PRIVACY AND COOKIE POLICY

PubGrade is committed to the protection of your personal data. We will process your personal data in compliance with applicable data protection provisions. Hereinafter we wish to provide you with an overview on how we ensure protection of your personal data and inform you about the types of personal data we process the respective purpose and scope as well. We also explain your rights as a data subject and how you may contact us.

 

I.          Controller/Contact

 

Controller, according to the applicable data protection law, is

 

PubGrade GmbH

Schloss-Rahe-Str. 15

52072 Aachen

Deutschland

 

Phone: +49 (0)241 9367 2513

Fax: +49 (0)241 9367 2525

Email: info@pubgrade.com

 

Trade Register HRB Aachen 18183

Managing Directors: Philipp Eckerle, Alexander Golubowitsch

 

For any questions related to the processing of your Personal Data by PubGrade or regarding general data protection issues please reach out to us using the contact details above.

 

II.         Your Rights as a data subject

 

Every data subject has the following rights:

·             right of access (Art. 15 GDPR)

·             right to rectification of inaccurate data (Art. 16 GDPR)

·             right to erasure (Art. 17 GDPR)

·             right to restriction of processing of personal data (Art. 18 GDPR)

·             right to data portability (Art. 20 GDPR)

·             right to lodge a complaint with a data protection authority (Art. 77 GDPR).

 

You may object to the processing of personal data for marketing purposes, including the analysis of customer data or the transfer of data to third parties for marketing purposes, at any time without stating reasons.

 

Moreover, every data subject has a general right to object (cf. Art. 21, para. 1 GDPR). In such cases, respective reasons must be stated for the objection to the data processing. To the extent the data processing is carried out on the basis of consent, your consent can be revoked at any time with future effect. The revocation of consent shall not affect the lawfulness of the processing carried out on the basis of the consent until revocation.

 

III.        Processing of personal data by PubGrade

 

We want to give you an overview on how we assure the protection of your personal data when accessing our website and which data we process for which purposes and to what extent.

 

1.         Data processing – Accessing our websites – Log files

 

When accessing our website, information of general nature will be processed. That information (server log files) contains e.g. the type of web browser, used operating system, your Internet Service Provider’s domain name etc. Furthermore, your IP Adress is being transferred and used to offer our website services. Transmission of his information is technically required to render website content you request and it is mandatory to use the internet.

 

According to our IT security concept, log file data will be stored for a duration of 30 days, e.g. to monitor and be able to analyze attacks on our website. The legal basis is Art. 6, para. 1, sentence 1, letter f GDPR.

 

3.         Data processing – Using our websites – Your contact requests

 

If you send us a request by email or our contact form, we will process your data to reply to your request. The period the data is stored and the legal basis depend on the individual purposes.

 

4.         Notes on data security

 

We have implemented technical and operational security measures on our website to protect the personal data stored by us against unauthorised access by third parties, loss or misuse, and to ensure safe data transfers.

 

We have to advise you, however, that owing to the structure of the internet, unwarranted access by third parties may occur whenever you transfer data. It is therefore also your responsibility to protect your data against misuse by using encryption or other appropriate safeguards. Without appropriate security measures, transmitted data might be read by third parties; this applies in particular to unencrypted data, even if sent via email.

 

IV.       Our Cookie directive

 

Our websites use various cookies. Cookies are small text files that are stored on your computer and saved in your browser. We use cookies with the aim to make our offer more user-friendly, more effective, and more secure. We use so-called temporary cookies, which are automatically deleted when you shut down your browser (“session cookies”), as well as persistent (permanent) cookies. Cookies help us to constantly improve our offers.

 

You can decide whether you want to allow the setting of cookies. You can change your settings in the browser settings. Your options are to allow all cookies, to be informed when cookies are set, or to allow no cookies at all. If you opt for the third alternative, you may not be able to use our internet offers to the full extent.

 

When using cookies, a differentiation between required cookies and cookies for other purposes (access statistics, advertising).

 

2.         Cookies that are indispensable for the use of our website   

 

We use session cookies that are indispensable for the use of our website. These include cookies that enable us to recognise you when you visit our site for a single session. These session cookies help to make our site more secure, e.g. by ensuring safe login and sessions within the PubGrade Platform. The legal basis for this data processing is Art. 6 (1) sentence 1 letter f GDPR.

 

3.         Use of cookies with your prior consent

 

Hereinafter, we provide you with an overview of the cookies we use if we have obtained your respective consent upon access to our websites (Art. 6 (1) sentence 1 letter a GDPR). These cookies are used for the purpose of analysing user behaviour and for marketing purposes. Respective opt-out options are included in each description.

 

a.         Use of cookies to analyse usage behaviour (tracking)

 

The use of tracking cookies allows us to “recognise” users when they revisit our website and to allocate usage events to an internal indicator (pseudonymous identifier). Thus, we can capture and analyse the repeated access to our websites.

 

Apart from PubGrade Tracking as described in para. 4, we use the following tracking cookies:

 

Tracking with Google Analytics

This website uses Google Analytics, a web analytics service of Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files that are stored on your computer and facilitate an analysis of your use of our website. The information about your use of this website generated by the cookie is usually transferred to a Google server in the U.S.A. and stored there. Since we have activated IP anonymisation on our website, Google will shorten your IP address within the member states of the European Union and contracting states of the agreement of the European Economic Area. Only in exceptional cases will your full IP address will be transferred to a server of Google in the U.S.A. and shortened there. Google uses this information on our behalf to analyse your use of this website, to compile reports on website activities and to provide additional services related to website and internet use. The IP address transferred by your browser in the context of Google Analytics will not be merged with other data of Google.

You can prevent the storage of cookies by adjusting the settings of your browser accordingly. Please note, however, that in such case you may not be able to use all functions of our website to their full extent. Moreover, you can prevent the collection of data related to your use of the website generated by the cookie (including your IP address) and the processing of such data by Google by downloading and installing the browser plugin available at http://tools.google.com/dlpage/gaoptout?hl=de

We use Google Analytics to analyse and constantly improve the use of our website. The resulting statistics help us to improve our offer and make it more attractive for our users. For exceptional cases where personal data is transferred to the U.S.A., Google has accepted the provisions of the EU-US Privacy Shield: https://www.privacyshield.gov/EU-US-Framework. The legal basis for the storage of the cookie is consent pursuant to Art. 6 (1) sentence 1 letter a GDPR. The further evaluation of the collected data with the help of Google Analytics for a period of up to 38 months is based on Art. 6 (1) sentence 1 letter f GDPR.

For further information please also refer to http://tools.google.com/dlpage/gaoptout?hl=de and https://www.google.de/intl/de/policies/privacy/ (general information on Google Analytics and data protection).

 

b.         Use of cookies for marketing purposes

 

We use cookies for advertising and marketing purposes, e.g. to display our advertisements in accordance with the interests of our users. Moreover, cookies are used for frequency capping (i.e. to limit the frequency of advertisement displays) and ad efficiency evaluation. By tracking which websites and which products were clicked, we can collect information on usage behaviour in order to display interest-based advertising. This information will be shared with third parties. In such cases, the cookies will be placed directly by our marketing partners.

 

We specifically use the following cookies:

 

            Use of Google DoubleClick

 

This website uses the online marketing tools by Google DoubleClick. DoubleClick uses cookies to display relevant advertisements to users, to improve campaign performance reports, or to prevent that a user is shown the same ads more than once. Google uses a cookie ID to track which ads are placed via which browsers and can thus prevent that they are displayed more than once. In addition, DoubleClick may use cookie IDs to detect so-called conversions in relation to ad requests. For example, a user sees a DoubleClick ad and later, using the same browser, visits the advertiser's website to make a purchase. According to Google, DoubleClick cookies do not contain any personal information.

 

By implementing this tool, your browser will automatically establish a connection with a Google server. Please note that in this context data processing outside the European Union/the European Economic Area may occur. Google has accepted the provisions of the EU-US Privacy Shield: https://www.privacyshield.gov/EU-US-Framework. We have no influence on how the data is handled and further used by Google. The legal basis for the processing of your data is Art. 6, para. 1, sentence 1, letter f GDPR.

 

If you do not wish to receive any interest-based advertising, you can deactivate the respective use of cookies by Google at https://www.google.de/settings/ads. For further information on DoubleClick by Google please refer to https://www.google.de/doubleclick and for general information of data privacy at Google go to https://www.google.de/intl/de/policies/privacy. Alternatively, you can visit the website of Network Advertising Initiative (NAI) at www.networkadvertising.org.

 

4.         Processing of data – Accessing Partner Websites

 

a)         Data Collection and Use

 

In cooperation with website publishers and advertisers, PubGrade uses its own and Google Doubleclick technology to perform its services. Any statements regarding www.pubgrade.com in this Privacy Policy, if applicable, also apply to how we handle data collected on our partners’ websites. Purpose of the integration of our technology into partner websites is the management of advertising inventory, delivery of and reporting on advertising campaigns, measurement of campaign efficiency, statistical analysis of audience composition, and creation of pseudonymous usage profiles. The legal basis for the processing of your data is Art. 6, para. 1, sentence 1, letter f GDPR.

 

b)        Von Nutzern auf Partner-Webseiten eingegebene Daten

 

PubGrade does not deliberately collect or store personally-identifiable information from e.g. contact, login or registration forms on partner websites.

 

c)         Opt-out

 

If you disagree with the way PubGrade handles pseudonymous information collected on www.pubgrade.com or partner websites for purposes of behavioural advertising without consent, you can object to such use for the future.

 

You can opt-out of behavioural advertising by Google DoubleClick by visiting youronlinechoices.com (EU) or aboutads.info (USA) and looking for „Google“, “Doubleclick” or „Google Inc.“ respectively. Please refer to the details given in the paragraphs above for additional information and individual Privacy Policies. PubGrade cannot take liability for the functionality of external websites or their fitness to perform a certain task.

 

In addition, you can opt-out of PubGrade’s use of data aggregated through our cookies for the purpose of behavioural targeting. To accomplish that, we will need to store your decision to opt-out within a PubGrade cookie on your device. Your objection will be effective for as long as the corresponding cookie can be found on your device and has not been removed by mechanisms outside of PubGrade’s control.