Due to the purpose of its enterprise, ad pepper media International N.V. and its subsidiaries (collectively and singularly referred to as “ad pepper media”) are concerned with the ascertainment, processing and use of personal data.
Personal data are data on the personal or material circumstances of an identified or identifiable individual natural person (“User”), such as his true name, address, age, e-mail address, telephone number or information on specific preferences, likes etc. On the other hand, information that cannot be associated with User’s genuine identity are not considered personal data: this includes, for example, the number of users of our website or comparable, summarized information. Personal data are protected by the data protection directive of the EU and, regarding each ad pepper media subsidiary, by the national regulations of the countries where such subsidiary is located (for example in the United States of America CAN-SPAM Act of 2003).
ad pepper media observe these regulations and thus respects the individual‘s right of personality and his/her right to protection of privacy. ad pepper media wants to justify the confidence the users have in its online services and makes the ascertainment, processing and use of personal data transparent for its Users by giving them the following information.
1. Whilst visiting our website(s) You can visit our website without providing personal information.
As a standard procedure, our web servers temporarily record the connection data of the enquiring computer, which of our websites you visit, the date and duration of the visit, the identification data of the browser and operating system used as well as the website from which you reach us. We may use tracking software to determine the frequency of use and the number of users of our website. This software is not used to collect personal data or IP addresses. The data is used exclusively in anonymous and summarized form for statistical purposes and for the development of the website. No other personal data – such as your name, your address, your telephone number or e-mail address – is collected, unless you provide this information voluntarily, e.g. within the scope of a survey or for the performance of an information enquiry. We also collect further personal data if you conclude a contract with us and register via our website in this respect or in connection with any such contract. The personal data collected in this context can be seen from the registration form that we provide via our website.
2. Whilst interacting with an advertising managed by us.
In mere advertising contacts with the User (e. g. the flashing of marquees on a website) ad pepper media does not automatically collect or process any personal data. Only non-personal data – such as information on the server via which the User has logged on to the Internet, the browser which is used and if the User clicks on the marquee – all this is recorded anonymously. ad pepper media collects and processes personal data through various means of advertising (pop-ups, pop-unders, banners). The extent and the kind of data depend on the information which the User enters on a voluntary basis by filling in the respective input fields and transmits to ad pepper media by sending off this information. ad pepper media will process and use the personal data on the User which they have collected to fulfill their obligations towards the User, to such an extent which is necessary for this purpose.
If, in collecting, processing and using the Users’ personal data, ad pepper media pursue any purposes beyond the implementation of the above obligations, this will only be done on the basis of an approval expressly declared by the User, and only to the extent specified in this approval. Such purposes are mainly marketing-oriented and include, among other things, the use of the collected data for market research, the soliciting of customers, sending commercial emails, product information or service development.
In this process, ad pepper media deploys various techniques to make reasonably sure that the User and not somebody else enter the Users’ data and grant ad pepper media the permission to use them.The User can withdraw his/her consent or part of it at any time, using the same means by which he/she has given this consent.
ad pepper media also collect, process and use personal data on behalf of business partners (e. g. website carriers, advertising customers, agencies), for example for the purpose of generating addresses for a newsletter subscription, product information, orders etc. If any data are collected by ad pepper media on behalf of any third party, the cooperation partner will be clearly identifiable at any time and is the owner of the collected personal data. In this case, the User can enforce his/her rights exclusively against the cooperation partner of ad pepper media, as ad pepper media will act as a simple technical supplier. If ad pepper media collect any personal data on behalf of any business partners and process and use these data, the business partner shall be responsible for the observance of data protection regulations. In this case, ad pepper media shall not assume any liability towards the User for the observance of data protection provisions on part of their business partners. No rights or obligations for ad pepper media shall result from any contracts or quasi-contractual relationships into which the User might enter with a business partner. ad pepper media cannot exercise any influence on such contracts, neither directly nor indirectly. In this case, ad pepper media are bound by the instructions of their business partner, however ad pepper media does not cooperate with such business partners who ad pepper knows be breaching of data protection regulations.
ad pepper media are bound by law to take the technical and organizational measures which are necessary to guarantee the protection of the personal data, i. e. in particular to protect these data from unauthorized access and unauthorized processing. All data processing programs and facilities have password protection and operate using encoding technology which is present state of the art.
If ad pepper media use any external server or service provider for the storage of the User data, ad pepper media will make sure that they are committed to at least the same data protection standard as ad pepper media themselves. The employees of ad pepper media are obligated to preserve data secrecy and data protection. This obligation includes, among other things, the fact that the employees may only process and use the personal data to such an extent which is necessary within the scope of contractual or quasi-contractual relationships, or in so far as the User has given his consent to the use of his/her data for the respective purposes. Any personal data which are no longer needed for the fulfillment of contractual obligations by ad pepper media and/or for the processing and use of which there is no (more) consent from User, will be deleted in such a way that any abuse can be ruled out. In certain cases prescribed by law (e.g. statutory periods of keeping), Users’ data can be blocked instead of being deleted.