You can choose to decline the web-based tracking features by visiting our opt-out page on your mobile web browser:
General Data Protection Regulation (GDPR)
I. WHAT IS PERSONAL INFORMATION?
According to Art.4 No. 1 GDPR, personal data is any information relating to an identified or identifiable natural person, therefore can be used to obtain personal or factual details about the data subject (such as name, address, telephone number, date of birth or e-mail address). Information that cannot (directly or indirectly) be associated with a natural person (or only with disproportionate effort), for example, anonymous information, is not personal information.
II. WHAT INFORMATION DO WE COLLECT AND PROCESS?
You can use a portion of our online content without providing personal information.
a) Contact forms
If you, however, decide to request further information via the contact forms provided on our website, we may ask for your name and further personal information in order to handle your personal request or to provide the services you requested from us or our customers. You can freely decide whether or not you want to provide that information. However, without this information, we are unable to make the desired services available to you.
b) User account (WS9 Platform)
Certain services of our Online-Service called “WS9 Platform” with which you can create and display advertising campaigns on your own, upload list of advertising IDs for retargeting campaigns and specify targeting criteria for your campaigns, can only be used by registered users with a user account. We store your e-mail address during registration. The e-mail address serves as a username to identify your member account, and to conduct relevant correspondence with you (e.g. setting up and maintaining your user account). As part of the registration process, we also collect your first and last name, your salutation and information about your company affiliation, mailing address, to ensure that you receive personalized, competent service. All mandatory information required in order to register is marked accordingly. All further information is provided voluntarily; this data is used for the purposes stated, or to improve our online services.
If you wish to register as a user of our WS9 App and open a user account, please select for your own safety a secret and secure password in order to ensure the confidentiality of your data. Your password is transmitted to and stored on our servers in encrypted form, in the event that you forget your password, please use the “Forgot your password?” function provided on the website to create a new, secure password.
If you want to delete your account, please contact us at firstname.lastname@example.org. If deletion is not possible for legal reasons, access to the data in question shall instead be blocked. Please note, however, that we may be unable to continue offering some or all of the services provided on our websites requiring registration in the event that your data is deleted or blocked.
c) WS9 newsletter
As part of our web services, we offer a regular subscription to our WS9 newsletter. When requested, the newsletter provides you with free, up-to-date information on our services. To register without WS9 newsletter service, we need your first and last name, your gender, and the e-mail address at which you wish to receive the newsletter. If you wish to subscribe to the WS9 newsletter, we ask that you provide us with the following declaration of consent:
III. DELIVERY OF PERSONALISED OR BEHAVIOUR-BASED ADVERTISING (BEHAVIORAL TARGETING)
In certain cases, we showcase advertising to you on the websites of our partners and for our customers, which are automatically selected on the basis of your surfing behaviour, in order to optimise the quality of the advertising notices for you (so-called “personalised” or “behaviour-based” advertising delivery and “behavioral targeting”). The objective of this system is to only demonstrate to you content that corresponds to your interests. Advertisements which are unlikely to be of interest to you or which are irrelevant will not be shown to you by the activated behavioral targeting system of WS9 and will be disabled.
In such a case, this section IV. of the data protection declaration applies as part of the respective web-based services of our partners or customers, from which (for example under “data protection” or “data protection declaration” direct reference was made or a link was created. We wish to disclose to you in a transparent manner how the behavioral targeting works, which data is gathered in the process, how this data is used and for what purpose and how you can object to the behavioral targeting function at any time and block it.
As a Serbian/German/European company, the protection of your data is a priority for WS9, also in the course of the delivery of behavior-based advertising and WS9 only uses anonymized data to improve advert quality. Therefore, an identification of your person is not possible either for WS9 or the respective operator of the website of our partners and customers which you are visiting. You can yourself decide at any time whether you would like to continue seeing the personalized banner from WS9.
a) How does behavioral targeting work in individual cases?
We take part in a programmatic auction system where placements for advertisement in apps and websites are sold. In this process, we may collect information about you and your use of the website or app. This information cannot be used to identify you in real life but it does enable us to recognize your device when you use sites or apps that have partnered with us.
Another way we may deliver personalized advertising to you is when you visit the website of one of our partners or customers. On some of these sites, a cookie file is stored on your computer. Cookies are small text files which are deposited by your web browser in a folder on your computer which is designated for this purposes and which contains a single character string as a means of identification. (The cookie does not store your IP address.) The same character string is also saved on our servers. The next time you visit one of our partners’ websites, only the character string is read which identifies the Internet browser you are using. This allows us, for example, to identify which page you have accessed for our partner and which advert you have been shown, without this being linked to your identity. Furthermore, all of the cookies created by us are given an expiry data and automatically expire after no more than 13 months. Without a valid cookie file, the character strong saved on our servers is no longer to be assigned for us.
Important: Using cookies we cannot ever collect any other personal data. For example, when you enter an email address or delivery address, or any other personal data, we cannot see your input and cannot, therefore, process or store it. We do not know your name, address or workplace, nor do we know your gender, age, email address or any other personally identifiable information about you. Even the IP address of your computer is not stored! You can view the data stored in the cookie on your computer. Please refer to your web browser’s help directory or your web browser’s FAQ to learn how cookies are stored and how to read their content. The information contained within the cookie is the exact data that we can see Cookie technology does not allow viruses, trojans or other harmful programs to be placed on your computer.
A full list of the cookies used by WS9 and their individual functions can be downloaded here at any time. Should you not agree to the saving of cookies on our part, you can examine your cookie status at the very top of this page at any time, and also deactivate the saving of behavioral targeting cookies by us. Therefore you can object to the personalized adverts from WS9 at any time.
b) How can I disable personalized advertising from WS9 banners?
If you do not agree to the storing of cookies by us, you can check your cookie status at any time at the very top of this page and disable the storage of retargeting cookies by us and therefore decline personalized adverts from WS9.
This means that in future you will receive random advertising that is not targeted to your interests.
Please note that the “opt-out” and “opt-in” functions offered are, for technical reasons, also controlled via cookies. This means that deleting all cookies on your computer means that you will have to opt-out again.
It is also the case that the deletion of all cookies on your computer does not lead to no personalized advertising being notified to you on a permanent basis. Therefore, you must use the “opt-out” function as described.
Finally, please note that we are continuously expanding our range of products. As this will technically involve a new system, the introduction of a new opt-out may be necessary, even if you have already opted prior to its introduction.
c) Can other forms of personalized advertising be disabled in addition to WS9?
The options described in this section refer only to the personalized adverts offered by WS9. If you wish to disable personalized advertising from other providers, you can do this via their respective websites.
There is an option to change your settings collectively for various providers under preference management on “Your Online Choices”: http://www.youronlinechoices.com/de/praferenzmanagement/.
If you want to opt-out from the usage of the Advertising ID, please refer to your operating system settings, or follow the instructions below:
Android Users (version 2.3 and above) To use the “opt-out of interest-based advertising” option, follow the instructions provided by Google here: Google Play Help.
iOS users (version 6 and above) To use the “Limit Ad-Tracking” option, follow the instructions provided by Apple here: Apple Support Center
Please note that these are device settings and will disable interest-based ads from all providers, and not just for us.
d) We also collect information about the advertisements that have been served to you by WS9 and match them we the Advertising ID from the programmatic buying process.
Information about the ads can contain:
- the details of the ad delivered (e.g. advertiser’s name, type of advert, etc);
- the website or the app where the ad was delivered;
- your interaction with the ad (i.e. whether you clicked, hid, muted or otherwise interacted with the ad);
- whether you performed certain actions after clicking on the ad (e.g. downloading an application, making a purchase, etc).
e) How do we use collected information?
We use the information we collect to display interest-based advertising customized to individuals’ inferred interests, preferences and locations, and to perform analysis aimed at improving our services and technologies. We also need the information in the billing process with our customers and to validate the billings we receive from our partners. The information we collect also helps us to provide filtering options for publishers and developers to manage ads appearing on their sites and in their apps, and to provide targeting options for advertisers. In the end, this helps publishers and developer clients, for example, not to present you ads that you have already seen, and helps our advertiser clients serve adverts that are most likely to be of interest to you.
Important: We do not store the IP-Addresses un-anonymized or the Geographic location
Further information and a full list of the cookies which are used by WS9 on its own websites or on those of customers or partners, as well as their individual functions, can be downloaded here at any time. In addition, you can generally prevent the storing of cookies by adjusting your browser settings accordingly.
V. LEGAL BASIS
The legal bases for the processing of your data could be the following:
- Your consent to the use of data in accordance with Art. 6 (1) lit. a) GDPR;
- The performance of our service obligations arising from contracts concluded with you in order to provide the services you request in accordance with Article 6 (1) lit. (b) GDPR;
- Our legitimate interest in accordance with Art. 6 (1) lit. f) GDPR, e. g.
- Our business interests in improving our services so that we can better understand your needs and expectations and thus improve the services we provide to you;
- To prevent fraud and to ensure that our websites are used completely and without any fraudulent behavior;
- To ensure and guarantee the security of our services, making sure that our offer is technically secure and properly functioning;
- to ensure and enforce our contractual requirements and claims.
- Legal reasons in accordance with Art. 6 (1) lit. c) GDPR if the collection, storage, transfer or other processing of data is prescribed by law or processing is necessary to fulfill our legal obligations.
VI. DATA STORAGE
We store personal information you submit to us only for as long as is necessary to fulfill the purposes for which such information was transmitted, or as required by law:
- If you conclude contracts with us, we store and process your personal data for the duration of the contractual relationship and beyond for the fulfillment of post-contractual obligations and handling of issues as well as for the duration of statutory retention periods (maximum 10 years);
- If you have consented to the promotional use of your e-mail address, we will store your e-mail address with our mail service provider until you unsubscribe, requesting us to delete the data;
- If you send us an inquiry, we process your personal data while we handle your request.
VII. IS PERSONAL INFORMATION FORWARDED TO THIRD PARTIES?
We forward your Advertising ID we received from our Partners to companies running the advertising campaigns on our service or companies providing anonymous audience data in case we register that you saw one of our advertisements or in case you clicked on an advertisement. This is only done for billing and statistical reasons. In certain cases, we are also required by law to disclose your personal information to third parties. This is, for example, the case when the suspicion of a criminal offense or a misuse of our websites occurs. We are then required to disclose your data to law enforcement authorities.
Outside of the cases described in this data protection declaration, your data is not forwarded on to third parties and, your information is solely stored in our databases / on our servers (or on the servers of third-party providers).
VIII. HYPERLINKS TO OTHER WEBSITES
IX. PROTECTION OF MINORS
Persons under 18 years are excluded from our services and from providing any personal information without the consent of their parents or guardians. We do not request personal information from children and adolescents. We do not knowingly gather or collect such data and do not disclose it to third parties.
X. HOW WE KEEP YOUR INFORMATION SECURE
When we collect information, we solely store your data on highly protected servers in Germany and the EU. Access to our IT infrastructure is strictly limited to authorized persons who are involved in the technical, commercial or editorial support.
In order to avoid loss or misuse of data stored by us, we have taken all necessary and extensive technical and organizational safety precautions, which are regularly checked and updated based on technological advancements in accordance to the GDPR.
XI. RIGHTS OF THE “DATA SUBJECT” ACCORDING TO THE RULES OF THE GDPR:
According to the EU General Data Protection Regulation, you deserve the right to request access to your personal data (see Art. 15), as well as rectification (see Art. 16), erasure (see Art. 17) or at least restriction of processing (see Art. 18) of your personal data.
Furthermore, you have a right to data portability (see Art. 20) and, of course, the right to revoke any consent given to the processing of personal data at any time (see Art. 7) and to object to processing based on the balancing of legitimate interests (see Art. 21(4) GDPR). In addition, you have a right to appeal to the competent data protection supervisory authority.
If you have any questions or other feedback on the subject of data protection or would like to exercise your rights regarding data protection, please contact our Data Protection Officer or ourselves:
Internet Agency WS9
Koste Josipovića br. 3.
Version: May 2018 – We reserve the right to adapt this data protection declaration and will announce any changes in good time.