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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)
Data entered by Users on Partner Websites
PubGrade does not deliberately collect or
store
personally-identifiable information from e.g. contact, login or
registration
forms on partner websites.
c)
Opt-out
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.
PubGrade reserves the right to publish updates to this Privacy Policy. The most recent version of this Policy can be reviewed online at www.pubgrade.com/about/privacy/.
Last Policy Update: 2018-05-25