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Privacy Policy

Privacy Statement

 

  1. Data Protection

With this privacy statement, WeQ Influencers GmbH, Schwedter Str. 263, 10119 Berlin, Germany (“We”) wants to inform you as the data subject (“You”) about the legal basis upon which and in what way, to what extent and for what purpose We process personal data and what rights You have when you as a person to whom online advertising has been addressed to, who provides an e-mail address to have access to certain advertised products or services or who clicks on a link in one of our influencer marketing campaigns.

  1. Contact Information
    In the context of an influencer marketing campaign, we may be the controller within the meaning of the Art 4 (7) GDPR and other national data protection laws of the Member States. Our contact details are:

WeQ Influencers GmbH

Schwedter Str. 263

10119 Berlin

Germany

E-Mail: privacy@weq.com

In other cases, We process your personal data as commissioned data processor (Art. 4 (8) GDPR). In these cases, details of the controller are available here [LINK].

  1. Scope of the processing of personal and other data
    We collect and use your personal data only to the extent necessary for the provision of influencer marketing campaigns.

    Personal data are available data pertaining to You personally such as name, e-mail, address, user behaviour, online identifiers.

    The processing of personal data takes place exclusively on a statutory basis and, insofar as no such laws exist for the specific processing, with your consent as the data subject concerned.

We may also use external service providers to process your data (“(sub-)processors”). These have been carefully selected and commissioned by us, are contractually bound by data processing agreements, are subject to our directives and are regularly checked.

 

  1. a) Scope of the processing of personal data when You visit a social media website of one of our campaign partners

In the case You visit a website of one of our campaign partners, we may collect on behalf a controller the following data:

– The IP address;

– The date and time of your request;

– The access status/HTTP status code;

– The respective quantity of data transferred;

– The website from which the request comes;

– The browser used by You;

– Your operating system;

– The language and version of the browser software;

We collect and use this data exclusively in non-personal form during your informational visit. This is done to display online-advertising on the social media website You have accessed and for campaign tracking purposes. Your IP address will only be evaluated for attacks on the network infrastructure and for statistical purposes, without any conclusions about your person being possible.

The aforementioned data will not be stored together with other personal data of yours.

The legal basis for the above processing is: Article 6 (1) sentence 1 lit. f GDPR. Our legitimate interest is based on the purposes listed above for data collection.

  1. b) Scope of the processing of personal data when providing your e-mail address

In the event You provide your e-mail address to receive access to certain advertised products or services, we collect the following data in order to implement the contract to be concluded with You as the customer:

– Your e-mail address;

– the IP address;

– the date and time of your submission;

The aforementioned data will not be stored together with other personal data of yours.

The legal basis for the above processing is: Article 6(1) sentence 1 lit. f GDPR.
Our legitimate interest is based on your request to receive access to certain services or products of our advertising partners.

  1. c) Analytics services

For the purpose of needs-oriented design and ongoing optimisation of our influencer marketing campaigns, Google Analytics is used, a web analytics service provided by Google, Inc., Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter “Google”).

Google Analytics uses cookies and created pseudonymised usage profiles to enable analysis of Your use of the website. The information generated by the cookie regarding Your use of this website (such as browser type/version, operating system used, referrer URL, host name of the accessing computer and time of the server request) are generally sent to a Google server in the USA and stored there.

Because IP anonymisation (IP masking) is activated for our influencer marketing campaigns, your IP address is first truncated by Google within Member States of the European Union or in other contracting states of the Agreement on the European Economic Area.

On behalf of us as the operator of the website, Google shall use this information to evaluate your use of the website, compile reports on website activities and provide further services relating to website activity and Internet usage for the website operator. The IP address transmitted from your browser within the context of Google shall not be combined with other data by Google. The information may be forwarded to third parties, provided that this is required by law or insofar as such third parties process the information on a contract basis.

Google Analytics cookies are stored on the basis of Art. 6 Par. 1 lit. f GDPR. Our legitimate interest is based on an analysis of Your user behaviour in order to optimise our influencer marketing campaigns.

You can prevent the saving of cookies by selecting the appropriate setting in your browser software; however, we would point out that You may then be unable to fully use all functions of this website. You can also prevent the capture of data generated by the cookie pertaining to Your use of the site (including your abbreviated IP address) by Google and the processing of these data by Google by downloading and installing the available browser deactivation add-on from the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

Further information is available in the Google privacy statement: https://www.google.com/intl/en/policies/privacy/.

In the case of the installation of an mobile app advertised as part of our influencer marketing campaigns, Firebase, a mobile service of Google is used. Firebase uses the Instance ID of your mobile device to identify individual installations of an mobile app. Since each Instance id is unique to a particular app and device, they give Firebase a way to refer to specific app instances. The information generated by the instance ID about your use of this mobile app is generally transmitted to and stored by Google on servers in the United States. Your IP address transmitted by this mobile app in the context of Firebase will not be merged with other data of Google.

Legal basis for the use of Firebase is Art. 6 Par. 1 S. 1 lit. a) or f. GDPR. Our legitimate interest is based on an analysis of Your user behaviour in order to optimise our influencer marketing campaigns and for campaign tracking purposes.

If IP anonymization is activated on the mobile app, your IP address will be anonymised beforehand within the Member States of the European Union or in other states party to the Agreement of the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. IP anonymization is active on all mobile apps within our influencer marketing campaigns. On behalf of us, Google will use this information to evaluate your use of the mobile app, to compile reports on mobile app activity and to provide other services relating to the mobile app. The IP address transmitted by the mobile app in the context of Google Analytics will not be merged with other Google data.

We use the Firebase service Analytics to provide analytics and attribution information in case you use a mobile device with Android operating systems. Firebase Analytics collects Mobile ad IDs, Android mobile device IDs, Instance IDs, Analytics App Instance IDs. Firebase Analytics retains ID-associated data for 60 days and retains aggregate reporting and campaign data without automatic expiration, unless the mobile app provider changes its retention preference in its Analytics settings or deletes its project.

We use the firebase service dynamic links that uses device specs IDs in case you have a mobile device with iOs operating system to facilitate use of newly-installed mobile apps. Dynamic Links only stores devices specs temporarily, to provide the service.

We use the Firebase service Performance Monitoring that uses Instance IDs to monitor the mobile app’s function and to react on specific instances. Performance monitoring retains instance-associated events for 30 days. Firebase retains Instance IDs until we request deletion. After that, the personal data are deleted by firebase within 180 days.

You can prevent Google from collecting the data generated by the Instance ID and relating to your use of the mobile app (including your IP address) and from processing this data by opting-out in this mobile app’s settings.

Further information on the data collected and used by Google Firebase:

https://firebase.google.com/terms/data-processing-terms

https://firebase.google.com/terms/

https://firebase.google.com/support/privacy/manage-iids

https://firebase.google.com/support/privacy/

  1. Data deletion and storage duration

The personal data of the affected person are generally deleted or disabled as soon as the purpose of storage expires.

Furthermore, storage may also occur if so required by European or national law under European Union regulations, laws or other provisions to which the Responsible Body is subject.

Blocking or deletion of data is carried out even if a storage period specified by the standards referred to expires, unless there is a need for further storage of the data in order to conclude or execute a contract.

 

  1. Your general rights

 

You may contact WeQ at any time and request

 

  • information about your personal data stored and processed by WeQ; or
  • correction or deletion of your personal data stored by WeQ.

 

However, WeQ may retain, store and process your personal data as necessary to the extend required by law, to resolve disputes or if necessary for the performance of any agreement between WeQ and You. Please use contract details as indicated in sect. 8 of this privacy policy.

 

  1. Your EU Data Subject rights

As an EU resident, You are granted the following rights against us in respect of the relevant data:

– The right to information;

– The right of correction or deletion;

– The right to the restriction of processing;

– The right to revoke Your consent;

– The right to object to the processing;

– The right to data portability;

You can assert all of these rights by contacting us at privacy@weq.com.

You also have the right to complain to a data protection supervisory authority in regard to the processing of your personal data by us.

The data protection authority responsible for us is the Berlin Commissioner for Data Protection and Freedom of Information, Friedrichstr. 219, 10969 Berlin.

In case We act as a commissioned processor of personal data, the controller can be contacted here [LINK TO DPO OF ADVERTISER|.

 

  1. Contact Details of Protection Officer

The Protection Officer can be contacted as follows:

WeQ Influencers GmbH

– The Data Protection Officer-

Schwedter Str. 263
DE- 10119 Berlin
Germany
Tel.: +49 (30) 2009 54 93 0
E-mail: privacy@weq.com

 

State: 09/03/2019/V. 1.0