Data Protection Data Protection Guidelines and Privacy Statement
Table of Contents
- Protection of your personal data
- Data collection
- Data usage and data transfer
- Consent and revocation
- Customer accounts
- Establishment of contact
- Push Notifications
- WebAnalytics/ Google Analytics/ Google Remarketing/ Ads/Doubleclick by Google
- Google reCAPTCHA
- GoogleTag Manager
- Bing Ads
- Social Media Plugins
- Retargeting via AdRoll
- Conversion measurement with Facebook Pixel’s visitor tracking
- Your rights, information
- DATA PROTECTION OFFICER
1. Protection of your personal data
We appreciate your interest in our website and our offers. The protection of your personal data is very important to us when you visit our website and is our primary concern. We take this protection very seriously, especially with regard to the collection, transmission, processing and use of your personal data when you visit our website.
We reserve the right to adapt or change this privacy statement. The most current version always applies. As such, we recommend that you check this statement regularly.
2. Data collection
We collect data about visits to our pages and about initiating, concluding, processing and cancelling a contract.
Your visit to our website will be logged. The main details recorded are the IP address, date and time currently used by your PC, the browser type and operating system used on your PC as well as the pages viewed by you. It is not normally intended or possible for data to be related to any specific person.
3. Data usage and data transfer
The personal data we collect, and which you give us e.g. when placing an order or via e-mail (for example, your name and address or e-mail address), will be processed only for correspondence with you and only for the purpose for which you provided us with the data. We only pass on your data to third parties where this is absolutely necessary to fulfil our contractual obligations.
When processing payments, we pass on your payment information to the bank responsible for the payment.
We forward your IP address to a third party provider for verification. This is to ensure that neither a proxy nor a VPN server is operated from the IP address you are accessing from.
The processing is lawful and necessary. It complies with the guidelines of the DSGVO Art. 6 para. 1 b) “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”.
We assure you we do not pass on your personal data to third parties, unless we are legally obliged to do so or if you have given us your prior consent. As far as we use service providers for the handling and implementation of data processing, the contractual relationships are governed by the provisions of the General Data Protection Regulation (DSGVO) and the Federal Data Protection Act (BDSG).
The commercial sale of your personal data expressly does not take place.
4. Consent and revocation
If you have provided us with personal data, you can ask us to delete this data at any time. We will delete your personal data, unless legal storage periods prevent us from doing so.
If you have consented to the processing of your personal data for specific purposes, e.g. for a newsletter, etc., you can revoke this consent at any time with future effect. We will then stop using your personal information. A withdrawal is possible via the link provided for this purpose in one of our e-mails or by sending an e-mail to the address provided by us in the data protection guidelines.
Duration of storage: Personal data which has been provided to us through our website will only be stored until the purpose for which it was entrusted to us is fulfilled. As far as commercial and tax retention periods must be observed, the storage period for certain data may be up to 10 years.
5. Customer accounts
Customer account: When you open a customer account, you agree that your data such as name, address, email address, phone number and bank details, as well as your user data (user name, password) and IP address, will be stored.
Customer Accounts for Authors (Copywriters)
If you register on our website as an author, we process personal data that you provide us with for the purpose of opening your customer account and creating your author profile, for documentation purposes and for processing and following up your requests on the basis of Art. 6 para. 1 a) or b) GDPR.
You can revoke your consent to receive information on Textbroker, industry updates and exclusive promotions by e-mail at any time. You will find a link in each of our e-mails through which you can revoke your consent or by e-mail to the address we have indicated in the data protection guidelines.
Customer Accounts for Clients
Sario Marketing GmbH is a commercial enterprise and uses personal data of clients in a commercial and industrial context, as far as legally allowed or agreed with the client. If you create a customer account as a client, we assume that the data you provide us with is also commercial. We use the data you provide us with to create your account, as well as to document, process and follow up your requests on the basis of Art. 6 para. 1 a) GDPR. We also use your data for internal documentation and evaluations in order to constantly improve our service. The legal basis for this type of processing is Art. 6, para. 1 f) GDPR.
6. Establishment of contact
Establishment of contact for authors
If you contact us by e-mail, telephone, post or by using other means of communication or personal contact (e.g. at trade fairs, events), we process personal data ( form of address, title, name, contact details) which you provide us with for the purpose of processing, documenting and following up your enquiry on the basis of Art. 6 Para. 1 b) GDPR or Art. 6 Para. 1 f) GDPR, as well as within the framework of the existing business relationship.
Establishment of contact for clients
If you contact us by e-mail, telephone, post or by using other communication channels or personal contact (e.g. at trade fairs, events), we process personal data ( form of address, title, name, company, company address, company contact data) which you provide us with for the purpose of processing, documenting and following up your enquiry on the basis of Art. 6 Para. 1 b) GDPR or Art. 6 Para. 1 f) GDPR. We assume that all data which you provide us with in this way is company organisation information or personal data in connection with the existing business relationship.
We reserve the right to use your data for sending information on Textbroker, industry updates, offers, as well as for surveys for quality assurance purposes. The legal basis for this is a legitimate interest on our part, Art. 6 para. 1 f) GDPR. If you do not wish to receive any information from us, you can inform us of this via the withdrawal link in one of our e-mails or by sending an e-mail to the address provided by us in the data protection guidelines.
By registering for the newsletter, your first name, last name and e-mail address will be used with your consent for our own advertising purposes. Registration for the newsletter is performed via the double opt-in procedure to ensure the documentation of your consent to receive the newsletter.
The newsletter is sent by a service provider.
The e-mail addresses of our newsletter recipients, as well as their further data described in the context of these notes concerning the newsletter, are stored on the service provider’s servers in Germany. The service provider uses this information for sending and evaluating the newsletter on our behalf. Consent to receive a newsletter by e-mail can be revoked at any time. In each newsletter you will find a link with which you can revoke your consent.
Statistical surveys and analyses
The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from the service provider’s server when the newsletter is opened. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval are initially collected. This information is used to technically improve the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined using the IP address) or access times.
The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our nor the service provider’s endeavour to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.
8. Push notifications
You can opt in to receive our push notifications. To send our push notifications, we use the delivery service “CleverPush”, which is provided by CleverPush UG (haftungsbeschränkt), Tondernstr. 1, 22049 Hamburg (“CleverPush”).
You will receive regular information about exciting online marketing topics – especially in the areas of content marketing, SEO, analytics, social media and better web texts – as well as about tips, tricks and exciting developments at Textbroker. Furthermore, you will receive exclusive discounts (e.g. voucher or BonusBack campaigns on text orders) and offers by Textbroker and their partners (such as information regarding events, products or services).
To opt in, you must confirm your browser’s request to receive notifications. This process is documented and stored by CleverPush. This includes saving the opt in time and your browser ID or device ID. The collection of this data is required so that we can understand the processes in case of misuse and therefore serves our legal protection.
To show you the push notifications, CleverPush collects and processes your browser ID on our behalf and your device ID in the case of mobile access.
By subscribing to our push notifications, you agree to their receipt. Legal basis for the processing of your data after registration for our push notifications is in the presence of your consent Art. 6 para. 1 lit. a GDPR. CleverPush also statistically evaluates our push notifications. CleverPush can detect if and when our push notifications were displayed and clicked by you.
Your consent to the storage and use of your personal information to receive our push notifications and the statistical survey described above may be revoked at any time with future effect. To revoke consent, you can change the setting to receive push notifications in your browser. If you use our push notifications on a desktop PC with the operating system “Windows”, you can also unsubscribe our push notifications by right-clicking on the respective push notification in the settings that appear there.
Your data will be deleted as soon as they are no longer necessary to achieve the purpose of their survey. Your data will be stored as long as the subscription to our push notifications is active.
Under the following link, the process of unsubscribing will be explained in detail: https://cleverpush.com/faq.
Cookies are small text files which make it possible to store specific user-related information on the user’s device while using the website.
We use two types of “Cookies”. Cookies are small files which typically consist of a sequence of text and numbers used to give you a unique ID. A “client cookie” is sent to your browser so our system remembers your searches and tracks the pages you visit on our site, as well as the services you use. A “server cookie” is installed on our system to recognise when you return to access this site again. This information enables us to better manage the website and customise our services to make them more user-friendly. We only evaluate the data collected in an anonymised form.
You can configure your browser so that you are notified of the receipt of a cookie or so that cookies cannot be received; in which case, you may be limiting the scope of the services you may expect when you visit our site.
|Third Party Cookie/Pixel||Details|
|Google Tag Manager||Conversion Linker Tag for Google Ads|
|Unbounce Conversion Pixel||Only on Thank You Pages to record successful registration|
|IBM Watson Campaign (Silverpop)||Monitoring all e-mail activity of individual contacts
Data Processing Addendum:
|Without enhanced comparison for author accounts (we do not upload any personal information to LinkedIn).
With extended comparison for customer data.
|AdRoll||Without enhanced comparison (we do not upload any personal customer information to AdRoll)|
|Outbrain||Only on Thank You Pages to record successful registration|
|YouTube||YouTube Videos are loaded into iframes|
|First Party Cookie/Pixel||Details|
|Google Analytics incl. Data Collection for Advertising Features (Remarketing and Advertising Reporting Features)||No use of User ID
Includes Ads, Search Console and Tag Manager Linking
With IP address anonymisation
|Google Ads Conversion Tracking||Only on Thank You Pages to record successful registrations or monies paid into account (incl. amount)|
|Google Ads||(Audiences, Doubleclick, Dynamic Remarketing, Remarketing User Lists)
Without extended comparison for author accounts (we do not upload any personal data to the services mentioned above).
With extended comparison for customer data.
|Facebook Pixel inkl. Facebook Custom Audiences||Without enhanced comparison of Custom Audiences from File for author accounts (we do not upload any personal information to Facebook).
With extended comparison for customer data.
c) WebAnalytics/ Google Analytics/ Google Remarketing/ Ads/Doubleclick by Google
This website uses Google Analytics and Google Remarketing web analytics services provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).
Google Analytics and Google Remarketing use “Cookies” – text files which are stored on your computer and allow us to analyse your use of our website. When you visit our site, your data is collected by a cookie provided to us by Google. This data as well as the information generated about your use of this website (including your IP address) is transmitted to and stored on a Google server located in the US. Google will use the information to evaluate your use of our website, to compile reports about website activity for website operators, and to provide other services related to website activity and Internet usage.
Google will also transfer this information to third parties if required by law, or if third parties process this data on Google’s behalf. Google will never associate your IP address with other Google data. You can prevent the installation of cookies by setting your browser software accordingly; however, please note that if you do this you may not be able to use the full functionality of our website. By using our website, you agree to the processing of data about you by Google in the manner and for the purposes described above.
You can opt-out of the collection of data for the future at any time by using the Google Analytics Opt-out Browser Add-on at: https://tools.google.com/dlpage/gaoptout?hl=en
Please note that this website uses Google Analytics with the extension “_anonymizeIp()”. As a result, IP addresses are stored exclusively in anonymous form, which rules out direct personal reference in connection with the stored data.
Using Google Remarketing allows third parties, including Google, to serve ads to sites on the Internet. Third parties, including Google, use stored cookies to serve ads based on your previous visits to our site. In addition, we use Google Analytics to analyse data from Google Ads and the Double-Click-Cookie for statistical purposes and to display relevant targeted ads for you.
If you do not want this to happen, you can disable this function via the Ads Preferences Manager at: https://adssettings.google.com/authenticated. Alternatively, you can disable the Doubleclick-Cookies via the Digital Advertising Alliance website at the following link: http://www.aboutads.info/choices/.
Doubleclick by Google assigns your browser a pseudo identification number (ID). This is used internally to check which ads have appeared in your browser and which ads have been viewed. The cookies used do not contain any personal information. Using the DoubleClick cookie allows Google and its affiliate websites to serve ads based on prior visits to our, and other, websites and services on the Internet. The information generated by these cookies is transmitted by Google to a server in the USA for evaluation, and stored there.
Ads also stores cookies on your device. When you visit our site, your data is collected by us through a cookie provided by Google. This data is then sent to Google. The cookie is set when a user clicks on an ad served by Google. This is not used for personal identification. If the user visits certain pages of our offer, Google and the advertiser can then see they have been redirected to the page via the corresponding ad. Each Google Ads customer receives a different cookie. Thus, no conclusions can be drawn about user behaviour on the advertiser‘s website. The data collected with the help of cookies serves statistical purposes. At no point in time will Ads advertisers receive information which could personally identify users.
https://www.google.com/analytics/terms/gb.html or at: https://policies.google.com/?hl=en.
d) Google reCAPTCHA
e) Google Tag Manager
We also use the Google Tag Manager. With this service you can manage website tags. The Google Tag Manager simply sets up tags – tags are code used to measure traffic and visitor behaviour. The tags come from other services – in our case, Bing Ads Tracking, Unbounce and Cleverpush (see below). The Google Tag Manager is used to manage these tags, and does not set cookies or collect personal information. If tracking is disabled, this also applies to all tracking tags managed by Google Tag Manager.
f) Bing Ads
We also use Bing Ads technology provided and operated by Microsoft Corporation (“Microsoft”). If you came to our website through Bing Ads, Microsoft places a cookie on your device. This allows Microsoft to recognize when someone has clicked on an ad, been redirected to our site, and reached a specific destination page (conversion page). Microsoft collects and processes data through the cookie that is used to create user profiles using pseudonyms. These user profiles are used to analyse visitor behaviour and are used to create advertisements. No personal data about the identity of the user is processed. If you do not wish this data about your behaviour to be used, you can object to the necessary placement of a cookie under the following link: https://account.microsoft.com/privacy/ad-settings/signedout. For more information on this topic and on Bing Ads, please visit the Microsoft website at https://privacy.microsoft.com/en-gb/privacystatement.
This website uses the Kissmetrics Analytical Service developed by Space Pencil Inc. (407 Morning Lane Redwood City, CA 94065). Kissmetrics-Tracking uses only first-party cookies. You can remove them simply by deleting your browser cookies. If you want to prevent Kissmetrics tracking in general, just activate the “Do-Not-Track” function in your browser. Kissmetrics will then no longer gather information in your browser.
Alternatively, you can exercise your right to opt out with future effect at: https://signin.kissmetrics.com/privacy/.
Please note that you must repeat this procedure for each different device you use, then delete all cookies or use a different browser afterwards.
We use the tool unbounce. The provider is unbounce Marketing Solutions Inc, 400-401 West Georgia Street, Vancouver, BC, Canada, V6B 5A1. The EU Commission has classified Canada as a safe third country with an adequate level of data protection and we have entered into a contract processing agreement with unbounce Marketing Solutions Inc.
Individual subpages are hosted by unbounce and your browser communicates directly with unbounce, so your IP address is transmitted and cookies can be set. Also, all information you enter on these pages will be saved by unbounce. We will then be provided with an anonymous evaluation of your activities.
Further information about unbounce and data protection at unbounce can be found here: https://unbounce.com/privacy/.
i) Social Media Plugins
We use various social media plugins on some of our web pages including Facebook, Twitter and Google+ buttons. We now inform you about the individual social media plugins we use, as follows:
1) Facebook Plugin
We use the “Facebook-Button” Plugin on our web pages, which is developed by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (Facebook). You can use it to inform your friends whether you like our website, and to reference or share content. The plugin is indicated by the Facebook logo or by the addition of a “Like” label. Personal data can be transferred to Facebook via the plugin, if you are logged in on that site.
When you visit our site, your data will be transmitted to Facebook to the same extent that it would be if you visited their website, even if you are not a registered user on Facebook and do not click a plugin on our pages. In this case, however, Facebook is not immediately able to make any direct personal reference by, for example, establishing your IP address. This would only be possible via information from your service provider.
Where applicable, the following data will be transmitted:
- IP address
- Your user ID, if you are registered and logged in to Facebook
- Date and time of your visit
- Browser version and operating system you are using, and screen resolution
- Visitor origins (Referrer), if you followed a link
- Installed plugins like Flash or Adobe Reader
- URL of our page on which the plugin is integrated.
3) LinkedIn Plugins
Our web pages use plugins developed by the LinkedIn Corporation(„LinkedIn“), 2029 Stierlin Court, Mountain View, CA 94043, USA. These plugins are indicated by the LinkedIn logo or appear as a “share button” (“Recommend”).
If you access LinkedIn from our site, LinkedIn collects information about your devices and networks.
As soon as you visit our website, your browser establishes a direct connection to LinkedIn’s servers. LinkedIn automatically obtains the URL of the webpage you came from or the page to which you are being directed. LinkedIn also receives the Internet Protocol (“IP”) address of your computer or the proxy server via which you access the Internet, as well as information about your computer’s operating system and the web browser you use, your mobile device (including the mobile device identifier provided by your mobile device’s operating system), the operating system of your mobile device (if you are accessing LinkedIn from a mobile device), and the name of your Internet service provider or wireless service provider. LinkedIn may also receive geolocation information.
If you are logged into your account as a LinkedIn member while visiting our website and link the contents of this website to your LinkedIn profile, LinkedIn will be able to associate your visit to this website with your user account. The current data protection information from LinkedIn, in particular information about your rights and set-up options, are available on the following website: https://www.linkedin.com/legal/privacy-policy.
This website uses Mouseflow, a web analytics tool developed by Mouseflow ApS, Flaesketorvet 68, 1711 Kopenhagen, Dänemark, to record randomly selected individual visits (using anonymised IP addresses only). The result is a log of mouse movements and clicks acquired with the intention of randomly sampling individual website visits and deriving potential improvements for the website. The information is not personal and will not be shared. If you do not want a record to be created, you can disable the function on all websites that use Mouseflow by visiting the following link: https://mouseflow.com/opt-out/.
k) Retargeting via AdRoll
l) Conversion measurement with Facebook Pixel’s visitor tracking
With your agreement, which you have given as follows:
“I consent to the use of Facebook’s Visitor Action Pixels”,
we employ “visitor action pixels” developed by:
1601 S. California Ave,
Palo Alto, CA 94304, USA
on our website. When you visit our site, your data is collected by us through a cookie provided by Facebook. This data is then sent to Facebook. This means users’ behaviour can be tracked after they have been redirected to a provider’s website by clicking on a Facebook ad. This process is designed to assess the effectiveness of Facebook advertisements for statistical and market research purposes and may help to optimise future advertising measures.
The data collected is anonymous to us, so we cannot reach any conclusions about the identity of the users. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes, according to the following Facebook data usage directive: https://www.facebook.com/about/privacy/. This facility enables Facebook and its affiliates to display ads both on Facebook and elsewhere. A cookie may be stored on your computer for these purposes.
A consent to the use of visitor action pixels may only be declared by users who are 13 years old and above. So if you are younger, we request that you ask your parents or legal guardians for permission.
Please click here if you wish to withdraw your consent.
10. Your rights, information
If you no longer agree to the storage of your personal data or if it has become inaccurate, we will initiate the deletion or blocking of your data or make the necessary corrections (as far as this is possible under statutory provisions) upon receiving an appropriate instruction. Upon request, at any time we can send you information free of charge about all of your personal data which we have saved.
For questions regarding the collection, processing or use of your personal data, or for enquiries about the correction, blocking or deletion of data, please call +44 1214 685 191 or send an e-mail to us at: [email protected] or [email protected]
11. DATA PROTECTION OFFICER
Sario Marketing GmbH
Data Protection Officer
An den Grachten 29
E-Mail: [email protected]
Tel.: +49 (0) 6131 32 720 – 0
Fax: +49 (0) 6131 32 720 – 84