Braintag Privacy Statement and Data Protection Declaration

Brief summary:

Effective Date: 25th of May, 2018

Following the art. 13 of the Regulation EU 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, we have updated our Privacy Statement, which you can find below.

JustClick Media GmbH (hereinafter, the “Company”, “We”, “Us”, “Our”) is the owner of Braintag (hereinafter, our/the “Product”). The product is proprietary technology of the Company and its used in the Online Media Trading business. We use it to track conversions of the campaigns we run, which is the main business of the Company.

This Product does not collect or share any personal data. Braintag.com (hereinafter, the “Website”) just as it is with all the services and products the Company develops and provides, they are all Data-Privacy-Compliant by Design. Although that is the summary of the Privacy Policy of the Company and the Product, we encourage you to read the rest to explain why and how we do just that.

In the Company we are committed to making sure that absolutely everything we do is always Data-Privacy-Compliant by Design. That means that you don’t have to worry about us collecting, sharing, storing, or even worse, losing your personal data; we couldn’t even if we tried. Information that is not collected can’t be lost, stolen demanded, leaked or exposed.

We have made sure that the only information this Product saves can’t be linked back to you or anyone else. That information is very limited, non-personal and even obfuscated to make sure it can’t be associated with a particular individual. This information is for statistical purposes as it helps us improve our service and product, but also to track conversions without the need of personal data, avoiding the identification of an exact user and therefore not compromising your privacy in any way.

JustClick Media GmbH will act as Controller and Processor. If you have any questions, comments, suggestions or doubts, regarding our Privacy Policy or anything related to your personal data, please contact us at: privacy@justclick.media or by mail at:

JustClick media GmbH

Eberswalder Str. 6-9,

10437 Berlin

HRB 189025 B

Personal Data:

It is important that you understand what is defined by the GDPR as personal data, in order to fully comprehend exactly what we do. As defined in Article 4 of the GDPR, under Definitions:

“‘personal data’ means any information relating to an identified or identifiable natural person (‘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;” (GDPR Art.4, https://gdpr-info.eu/art-4-gdpr/)

Collection and Processing:

When do we collect personal data about you?

We do not store your personal data.

Personal data of underage users?

We do not store the Personal Data of anyone, that includes underage users.

Why do we collect and use personal data?

We can’t say why we do it, as we don’t collect any personal data.

What type of personal data is collected?

No type of personal data is colelcted.

What are our processing methods?

Although the Product does not store, have access to, share, or use any of your personal data, we still use data to have statistically-relevant insights conversion-relevant information that helps us run our business. That means, that we do collect, process and store data, just not any personal data of yours. In each and every case where we collect data that might be considered personal data, we obfuscate that data to eliminate all possibilities of it being linked to an specific person. This process that is known, under the GDPR guidelines, as pseudonymisation, can take information such as your IP Address (which is personal data) and convert it into anonymous data that can only serve for statistical and conversion related purposes. This process is done automatically, it is irreversible and allows us to work with data without compromising your privacy.

Links to other websites?

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question. We will immediately remove any links of this type upon being notified of such violations.

Storage and Security:

Do we retain your personal data?

We do not retain any of your personal data.

How long do we keep your personal data?

It is impossible to say, because we don’t store any of your personal data.

Do we share your personal data with anyone?

We would have to store it to share it. But we don’t. So we don’t.

Do we disclose or disseminate your personal data?

No, we do not disclose or disseminate your personal data.

How do we keep your personal data secure?

We keep your data secure by not collecting it.

Do we transfer personal data internationally?

No, we do not.

Cookies:

What are cookies?

Cookies are text files/pieces of information, where the story of your experience on a website is written. Cookies can collect data such as: number of page views, visitor browser types, operating systems, which links did you click in a website, among many others.

Do we use cookies?

Yes, we use cookies.

For what purpose?

The Product’s website exists as a landing page with very little information. There is no need to interact with the website, as the important part is the product itself. So our website collects no information and uses no cookies.

The only cookies that we use are the ones that the Company uses to provide its services, with the product technology. These cookies we call Interaction Cookies.They allow us to know if a user has interacted with an advertisement we have placed. That is all they do. They don’t collect any personal data.

Cookies used

All information these cookies collect is anonymous. If you do not allow these cookies we will not know when you have used our product, and will not be able to monitor its performance. Regardless of the cookie type and our best intentions, you can always choose to opt-out. We wouldn’t hold that against you; our priority will always be to respect your privacy in every aspect.

Also know, that you can set your cookie preferences in your browser setting, so that you can always allow or always refuse cookies from websites. We encourage you to check your browser preferences to improve your online experience and take control of your privacy.

Cookies used by our service providers:

We do not have access to any of the cookies or any of the information that any our service providers might collect.

Data Subject’s rights:

Even though we don’t collect any personal data, we think it is important that you understand your rights in regards to your personal data. These are the rights that are stipulated under the GDPR, to which you are entitled to:

The right to be informed – all organisations must be completely transparent in how they are using personal data (personal data may include data such as a work email and work mobile if they are specific to an individual).

The right of access - individuals will have the right to know exactly what information is held about them and how it is processed.

The right of rectification - individuals will be entitled to have personal data rectified if it is inaccurate or incomplete.

The right to erasure - also known as 'the right to be forgotten', this refers to an individual's right to having their personal data deleted or removed without the need for a specific reason as to why they wish to discontinue.

The right to restrict processing - an individual's right to block or suppress processing of their personal data.

The right to data portability - this allows individuals to retain and reuse their personal data for their own purpose.

The right to object - in certain circumstances, individuals are entitled to object to their personal data being used. This includes, if a company uses personal data for the purpose of direct marketing, scientific and historical research, or for the performance of a task in the public interest.

Rights of automated decision making and profiling - the GDPR has put in place safeguards to protect individuals against the risk that a potentially damaging decision is made without human intervention. For example, individuals can choose not to be the subject of a decision where the consequence has a legal bearing on them, or is based on automated processing.

If you want to exercise any of these rights, or feel that we might be doing something against them, please contact: the Controller we will resolve any matter in less than 30 days.

Changes to this privacy statement:

JustClick Media GmbH and Braintag reserve the right to update this Privacy Policy from time to time to reflect, among other things, changes in the law, our data collection and use practices, our Services, or advances in technology, by posting revised terms on our website. But rest assured, we will always be data-privacy-compliant by design. If we make changes that significantly alter our privacy practices, we will post a notice on our website and link to previous versions in this section:

A previous version of this privacy statement can be found here: LINK

Disclaimer:

The Controller is not responsible for updating all links that can be viewed in this Privacy Policy, therefore whenever a link is not functional and/or updated, Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to such link.

JustClick media GmbH

Eberswalder Str. 6-9,

10437 Berlin

HRB 189025 B