Freechoice Privacy Policy
In order to use our website, it is essential that your personal data is processed. We process your data in compliance with all legal requirements, in particular the GDPR, the BDSG and the TTDSG, and ensure the protection of your data during processing.
This Privacy Policy informs you about • when we process which data and • how the processing takes place. The policy also contains information about your rights in relation to data processing and how you can assert them.
1. Controller
Responsible for data collection and processing in accordance with Art. 4 para. 7 GDPR is the:
Traffective GmbH | Dachauer Str. 90 | 80335 München (nachfolgend auch “wir” oder “uns”).
2. Contact
If you have any questions about data protection and your rights, please contact our data protection officer at any time:
neumeier AG | Thomas Neumeier | Marktstr. 29 | D-84066 Mallersdorf | Mail: [email protected]
3. Purposes and legal bases for the processing of personal data
3.1. 3.1 Contract execution / freechoice subscription
The following data is processed for the fulfilment of the contract and as part of the freechoice-subscription:
- E-mail adress
- IP adress
- Bank details, if applicable
Legal basis for this processing is Art. 6 para 1 sentence 1 lit. b) GDPR.
We use the payment service provider Stripe Payments Europe Limited, 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland, to process payments. The legal basis for the transfer of data to this provider is Art. 6 para. 1 sentence 1 lit. b) GDPR. You can find more information about Stripe under 5.“Order processing and recipients of data“.
3.2. 3.2 Accounting
The following categories of data are processed as part of optional billing, provided you use this option:
- First name and surname
- Your adress
- Means of payment
- Date of birth, if applicable
The legal basis for this is your consent in accordance with Art. 6 para. 1 sentence 1 lit. a in conjunction with Art. 7 GDPR. You can revoke your consent at any time, but in this case we will not be able to invoice you.
3.3 Rights of data subjects under the GDPR
The GDPR grants you various rights in relation to the data processing carried out by us. We summarise these rights briefly here:
Right to information: Art. 15 GDPR grants you the right to request information about the data processed about you, including the recipients and the storage period.
Right to correction: You can request the rectification of your data if we process incorrect data (Art. 16 GDPR).
Right to deletion or restriction of processing: Art. 17, 18 GDPR grant you the right, under certain conditions, to request the deletion of your personal data or the restriction of processing.
Right to lodge a complaint with a supervisory authority: You are entitled to lodge a complaint with the supervisory authority in charge (Bavarian State Office for Data Protection Supervision) if you are of the opinion that the data processing carried out by us violates applicable data protection law and your rights have been violated.
Right of withdrawal: If we process your data on the basis of consent in accordance with Art. 6 para. 1 sentence 1 lit. a in conjunction with Art. 7 GDPR, you have the right to revoke this consent at any time by notifying us. We would like to point out that all processing based on consent that takes place until withdrawal does not lose its legality.
4. Storage duration
We will store your data for as long as the storage is permitted by law. We will carefully examine the possibility of deletion or restriction in the event that you exercise your rights under Art. 17 and 18 GDPR. We would like to point out that we may still be obliged to store data in individual cases due to legal regulations. Otherwise, data will be deleted as soon as it is no longer required for the intended purpose (purpose limitation).
Beyond this, we only store data insofar as we are obliged to do so by law (in particular § 257 para. 1 HGB in conjunction with § 147 AO) or by official or court order.
5. Order processing and recipients of data
5.1. 5.1 Cloudflare (Cloudflare, Inc)
Um unsere Dienste anbieten zu können, nutzen wir den Cloud-Computing- und Hosting-Dienst Cloudflare. This is necessary to distribute the content of this website via servers in different countries and to optimise performance.
Due to the way in which Cloudflare’s functions are integrated, the service filters all traffic that takes place via this website, i.e. the communication that takes place via this website and the user’s browser, and at the same time enables the collection of analytical data that this website contains.
Personal data processed: Cookie; various types of data as described in the privacy policy of the service.
Cloudflare is used to offer you our website efficiently and securely. This is our legitimate interest according to Art. 6 para. 1 lit. f GDPR.
Processing location: USA – Privacy policy.
5.2. 5.2 Auth0 (Auth0, Inc)
We use Auth0 for registration and authentication to grant you access to specific services.
Auth0 is a registration and login service provided by Auth0, Inc. To simplify the sign-in and sign-out process, Auth0 may use third-party identity services and store the information on its platform.
Personal Data processed: Image; e-mail; first name; last name; password; tracker; various types of data as described in the privacy policy of the service; date of birth, if applicable.
The processing is based on Art. 6 para. 1 lit. b GDPR, as this is necessary for the fulfilment of the contract.
Place of processing: European Union – Privacy Policy.
5.3. 5.3 Direct registration
Registration takes place by filling in the registration form with the user’s personal data directly on this website.
Personal data processed: Address; e-mail; country; name; password; billing address and date of birth, if applicable.
Legal basis: Art. 6 para. 1 lit. b GDPR.
5.4. 5.4 Stripe (payment processing)
We use the payment service provider Stripe of Stripe Technology Europe Ltd.
Payment processing via Stripe is carried out under Stripe’s own responsibility in accordance with Art. 4 No. 7 GDPR. Stripe requires payment data, details of the means of payment and your IP address. This data is transmitted to Stripe.
Processed personal data: see the provider’s privacy policy, including payment data, IP address.
Legal basis: Art. 6 para. 1 sentence 1 lit. f GDPR (legitimate interest in secure payment processing and fraud prevention)
Processing location: Ireland – Privacy Policy.
Note: The parent company Stripe Inc. is based in the USA. If data is transferred there, this is done on the basis of standard data protection clauses with additional protection mechanisms.
5.6. 5.5 PayPal (payment processing)
We also use the payment service provider PayPal of PayPal Inc.
This enables us to provide users with the option of making online payments. PayPal acts on its own responsibility in accordance with Art. 4 No. 7 GDPR. Payment data is also transmitted to PayPal for payment processing.
Processed personal data: E-mail address.
Processing location: See the PayPal Privacy Policy – Privacy Policy.
Legal basis: Art. 6 para. 1 sentence 1 lit. f GDPR (legitimate interest in secure payment processing and fraud prevention)
Insofar as PayPal transfers personal data to the US parent company PayPal Inc. or other companies of the PayPal group of companies, PayPal (Europe) guarantees to maintain the European level of data protection by using binding internal data protection regulations (“Binding Corporate Rules”).
5.6 WP Statistics
We use the analysis tool WP Statistics from Veronalabs OÜ to statistically evaluate visitor access and analyse the use of our website.
Processed personal data: IP address, referrer, browser used, origin of the user, search engine used and actions taken by website visitors on the page (e.g. clicks and views).
We use WP Statistics with anonymised IP. Your IP address is truncated so that it can no longer be directly assigned to you.
WP Statistics is used to improve our service for you. This is our legitimate interest according to Art. 6 para. 1 lit. f GDPR.
Processing location: Estonia – Privacy policy
5.7 Live Ramp, Inc.
If you do not have an active, paid subscription If you do not have an active, paid subscription and enter your e-mail address on our website (to sign up, subscribe to a newsletter or similar), we may share personal or other data we collect from you, such as your e-mail address (in hashed, pseudonymised form), your IP address or information about your browser or operating system with our partner LiveRamp, Inc. and its affiliates. LiveRamp uses this information to create an online identification code that allows you to be recognised on the devices you use. The code does not contain any of your directly identifying personal data and is not used by LiveRamp to directly identify you again. We store the code in our cookie or use a LiveRamp cookie and let you use it for online and cross-platform advertising. It may be shared with our advertising partners and other third-party advertising providers worldwide to enable interest-based content or targeted advertising across your online experience (e.g. web, e-mail, connected devices, apps, etc.). These third parties may in turn use the code to link demographic or interest-based information that you have provided when interacting with them.
You have the right to decide at any time about our use of LiveRamp cookies and our transfer of this data to LiveRamp for the above-mentioned purposes! With an active, paid subscription, these cookies are always deactivated and no data is passed on!
You can find LiveRamp’s privacy policy and the option to object here: https://liveramp.de/privacy/datenschutzerklarung-fur-die-liveramp-dienste/.
6. Cookies
When you log in to your Freechoice account, a first-party cookie is stored and processed so you can use our service.
The cookie recognises the user as a logged-in user. Depending on your personal browser settings, the cookie is usually deleted after closing the browser (temporary cookie).
Technically, it is not possible for the cookie to recognise you as a logged-in user across participating publisher sites, so that a cross-site link is not possible.
