Privacy policy for Splicky Demand Side Platform

Last status – January 2022

We are pleased that you are visiting our website and thank you for your interest in our agency and the corresponding services.

Data protection is not only a legal obligation for us, but also an important instrument for increasing transparency in our daily handling of your personal data. With this privacy policy, we would like to inform you about how we process personal data and inform you about your rights. We are aware of the importance of processing personal data for you as an affected user and therefore comply with all relevant legal requirements. The protection of your privacy is of the utmost importance to us.We process your personal data in compliance with the General Data Protection Regulation and federal and state data protection regulations.

Splicky is a registered member of the IAB Transparency and Consent Framework 2.2 (Vendor ID 252) and adheres to the guidelines specified for this. The IAB TCF 2.2 is an industry standard that enables all digital market participants (publishers, advertisers, technology service providers, etc.) to inform end users about the processing of their personal data and to give them the opportunity to consent to or object to this. We always process your personal data (hereinafter referred to as ‘data’) in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as ‘GDPR’).

Splicky GmbH
Körtestrasse 10, 10967 Berlin

Managing directors authorised to represent the company: Sven Ruppert and Markus Alexander Wirth

Phone: +49 30 609 40 280

Mail: info@jaduda.com

E-Mail:
info@jaduda.com

Postal address
Splicky GmbH
Körtestrasse 10, 10967 Berlin

This Privacy Policy makes use of the terminology of the General Data Protection Regulation (GDPR).

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Restriction of processing” means the marking of stored personal data with the aim of limiting its future processing.

“Profiling” means any type of automated processing of personal data that consists of using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s job performance, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.

“Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separate and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.

“File system” means any structured collection of personal data accessible according to specified criteria, whether such collection is maintained centrally, decentrally, or on a functional or geographical basis;

“Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its designation may be provided for under Union or Member State law.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

“Recipient” means a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, public authorities that may receive personal data in the context of a specific investigative task under Union or Member State law shall not be considered as recipients; the processing of such data by the aforementioned authorities shall be carried out in accordance with the applicable data protection rules in accordance with the purposes of the processing.

“Third Party” means a natural or legal person, public authority, agency or other body, other than the Data Subject, the Controller, the Processor and the persons authorized to process the Personal Data under the direct responsibility of the Controller or the Processor.

“Consent” means the data subject’s freely given, informed and unambiguous indication of his or her wishes in the form of a statement or other unambiguous affirmative act by which the data subject signifies his or her agreement to the processing of personal data relating to him or her.

The data we collect is not intended to identify you by name, address, etc., as this is not even needed for the purpose of personalized advertising playout. On the contrary, the data collected about you (see below) is assigned to an identification number of your end device – i.e. your cell phone, tablet, SmartTV, etc. Therefore, the collected data is so-called pseudonymous data that cannot be easily assigned to a person.

The following information may be the subject of our data collection

  • Device identification numbers (device identifiers, IP addresses)
  • Information about your use of the websites and apps (which subpage in the website, which function in the app)
  • Information you have provided on the websites and apps (e.g. age, interests) (only with your consent)
  • Geo-location data (only with your consent).
  • Privacy settings you have made (opt-in, opt-out) – so we know which of your data we are allowed to process and for which purposes

In addition to the primary purpose of delivering relevant, usage-based advertising to your device, these additionally include the following purposes

  • Reporting to end users – we process data to show Jaduda’s customers how advertisers have interacted with their advertising (qualitatively as well as quantitatively).
  • Frequency capping – we process data to ensure that you do not see the same ad too often
  • Ad fraud prevention – we process data to combat unfair activities by participants in the advertising industry
  • We process data for market research purposes
  • for our statistics.

Your data is processed on the following legal bases:

  • Consent(Art. 6 para. 1 p. 1 lit. a GDPR) – The data subject has given his/her consent to the processing of personal data concerning him/her for a specific purpose or purposes.
  • Performance of a contract and pre-contractual requests (Art. 6 (1) p. 1 lit. b GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures carried out at the data subject’s request.
  • Legal obligation (Art. 6 (1) p. 1 lit. c GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 (1) p. 1 lit. f GDPR) – Processing is necessary for the purposes of the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

Insofar as we base the processing of your personal data on legitimate interests within the meaning of Art. 6 (1) lit. f GDPR, such interests include.

  • The improvement of our offer,
  • the protection against misuse and
  • the maintenance of our statistics.

We receive the data from you (including about the devices you use). If we do not collect the personal data directly from you, we will also tell you the source of the personal data and, if applicable, whether it comes from publicly available sources.

A detailed list of which data is processed by which recipient can be found here: Listing of provider

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of using third-party services or disclosing or transferring data to other persons, bodies or companies, this will only be done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de) .

We store your personal data only as long as it is necessary to achieve the purpose of processing or the storage is subject to a legal retention period.

We store your data,

  • if you have consented to the processing, at most until you revoke your consent,
  • if we need the data to perform a contract, at most for as long as the contractual relationship with you exists or legal retention periods run,
  • if we use the data on the basis of a legitimate interest, at most as long as your interest in deletion or anonymization does not prevail.

You have – partly under certain conditions – the right to

  • to request information about the processing of your data free of charge, as well as to receive a copy of your personal data. Among other things, you can request information about the purposes of processing, the categories of personal data that are processed, the recipients of the data (if a transfer takes place), the duration of storage or the criteria for determining the duration;
  • To have your data rectified. If your personal data is incomplete, you have the right, taking into account the purposes of processing, to complete the data;
  • To have your data erased or blocked. Grounds for the existence of a right to erasure/blocking may include: withdrawal of consent on which the processing is based, the data subject’s objection to the processing, unlawful processing of personal data;
  • to have the processing restricted;
  • to object to the processing of your data;
  • revoke your consent to the processing of your data for the future; and
  • complain to the competent supervisory authority about unlawful data processing (Berlin State Commissioner for Data Protection and Freedom of Information).

Unless expressly stated at the time of collection, the provision of data is not required or obligatory. Such an obligation may result from legal requirements or contractual regulations.

The contact form on our website www.splicky.com is a simple way to quickly contact us. To make it possible to contact us, some fields are marked as mandatory. If you fill in the fields and select “Send”, you agree that your data will be transmitted to us by e-mail with the message.

We have taken extensive technical and organizational measures to secure your data against possible threats, such as unauthorized access or entry, unauthorized disclosure, modification or dissemination, as well as against loss, destruction or misuse.

To protect your personal data from unauthorized access by third parties during transmission, we secure data transmissions using SSL encryption where necessary. This is a standardized encryption method for online services, especially for the web.

Our website does not collect any log files from the user. Only in the event that an error message is generated by the host, a log note is included in the error report.

A cookie is a text file with an identification number that is transmitted to the user’s computer and stored there together with the other data actually requested when the website is used. The file is kept there for later access and serves to authenticate the user. Since cookies are only simple files and not executable programs, they do not pose any danger to the computer. Depending on the settings selected by the user, the Internet browser automatically accepts cookies. However, this setting can be changed and the storage of cookies can be disabled or set in such a way that the user is notified as soon as a cookie is set. In the event that the use of cookies is deactivated, however, some functions of the website may not be available or may only be available to a limited extent. You can prevent the setting of cookies by our website at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Cookies that are already active can be deleted at any time using an Internet browser or other software programs. Our website does not set its own cookies, but we may work together with advertising partners who help us to make our website more interesting for you. For this purpose, cookies from partner companies are stored on your hard drive when you visit our website (third-party cookies). If we cooperate with aforementioned advertising partners, you will be informed individually and separately about the use of such cookies and the scope of the information collected in each case within the paragraphs below.

The following types of cookies are distinguished:

First-party cookies: first-party cookies are transferred by the platform just visited.

Third-party cookies: Third-party cookies are cookies that are transferred by a provider oter than the platform visited by the user. When a user visits a platform and another entity transmits a cookie through that platform, it is a third-party cookie.

Essential cookies: these cookies are necessary for you to navigate the Platform and use its features, such as accessing secure areas of the Platform. Without them, certain services cannot be provided, such as displaying content customized for your computer or device.

Performance cookies: these cookies collect information about how visitors use the Platform, such as which pages are viewed most frequently and whether they receive error messages from websites. However, these cookies do not collect information about the identity of the visitor. All information that these cookies collect is aggregated and therefore anonymous. They are only used to optimize the platform.

Functionality cookies: these cookies allow the Platform to remember choices you make (for example, language preferences and your region) and provide you with improved, more personalized features. They may also be used to store your preferences regarding text size, font, and other customizable parts of the website. They may also be used to provide services you request such as viewing a video or commenting within a blog. The information that these cookies collect can be anonymized. Your browsing activity cannot be tracked on other platforms.

Social media cookies: these cookies are used when you click a social media sharing button on the platform. The social network records this action and may use it for marketing or advertising purposes.

Marketing/advertising cookies: These cookies are used to show you advertisements that may be relevant to you based on your interests. They are also used to limit the frequency with which you are shown a particular advertisement. We also use cookies to measure how effective an advertising campaign is. They are usually placed with our permission by advertising networks and record your visit to a platform. This information is shared with other organizations such as advertising providers. Often, marketing and advertising cookies are tied to platform features. Our advertising cookies also allow you to participate in customer surveys to provide us with your feedback so that we can improve your user experience with us.

We reserve the right to change this privacy policy at any time with effect for the future.