0. General Notes and Mandatory Information
We would like to point out that data transmission on the Internet can have security gaps. A complete protection of the data against access by third parties is not possible.
Areas in which We Collect Personal Data
There are three areas where personal data may be collected:
- Data from users of our clients
- Functions and user interface of the app
- Marketing and usage of the website and the app.
In the main chapters below, we go into more detail about these areas.
Who is Responsible for Data Collection on this Website and App?
Data processing on this website and in the app is carried out by the provider of the website and the app:
Modular Minds GmbH
1. Data from Users of Our Clients.
The essential functionality of Adwary is to check whether clicks on your ads are fraudulent or not and to evaluate these clicks for this purpose. To do this, we need data about the clicks in order to evaluate them.
How Do We Collect Data from Your Users?
You give us permission to process the data by instructing us to record, evaluate and analyze the clicks on your ads and then initiate the transmission of clicks to our systems. In the process, IP addresses are generated that are considered personally identifiable. You can find out more about IP address protection in the following paragraphs.
What Personal Data Do We Collect?
Basically, a request is sent to our systems with every click on your ads. Since we do not use fingerprinting to merge different clicks, the only personal data that remains is the IP address of the user who clicked on your ad.
What Do We Use Your Users' Data for?
The IP address serves as the starting point for further analysis and as a blocking criterion for placing ads with the respective advertising platform. In order to process the IP address in accordance with data protection regulations, we firstly store it only in mathematically irreversible form (as a so-called hash) in order to recognize repeated accesses and other patterns, and secondly only process it in anonymized form (the last 8 bits are replaced by zeros) in order to enable the blocking of ad placements for specific IPs with the advertising platform.
Transmission of the IP address to third parties is explicitly not carried out!
2. Functions and User Interface of the App
In order to provide certain functions and to be able to address you in the user interface of the app, we need certain data from you. This can be, for example - not finally enumerated - your e-mail address or your name.
How Do We Collect Your Data?
On the one hand, your data is collected by you providing it to us. This can be, for example, data that you enter in a contact or registration form. In addition, it is possible that you authorize us to use certain data, such as the name of a login to an advertising platform such as Google Ads.
What Personal Data Do We Collect?
In the App
- Email address (yours and other invited users)
Access to Google Ads Accounts via Log in with Google.
- The email address of the authorizing Google account
- The name of the authorizing Google account
What Do We Use Your Data for?
We use the data to target you in the app or in features of the app and to perform functions in the app to display, evaluate and protect your advertising accounts.
Data from Requests
If you send us a request, the information you provide in your request, including your contact details, will be stored by us for the purpose of processing the request and in the event of follow-up questions. We do not pass on this data without your consent.
The processing of the transmitted data is therefore based exclusively on your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke this consent at any time. For this purpose, an informal communication by e-mail to us is sufficient. The legality of the data processing operations carried out until the revocation remains unaffected by the revocation.
The data you provide will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies (e.g. after we have completed processing your request). Mandatory legal provisions - in particular retention periods - remain unaffected.
Registration on this Website and in the App.
You can register on our website to use the app in order to use additional features on the site. We use the data entered for this purpose only for the purpose of using the respective offer or service for which you have registered and for the transmission of offers in this regard. The mandatory information requested during registration must be provided in full. Otherwise, we will reject the registration.
For important changes, for example in the scope of the offer or for technically necessary changes, we will use the e-mail address provided during registration to inform you in this way.
The processing of the data entered during registration is based on your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke any consent you have given at any time. For this purpose, an informal communication by e-mail to us is sufficient. The legality of the data processing already carried out remains unaffected by the revocation.
The data collected during registration will be stored by us as long as you are registered on our website and will then be deleted. Legal retention periods remain unaffected.
Processing of Data (Customer and Contract Data)
We collect, process and use personal data only to the extent that they are necessary for the establishment, content or amendment of the legal relationship (inventory data). This is done on the basis of Art. 6 (1) lit. b DSGVO, which permits the processing of data for the performance of a contract or pre-contractual measures. We collect, process and use personal data about the use of our Internet pages (usage data) only insofar as this is necessary to enable or bill the user for the use of the service or to communicate offers relating to the service.
The collected customer data will be deleted after completion of the order or termination of the business relationship after 90 days. Legal retention periods remain unaffected.
On our website we offer payment via Digistore24. Provider of this payment service is Digistore24 GmbH, St.-Godehard-Straße 32, DE-31139 Hildesheim (hereinafter "DS24").
At the beginning of a booking, we forward some data entered by you, such as e-mail address and name, to DS24. The booking is then made with DS24 as the seller. DS24 collects personal data from you in its own forms. We then have no access to this, except for the data that is returned to us after the booking. For example, a changed e-mail address can be transferred to us. Other personal data does not flow to us. DS24 has its own data protection regulations and contractual arrangements over which we have no control. DS24 as a seller becomes your contractual partner, all data protection concerns that have arisen through the conclusion of the contract are to be declared to DS24.
The transfer of your data to DS24 is based on Art. 6 para. 1 lit. a DSGVO (consent) and Art. 6 para. 1 lit. b DSGVO (processing for the fulfillment of a contract). You have the option to revoke your consent to data processing at any time. A revocation does not affect the validity of past data processing operations. In the event of a revocation of permission for data processing, current contracts will end with the expiry of the current payment period.
3. Marketing and Usage of the Website and the App.
For marketing purposes and to determine which areas of the app are used frequently or less frequently, we collect usage data from both the website and the app.
How Do We Collect Your Data?
Certain data is automatically collected by our IT systems when you visit the website or use the app. This is primarily technical data (e.g. internet browser, operating system or time of page view). This data is collected automatically as soon as you enter our website or access our app.
What Do We Use Your Data for?
Part of the data is collected to ensure error-free provision of the website. Other data may be used to analyze your user behavior. In addition, we evaluate how successful our marketing measures are.
The website and the app use so-called cookies. Cookies do not cause any damage to your computer and do not contain viruses. Cookies serve to make our offer more user-friendly, effective and secure. Cookies are small text files that are stored on your computer and saved by your browser.
You can set your browser so that you are informed about the setting of cookies and allow cookies only in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.
Server Log Files
The operators of the servers of the website and the app automatically collect and store information in so-called server log files, which your browser automatically transmits to us. These are essentially:
- Browser type and browser version
- Operating system used
- Referrer URL
- Host name of the accessing computer
- Time of the server request
- IP address
This data is not merged with other data sources.
The basis for data processing is Art. 6 (1) lit. b DSGVO, which permits the processing of data for the fulfillment of a contract or pre-contractual measures.
This website uses functions of the web analysis service Google Analytics. The provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Google Analytics uses so-called "cookies". These are text files that are stored on your computer and enable an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.
The storage of Google Analytics cookies is based on Art. 6 (1) lit. f DSGVO. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its website and its advertising.
We have activated the IP anonymization function on this website. This means that your IP address will be shortened by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with any other data held by Google.
Objection to Data Collection.
You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set that will prevent the collection of your data during future visits to this website: Google Analytics opt-out.
Processing of Commissioned Data.
We have concluded an order data processing contract with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.
Demographic Characteristics in Google Analytics.
This website uses the "demographic characteristics" function of Google Analytics. This allows reports to be generated that contain statements about the age, gender and interests of site visitors. This data comes from interest-based advertising from Google as well as visitor data from third-party providers. This data cannot be assigned to a specific person. You can deactivate this function at any time via the ad settings in your Google account or generally prohibit the collection of your data by Google Analytics as shown in the item "Objection to Data Collection".
Google Analytics Remarketing
Our websites use the functions of Google Analytics Remarketing in conjunction with the cross-device functions of Google Ads and Google DoubleClick. The provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
This function makes it possible to link the advertising target groups created with Google Analytics Remarketing with the cross-device functions of Google Ads and Google DoubleClick. In this way, interest-based, personalized advertising messages that have been adapted to you depending on your previous usage and surfing behavior on one end device (e.g. cell phone) can also be displayed on another of your end devices (e.g. tablet or PC).
If you have given your consent, Google will link your web and app browsing history with your Google account for this purpose. In this way, the same personalized advertising messages can be displayed on every device on which you log in with your Google account.
To support this feature, Google Analytics collects Google-authenticated IDs of users that are temporarily linked to our Google Analytics data to define and create audiences for cross-device ad targeting.
You can permanently object to cross-device remarketing/targeting by deactivating personalized advertising in your Google account; follow this link: https://www.google.com/settings/ads/onweb/.
The aggregation of the collected data in your Google account is based solely on your consent, which you can give or revoke at Google (Art. 6 para. 1 lit. a DSGVO). In the case of data collection processes that are not merged in your Google account (e.g. because you do not have a Google account or have objected to the merging), the collection of the data is based on Art. 6 (1) lit. f DSGVO. The legitimate interest arises from the fact that the website operator has an interest in the anonymized analysis of website visitors for advertising purposes.
Google Ads and Google Conversion Tracking
This website uses Google Ads. Google Ads is an online advertising program of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States ("Google").
Within the framework of Google Ads, we use so-called conversion tracking. When you click on an ad placed by Google, a cookie is set for conversion tracking. Cookies are small text files that the internet browser stores on the user's computer. These cookies lose their validity after 30 days and are not used to personally identify the user. If the user visits certain pages of this website and the cookie has not yet expired, Google and we can recognize that the user clicked on the ad and was redirected to this page.
Each Google Ads customer receives a different cookie. The cookies cannot be tracked across Google Ads customers' websites. The information obtained using the conversion cookie is used to create conversion statistics for Google Ads customers who have opted in to conversion tracking. The customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that personally identifies users. If you do not wish to participate in the tracking, you can object to this use by easily deactivating the Google conversion tracking cookie via your internet browser under user settings. You will then not be included in the conversion tracking statistics.
The storage of "conversion cookies" is based on Art. 6 (1) lit. f DSGVO. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its website and its advertising.
You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. When deactivating cookies, the functionality of this website may be limited.
4. What Rights Do You Have Regarding Your Data?
Revocation of Your Consent to Data Processing.
Many data processing operations are only possible with your express consent. You can revoke consent you have already given at any time. For this purpose, an informal communication by e-mail to us is sufficient. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
Information, Blocking, Deletion
Within the framework of the applicable legal provisions, you have the right to obtain information free of charge at any time about the origin, recipient and purpose of your stored personal data. You also have the right to demand the correction, blocking or deletion of this data. For this purpose, as well as for further questions on the subject of data protection, you can contact us at any time at the address given in the imprint. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.
SSL or TLS Encryption
For security reasons and to protect the transmission of confidential content, such as orders or requests that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.
If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties according to the current state of technology. The state of the art can change at any time.
Objection to Advertising Mails
We hereby object to the use of contact data published within the scope of the imprint obligation to send advertising and information material that has not been expressly requested. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam e-mails.