SponsorPay GmbH Privacy Policy
This is the privacy policy of SponsorPay GmbH, Ackerstr. 14/15, 10115 Berlin, (heretoafter referred to as "SponsorPay"). It applies to all SponsorPay websites and services.
This privacy policy is intended for all users of SponsorPay websites and services ("user"). The SponsorPay services relate primarily to advertising from third parties ("advertising partners") on websites operated by other third parties ("publishers"). Thus users are predominantly advertisers, publishers and other interested parties or their employees. Among the users are also users of services on the Internet provided by publishers ("publisher-user") as well as other private users who are in direct contact with us.
All personal information that the user provides in the course of all business relations that SponsorPay collects through use of the websites and services and the user voluntarily submits will of course be handled by SponsorPay in regards to applicable data protection legal provisions.
SponsorPay saves and uses data to prevent and combat fraud and abuse on SponsorPay pages and to offer services adapted to our users.The details are laid out in this privacy policy.
In the event that the user is forwarded – for instance via a link or an advertisement – to another website not operated by SponsorPay, the user will be informed by SponsorPay that this document does not apply to website concerned. This privacy policy does not apply to the websites of the publishers. SponsorPay is not responsible for the way the operator of the other website handles data. In particular, SponsorPay is not responsible for the fact that this privacy policy does not apply on websites not operated by SponsorPay. SponsorPay recommends that users always carefully read the privacy policy of third policy websites.
I. Which personal information does SponsorPay collect, process and store?
SponsorPay collects, processes and stores that personal information that SponsorPay collects from the user or the user voluntarily submits (for instance in forms or elsewhere on websites or for services operated by SponsorPay) in electronic or any other form of communication.
To register to use the websites or services from SponsorPay the users needs to submit certain personal information. This includes among other things names, position in the company and email address.
The following describes which information is stored by SponsorPay:
Usage data:
When a user makes use of websites or services operated by SponsorPay, the latter automatically saves the domain name and/or IP address of the computer used to contact SponsorPay; the date as well as the length of the visit at websites and services operated by SponsorPay for instance through cookies; as well as pages accessed by the user on SponsorPay operated websites and services as well as the browser used.
Mobile Use of SponsorPay Services:
Users can also access content and services from SponsorPay on mobile devices (such as smartphones or other mobile devices that use the Apple iOS). SponsorPay additionally stores the device's identification number (i.e. UDID or IMEI) that accesses the content as well as the standard technical information such as the operating system version and the device type to enable the user to access the content or service.
Email Address:
SponsorPay stores the email addresses of its users if they are submitted. The user can either submit their email address voluntarily via contact form through the websites or services of SponsorPay or submit it in the course of direct communication with SponsorPay.
Information resulting from communication with SponsorPay:
When the user submits a ticket to SponsorPay customer support, SponsorPay saves the history of communication with the user as well as the information submitted by the user in the course of the communication (for example the email address), to answer their inquiry as best we can. SponsorPay does not share this information with third parties.
Other, voluntarily submitted information about the user:
SponsorPay always strives to improve its offerings and services as well as to adapt them to its users. Therefore the user can submit additional information to SponsorPay as part of the use of SponsorPay offers and services or in the course of direct communication with SponsorPay such as name, address, age, gender, interests and, if applicable, payment data (if the user processes a payment via SponsorPay). The user can also allow SponsorPay to record their usage behavior on partner websites.
Usage data of users of offers from publishers (publisher-user):
The publisher who works with SponsorPay shares information about publisher-user's usage behavior with SponsorPay. SponsorPay needs the publisher-user's data so that the user can receive benefits for offers from the publisher. In doing so, the publisher assigns each user a personal ("UserID") connected with the usage data. The UserID can only be read out by the publisher. SponsorPay cannot directly associate the usage data shared by the publishers via the UserID with the user. The identity of the publisher-user can only be determined by SponsorPay if the publisher-user itself initiates such a request.
Therefore, the information transmitted to SponsorPay by the publishers is not related to one individual unless the publisher-user disclosed its identity thus waiving the protection of his private information (for instance accessing the publisher's content with a user name connected to the real name or entering the email address on the publisher's website). In this case, but not solely, SponsorPay is entitled to the above-mentioned rights to use the personal information.
Publisher-users should check the privacy policy of the publisher's website in regard to the publisher's handling of personal information.
II. How does SponsorPay use personal information?
Usage data from users and publisher-users:
Optimization of the service
SponsorPay collects, processes, and stores users' personal information, in so far as SponsorPay sees legitimate business purposes for it. In other words: SponsorPay collects, processes, and stores the user data to better understand users of their websites and services and thus offer them better services. SponsorPay can, for instance, not only use the information stored for direct processing of the agreement concluded with the user (i.e. use of services, creation of invoices, use of customer support), but we can also use it to identify malfunctions and/or misuse of SponsorPay websites and services.
Prevention and combat of abuse
Therefore, SponsorPay logs and stores information on the use of SponsorPay websites and services such as activity on the publisher's website and regard to customers' advertisements or services. These include the monitoring of behavior patterns and checking for manipulations that can be useful in detecting misuse or improper activity by the user or user-publisher. SponsorPay uses special software, for example, to detect the use of illicit scripts and identify the IP address as well as other data in regard to the behavior of users and publisher-users. If SponsorPay determines that a user or user-publisher violates its contractual obligations, for instance by using illicit scripts, SponsorPay explicitly reserves the right to bring the user's or user-publisher's data together with other data stored by SponsorPay on this person to prove the violation. SponsorPay will then possibly take additional measures against the users or publisher-users concerned to restore normal operation.
Billing of services
SponsorPay is entitled to share user data with the service provider responsible for payment processing insofar as this is required for billing. SponsorPay is also entitled to provide user data to third parties authorized to collect outstanding balances, insofar as this information is required or useful to collect the balance. SponsorPay will inform the user of the name of the third party. If SponsorPay cooperates with third parties for these services, SponsorPay will obligate them to observe applicable data protection laws and guarantee sufficient data protection.
Market research
SponsorPay is entitled to use the information stored by and from the user or publisher-user to evaluate demography, interests and user behavior. This occurs anonymously. SponsorPay is also entitled to analyze information stored about the user or publisher-user in an anonymous, statistical and aggregate form. If and to the extent to which SponsorPay uses data to create user profiles, SponsorPay will never share the profiles with third parties without the consent of the person concerned and will immediately cease the use of the user profile if said objects to it.
Personalized offers tailored to the user.
SponsorPay may allow third parties to contact the user for advertising purposes. As long as the user does not object to the use of its user data for this purpose, advertising can be sent that matches his or her profile and interests (based on the information submitted to SponsorPay as well as the actions within SponsorPay websites and services. This information cannot be attributed to the user, unless the user voluntarily made this information known on a website operated by or on behalf of SponsorPay.
Email Address:
SponsorPay can use the email addresses acquired through an offer from SponsorPay or received directly from the user, to send the user newsletters and information on SponsorPay offers. The user can of course withdraw this consent in writing at any time (for example via email) at no charge, apart from costs incurred for transmission of the withdrawal (at the basic rates). The user will have the opportunity in every information and newsletter sent by SponsorPay to unsubscribe or send a cancellation notice.
Miscellaneous, voluntarily submitted information:
If the user voluntarily shares personal information on request by SponsorPay, then SponsorPay will use this information with his or her consent so that the user receives personalized special offers.
III. Which information does SponsorPay share?
User data
Personal and pseudonymized user data are used solely by SponsorPay and not shared with third parties. Third parties receive information about user behavior only without being able to attribute it to a specific person.
Personal information about the user
SponsorPay will use and when necessary share personal information in the course of fraud prevention and detection.
SponsorPay will transmit user's personal information to advertisers only when the user redeems a promotional offer of such a partner company participates in a survey and the information is required for processing or for participation in the survey.
SponsorPay will not provide third parties with email addresses or information from the communication with customer support or other information volunteered to SponsorPay.
IV. Change or delete personal information
The user and publisher-user can change their personal information at any time (for example to update or correct it) or delete their information altogether. The user or publisher-user can contact customersupport@sponsorpay.com if they would like SponsorPay to change or stop using their information. SponsorPay will change or delete the user's or publisher-user's information as quickly as possible. However, SponsorPay points out that due to technical and organizational constraints, it is possible that some ongoing measures or those have not yet begun may continue to be carried out after SponsorPay the request for deletion has been made.
V. Disclosure of personal information
On request, SponsorPay will disclose all of the information stored about the user or publisher-user immediately and at no charge. This information will always be conveyed in electronic form - normally via email.
SponsorPay reserves the right to change this privacy policy at any time while observing current data protection laws. SponsorPay recommends that you regularly inform yourself about the current privacy policy. In the event that SponsorPay intends to use personal user or publisher-user information on a larger scale than up to now, SponsorPay will of course announce this beforehand.
Data protection officer: Michael Panienka, 32791 Lage, Germany
Glossary
The most important terms are explained below to help understand the privacy policy:
What is personal information?
Personal information is information that can be attributed to an identified or identifiable user. This information can be used to contact or identify the user outside of the website and the services of SponsorPay. This information includes, for instance, the user's name, email address, telephone number, and mailing address or credit card details.
What is user data?
User data is information that SponsorPay collects, processes and stores when the website is used. User data include in particular the features necessary to identify the user (such as the domain name and/or IP address of the computer used to contact SponsorPay, which can be used to determine the location of the computer), information about the start and end of the respective use of the SponsorPay websites and services as well as information about the pages accessed.
What are IP addresses?
IP addresses serve to identify devices that are connected to the Internet. Every computer connected to the Internet can be attributed to a specific IP address or combination of numbers.
What are UDID and IMEI?
The UDID and IMEI serve as identification of mobile devices. The iPhone manufacturer Apple Inc. uses the so-called UDID, whereas the IMEI is used for other mobile devices. The codes are stored in the devices and cannot be modified by the user.
What is a cookie?
A cookie is a small text file that websites and services operated by SponsorPay - transfer to the cookie file of the user's browser so that the website and services can identify you the next time you visit. A cookie typically contains the name of the domain from which the cookie has come, the "life span" of the cookie, and a value, usually a randomly generated unique number. With the help of cookies, SponsorPay is able to recognize the user. This can help facilitate the use of SponsorPay websites and services. However, cookies per se cannot be used to identify the user. Of course, SponsorPay websites and services can also be used without cookies if the browser is set to decline cookies. Cookies already placed on the computer can be manually deleted by the user at any time. SponsorPay warns the user that use of its websites and services without cookies may be limited.
Last updated: March 31, 2011
