Privacy Notice for Splicky GmbH

 

Status of this privacy notice – January 2025

 

We are pleased that you are visiting our website and thank you for your interest in our company and the corresponding services. Data protection is not only a legal obligation for us, but also an important instrument for increasing transparency in our daily handling of your personal data. With this privacy notice, we would like to inform you about how we process personal data and make you aware of your rights. We are aware of the importance of processing personal data in your capacity as a data subject and therefore comply with all relevant legal requirements. The protection of your privacy is of utmost importance to us. We process your personal data in compliance with the General Data Protection Regulation and the data protection regulations under federal and state law.

Splicky GmbH is a registered member of the IAB Transparency and Consent Framework (Vendor ID 252) and adheres to its guidelines. The IAB TCF is an industry standard enabling all digital market participants (publishers, advertisers, technology service providers, etc.) to inform end users about the processing of their personal data and to give them the opportunity to consent to or object to this.We always process your personal data (hereinafter referred to as “data”) in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as “GDPR”).

Splicky GmbH is responsible within the meaning of the applicable data protection regulations

Körtestrasse 10, 10967 Berlin,
Managing directors authorized to represent: Sven Ruppert, Markus Alexander Wirth
Phone: +49 30 609 40 280
e-mail: info@splicky.com

 

Contact details of the data protection officer:
ePrivacy GmbH
Burchardstrasse 14
DE-20095 Hamburg
Germany
www.eprivacy.eu

This privacy notice uses the terminology of the General Data Protection Regulation (GDPR).

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

“Restriction of processing” is the marking of stored personal data with the aim of restricting its future processing.

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

“Pseudonymization” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

“File system” means any structured collection of personal data that is accessible according to specific criteria, regardless of whether this collection is managed centrally, decentrally or according to functional or geographical aspects;

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

 

“Recipient” means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

“Third party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

“Consent” means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

We collect and process the following personal data about you:

  • Contact and address information, if you have provided us with your contact information or registered on our site,
  • Online identifiers (e.g. your IP address, browser type and browser version, the operating system used, the referrer URL, the file name, the access status, the amount of data transferred, the date and time of the server request).

The data we collect below is not intended to identify you by name, address, etc., as this is not required for the purpose of personalized advertising. On the contrary: the data collected about you (see below) is assigned to an identification number of your end device – i.e. your cell phone, tablet, SmartTV etc. Therefore, the data collected is so-called pseudonymous data that cannot be easily assigned to a person.

The following information may be the subject of our data collection

  • Device identification numbers (device identifiers, IP addresses)
  • Information about your use of the websites and apps (which subpage on the website, which function in the app)
  • Information you have provided on the websites and apps (e.g. age, interests) (only with your consent)
  • Geo-location data (only with your consent)
  • The privacy settings you have made (opt-in, opt-out) – so that we know which of your data we may and may not process and for what purposes

In addition to the primary purpose of delivering relevant, usage-based advertising to your device, these also include the following purposes

  • for the contact you have requested,
  • for the provision of our services,
  • to process contracts, in particular to process orders and to issue invoices,
  • for advertising purposes,
  • to send you the e-mail newsletter if you have registered for it,
  • for quality assurance
  • for market research purposes
  • for our statistical purposes
  • Reporting to end customers: we process data to show Splicky customers how advertising recipients have interacted with their advertising material (qualitatively and quantitatively).
  • Frequency capping: – we process data so that you are not shown the same advertisement too often
  • Ad fraud prevention: – we process data to combat unfair activities by participants in the advertising industry

Your data is processed on the following legal bases:

  • Consent (Art. 6 para. 1 sentence 1 lit. a GDPR) – The data subject has given their consent to the processing of their personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR) – 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.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

If we base the processing of your personal data on legitimate interests within the meaning of Art. 6 para. 1 lit. f GDPR, these are

  • the improvement of our offering,
  • protection from abuse and
  • the management of our statistics.

We receive the data from you (including via the devices you use). If we do not collect the personal data directly from you, we will also inform you of the source from which the personal data originates and, if applicable, whether it originates from publicly accessible sources.

A detailed list of which data is processed by which recipient can be found here:
List of advertising delivery providers
Listing of the provider website

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard contractual clauses of the EU Commission or if certifications or binding corporate rules exist (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

We only store your personal data for as long as is necessary to achieve the purpose of processing or for as long as the storage is subject to a statutory retention period.

We store your data,

  • if you have consented to the processing, for no longer than until you withdraw your consent
  • if we require the data for the performance of a contract, for no longer than the duration of the contractual relationship with you or statutory retention periods,
  • If we process the data on the basis of a legitimate interest, for no longer than your interest in erasure or anonymization overrides this interest.

You have the right – in some cases under certain conditions,

  • to request information about the processing of your data free of charge and to receive a copy of your personal data. Among other things, you can request information about the processing purposes, the categories of personal data being processed, the recipients of the data (if it is passed on), the storage period or the criteria for determining the period;
  • to have your data rectified. If your personal data is incomplete, you have the right to have the data completed, taking into account the purposes of the processing;
  • to have your data erased or blocked. The grounds for the existence of a right to erasure/blocking may include: the withdrawal of consent on which the processing is based, the data subject’s objection to the processing, the unlawful processing of personal data;
  • to have the processing restricted;
  • to object to the processing of your data;
  • to revoke your consent to the processing of your data for the future and
  • to complain to the competent supervisory authority about unauthorized data processing (Berlin State Commissioner for Data Protection and Freedom of Information)

If you have any queries regarding your data subject rights, please contact us

  • by email at: oba@splicky.com or
  • by post to: Splicky GmbH, Körtestrasse 10, 10967 Berlin

Unless expressly stated at the time of collection, the provision of data is not required or mandatory. Such an obligation may arise from legal requirements or contractual regulations.

The contact form on our website www.splicky.com is an easy way to get in touch with us quickly. To make it possible to contact us, some fields are marked as mandatory. If you fill in the fields and select “Send”, you agree that your data will be transmitted to us with the message by e-mail. The data will not be stored on the web server.

We have taken extensive technical and organizational measures to protect your data against possible risks, such as unauthorized access, unauthorized disclosure, modification or dissemination, as well as against loss, destruction or misuse.

In order to protect your personal data from unauthorized access by third parties during transmission, we secure data transmissions using SSL encryption where necessary. This is a standardized encryption method for online services, especially for the website.

Our website collects log files from users with truncated IP addresses. A log note is only included in the error report in the event that an error message is generated by the host.

A cookie is a text file with an identification number that is transmitted to the user’s computer together with the other data actually requested when the website is used and stored there. The file is stored there for later access and serves to authenticate the user. As cookies are only simple files and not executable programs, they do not present an inherent risk to the computer. Depending on the settings selected by the user, the Internet browser automatically accepts cookies. However, this setting can be changed and the storage of cookies deactivated or set in such a way that the user is notified as soon as a cookie is set. However, if the use of cookies is deactivated, some functions of the website may not be available or may only be available to a limited extent. You can prevent the setting of cookies by our website at any time by means of a corresponding setting of the Internet browser used and thus permanently object to the placement of cookies. Cookies that are already active can be deleted at any time via an Internet browser or other software programs. Our website does not set its own cookies, but we may work with advertising partners who help us to make our website more interesting for you. For this purpose, cookies from partner companies are stored on your hard disk when you visit our website (third-party cookies). If we work together with the aforementioned advertising partners, you will be informed individually and separately about the use of such cookies and the scope of the information collected in each case in the following paragraphs.

A distinction is made between the following types of cookies:

First-party cookies: First-party cookies are transmitted by the platform you are currently visiting.

Third-party cookies (so-called third-party cookies): Third-party cookies are cookies that are transmitted by a provider other than the provider of the platform visited by the user. If a user accesses a platform and another entity transmits a cookie through this platform, this is a third-party cookie.

Strictly necessary cookies: These cookies are essential in order to enable you to move around the platform and use its features, such as accessing secure areas of the platform. Without them, certain services cannot be provided, such as displaying content customized for your computer or device.

Performance cookies: These cookies collect information about how visitors use the platform, e.g. which pages are accessed most frequently and whether they receive error messages from websites. However, these cookies do not collect any information about the visitor’s identity. All information these cookies collect is aggregated and therefore anonymous. They are only used to optimize the platform.

Functionality cookies: These cookies allow the platform to remember choices you make (such as language preferences and your region) and provide you with enhanced, more personal features. They can also be used to remember your preferences for text size, font and other customizable parts of the website. They can also be used to provide services you have requested, such as displaying a video or the comment function within a blog. The information that these cookies collect can be anonymized. Your browsing activity cannot be tracked on other platforms.

Social media cookies: These cookies are used when you click a button on the platform to share information on social media. The social network records this action and may use it for marketing or advertising purposes.

Marketing/advertising cookies: These cookies are used to show you advertisements that may be relevant to you based on your interests. They are also used to limit the number of times you are shown a particular advertisement. We also use cookies to measure how effective an advertising campaign is. They are usually placed by advertising networks with our permission and record your visit to a platform. This information is shared with other organizations such as advertising providers. Marketing and advertising cookies are often linked to platform functions. Our advertising cookies also allow you to participate in customer surveys and provide us with your feedback so that we can improve your user experience with us.

We reserve the right to amend this privacy notice at any time with effect for the future.

In the event of contradictions between the English and German versions of the privacy notice, the German version shall prevail.