This service (hereinafter "App") is provided by Rissland Marketing UG, Kurfürsten-Anlage 52, 69115 Heidelberg, Germany, represented by its managing director Alexander Rissland (hereinafter "we" or "us") as the responsible party within the meaning of the applicable data protection law.
With our app, we enable interaction between users and advertising companies (hereinafter referred to as partner companies). Our services include:
Our service is insofar based on an evaluation of the user's surfing behaviour, whereby we also make use of the help of third parties (Google Ireland Limited, Ireland).
As a thank you for participating in various campaigns, users receive points that are paid out in the form of rewards (e.g. a gift voucher). If there are matches between the user's interest and the offer of a partner company, the user is also informed about relevant offers of the respective partner company.
The use of the app, as well as the performance of actions, tasks and surveys, is voluntary and can also be cancelled at any time.
When using the app, we process personal data (in particular the IP address, preferences, etc.) about you, whereby we avoid sensitive topics such as religion, health and sexuality.
Personal data means any information relating to an identified or identifiable natural person.
Because protecting your privacy when using the app is important to us, we would like to inform you in the following which personal data we process when you use the app and how we handle this data. In addition, we will inform you about the legal basis for the processing of your data and, insofar as the processing is necessary to protect our legitimate interests, also about our legitimate interests.
You can access this privacy policy at any time under the menu item "Settings" > "Privacy" within the app.
Certain information is already processed automatically when you use the app. We have listed exactly which personal data is processed for you below:
When downloading the app, certain required information is transmitted to the app store selected by you (e.g. Google Play or Apple App Store), in particular the user name, the email address, the customer number of your account, the time of the download, payment information and the individual device identification number may be processed. The processing of this data is carried out exclusively by the respective App Store and is beyond our control. If you would like more information on this, you should take a look at the privacy policy of the respective app store.
As part of your use of the App, we automatically collect certain data that is necessary for the use of the App. This includes:
Internal device ID, version of your operating system, time of access, IP address.
This data is automatically transmitted to us, but not stored, (1) to provide you with the Service and related features; (2) to improve the functions and performance features of the App; and (3) to prevent and remedy misuse and malfunctions. This data processing is justified by the fact that (1) the processing is necessary for the performance of the contract between you as the data subject and us pursuant to Art. 6 (1) (b) DSGVO for the use of the App, and / or (2) we have a legitimate interest in ensuring the functionality and error-free operation of the App and in being able to offer a service that is in line with the market and interests, which here outweighs your rights and interests in the protection of your personal data within the meaning of Art. 6 (1) (f) DSGVO.
When you create a user account or register, we use your access data (email address and password) to grant you access to your user account and to manage it ("mandatory data"). Mandatory data within the scope of registration are required for the conclusion of the user contract. If you do not provide this information, you will not be able to create a user account.
We use the mandatory data to authenticate you when you log in and to follow up on requests to reset your password. We process and use the information you provide during registration or login to (1) verify your eligibility to manage the user account; (2) enforce the app's terms of use and any associated rights and obligations; and (3) contact you to send you technical or legal notices, updates, security notifications or other messages relating to, for example, the management of the user account.
This data processing is justified by the fact that (1) the processing is necessary for the performance of the contract between you as the data subject and us pursuant to Art. 6 (1) (b) DSGVO for the use of the app, and / or (2) we have a legitimate interest in ensuring the functionality and error-free operation of the app, which here outweighs your rights and interests in the protection of your personal data within the meaning of Art. 6 (1) (f) DSGVO.
Within the framework of the app, you can carry out, manage and edit various activities. As part of the activities, we store certain information about you and your user and surfing behaviour. The most important functions of the app include that
The following data processing takes place:
We store your activities, such as survey results, in order to transmit them anonymously as statistical evaluation data to partner companies after the end of a campaign. These partner companies in turn use this data for marketing and analysis purposes.
In addition, we integrate third-party advertisements and videos within the app via the "Google Admob" advertising network and the "YouTube" video portal of the Irish company Google Ireland Limited. You can find more details on data processing in this respect under point 2 of this notice.
The app also requires the following authorisations:
The processing and use of usage data is carried out to provide the service. This data processing is justified by the fact that the processing is necessary for the performance of the contract between you as the data subject and us pursuant to Art. 6 (1) lit. b) DSGVO for the use of the app. Data processing for advertising purposes is a main service in this respect. In addition, we have a legitimate interest in the data processing within the meaning of Art. 6 para. 1 lit. f DSGVO. Since you are free to use our app and we also provide detailed information about data processing, our legitimate interest outweighs your rights and freedoms.
Our app is for marketing purposes and is ad-supported. As we use Google AdMob and YouTube to display personalised ads and partner videos within the app, you consent to the transfer of your personal data such as the advertising ID of your device, the IP address, your location data, your interactions with advertisers' ads via cookies or cookie-like technologies (so-called mobile identifiers, e.g. Google AdMob and YouTube). mobile identifier, e.g. Web Beacon, IDFA, GAID) to Google Ireland Limited, Ireland, as the provider of Google AdMob and YouTube, as well as to the Google partner companies named below (hereinafter referred to as advertising partners) for the purpose of generating and displaying personalised advertising.
In the case of Google AdMob, conversion statistics are created for AdWords customers (advertising partners) who have opted for conversion tracking via cookie-like technologies (so-called mobile identifiers). Mobile identifiers are stored on your end device and enable the storage of information with which your surfing behaviour can be tracked. The advertising partners thus learn the total number of users who clicked on their ad and were redirected to a page marked with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users.
When clicking on a partner video, we use the YouTube service. We use the extended data protection mode, which, according to the provider, only starts storing user information when the video(s) is/are played. If the playback of embedded YouTube videos is started, Google uses "YouTube" cookies or mobile identifiers to collect information about user behaviour. According to information from "Youtube", these are used, among other things, to collect video statistics, to improve user-friendliness and to prevent abusive behaviour. If you are logged in to Google, your data is directly assigned to your account when you click on a video.
We have no influence on the data processing by Google after clicking on a partner video / an advertisement. The data processing is then the sole responsibility of Google Ireland Limited.
Details of what data Google collects and how it is processed can be found here:
Admob: https://policies.google.com/technologies/ads
YouTube and other Google services: https://policies.google.com/privacy
This application also uses the Pollfish SDK. Pollfish is an online survey platform that allows anyone to conduct surveys. Pollfish works with publishers of applications for smartphones to gain access to users of such applications and direct questionnaires to them. When a user connects to this app, a certain set of the user's device data (including the advertising ID, the device ID if the app user has enabled access to their advertising and/or device ID either through their system settings or through a consent prompt displayed to them) and other response metadata is automatically sent to Pollfish's servers through our app so that Pollfish can determine whether the user is eligible for a survey. Pollfish is a US-based company, so you expressly consent to the transfer of this data to the US. Pollfish collects and processes your data in accordance with all applicable GDPR requirements. For a full list of the data Pollfish receives through this App and for more information about how Pollfish processes this data, please carefully read Pollfish's Respondent Terms at https://www.pollfish.com/terms/respondent. This data will be associated with your responses to questionnaires when Pollfish sends such questionnaires to eligible users. Your data may be transferred by Pollfish to non-EEA countries in accordance with all applicable GDPR requirements, including the use of the EU Commission's standard contractual clauses. Pollfish may share this data with third parties, customers and business partners for commercial purposes. By downloading the Application, you accept this Privacy Policy and hereby give your consent to the processing of the above data by Pollfish. In addition, you are informed that you can deactivate the operation of Pollfish at any time by clicking on the following link: https://www.pollfish.com/respondent/opt-out. We invite you to read Pollfish's Terms of Use again if you would like to have a more detailed insight into how Pollfish works and to know with whom Pollfish shares your data.
NOTE:
We would like to point out once again in all clarity that the purpose of our service / our app is the evaluation of your surfing behaviour by processing your data in order to use this data for the purpose of online marketing in so-called advertising networks. "Online marketing" includes in particular the referral of the user of the app to advertising partners of ours and the interaction with advertising material provided by advertising partners in the app and through links. Your data will not only be evaluated and used by us, but also by third parties such as Google Ireland Limited and our advertising partners.
If you would like to deactivate personalised advertising on your mobile device, you can deactivate interest-based advertising when using Android smartphones (Google Setting => Setting => Google => Display => Deactivate interest-based advertising). In this case, however, certain functions of our app can no longer be used. The same applies to deactivating the operation of Pollfish.
If you do not wish to be associated with your YouTube profile, you must log out before clicking on the video. You also have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.
You can revoke your consent at any time under the menu item "Profile" => "Settings" => "Revoke consent" with effect for the future. In this case, however, participation in campaigns (surveys, videos, messages, etc.) and the receipt of rewards are no longer possible.
We would like to point out that rewards are only due once a certain number of "Smatches" points has been reached. If the user revokes his/her consent to data processing before reaching this number of points, the premium can no longer be distributed.
The legal basis for the forwarding and transfer of data is - in addition to the legal bases mentioned below - your consent, Art. 6 para. 1 lit. a) DSGVO.
In addition to the cases explicitly mentioned in this data protection declaration, your personal data will only be passed on without your express prior consent if this is permitted or required by law. A technical transfer may also take place if and to the extent that this is necessary for the operation of our app or for other reasons for the establishment, implementation or processing of your user relationship with us. This may be the case, for example, if we host the app with an external service provider. If this is not a case of commissioned processing, the transfer is based on Art. 6 para. 1 lit. b) DSGVO.
2.1 As a matter of principle, we do not pass on to third parties the personal data that you provide when registering.
2.2 The data that we receive from you when you redeem / order a premium (first name, surname, address) will only be passed on to the company delivering the premium for the purpose of sending the premium. This transfer of your data is justified by the fact that (1) the transfer of the data is necessary for the fulfilment of the contract between you as the data subject and us in accordance with Art. 6 Para. 1 lit. b) DSGVO for the use of the app, as we would otherwise not be able to send you the rewards. (2) We also have a legitimate interest within the meaning of Art. 6 (1) (f) DSGVO in sending you the rewards by way of a so-called drop shipment (i.e. directly from the manufacturer of the rewards, e.g. from the brewery). In this respect, your rights and freedoms do not outweigh our legitimate interests in the delivery of the rewards.
2.3 Irrespective of your consent referred to in section 2.2, we also disclose your personal data, such as your advertising ID, to our advertising partners and the aforementioned third parties on the basis of a legitimate interest within the meaning of Article 6(1)(f) and on the basis of the user agreement concluded with us pursuant to Article 6(1)(b) of the Data Protection Regulation. Since we offer our app free of charge, we have a legitimate interest in using marketing tools such as Google AdMob. This interest also outweighs the interests of the user, as it is up to each user whether they want to use our app and participate in promotions, surveys, games, etc.
2.4 If it is necessary to clarify an illegal or abusive use of the app or for legal prosecution, personal data will be forwarded to law enforcement agencies or other authorities and, if applicable, to injured third parties or legal advisors. However, this only happens if there are indications of unlawful or abusive behaviour. A transfer may also take place if this serves the enforcement of terms of use or other legal claims. We are also legally obliged to provide information to certain public authorities upon request. These are law enforcement agencies, authorities that prosecute administrative offences subject to fines and the tax authorities.
Any disclosure of personal data is justified by the fact that (1) the processing is necessary for compliance with a legal obligation to which we are subject pursuant to Art. 6 para. 1 lit. f) DSGVO in conjunction with. national legal requirements to disclose data to law enforcement authorities, or (2) we have a legitimate interest in disclosing the data to the aforementioned third parties if there are indications of abusive behaviour or to enforce our terms of use, other conditions or legal claims, and your rights and interests in the protection of your personal data within the meaning of Art. 6 para. 1 lit. f) DSGVO are not overridden.
2.5 We rely on the following third party companies and external service providers to provide our service:
Transport and logistics companies, such as DHL, etc.
technical support: Antony Konstantinidis,
Google Ireland Limited, Ireland. (Google AdMob / YouTube)
Pollfish Inc, USA
Hoster: Amazon Web Services Inc, United Stated, our servers are hosted in eu-central-1 located in Frankfurt (AWS)
Any disclosure of personal data is justified by the fact that (1) this is either necessary for the implementation of the user relationship, Art. 6 para. 1 lit. b) or (2) we have a legitimate interest in the data processing, Art. 6 para. 1 lit. f) or we have carefully selected our third-party companies and external service providers as processors within the framework of Art. 28 para. 1 DSGVO, regularly checked them and contractually obliged them to process all personal data exclusively in accordance with our instructions.
2.6 As part of the development of our business, the structure of our company may change by changing its legal form, establishing, buying or selling subsidiaries, parts of companies or components. In such transactions, customer information may be transferred along with the part of the business being transferred. In any transfer of personal information to third parties to the extent described above, we will ensure that it is done in accordance with this Privacy Policy and applicable data protection law.
Any disclosure of personal data is justified by the fact that we have a legitimate interest in adapting our corporate form to the economic and legal circumstances as required and that your rights and interests in the protection of your personal data within the meaning of Article 6 (1) (f) of the Data Protection Regulation are not overridden.
In addition, you will be redirected to third parties who are responsible for data processing when you click on or download third-party content. This content is marked as third-party content. It may be external links in messages, apps from third parties, tasks from third parties, etc..
You are leaving our app.
We use so-called cookie technology in our app. Cookies are small text files that are sent from our server to your smartphone when you use the app and are stored there for later retrieval. We use both so-called session cookies (also referred to as temporary cookies) and cookies that are stored for a longer period of time (also referred to as persistent cookies).
We use cookies to continue to identify your smartphone during your app use, but also to detect the end of your use and to be able to recognise your device when you use it again.
You delete the cookies by deleting the smatched app from your smartphone.
As explained in section 2, Google also uses cookie-like technologies. If you do not want to allow tracking, you must either revoke your consent or delete our app.
Processing of your personal data for purposes other than those described will only take place if permitted by law or if you have consented to the changed purpose of the data processing. In the event of further processing for purposes other than those for which the data was originally collected, we will inform you about these other purposes prior to further processing and provide you with all other relevant information.
We will delete or anonymise your personal data as soon as it is no longer necessary for the purposes for which we collected or used it in accordance with the above paragraphs. As a rule, we store your personal data for the duration of the usage or contractual relationship via the app plus a period of 7 days, during which we keep backup copies after deletion, unless this data is required for longer for criminal prosecution or to secure, assert or enforce legal claims.
Specific statements in this privacy policy or legal requirements for the retention and deletion of personal data, in particular data that we are required to retain for tax reasons, remain unaffected.
You have the right to receive information from us at any time, upon request, about the personal data we process concerning you within the scope of Art. 15 DSGVO. To do this, you can send a request by post or email to the address below.
You have the right to ask us to correct personal data relating to you without delay if it is inaccurate. To do so, please contact us at the addresses below.
You have the right to request that we delete the personal data relating to you under the conditions described in Article 17 of the GDPR. These conditions provide in particular for the right to erasure if the personal data are no longer necessary for the purposes for which they were collected or otherwise processed, as well as in cases of unlawful processing, the existence of an objection or the existence of an erasure obligation under Union law or the law of the Member State to which we are subject. For the period of data storage, please also see section 6 of this privacy policy. To exercise your right to erasure, please contact us at the addresses below.
You have the right to demand that we restrict processing in accordance with Art. 18 DSGVO. This right exists in particular if the accuracy of the personal data is disputed between the user and us, for the duration that the verification of the accuracy requires, as well as in the event that the user requests restricted processing instead of erasure in the case of an existing right to erasure; furthermore, in the event that the data is no longer necessary for the purposes pursued by us, but the user requires it for the assertion, exercise or defence of legal claims, as well as if the successful exercise of an objection is still disputed between us and the user. To exercise your right to restrict processing, please contact us at the contact addresses below.
You have the right to receive from us the personal data relating to you that you have provided to us in a structured, commonly used, machine-readable format in accordance with Article 20 of the GDPR. To exercise your right to data portability, please contact us at the addresses below.
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out, inter alia, on the basis of Article 6(1)(e) or (f) DSGVO, in accordance with Article 21 DSGVO. We will stop processing your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if the processing serves the purpose of asserting, exercising or defending legal claims. In the event of objection, you will no longer be able to use the app.
If you have given us consent to data processing, you can revoke this at any time with effect for the future via the menu item "Profile" => "Settings" => "Revoke consent" or our contact details given in the imprint. The use of the app is no longer possible after the revocation.
You also have the right to complain to the relevant supervisory authority. You can find a list of supervisory authorities here:
https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node
If you have any questions or comments about our handling of your personal data, or if you wish to exercise your rights as a data subject, please contact Rissland Marketing UG (hb), Mr Alexander Rissland at the following contact details: Kurfürsten-Anlage 52 in 69115 Heidelberg, Email: alex@smatched.de
In order to protect your data from manipulation, loss and unauthorised access by third parties, for example, we use technical and organisational measures to ensure an appropriate level of protection for your personal data. These measures include the use of firewalls and antivirus programs as well as manual security precautions. We continuously review and improve our security measures in line with the current state of the art. In addition, in accordance with the principle of "data protection by default", the strictest privacy settings are preset when you first register.
We always keep this privacy policy up to date. Therefore, we reserve the right to change it from time to time and to update any changes in the collection, processing or use of your data. The current version of the privacy policy is always available under "Settings" > "Privacy" within the app.
Status: 17.08.2021