Due to the purpose of their enterprise, ad pepper media International N.V. are concerned with the ascertainment, processing and use of personal data on a large scale.

Personal data are data on the personal or material circumstances of an identified or identifiable individual (the so-called data subject), such as name, address, age, e-mail address, telephone number or information on specific preferences, likes etc.

The ascertainment of such data means collecting them; the processing of personal data means their storage, modification, communication, locking and deletion; use is any use of personal data which is no processing.

Personal data are protected by the data protection directive of the EU and the national regulations of the member states. ad pepper media observe these regulations and thus respect the individual‘s right of personality and his/her right to protection of privacy. ad pepper want to justify the confidence the users have in their online services and make the ascertainment, processing and use of personal data transparent for their users by giving them the following information:

1. In mere advertising contacts with the user (e. g. the flashing of marquees on a website), ad pepper media do not 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. There is no personal context.

2. ad pepper media collect and process 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 by filling in the respective input fields and transmits to ad pepper media by sending off this information.

If there is any contractual or quasi-contractual relationship between ad pepper media and the Internet user (for example when requesting a newsletter), ad pepper media will process and use the information 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 data, ad pepper media pursue any purposes beyond the implementation and fulfillment of contractual or quasi-contractual relationships, 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, product information or service development.

In this process, ad pepper media rely on the double-opt-in solution: the user who consents to the use of his/her data for the defined purposes confirms this consent in a second step. In this way, ad pepper media make sure that the customer and not somebody else enters the customer data and grants ad pepper media the permission to use them. In this way, ad pepper media respect the customer’s right to informational selfdetermination.

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.

3. ad pepper media use cookies to optimize the use of the Internet for their users by a reduced repetition of advertising and an increased share of relevant contents. No personal data are collected by means of the cookies. The use of cookies, however, is not indispensable to ad pepper media. Therefore, the user can deactivate the cookie function at any time by changing the preferences of his/her Internet browser. If you need any help with this, please contact the address below.

4. 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 dataprocessing programs and facilities have password protection and operate using encoding technology which is present state of the art.

5. 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 customer 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 by ad pepper media there is no (more) consent, will be destroyed in such a way that any abuse can be ruled out.

6. ad pepper media also collect, process and use personal data on behalf of contractors or cooperation 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 on behalf of any third party, the cooperation partner will be clearly identifiable at any time. In this case, the user can enforce his/her rights exclusively against the cooperation partner of ad pepper media.

If ad pepper media collect any data on behalf of any cooperation partners and process and use these data, the cooperation 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 cooperation 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 cooperation 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 cooperation partner.

However, ad pepper media of course endeavor to only cooperate with such cooperation partners who observe the data privacy policy laid down in this statement in the same way ad pepper media do, or who at least guarantee the observance of the standard applicable under the EU data-protection directive.

7. The user is entitled to receive information on the stored data relating to the user from ad pepper media or their cooperation partners, and to have these data deleted or locked. These rights have to be enforced against ad pepper media if ad pepper media have collected the user data, and if they process and use them; they have to be enforced against the cooperation partner if he has the user data collected, processed and used by ad pepper media.

If you have any questions concerning our Data Privacy Policy, or if you want to exercise your right to information, deletion or locking, please do not hesitate to contact us at: dataprivacy@adpepper.com.

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