with each impression and click, and if accepted, Google sets a cookie on the user’s device for optimisation of advertising.
Detailed information can be found in the privacy policy of the Google Marketing Platform: policies.google.com
Sociomantic – Sociomantic is an online advertising technology company that helps advertisers deliver more relevant online display (banner) advertisements with anonymous, non-personally identifiable information. The information collected about the use of this website (such as timestamps, visited pages or browser details) is stored pseudonymously.
Further information on privacy at Sociomantic can be found at: sociomantic.com/privacy/de
8. Social Media Ads: Facebook & Instagram
Facebook and Instagram share infrastructure, systems and technology with other Facebook companies (such as WhatsApp and Oculus) to provide an innovative, relevant, unified and secure experience across all products of the Facebook companies. For this purpose, the collected information may be processed across the Facebook companies as permitted by applicable law and their terms and policies.
Detailed information can be found in the privacy policies of the Facebook companies:
facebook.com/privacy
9. Identification of Online Advertising
VIVALU labels its advertising placements with an icon licensed by the European Interactive Digital Advertising Alliance (EDAA). This icon is located in one of the corners of the advertisement. By clicking the icon, users have the opportunity to learn about the purpose of anonymous data collection or to exercise their right to object to the currently used targeting technology.
VIVALU is part of the EDAA (European Interactive Digital Advertising Alliance) framework for Online Behavioural Advertising and is committed to ensuring that data are collected and used appropriately. For further information and to manage your preferences regarding usage-based online advertising and to deactivate or activate other providers participating in the voluntary initiative, please visit: www.youronlinechoices.eu
10. Rights of the Data Subject
Every data subject whose personal data are processed has the rights granted by the European legislators.
If a data subject wishes to exercise the rights listed and named below, they may contact our Data Protection Officer at any time.
a) The right to confirmation includes requesting confirmation from us as to whether personal data concerning them are being processed.
b) The right to access includes obtaining from us at any time free of charge information about the personal data stored about them and a copy of that information. Furthermore, the European legislators have granted the data subject access to the following information:
- Purposes of processing
- Categories of personal data
- Categories of recipients to whom data have been disclosed
- Planned storage period
- Existence of a right to rectification, erasure, restriction of processing or objection
- Existence of a right to lodge a complaint
- Origin of data, if not collected by us
- Existence of automated decision-making including profiling
c) The right to rectification includes the right to request the immediate correction of incorrect personal data concerning them.
d) The right to erasure (right to be forgotten) includes the deletion of personal data concerning them without delay under certain conditions set out in the GDPR.
e) The right to restriction of processing includes requesting restriction under specified conditions.
f) The right to data portability includes receiving personal data concerning them which they have provided to a controller in a structured, commonly used and machine-readable format, and the right to transmit those data to another controller.
g) The right to object includes the right to object at any time to processing of personal data concerning them, including profiling under specified legal grounds.
11. Legal Basis for Processing
Our company uses Article 6(1)(a/b/c/d/f) of the GDPR as the legal basis for processing operations, meaning that one of the following conditions must be met for processing:
- The data subject has given consent
- Processing is necessary for the performance of a contract
- Processing is required by law
- Processing is necessary to protect vital interests
- Processing is necessary for the legitimate interests of the controller or a third party, unless the rights and freedoms of the data subject prevail.
12. Legitimate Interests in Processing
Where processing is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business activities for the benefit of all our employees and shareholders.
13. Duration of Storage of Personal Data
The criterion for the duration of storage of personal data is the respective statutory retention period. After expiry of this period, the corresponding data are routinely deleted unless they are required for contract fulfilment or contract initiation.
14. Legal or Contractual Requirements for Provision of Personal Data
We inform you that the provision of personal data is partly legally required (e.g. tax regulations) or may arise from contractual provisions (e.g. information about the contracting party).
If it is necessary for contract conclusion that a data subject provides us with personal data, the data subject is obliged to provide it. Failure to provide such personal data may mean that the contract cannot be concluded.
15. Updates to This Privacy Policy
This privacy policy is currently valid and has the status of May 2018. Due to the further development of our website and offers or due to changed legal or regulatory requirements, it may become necessary to amend this privacy policy. The current privacy policy can be accessed and printed at any time at: vivalu.com/privacy-policy-for-online-advertising