Thank you for your interest in Webys Traffic. With this privacy policy, we inform you about the nature, scope, and purpose of the personal data we process and your rights as a data subject.
Person Responsible
The responsible party for data processing pursuant to Art.4 No. 7 of the GDPR is Webys Traffic Inc of www.webys-traffic.com (hereinafter also referred to as “we” or “us”) unless otherwise stated in this privacy policy.
We also design Internet pages from our website as Accelerated Mobile Pages (AMP). If you call up one of these Internet pages, e.g. after a Google search with your smartphone, this AMP may not be delivered from our servers, but directly from the cache of third-party providers such as Google. In these cases, our domain name (our internet address) does not appear in the address bar of your browser at the second level domain level, but e.g. the domain name of Google or “ampproject.org”. In the case of such calls from the cache of Google or other third-party providers, we have no influence on the data processing by them. In accordance with Art. 4 No. 7 of the GDPR, the third-party provider is solely responsible for data processing in these cases. We make sure that we do not collect any personal data via our AMP and have therefore deactivated all contact forms in the AMP version.
Service pages of partners are integrated into our website (“partner service page”). You can recognize these by the corresponding marking (e.g. “A service from”). The partner service page is provided by the partner indicated there. The partner is responsible for the content of the partner service and the data processing operations that take place there in accordance with Art. 4 No. 7 GDPR – with the exception of the header and footer of the website. Information on the partner can be found in the partner’s imprint linked to the partner service. For information on the data processing operations that take place via the partner service page and your rights as a data subject, please refer to the partner’s privacy policy, which is also linked there.
Calling up the website
When you use our offer, various data are automatically collected and processed by us to enable the usability of the functions provided and to ensure the security and stability of our offer, such as:
- Information about the accessing end device and the software used.
- Date and time of access
- Cookies (special category technically necessary)
- Websites from which the user accesses our website or which the user accesses via our website
- IP address
The at least temporary storage of the IP address is technically necessary to enable the delivery of our offer to your end device. The legal basis for data processing is Art. 6 para. 1 lit. b GDPR.
In addition, we process your unabbreviated IP address or your pseudonymous ID during the use of our offer for the purpose of and in our interest to measure the efficiency and performance of our offer. Usage profiles are not created in the process. Your IP address or pseudonymous ID is automatically anonymized immediately after the respective session is closed. The legal basis for data processing is Art. 6 para. 1 lit. f GDPR.
Mailings and newsletters
We also use your e-mail address collected in the course of registration or in the course of contract performance to inform you by e-mail about our own similar goods or services as well as about existing subscriptions or generally about our online services, provided that we pointed this out to you when collecting the e-mail address and you did not object to this. In this case, the e-mail address is processed on the basis of our legitimate interest in advertising our goods and services (Art. 6 para. 1 lit. f GDPR, ). You have the option to object to the sending of this information about further product offers at any time, e.g. by clicking on the unsubscribe link provided for this purpose in each of these emails.
If you have ordered one of our mailings or newsletters, we will use your e-mail address to send you the newsletter you have ordered. In these cases, the legal basis for the data processing is Art. 6 Para. 1 lit. b GDPR or Art. 6 Para. 1 lit. a GDPR. You have the option at any time to revoke your consent with effect for the future or to unsubscribe from the ordered newsletter, e.g. by clicking on the unsubscribe link provided for this purpose in each newsletter.
Personalized product and media offers by e-mail or push messages
If you have given your consent to receive newsletters by e-mail and/or push messages with product offers and/or media offers based on your personal use of Webys Traffic, we will combine your pseudonymous usage profile (usage data) with your randomly generated identification number (user ID) and your e-mail address. The usage data collected includes the following information:
- Frequency and duration of use
- Article and image views
- Region of use
- Actions (e.g. sharing content, comments)
The data is aggregated for the purpose of sending you interesting advertising by e-mail according to your interests based on your usage behavior in accordance with your consent.
E-mail tracking
If you have subscribed to one of our mailings or newsletters or personalized product and media offers by e-mail, so-called tracking pixels are integrated into the e-mails for the purpose and in our interest of being able to optimize our newsletter. This provides us with information about which browser and operating system are being used, which IP address is currently being accessed, and at the same time, who the access provider is. Furthermore, it is recognized whether the e-mail has been read and whether the link integrated into the e-mail has subsequently been clicked on and the respective website visited via this IP address. In addition, the number of accesses to the website is counted and the corresponding time of day is recorded when the e-mail was retrieved and the access was made. The approximate location of the user is also transmitted. The legal basis for the data processing is Art. 6 para. 1 lit. a GDPR. If you do not wish this, you can unsubscribe from the newsletter at any time as described above and thus revoke your consent.
Geo-localisation
Based on the shortened IP address, we can display content with a regional reference on all our websites that are accessed from a specific region. This so-called geo-localization, i.e. the allocation of a website call to the location of the call, is carried out exclusively on the basis of the anonymized IP address and only up to the geographical level of the federal states/regions. No conclusions can be drawn about the specific location of a user from the geographical information obtained in this way.
Your contact
When you contact us via one of our contact forms or by e-mail, the data you provide (your e-mail address, name, and telephone number, if applicable) will be processed by us in order to deal with your inquiry. We delete the data accruing in this context when it is no longer required for the aforementioned purpose, provided that there are no legal retention obligations that prevent deletion. The legal basis for data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. If you provide us with the personal data of another person, you must obtain that person’s express prior consent to do so and inform them of how we process personal data in accordance with our privacy policy.
Occasionally, we also provide contact forms of providers for the purpose and in the interest of enabling you to directly contact the provider identified in the respective contact form. The personal data you enter in the contact form is forwarded directly to the provider via an interface. We do not have access to the data, and the data is not (temporarily) stored. For information on data processing, please refer to the provider’s privacy policy linked in the respective contact form. The legal basis for the data transfer is Art. 6 para. 1 lit. b or Art. 6 para. 1 lit. f GDPR.
Direct marketing
The legal basis for the processing of your personal data in the context of direct marketing measures is either your consent or our legitimate interest in marketing and promoting our services. The purpose of processing your personal data in the context of direct marketing measures is to send information, offers, and, if applicable, to promote sales through the sale of services. Your personal data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected; this is the case in particular upon receipt of the revocation or objection.
You can revoke your consent at any time for the future or object to the processing of your personal data in the context of direct marketing measures at any time for the future.
When you send a data subject access request
The legal basis for the processing of your personal data in the context of handling your data subject access request is our legal obligation and the legal basis for the subsequent documentation of t data subject access request is both our legitimate interest and our legal obligation.
The purpose of processing your personal data in the context of processing data when you send a data subject access request is to respond to your request. The subsequent documentation of the data subject access request serves to fulfill the legally required accountability.
Your personal data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. In the case of the processing of a data subject access request, this is three years after the end of the respective process.
You have the possibility at any time to object to the processing of your personal data in the context of the processing of a data subject access request for the future. In this case, however, we will not be able to further process your request. The documentation of the legally compliant processing of the respective data subject access request is mandatory. Consequently, there is no possibility for you to object.
Legal defense and enforcement of our rights
The legal basis for the processing of your personal data in the context of legal defense and enforcement of our rights is our legitimate interest.
The purpose of processing your personal data in the context of legal defense and enforcement of our rights is the defense against unjustified claims and the legal enforcement and assertion of claims and rights. Your personal data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected.
The processing of your personal data in the context of legal defense and enforcement is mandatory for legal defense and enforcement of our rights. Consequently, there is no possibility for you to object.
Place of processing
We also process personal data in countries outside the European Economic Area (“EEA”), including the USA. In order to ensure an adequate level of data protection, we use the standard contractual clauses of the EU Commission in accordance with Article 46 (2) c of the GDPR when structuring the contractual relationships with the services used in third countries, unless an adequacy decision of the European Commission exists for the respective third country:
- Standard contractual clauses with processors
- Standard contractual clauses with data controllers
Storage period
We process personal data only as long as necessary for the purpose stated in this privacy policy. The personal data will then be deleted, provided that no legal retention periods prevent data deletion.
Third-party providers
The third-party providers whose services or content we integrate help us to improve and finance our website. You will find an overview of all possible third-party providers at the appropriate place in the privacy policy. There you also have the option of rejecting the transfer of data to all or individual third-party providers as such (i.e. irrespective of the purpose) or to give or revoke your consent for this. The term “third-party provider” is not to be understood in the sense of Art. 4 No. 10 GDPR (third party). Rather, the third-party providers listed in the privacy policy also include our processors within the meaning of Article 28 of the GDPR, who are not named in this privacy policy, as we remain responsible for the data processing in these cases in accordance with Article 4 No. 7 of the GDPR. Furthermore, the third-party providers listed in the privacy also include the third parties and processors (subcontractors) used by our contractual partners and marketers. For the foregoing reasons, there are regularly more third-party providers listed by name in the Privacy Policy than in this Privacy Policy.
Advertisements
For the purpose and in the interest of optimizing the selection and display of the advertisements played to refinance our offer, to control the frequency and sequence of the display of the advertisements, and to prevent an advertisement from being displayed in an unsuitable editorial environment (brand-unsafe), we or the relevant third-party provider’s process real-time information about the advertisements. the relevant third-party provider’s process real-time information about the context in which the ad is displayed, including information about the content environment as well as the device used, such as device type and functions, browser identifier, URL, IP address, and the approximate location data of a user. The legal basis for data processing is regularly Art. 6 para. 1 lit. f GDPR. You have the option at any time to reject the selection of simple ads in the privacy settings and thus object to data processing for this purpose.
At this point, moreover, once again for clarification: even if the legal basis for the processing of personal data, in this case, is not your consent (Art. 6 para. 1 lit. a GDPR), but our aforementioned legitimate interest (Art. 6 para. 1 lit. F GDPR), data processing will cease if the service in question uses cookies or comparable technologies and you have not given your consent to the retrieval and/or storage of information in the terminal device. Then no cookies are set by or for the service and the service is not loaded.
For the aforementioned purposes, we also use the services of third parties listed below, who are responsible for the data processing taking place via their respective service in accordance with Art. 4 No. 7 GDPR.
Individual third-party providers also base the data processing for the aforementioned purposes on the legal basis of consent (Art. 6 para. 1 lit. a GDPR). In these cases, no processing of personal data by these third-party providers takes place without your prior consent in the private sphere, even if you should have given your consent to the storage and/or retrieval of information in the terminal device. You can find out which third-party providers are involved in each individual case in the privacy policy at the appropriate place.
In order to display the ads on our website or in our app in the correct size and in a format supported by your device and to be able to forward you to the corresponding target page when you click on the ad, your IP address and information about your device are also stored by the respective third-party provider.
IP address and information about your device type. This is the special category of “technically providing ads or content”.
Use market research to gain insights about target groups
Subject to your consent, we use services for the purpose of gaining insights about audiences for advertising and content. This involves generating aggregated reports for advertisers or their representatives about the audiences reached by their ads based on survey panels or similar methods. Aggregated reports will also be produced for service providers on the audiences reached or interacted with by the content and/or ads on their services, obtained through survey panels or similar methods. The reports do not allow any conclusions to be drawn about a specific or identifiable person. However, information about your usage behavior is processed in order to create these reports. In addition, for the purposes of market research, offline data is assigned to an online user in order to gain insights into target groups, insofar as providers have declared that they will match and merge offline data sources. The legal basis for data processing is Art. 6 para. 1 lit. a GDPR. You have the option at any time to revoke any consent you have given in the privacy settings. We also use the services of third parties listed below, who are responsible for the data processing taking place via the service in accordance with Art. 4 No. 7 GDPR.
Subject to your consent, we also use services for the purpose of developing and improving products, e.g. by adding new functions. For this purpose, information about your usage behavior is processed. The legal basis for the data processing is Art. 6 para. 1 lit. a GDPR. You have the option at any time to revoke any consent you have given in the privacy settings. We also use the services of third parties listed below, who are responsible for the data processing taking place via the service in accordance with Art. 4 No. 7 GDPR.
Ensuring security, preventing fraud, and fixing bugs
For the purposes of ensuring security, preventing fraud, and correcting errors, the third-party providers listed in the privacy under the relevant special category process information that you use to ensure that data is transferred securely, to detect and prevent harmful, fraudulent, invalid, or illegal activities, and to ensure the correct and efficient operation of systems and processes – including monitoring and improving the performance of systems and processes – within the scope of the permitted processing purposes. This is necessary to ensure the security of the respective data processing, prevent fraud, and be able to correct errors. The information processed for this purpose may include automatically sent device properties for identification, precise geolocation data, and data obtained by reading device properties for identification without separate disclosure and/or opt-in. This assumes, of course, as far as processing for the purposes of ensuring security, preventing fraud, and fixing bugs by third-party providers for their own purposes, that you have given your consent to the respective third-party provider to process personal data for a specific purpose in the first place or have not objected to the data processing.
Affiliate marketing
If you have accessed our website via an advertising banner from an external website, we receive information from the operator of the external website (“affiliate”) that a user has accessed our offer via the external site. This is the product ID assigned to the advertised offer as well as the identification number of the affiliate (affiliate ID) and a user ID created from any number sequence. This information is stored by us in a cookie on your terminal device subject to your consent to the storage and/or retrieval of information in the terminal device in the private sphere. Should you order the offer on our website within 30 days, this information will be transmitted to the affiliate automatically and in encrypted form upon completion of the order process. The cookie is automatically deleted upon completion of the order process, but at the latest after 30 days. This data is processed for the purpose and in the interest of settling commission payments between us and the affiliate. The legal basis is Art. 6 para. 1 lit. f GDPR. The affiliate can only recognize from the information that a user has reached our website from the external website via the advertising banner and has ordered the advertised product there. The same applies the other way round if you are directed to the advertiser’s website from an advertising banner of a third party (“advertiser”) placed on our website.
We also use the services of so-called affiliate networks. Affiliate networks act as an interface between advertisers and publishers. Insofar as you have given your consent in the privacy to the affiliate network to process personal data for the purposes listed in the privacy, the affiliate network processes information about the advertiser’s campaign, the affiliate, the user action (e.g. click or “view” and in which country it took place) as well as the device used for the purpose of processing commission payments between the advertiser and the affiliate when the advertising material is clicked.
Partner offers
In the interest and for the purpose of showing you interesting offers from selected partners, offers from partners are integrated into our website (“Partner Offers”). You can recognize these by the corresponding marking (e.g. “An offer from”). The partner offers are provided by the partner indicated there. In order to play the partner offers, it is necessary for your browser to establish a direct connection to the partner’s servers. This requires the processing of your IP address. The legal basis for the data processing is Art. 6 para. 1 lit. f GDPR. The partner is responsible for the data processing operations taking place via the partner offer in accordance with Art. 4 No. 7 GDPR. For information on the data processing operations taking place via the partner offers and your rights as a data subject, please refer to the privacy policy of the partner linked in the respective partner offer.
Displaying third-party content (social networks, videos)
For the purpose of enhancing the user experience in our offer, we also embed services of the providers listed below, who are each responsible for data processing pursuant to Art. 4 No. 7 GDPR. Subject to your privacy consent, your browser establishes a direct connection to the server of the respective provider. In doing so, the provider always processes your IP address, which is required to establish the connection to the provider’s server and to play out the content. The legal basis for the integration of these services is Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future in your privacy settings. If you have not given consent to “Show third-party content (social networks, videos)” in your privacy settings or have revoked consent you have given, you will see a placeholder instead of the third-party content with a note and the option to give your consent and have the third-party content displayed by clicking on the placeholder. If you make use of this option, your consent will be stored in your privacy. You have the possibility to revoke your consent in the privacy at any time.
Your rights
Please contact us at any time with questions and suggestions regarding data protection and to enforce your rights as a data subject using our Contact Form
Insofar as data processing is carried out with a joint controller pursuant to Art. 26 GDPR, both controllers act as a joint contact point.
With regard to the data processing described in more detail below, users and data subjects have the right to
- to confirmation as to whether data relating to them is being processed,
- to information about the data processed, to further information about the data processing and to copies of the data;
- to correction or completion of incorrect or incomplete data;
- to immediate erasure of the data concerning them;
- to receive the data concerning them and provided by them and to transfer this data to other providers/controllers;
- to lodge a complaint with the supervisory authority if they are of the opinion that the data concerning them is being processed by the provider in breach of data protection provisions.
In addition, the provider is obliged to inform all recipients to whom data has been disclosed by the provider of any correction or deletion of data or restriction of processing that takes place. However, this obligation does not apply if such notification is impossible or involves a disproportionate effort. Notwithstanding this, the user has a right to information about these recipients.
Likewise, users and data subjects have the right to object to the future processing of data concerning them, insofar as the data is processed by the provider. In particular, an objection to data processing for the purpose of direct advertising is permissible.
The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal personal information about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it. We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your personal information.
We encourage you to get in touch if you have any concerns with how we collect or use your personal information.
Information, correction, deletion, restriction, and the right to be forgotten
You can obtain information from us at any time and free of charge about whether personal data relating to you is being processed by us and also specifically what data is being stored about you, as well as request a copy of the stored data. You can also have incorrect data corrected and completed.
You can also request the deletion and restriction of your personal data. Please note that there are legal obligations to retain data, e.g. for contracts against payment such as the purchase of a subscription to Webys Traffic and that we are therefore not always allowed to delete your data completely. In this case, your data will be marked with the aim of limiting its future processing.
Data portability
Where applicable, you also have the right to have personal data relating to you transferred to you or another controller in a structured, commonly used and machine-readable format, provided that the processing is based on consent or a contract and is carried out using automated means. However, this does not apply if the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. You also have the right to obtain the direct transfer of personal data from one controller to another controller, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.
Revocation / objection
You can revoke the consent you have given at any time with effect for the future at the above contact address. In particular, you can object to the use of your e-mail address for the purpose of sending newsletters at any time in writing or in text form to us with effect for the future, without incurring any costs other than the transmission costs according to the basic rates. Furthermore, you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of a legitimate or public interest. This also applies to profiling based on these provisions. We shall no longer process the personal data in the event of the objection unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the assertion, exercise or defense of legal claims.
If we process personal data for the purposes of direct marketing, you have the right to object at any time to the processing of personal data for such marketing by using the contact address specified above. This also applies to profiling, insofar as it is connected with such direct advertising. In addition, you have the right to object, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out by us for scientific or historical research purposes or for statistical purposes, unless such processing is necessary for the performance of a task carried out in the public interest.
Right of complaint
Furthermore, you have the right to lodge a complaint with the competent supervisory authority as well as the possibility to seek legal remedy. The supervisory authority to which the complaint has been submitted will inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy.
The legal bases for processing
The legal bases for processing are listed below and at least one of these must apply whenever we process personal data:
- Consent: the individual has given clear consent to process personal data for a specific purpose.
- Contract: the processing is necessary for a contract or because you have asked us to take specific steps before entering into a contract.
- Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).
- Vital interests: the processing is necessary to protect someone’s life.
- Public task: the processing is necessary for us to perform a task in the public interest or for official functions, and the task or function has a clear basis in law.
- Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.
Existence of automated decision making
We do not use automated decision-making or profiling within the meaning of Art. 22 GDPR.
SSL encryption
To protect the security of your data during transmission, we use state-of-the-art encryption procedures (e.g. SSL) via HTTPS.
Social Media
The data you enter on our social media pages, such as comments, videos, pictures, likes, public messages, etc. are published by the social media platform and are not used or processed by us for any other purpose at any time. We only reserve the right to delete content if this should be necessary. Where applicable, we share your content on our site if this is a function of the social media platform and communicate with you via the social media platform. The legal basis is our legitimate interest. The data processing is carried out in the interest of our public relations and communication.
If you wish to object to certain data processing over which we have an influence, please contact us. We will then examine your objection. If you send us a request on the social media platform, we may also refer you to other secure communication channels that guarantee confidentiality, depending on the response required. You always have the option of sending us confidential inquiries to our address stated in the imprint.
As already stated, where the social media platform provider gives us the opportunity, we take care to design our social media pages to be as data protection compliant as possible. With regard to statistics that the provider of the social media platform makes available to us, we can only influence these to a limited extent and cannot switch them off. However, we make sure that no additional optional statistics are made available to us.
Data processing by the operator of the social media platform
The operator of the social media platform uses web tracking methods. Web tracking can also take place regardless of whether you are logged in or registered with the social media platform. As already explained, we can unfortunately hardly influence the web tracking methods of the social media platform. We cannot, for example, switch this off.
Please be aware: It cannot be ruled out that the provider of the social media platform uses your profile and behavioral data, for example, to evaluate your habits, personal relationships, preferences, etc. We have no influence on this. In this respect, we have no influence on the processing of your data by the provider of the social media platform.
Content Delivery Network
Our website uses a so-called Content Delivery Network (CDN). A CDN is a network of powerful servers that cache content at various locations around the world. A CDN has two main tasks: to deliver content in the shortest possible time and to reduce the load on the web host by distributing traffic. CDNs transmit two types of content: Static and dynamic content. Static content is delivered to all website visitors in the same form, such as video content from streaming services or code frameworks (e.g. Javascript, jQuery). Dynamic content is first adapted to the user and only created at the moment of the request. This includes content that takes place via web applications, email, or online shops and is personalized. In order to use the latter, information about the website visitor must first be transmitted to the CDN. The legal basis for the use of a CDN and the transmission of your data to it is our legitimate interest. The legitimate interest results from our need for a technically flawless and fast presentation of our website and the relief of our IT infrastructure. You can object to the processing of your data on the basis of our legitimate interest at any time. To do so, please use the contact details provided.
Changes to our privacy policy
We reserve the right to adapt this privacy policy so that it always complies with the current legal requirements or in order to implement changes to our services in the privacy policy, e.g. when introducing new services. The new privacy policy will then apply to your next visit.
Questions
If you have any questions about data protection, please write us an e-mail or contact us using the details provided on the website.