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Data Protection Policy

The wywy GmbH, Landwehrstraße 60-62, 80336 Munich, Germany, and its subsidiaries (“wywy” or “we”), take data protection matters very seriously and wish to ensure that your privacy as a user of websites and mobile applications using our Analytics and Advertisement Services is protected and that you are informed about how we collect and use data.

1. Scope of this Data Protection Policy

In this Data Protection Policy, we explain how we handle data in connection with our Analytics and Advertisement Services (the “Services”). The Data Protection Policy particularly illustrates which data we collect and what purpose we collect them for, how we use the data, and how you can opt-out from us using the data as described herein.

For the Privacy Policy governing the use of our website, follow this link: http://wywy.com/privacy-policy/.

The right is reserved to modify the content of this Data Protection Policy from time to time. It is therefore recommended that you re-acquaint yourself with the Data Protection Policy at regular intervals.

2. General Aspects

We shall comply at all times with the applicable data protection laws, in particular the stipulations in the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG) and the German Telemedia Act (Telemediengesetz, TMG).

We do not collect, process and use your personally identifiable information, unless your prior consent has been obtained or if such processing or use is permitted by law.

3. Our Services

Our company is specialised in analysing and optimizing advertisements. On behalf of our customers, we analyse user behaviour on our customer’s websites and mobile applications in order to compile and aggregate non-personalized statistics, allowing the respective customer to evaluate the success of his TV advertisement campaigns and to improve said campaigns in the future.

The Services we provide also include displaying customized online advertisement. For this purpose, we use information we obtain from analysing our customer’s websites and mobile applications (as mentioned above) and TV audience viewership data from our partners in connection with information on TV campaigns in order to calculate the likelihood of which advertisement is most likely relevant to a specific group of users. Our major goal is to provide you with advertisements that are most likely to be relevant and interesting to you and to reduce advertising-spam that is displayed while you browse certain websites or use mobile applications.

We work together with partners to create and deliver such customized advertisements for users who visit our customer’s websites or use their mobile applications and with an advertisement network to display customized advertisements to users while they use the Internet or mobile applications.

4. What we use Data for

We collect and use data exclusively in order to provide our Services as described above, unless you intentionally provide us with data for other purposes, e.g. to contact us.

The cookies stored on your system when visiting one of our customer’s websites are stored and used on behalf of our customers. The same applies to the collection and use of Advertising IDs when you are using mobile applications (see section 5 for details).

We use the data collected on behalf of our customers, in order to provide them with non-personalized statistics on the effects of TV advertisement campaigns on the use of their website or mobile applications. We therefore aggregate and compile the data collected for that purpose.

In order to provide you with customized advertisement on websites or mobile applications you are using, the data we collect (see section 6) is aggregated by software we or the partners working on our behalf are using for that purpose.

We create a non-personalized user profile from the data we collect from you, exclusively by using aliases (section 3 (6a) BDSG), meaning that all identifying characteristics that may be contained in that data are replaced by a non-identifiable label. We create and use said profiles exclusively in order to provide you with customized advertisement as described above and in order to improve our services provided in connection with such customized advertisement. If you do not wish your use of our customer’s website or mobile application to be collected and used for these purposes, you may at any time prevent us from doing so. Please refer to sections 7 and 8 for further information.

5. How we collect Data for our Services

If you are using a web browser on your desktop, tablet or on your smartphone, data is collected through cookies used on our customer’s websites. Cookies are small text files stored in your web browser on your device that allow your use of a website to be analysed. They help you navigate websites efficiently, by remembering settings and choices you make during your visits to a website. We use cookies in order to recognise you as a user during your (recurring) visits of our customer’s websites, and when serving online advertising to you.

Using cookies, we store details of your visit of the website only under a generated session and user ID. As an example, the data we collect through the use of cookies may contain information about which of the advertising material delivered by us you have seen or have clicked on. The cookies automatically expire 18 months after they have been placed or updated on your system.

We use technologies similar to cookies in order to collect data, if the environment used by you does not support cookies. To provide customized advertisements in mobile applications, we collect the Advertising ID of our customer’s mobile application you are using.

If you do not want cookies to be used, you can block such use in your browser. If you do not want the Advertising ID to be transferred from your mobile device you can disable the transmission of the Advertising ID in its privacy settings. In such case, however, you are not able to receive advertisement customized for you. See sections 7 and 8 for further information.

6. What Data we collect

We collect data relating to your browsing activities on our customer’s websites and on your use of their mobile applications, i.e. your IP address, and, to the extent available, the browser and operating system you are using, referrer and the user agent. We do not save or use any personally identifiable information that would allow us to identify you.

7. Opt Out to wywy’s Services

In case you do not want us to collect and use your data for our Services as described in this Data Protection Policy, you can opt-out of our Services here:

Click the below button to change your tracking settings.

On: Tracking is enabled.

Off: Tracking is disabled and you have opted out.

The opt-out cookie overwrites the cookie placed by us on your system, preventing us from collecting any further data from your activities on our customer’s website. The opt-out cookie must remain on your browser in order to recognize you as having opted out from our Services.

In case you delete or block the cookies on your system, or in case you browse the Internet using different browsers, such opt-out must be renewed and/or be executed in all browsers you are using.

You can also completely disable cookies from the domain wywyuserservice.com by adjusting your browser settings accordingly. This will prevent us from placing cookies on the browser you are using (including opt-out cookies). Please note, however, that cookies already placed in your browser at that time must be deleted in order to disable our Services for that browser.

For mobile applications you are using, you can disable our Services by disabling the transmission of the Advertising ID in the privacy settings of your mobile device.

In each case, you can enable our Services again by using just one click.

8. Opt Out to wywy’s Partners

wywy works together with partners that place and use cookies on behalf of wywy. Currently, these partners are:

  1. Appnexus, Inc., New York, NY, USA (Appnexus)
  2. Google, Inc., Mountain View, CA, USA (Doubleclick)
  3. Revenue Cloud GmbH, Berlin, Germany (RevCloud)
  4. Sticky Ads TV S.A.S., Neuilly-sur-Seine, France (StickyAds)

You can disable cookies placed and used by these partners by visiting the following platforms:

http://www.networkadvertising.org/choices/ (for the United States)

http://www.youronlinechoices.com/ (for the European Union)

Please acknowledge that these platforms allow you to opt out of interest based advertising delivered by members to the respective platforms on the current browser you are using by using an opt-out cookie. For further information on how opt-out cookies work, please see section 7 or visit the above mentioned platforms.

9. Sharing of personal data

We will not share your personal data with third parties unless you have given your prior explicit consent or such sharing of data is prescribed by law or legally permissible. Data is shared with government agencies and authorities only in compliance with mandatory national laws. Our employees and partners are obligated by us to maintain confidentiality and to comply with the data protection regulations.

10. Storing your personal data

Your personal data is only stored for as long as this is necessary to achieve the purposes specified in this Data Protection Policy, or as long as we are obligated to store them by law. 11. Information, correction, deletion

You can obtain information at any time, free of charge, about the personal data we store about you. If your data is incorrect or wrongly stored by us, we shall be pleased to correct, block or delete such data. Please notify us immediately of any changes in your data. Please send any requests for information, questions, complaints or suggestions to the following address: privacy@wywy.com

Munich, May 2015