Data Protection Notice

1. What is this Privacy Notice about?

The Playbrush Group (also «we», «us») collects and processes personal data that concern you but also other individuals («third parties»). We use the word «data» here interchangeably with «personal data».

In this Privacy Notice, we describe what we do with your data when you use https://eu.playbrush.com/, our other websites or apps (collectively «website»), obtain services or products from us, interact with us in relation to a contract, communicate with us or otherwise deal with us. When appropriate we will provide a just-in-time notice to cover any additional processing activities not mentioned in this Privacy Notice. In addition, we may inform you about the processing of your data separately, for example in consent forms, terms and conditions, additional privacy notices, forms and other notices.

If you disclose data to us or share data with us about other individuals, we assume that you are authorized to do so and that the relevant data is accurate. When you share data about others with us, you confirm that. Please make sure that these individuals have been informed about this Privacy Notice.

This Privacy Notice is aligned with the EU General Data Protection Regulation («GDPR»), Data Protection Act 2018 (DPA), and the UK General Data Protection Regulation (UK GDPR). However, the application of these laws depends on each individual case.

2. Who is the controller for processing your data?

The Playbrush GmbH, Obere Donaustraße 71/9-12, 1020 Vienna, Austria (the «Playbrush») is the controller for the Playbrush group’s processing under this Privacy Notice, unless we tell you otherwise in an individual case, for example in additional privacy notices, on a form or in a contract. However, unless we tell you otherwise, this Privacy Notice also applies where a group company of the Playbrush group is the controller, instead of Playbrush. This applies, in particular, where your data is processed by a group company in connection with its own legal obligations or contracts or where you share data with such a group company. In these cases, this group company is the controller and only if it shares your data with other group companies for their own processing (see section 7), will these other group companies also become controllers.

You may contact us for data protection concerns and to exercise your rights under Section 11 as follows:

Playbrush GmbH
Obere Donaustraße 71/9-12
1020 Wien
Österreich
support@playbrush.com

We have appointed the following additional positions:

  • Data Protection Representative in the United Kingdom (UK) pursuant to article 27 UK GDPR:
    PlaybrushLtd, UK
    21-24 Millbank London
    SW1P 4QP, London, United Kingdom
    support@playbrush.com
  • Data Protection Representative in the EU according to article 27 GDPR:
    Playbrush GmbH
    Obere Donaustraße 71/9-12
    1020 Wien
    Österreich
    support@playbrush.com

You can also contact these parties for privacy concerns.

3. What data do we process?

All personal data collected by Playbrush will only be stored for as long as necessary for the performance of the contract with users or for the purposes described, unless longer storage is required by law (e.g. 7 years for tax and audit purposes for billing data).

We process various categories of data about you. The main categories of data are the following:

  • Technical data: When you use our website or other online offerings, we collect the IP address of your terminal device and other technical data in order to ensure the functionality and security of these offerings. This data includes logs with records of the use of our systems as well as data related to the use of our brushes. We generally keep technical data for 6 months. In order to ensure the functionality of these offerings, we may also assign an individual code to you or your terminal device (for example as a cookie, see Section 12). Technical data as such does not permit us to draw conclusions about your identity. However, technical data may be linked with other categories of data (and potentially with your person) in relation to user accounts, registrations, access controls or the performance of a contract.
  • Registration data: Certain offerings, for example competitions, and services (such as login areas of our website, newsletters, free WLAN access, etc.) can only be used with a user account or registration, which can happen directly with us or through our third-party login service providers. In this regard you must provide us with certain data, and we collect data about the use of the offering or service. If you redeem a voucher issued by the Playbrush group with us, we may require certain data from you at the time of redemption. If we issue a voucher to you for one of our contractual partners, we may share or receive some of your registration data from the relevant contractual partner (see Section 7). Registration data may be required in relation to access control to certain facilities, potentially including biometric data, depending on the control system. We generally keep registration data for 12 months from the date the use of the service ceases or the user account is closed.
  • Communication data: When you are in contact with us via the contact form, by e-mail, telephone or chat, or by letter or other means of communication, we collect the data exchanged between you and us, including your contact details and the metadata of the communication. If we record or listen in on telephone conversations or video conferences, for example for training and quality assurance purposes, we will tell you specifically. Such recordings may only be made and used in accordance with our internal policies. You will be informed if and when such recordings take place, for example by an indication during the video conference in question. If you do not want to be recorded, please notify us or leave the (video) conference. If you simply do not want your image to be recorded, please turn off your camera. If we have to determine your identity, for example in relation to a request for information, a request for press access, etc., we collect data to identify you (for example a copy of an ID document). We generally keep this data for 12 months from the last exchange between us. This period may be longer where required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. E-mails in personal mailboxes and written correspondence are generally kept for at least 10 years. Recordings of (video) conferences we will usually keep for 24 months. Chats are generally stored for 2 years.
  • Master data: With master data we mean the basic data that we need, in addition to contract data (see below), for the performance of our contractual and other business relationships or for marketing and promotional purposes, such as name and contact details, and information about, for example, your role and function, your bank details, your date of birth, customer history, powers of attorney, signature authorizations and declarations of consent. We process your master data if you are a customer or other business contact or work for one (for example as a contact person of the business partner), or because we wish to address you for our own purposes or for the purposes of a contractual partner (for example as part of marketing and advertising, with invitations to events, with vouchers, with newsletters, etc.). We receive master data from you (for example when you make a purchase or as part of a registration), from parties you work for, or from third parties such as contractual partners, associations and address brokers, and from public sources such as public registers or the internet (websites, social media, etc.). We may also process health data or related data (brushing behavior) and information about third parties as part of master data. We may also collect master data from our shareholders and investors. We generally keep master data for 10 years from the last exchange between us or from the end of the contract. This period may be longer if required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. For contacts used only for marketing and advertising, the retention period is usually much shorter, usually no more than 2 years from the last contact.
  • Contract data: This means data that is collected in relation to the conclusion or performance of a contract, for example information about the contracts and the services provided or to be provided, as well as data from the period leading up to the conclusion of a contract, information required or used for performing a contract, and information about feedback (for example complaints, feedback about satisfaction, etc.). This includes health data and information about third parties (family members using brushes). We generally collect this data from you, from contractual partners and from third parties involved in the performance of the contract, but also from third-party sources (for example credit information providers) and from public sources. We generally keep this data for 10 years from the last contract activity or from the end of the contract. This period may be longer where necessary for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons.
  • Behavioral and preference data: Depending on our relationship with you, we try to get to know you better and to tailor our products, services and offers to you. For this purpose, we collect and process data about your behavior and preferences. We do so by evaluating information about your behavior in our domain, and we may also supplement this information with third-party information, including from public sources. Based on this data, we can for example determine the likelihood that you will use certain services or behave in a certain way. The data processed for this purpose is already known to us (for example where and when you use our services), or we collect it by recording your behavior (for example how you navigate our website). We anonymize or delete this data when it is no longer relevant for the purposes pursued, which may be – depending on the nature of the data – between 2 weeks and 24 months (for product and service preferences). This period may be longer where necessary for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. We describe how tracking works on our website in Section 12.
  • Other data: We also collect data from you in other situations. For example, data that may relate to you (such as files, evidence, etc.) is processed in relation to administrative or judicial proceedings. We may also collect data for health protection (for example as part of health protection concepts). We may obtain or create photos, videos and sound recordings in which you may be identifiable (for example at events, with security cameras, etc.). We may also collect data about who enters certain buildings, and when or who has access rights (including in relation to access controls, based on registration data or lists of visitors, etc.), who participates in events or campaigns (for example competitions) and who uses our infrastructure and systems and when. Moreover, we collect and process data about our shareholders and other investors, in addition to master data, including information for registers, in relation to the exercise of their rights and events (for example general meetings). The retention period for this data depends on the processing purpose and is limited to what is necessary. This ranges from a few days for many security cameras, to a few weeks for contact tracing and visitor data, which is usually kept for 3 months, to several years or more for reports about events with images.
  • Much of the data set out in this Section 3 is provided to us by you (through forms, when you communicate with us, in relation to contracts, when you use the website, etc.). You are not obliged or required to disclose data to us except in certain cases, for example within the framework of binding health protection concepts (legal obligations). If you wish to enter into contracts with us or use our services, you must also provide us with certain data, in particular master data, contract data and registration data, as part of your contractual obligation under the relevant contract. When using our website, the processing of technical data cannot be avoided. If you wish to gain access to certain systems or buildings, you must also provide us with registration data. However, in the case of behavioral and preference data, you generally have the option of objecting or not giving consent.
    As far as it is not unlawful we also collect data from public sources or receive data from other companies within our group, from public authorities and from other third parties (such as credit agencies, address brokers, associations, contractual partners, internet analytics services, etc.).

4. For what purposes do we process your data?

We process your data for the purposes explained below. Further information is set out in Sections 12 and 13 for online services. These purposes and their objectives represent interests of us and potentially of third parties. You can find further information on the legal basis of our processing in Section 5.

We process your data for purposes related to communication with you, in particular in relation to responding to inquiries and the exercise of your rights (Section 11) and to enable us to contact you in case of queries. For this purpose, we use in particular communication data and master data, and registration data in relation to offers and services that you use. We keep this data to document our communication with you, for training purposes, for quality assurance and for follow-up inquiries.

We process data for the conclusion, administration and performance of contractual relationships. This includes the processing of brushing data for the purpose of in-app notifications based on toothbrushing performance (frequency, duration, accuracy), users receive reminders within the respective Playbrush mobile app to use their Playbrush or download more games (contract fulfillment and consent), the Storage of brushing data on toothbrushing performance and aggregation of this data from multiple Playbrush Mobile Applications of a respective user in order to make it accessible to the respective user (or in the case of minors, to his/her legal representative) on the Playbrush Dashboard web application and to display it graphically.

Through the application, parents have the opportunity to view their children's collected data on the Playbrush.com platform, assign it to user profiles and compare it. In doing so, the data is displayed graphically and feedback on toothbrushing performance is provided. Playbrush profiles in the Playbrush Dashboard are always assigned to the profiles of the respective children (only using the selected alias name). The data is only made available to the respective user (or in the case of minors, to their legal representative) and not to third parties. The cleaning data is always stored with a game profile in one of the respective Playbrush mobile applications in connection with the hardware identification number of the Playbrush device, so that it can be clearly assigned (contract fulfillment and consent).

We process data for marketing purposes and relationship management, for example to send our customers and other contractual partners personalized advertising for products and services from us and from third parties (for example from advertising partners). This may happen in the form of newsletters and other regular contacts (electronically, by e-mail or by telephone), through other channels for which we have contact information from you, but also as part of marketing campaigns and may also include free services. You can object to such contacts at any time (see at the end of this Section 4) or refuse or withdraw consent to be contacted for marketing purposes. With your consent, we can target our online advertising on the internet more specifically to you (see Section 12). Finally, we also wish to enable our contractual partners to contact our customers and other contractual partners for marketing purposes (see Section 7).

We further process your data for market research, to improve our services and operations, for product development and to provide technical support for users (contract fulfillment). This includes the analysis of the collected brushing data to develop personalized performance improvement advice for the respective user, which is provided to the user within the respective Playbrush mobile application or within the Playbrush Dashboard application (contract fulfillment and consent), the analysis of collected brushing data in terms of toothbrushing performance by aggregating it with other users' data to explore toothbrushing behaviors and opportunities for improvement in general contract fulfillment and consent)

We may also process your data for security, access control purposes and fraud prevention and detection (legitimate interest in the security and integrity of the systems).

We process personal data to comply with laws, directives and recommendations from authorities and internal regulations («Compliance»).

We also process data for the purposes of our risk management and as part of our corporate governance, including business organization and development.

We may process your data for further purposes, as part of our internal processes and administration or for quality assurance purposes and trainings. These further purposes may include Storage for the purpose of comparing the toothbrushing performance data collected by the Playbrush mobile applications with other users' data by graphically displaying it under the respective selected alias name.

5. On what basis do we process your data?

Where we ask for your consent for certain processing activities (for example for the processing of sensitive personal data, for marketing mailings, for personalized motion profiles and for advertising management and behavior analysis on the website), we will inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future by providing us written notice (by mail) or, unless otherwise noted or agreed, by sending an e-mail to us or selecting the appropriate setting in our apps and cookies management; see our contact details in Section 2. For withdrawing consent for online tracking, see Section 12. Where you have a user account, you may also withdraw consent or contact us also through the relevant website or other service, as applicable. Once we have received notification of withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.

Where we do not ask for consent for processing, the processing of your personal data relies on the requirement of the processing for initiating or performing a contract with you (or the entity you represent) or on our or a third-party legitimate interest in the particular processing, in particular in pursuing the purposes and objectives set out in Section 4 and in implementing related measures. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognized as a legal basis by applicable data protection law (for example in the case of the GDPR, the laws in the EEA and in the case of the UK DPA and GDPR the UK law). This also includes the marketing of our products and services, the interest in better understanding our markets and in managing and further developing our company, including its operations, safely and efficiently.

Where we receive sensitive personal data (for example health data, data about political opinions, religious or philosophical beliefs, and biometric data for identification purposes), we may process your data on other legal basis, for example, in the event of a dispute, as required in relation to a potential litigation or for the enforcement or defense of legal claims. In some cases, other legal basis may apply, which we will communicate to you separately as necessary.

6. What applies in case of profiling and automated individual decisions?

We may automatically evaluate personal aspects relating to you («profiling») based on your data (Section 3) for the purposes set out in Section 4, where we wish to determine preference data, but also in order to detect misuse and security risks, to perform statistical analysis or for operational planning. We may also create profiles for these purposes, i.e. we may combine behavioral and preference data, but also master data, contract data and technical data relating to you in order to better understand you as a person with your various interests and other characteristics.

In both cases, we pay attention to the proportionality and reliability of the results and take measures against misuse of these profiles or profiling. Where these can produce legal effects concerning you or similarly significantly affect you, we generally ensure human review.

In certain situations, it may be necessary for the efficiency and consistency of decision-making processes that we automate discretionary decisions that produce legal effects concerning you or similarly significantly affect you («automated individual decisions»). In these cases, we will inform you accordingly and take the measures required by applicable law.

7. With whom do we share your data?

In relation to our contracts, the website, our services and products, our legal obligations or otherwise with protecting our legitimate interests and the other purposes set out in Section 4, we may disclose your personal data to third parties, in particular to the following categories of recipients:

  • Group companies: A list of our group companies can be found here. These group companies may use the data according to this Privacy Notice for the same purposes as we use it (see Section 4). We may also disclose health and related data to our group companies.
    In the context of providing the APPs, Playbrush GmbH Austria works closely with its subsidiary Playbrush Ltd. UK. This also concerns the processing of your personal data. The group companies have jointly determined the order of processing of this data in the individual process sections. They are therefore jointly responsible for the protection of your personal data within the process sections described below (Art. 26 DS-GVO).
    As part of the signup process in the app, your data is collected by the group companies. The app is developed and technically administered by Playbrush UK as well as provided as a rights holder. In addition, after the signup you can conclude service contracts (subscriptions) and possible further purchase contracts (hardware) with Playbrush Austria. The group companies operate a central database in which all customer data, i.e. the data from the APPs, as well as the purchase information and any insurance benefits are recorded and used for contract fulfillment as well as for product improvement, support and for own marketing purposes (e.g. newsletter). In the majority of cases, this data is used by Playbrush Austria as the central point of contact. The processing by Playbrush UK is limited here to the provision of the technical infrastructure and the granting of license rights to the users of the APPs. A detailed description of the purpose of the processing can be found in Section 4.
  • As part of their joint responsibility under data protection law, the group companies have agreed which of them will fulfill which obligations under the GDPR. This relates in particular to the exercise of the rights of data subjects and the fulfillment of the information obligations under Articles 13 and 14 of the GDPR. This agreement is necessary because when using the APPs and Products, personal data is processed in different process sections and systems operated by our group companies. In section 4 you will find the description of the data collection,- processing and transfers with reference to the respective service. Even if there is joint responsibility, the group companies will fulfill the data protection obligations according to their respective responsibilities for the individual process steps as described in Section 4. The group companies shall make the information required under Articles 13 and 14 of the GDPR available to the data subjects free of charge in a precise, transparent, understandable and easily accessible form in clear and simple language. In doing so, each party shall provide the other party with all necessary information from its sphere of influence. The group companies shall inform each other without delay about legal positions asserted by affected parties. They shall provide each other with all information necessary to respond to requests for information. As a contact and information point, affected parties can contact Playbrush Austria (privacy@playbrush.com) directly.
  • Service providers: We work with service providers in Switzerland and abroad who process your data on our behalf or as joint controllers with us or who receive data about you from us as separate controllers (for example IT providers, shipping companies, advertising service providers, login service providers, cleaning companies, security companies, banks, insurance companies, debt collection companies, credit information agencies, or address verification providers). This may include health data. For the service providers used for the website, see Section 12. Key service providers in the IT area are Google…, Amazon Web Services EMEA SARL, Luxembourg (Server in EU, Recurring Payments, Data Storage), ObjectLabs Corporation, 660 York St. Suite 101, CA 94110 San Francisco, USA (Data Storage), Stripe payments Europe Ltd., 1 Grand Canal street Lower, Grand Canal Dock, Dublin, Ireland (Purchases, Payment Processing Platform, Recurring Payments, Accounting), Klarna Bank AB (publ) Sveavägen 46, 111 34 Stockholm, Schweden (Payment Processing Platform, Recurring Payments), PayPal (Europe) S.à. r. l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg (Payment processing Platform, Recurring Payments), SUXESS LOGISTIC GmbH, Wargamer Strasse 120/37, 1220 Wien, Österreich (Shipment), Billomat GmbH & Co. KG, Lorenzer Straße 31, 90402 Nürnberg, Germany (Accounting), sevDesk GmbH, Hauptstraße 115, 77652 Offenburg, Germany (Accounting), Xero (NZ) Limited, 19-23 Taranaki Street, Wellington 6011 New Zealand (Accounting), Freshworks, Inc., 1250 Bayhill Drive, Suite 315, CA 94066 San Bruno, USA (Q&A & Support), The Rocket Science Group LLC (Mailchimp), 675 Ponce De Leon Ave NE Ste 5000, GA 30308 Atlanta, USA (Newsletter).
  • Contractual partners including customers: This refers to customers (for example service recipients) and our other contractual partners as this data disclosure results from these contracts. For example, they receive registration data in relation to issued and redeemed vouchers, invitations, etc. If you work for one of these contractual partners, we may also disclose data about you to that partner in this regard. This may include health data. These recipients also include contractual partners with whom we cooperate or who carry out advertising for us and to whom we may therefore disclose data about you for analysis and marketing purposes (these may again be service recipients, but also sponsors and online advertising providers). We require these partners to send you or display advertising based on your data only with your consent (for online advertising, see Section 12). Our online advertising partners are listed in Section 12.
  • Authorities: We may disclose personal data to agencies, courts and other authorities in Switzerland and abroad if we are legally obliged or entitled to make such disclosures or if it appears necessary to protect our interests. This may include health data. These authorities act as separate controllers.
  • Other persons: This means other cases where interactions with third parties follows from the purposes set out in Section 4.

All these categories of recipients may involve third parties, so that your data may also be disclosed to them. We can restrict the processing by certain third parties (for example IT providers), but not by others (for example authorities, banks, etc.).

8. Is your personal data disclosed abroad?

As explained in section 7, we disclose data to other parties. These are not all located in Austria. Your data may therefore be processed both in Europe and in the UK; in exceptional cases, in any country in the world.

If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the revised European Commission’s standard contractual clauses, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exception. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing.

Please note that data exchanged via the internet is often routed through third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country.

9. How long do we process your data?

We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in documentation and keeping evidence require it or storage is a technical requirement. You will find further information on the respective storage and processing periods for the individual data categories in Section 3, and for cookies in Section 12. If there are no contrary legal or contractual obligations, we will delete or anonymize your data once the storage or processing period has expired as part of our usual processes.

10. How do we protect your data?

We take appropriate security measures in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.

11. What are your rights?

Applicable data protection laws grant you the right to object to the processing of your data in some circumstances, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing.

To help you control the processing of your personal data, you have the following rights in relation to our data processing, depending on the applicable data protection law:

  • The right to request information from us as to whether and what data we process from you;
  • The right to have us correct data if it is inaccurate;
  • The right to request erasure of data;
  • The right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
  • The right to withdraw consent, where our processing is based on your consent;
  • The right to receive, upon request, further information that is helpful for the exercise of these rights;
  • The right to express your point of view in case of automated individual decisions (Section 6) and to request that the decision be reviewed by a human.

If you wish to exercise the above-mentioned rights in relation to us (or with one of our group companies), please contact us in writing, at our premises or, unless otherwise specified or agreed, by e-mail; you will find our contact details in Section 2. In order for us to be able to prevent misuse, we need to identify you (for example by means of a copy of your ID card, unless identification is not possible otherwise).

You also have these rights in relation to other parties that cooperate with us as separate controllers – please contact them directly if you wish to exercise your rights in relation to their processing. You will find information on our key partners and service providers in Section7 and additional information in Section 12.

Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.

If you do not agree with the way we handle your rights or with our data protection practices, please let us (Section 2) know. If you are located in the EEA, the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country. You can find a list of authorities in the EEA here: https://edpb.europa.eu/about-edpb/board/members_en. You can reach the UK supervisory authority here: https://ico.org.uk/global/contact-us/.

12. Do we use online tracking and online advertising techniques?

We use various techniques on our website that allow us and third parties engaged by us to recognize you during your use of our website, and possibly to track you across several visits. This Section informs you about this.

In essence, we wish to distinguish access by you (through your system) from access by other users, so that we can ensure the functionality of the website and carry out analysis and personalization. We do not intend to determine your identity, even if that is possible where we or third parties engaged by us can identify you by combination with registration data.  However, even without registration data, the technologies we use are designed in such a way that you are recognized as an individual visitor each time you access the website, for example by our server (or third-party servers ) that assign a specific identification number to you or your browser (so-called «cookie»).

We use these technologies on our website and may allow certain third parties to do so as well. However, depending on the purpose of these technologies, we may ask for consent before they are used. You can access your current settings here . You can also set your browser to block or deceive certain types of cookies or alternative technologies, or to delete existing cookies. You can also add software to your browser that blocks certain third-party tracking. You can find more information on the help pages of your browser (usually with the keyword «Privacy») or on the websites of the third parties set out below.

We distinguish the following categories of «cookies» (including other technologies such as fingerprinting):

  • Necessary cookies: Some cookies are necessary for the functioning of the website or for certain features. For example, they ensure that you can move between pages without losing information that was entered in a form. They also ensure that you stay logged in. These cookies exist temporarily only («session cookies»). If you block them, the website may not work properly. Other cookies are necessary for the server to store options or information (which you have entered) beyond a session (i.e. a visit to the website) if you use this function (for example language settings, consents, automatic login functionality, etc.). These cookies have an expiration date of up to 24 months.
  • Performance cookies: In order to optimize our website and related offers and to better adapt them to the needs of the users, we use cookies to record and analyze the use of our website, potentially beyond one session. We use third-party analytics services for this purpose. We have listed them below. Before we use such cookies, we ask for your consent. You can withdraw consent at any time through the cookie settings at the bottom of the page. Performance cookies also have an expiration date of up to 24 months. Details can be found on the websites of the third-party providers.
  • Marketing Cookies: We and our advertising partners have an interest in targeting advertising as precisely as possible, i.e. only showing it to those we wish to address. We have listed our advertising partners below. For this purpose, we and our advertising partners – if you consent – use cookies that can record the content that has been accessed or the contracts that have been concluded. This allows us and our advertising partners to display advertisements that we think will interest you on our website, but also on other websites that display advertisements from us or our advertising partners. These cookies have an expiration period of a few days to 12 months, depending on the circumstances. If you consent to the use of these cookies, you will be shown related advertisements. If you do not consent to them, you will not see less advertisements, but simply any other advertisement.

In addition to marketing cookies, we use other technologies to control online advertising on other websites and thereby reduce advertising wastage.

We currently use offers from the following service providers and advertising partners (where they use data from you or cookies set on your computer for advertising purposes.

13. What data do we process on our social network pages?

We may operate pages and other online presences («fan pages», «channels», «profiles», etc.) on social networks and other platforms operated by third parties and collect the data about you described in Section 3 and below. We receive this data from you and from the platforms when you interact with us through our online presence (for example when you communicate with us, comment on our content or visit our online presence). At the same time, the platforms analyze your use of our online presences and combine this data with other data they have about you (for example about your behavior and preferences). They also process this data for their own purposes, in particular for marketing and market research purposes (for example to personalize advertising) and to manage their platforms (for example what content they show you) and, to that end, they act as separate controllers.

We process this data for the purposes set out in Section 4, in particular for communication, for marketing purposes (including advertising on these platforms, see Section 12) and for market research. You will find information about the applicable legal basis in Section 5. We may disseminate content published by you (for example comments on an announcement), for example as part of our advertising on the platform or elsewhere. We or the operators of the platforms may also delete or restrict content from or about you in accordance with their terms of use (for example inappropriate comments).

For further information on the processing of the platform operators, please refer to the privacy information of the relevant platforms. There you can also find out about the countries where they process your data, your rights of access and erasure of data and other data subjects rights and how you can exercise them or obtain further information. We currently use the following platforms:

  • Facebook: On Facebook we operate the pages www.facebook.com/gumkinder and www.facebook.com/SunstarGUMUSA. The controller for the operation of the platform for users from Europe is Facebook Ireland Ltd., Dublin, Ireland. Their privacy notice is available at www.facebook.com/policy. Some of your data will be transferred to the United States. You can object to advertising here: www.facebook.com/settings?tab=ads. With regard to the data collected and processed when visiting our site for «page insights», we are joint controllers with Facebook Ireland Ltd., Dublin, Ireland. As part of page insights, statistics are created about the actions visitors perform on our site (comment on posts, share content, etc.). This is explained at www.facebook.com/legal/terms/information_about_page_insights_data. It helps us understand how our page is used and how to improve it. We receive only anonymous, aggregated data. We have agreed our data protection responsibilities according to the information on www.facebook.com/legal/terms/page_controller_addendum.
  • Instagram
  • TikTok
  • Pinterest
  • Youtube

14. Can we update this Privacy Notice ?

This Privacy Notice is not part of a contract with you. We can change this Privacy Notice at any time. The version published on this website is the current version.

Last updated: 20.11.2023