Privacy policy

Responsible entity:

Welect GmbH

Duisburger Straße 19

40477 Düsseldorf

Germany

Phone.: +49 211 1581 9744

E-Mail: datenschutz@welect.de

Website: www.welect.de

Data protection officer:

AGOR AG

Niddastraße 74

60329 Frankfurt am Main

Germany

Phone: +49 (0) 69 - 9494 32 410

E-Mail: info@agor-ag.com

Website: www.agor-ag.com

General information on data processing

Scope of the processing of personal data

As a matter of principle, we collect and use personal data of the users of our homepage only to the extent that this is necessary for the provision of a functional website, our contents and services.

As a matter of principle, the collection and use of personal data of our users is only carried out with their consent. An exception to this principle applies in cases where processing of the data is permitted by legal regulations or where obtaining prior consent is not possible for actual reasons.

Legal basis for the processing of personal data

The legal basis for the processing of personal data result in principle from:

Art. 6 (1) p. 1 lit. a GDPR when obtaining the consent of the data subject.

Art. 6 para. 1 p. 1 lit. b GDPR for processing operations that serve to fulfill a contract to which the data subject is a party. Included here are processing operations that are necessary for the implementation of pre-contractual measures.

Art. 6 (1) sentence 1 lit. c GDPR for processing operations that are necessary for the fulfillment of a legal obligation.

Art. 6 (1) p. 1 lit. d GDPR if vital interests of the data subject or another natural person make processing of personal data necessary.

Art. 6 para. 1 p. 1 lit. f GDPR, if the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the former interest. In order to be able to base the processing of personal data on a legitimate interest, an assessment is carried out in each case in consultation with the Data Protection Officer for each relevant process, whereby the following three conditions must be met:

1. The controller or a third party has a legitimate interest in the processing of personal data.

2. The processing is necessary to safeguard the legitimate interest.

3. Interests or fundamental rights and freedoms of the data subject which require the protection of personal data do not prevail.

Data deletion and storage period

Users' personal data will be deleted or blocked as soon as the purpose for storing it no longer applies. Storage beyond this may take place if this has been provided for by the European or national legislator in Union regulations, laws or other regulations to which the responsible party is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.

Use of our website, general information

Description and scope of data processing

Each time our website is accessed, our system automatically collects data and information from the user's computer system. The following information may be collected:

· Information about the browser type and version used,

· Operating system used,

· Internet service provider,

· IP address,

· Time and date of the server request,

· Websites from which the user's system accesses our website,

· Websites accessed by the user's system through our website.

Purpose and legal basis for data processing

The temporary storage of the IP address by our system is necessary to enable delivery of the website to the user's computer. For this purpose, the user's IP address must remain stored for the duration of the session.

The temporary storage in log files is done to ensure the functionality of the website.

The legal basis for the temporary storage of the data and the log files is Art. 6 para. 1 p. 1 lit. f GDPR.

The collection of your personal data for the provision of our website and the storage of the data in log files is necessary for the operation of the website. There is therefore no possibility of objection by the user.

Duration of storage

Your data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. If your data is collected to ensure the provision of the website, the data will be deleted when the respective session has ended.

General information on the use of cookies

Cookies are text files that are stored in the Internet browser or by the Internet browser on the user's computer system. When you access a website, a cookie may be stored on your operating system. This contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again.

TDDDG:

The legal basis for the storage of cookies, device identifiers and similar tracking technologies or for the storage of information in the end user's terminal equipment and access to this information is the European ePrivacy Directive in conjunction with the Telecommunications and Telemedia Data Protection Act (TDDDG).

Please note that the legal basis for the processing of personal data collected in this context is then derived from the GDPR (Art. 6 para. 1 p.1 GDPR). The relevant legal basis for the processing of personal data in each specific case can be found below the respective cookie or the respective processing itself.

The primary legal basis for the storage of information in the end user's terminal equipment - consequently in particular for the storage of cookies - is your consent, Section 25 para. 1 p.1 TDDDG. Consent is given when you visit our website - although it does not have to be given, of course - and can be revoked at any time in the cookie settings.

According to Section 25 (2) No. 2 TDDDG, consent is not required if the storage of information in the end user's terminal equipment or access to information already stored in the end user's terminal equipment is absolutely necessary for the provider of a telemedia service to provide a telemedia service expressly requested by the user. You can see from the cookie settings which cookies are to be classified as absolutely necessary (often also referred to as "technically necessary cookies"), and therefore fall under the exception of Section 25 (2) TDDDG and thus do not require consent.

GDPR:

No technically essential cookies are used. Cookies are stored on the user's computer and transmitted from it to our site. As a user, you therefore have control over the use of cookies. You can restrict or deactivate the transmission of cookies by making changes in the settings of your Internet browser. There, stored cookies can also be deleted again. Please note that you may no longer be able to use all the functions of our website if you disable cookies.

The legal basis for the processing of personal data using cookies results from Art. 6 para. 1 p. 1 lit. f GDPR. The purpose of the use of technically necessary cookies is to simplify the use of our website. We do not use user data collected through technically necessary cookies to create user profiles.

The legal basis for the processing of personal data using cookies for analysis and advertising purposes is Art. 6 para. 1 p. 1 lit. a GDPR if the user has consented to this.

Your rights / rights of the data subject

According to the EU General Data Protection Regulation, you have the following rights as a data subject:

Right to information

You have the right to receive information from us as the responsible party as to whether and which personal data concerning you are processed by us, as well as further information in accordance with the legal requirements under Art. 13, 14 GDPR.

You could assert your right to information at: datenschutz@welect.de.

Right to rectification
If the personal data processed by us and concerning you is incorrect or incomplete, you have a right to rectification and/or completion vis-à-vis us. The correction will be made without delay.

Right to restriction
You have the right to restrict the processing of personal data concerning you in accordance with the legal provisions (Art. 18 GDPR).

Right to deletion

If the reasons outlined in Art. 17 GDPR apply, you may request that the personal data concerning you be deleted without delay.

We would like to point out that the right to erasure does not exist insofar as the processing is necessary for one of the exceptional circumstances mentioned in Art. 17 (3).

Right to information
If you have asserted the right to rectification, erasure or restriction of processing, we are obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. Furthermore, you have the right to be informed about these recipients.

Right to data portability
According to the GDPR, you also have the right to receive the personal data concerning you that has been provided to us in a structured, common and machine-readable format or to request its transfer to another controller.

Right to revoke the declaration of consent under data protection law.

You have the right to revoke your declaration of consent under data protection law at any time. We would like to point out that the revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

Right of objection
Furthermore, you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you which is carried out on the basis of Article 6 (1) sentence 1 lit. e or f GDPR.

Automated decision in individual cases including profiling
According to the EU General Data Protection Regulation, you also have the right not to be subject to a decision based solely on automated processing - including profiling - which produces legal effects concerning you or similarly significantly affects you.

Right to lodge a complaint with a supervisory authority

Finally, if you consider that the processing of personal data concerning you infringes the GDPR, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, workplace or the place of the alleged infringement.

Data transfer outside the EU

The GDPR ensures an equally high level of data protection within the European Union. When selecting our service providers, we therefore rely on European partners wherever possible when your personal data is to be processed. Only in exceptional cases will we have data processed outside the European Union in the context of using third-party services. We will only allow your data to be processed in a third country if the special requirements of Art. 44 et seq. GDPR are fulfilled. This means that the processing of your data may then only take place on the basis of special guarantees, such as the officially recognized determination by the EU Commission of a level of data protection corresponding to the EU or the observance of officially recognized special contractual obligations, the so-called "standard data protection clauses".

EU-US Trans-Atlantic Data Privacy Framework
Within the framework of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the level of data protection for certain companies from the U.S. as safe within the framework of the adequacy decision of 10.07.2023. The list of certified companies as well as further information on the DPF can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/s/participant-search.

What is the IAB Transparency and Consent Framework (IAB TCF)?
We participate in the IAB TCF. The IAB TCF is a common standard for handling transparency requirements and obtaining consent related to online advertising. Companies organized within the IAB TCF commit to adhering to standards beyond the GDPR. Welect is registered under the IAB TCF as a vendor (T.C.F. 2.2.). More information can be accessed at:https://iabeurope.eu/tcf-for-vendors/. We recommend all our customers to also register within the IAB TCF. If you utilize a service from a company already registered as a publisher within the IAB TCF, you benefit from it. The IAB TCF provides transparency and control over the usage of your personal data. On a technical level, the latest version of the IAB TCF (currently Version 2.2) allows each involved company to track which processing activities are permissible based on the user's individual choices. (Vendor ID- 282)

Minors under 16 years

Minors under the age of 16 are expressly not addressed to our website and our offers on this website. We point out that legal guardians must accompany the online activities of their children. Minors under the age of 16 should not transmit any personal data to us without the consent of their parents or legal guardians. We explicitly do not request personal data from minors under the age of 16, do not knowingly collect such data and do not pass it on to third parties.

Electronic contact

If you wish to contact us, you have the option of contacting us via the e-mail address provided. In this case, the user's personal data transmitted with the e-mail will be stored.

Your data will not be passed on to third parties in this context; the data will be used exclusively for processing the establishment of communication.

The legal basis for the processing of the contact request and its handling is regularly Art. 6 para. 1 p.1 lit. b GDPR.

If further personal data is processed during the sending process, this is only used to prevent misuse of the contact form and to ensure the security of our information technology systems.

Your data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is ended when it is clear from the circumstances that the matter in question has been conclusively clarified.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

Social Media

We currently use the following social media platforms:

Facebook

Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland

Opt-Out: https://www.facebook.com/settings?tab=ads

and http://www.youronlinechoices.com

Instagram

Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland

Twitter

Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.

Opt-Out: https://twitter.com/settings/account/personalization

LinkedIn

LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland

Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

Xing

XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany

Social media presence

We maintain fan pages within various social networks and platforms with the aim of communicating with customers, interested parties and users active there and informing them about our services there.

We would like to point out that in doing so, your personal data may be processed outside the European Union, so that risks may arise for you in this regard (for example, when enforcing your rights under European / German law).

User data is usually processed for market research and advertising purposes. For example, usage profiles can be created from the usage behavior and resulting interests of the users. These usage profiles can in turn be used, for example, to place advertisements within and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and interests of the users are stored. Furthermore, data may also be stored in the usage profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

The processing of the users' personal data is based on our legitimate interests in effectively informing users and communicating with users pursuant to Art. 6 para. 1 p. 1 lit. f. GDPR. If the users are asked by the respective providers for consent to data processing (i.e. declare their consent, e.g. by ticking a checkbox or confirming a button), the legal basis of the processing is Art. 6 para. 1 p. 1 lit. a. GDPR.

For more information about the processing of your personal data and your objection options, please refer to the links of the respective provider listed below. The assertion of information and other rights of the data subjects can also be made against the providers, then only they have direct access to the data of the users and have the corresponding information. Of course, we are available to answer any questions and to support you if you need assistance.

WelectPublish

Our product, WelectPublish, is utilized by our contractual partners, referred to as publishers. These publishers operate online platforms and use our product to finance the provision of free content on their digital platforms while respecting the privacy of their website visitors.

With WelectPublish, we provide publishers with technical solutions to integrate advertising on their platforms using our Choice Driven Advertising model (CDA). Visitors are presented with various categories of advertising content to choose from, allowing them to select the ads most relevant to them. After watching the selected advertisement, visitors gain free, time-limited access to the desired content on the website. This choice-driven advertising model enables us to minimize tracking the interests of website users.

Use, Functionality, and Legal Basis of Cookies (Tracking Technologies)

The technical implementation involves the use of tracking technologies, referred to here as "cookies." Below, we explain how our product functions both when website visitors provide their consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR for the processing of personal data or § 25 para. 1 TTDSG for the processing of data from technical devices without personal identifiers, and when no consent is provided.

Shortened IP Address

The shortened IP address is used to determine the approximate location of users and to provide regional advertising offers. The last 8 bits of the IP address are deleted for advertising purposes to ensure user anonymity. Storage lasts for a maximum of seven days. After each session, the shortened IP address is no longer used for advertising purposes. The IP address is only stored to verify fraudulent IP addresses for billing purposes with our partners and is then deleted.

Processing is based on consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR. If no consent is provided, processing is carried out under legitimate interest in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR. If you have questions regarding this, particularly about the balancing of interests, we are happy to assist.

mable_key

This cookie is used for frequency capping, ensuring that the same advertisement is not displayed to users multiple times. It is used exclusively on the respective website, with no cross-site tracking. The storage duration is 14 days, and the domain is welect.de. The cookie is only set with the user's consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR. Without consent, the cookie is not set.

Adblock Detection

This function checks whether an ad blocker is active. If so, users are given the option to disable the ad blocker or view alternative advertisements to access website content. Data is deleted after ad delivery. Processing is based on legitimate interest under Art. 6 para. 1 sentence 1 lit. f GDPR. If you have questions regarding this, particularly about the balancing of interests, we are happy to assist.

welect_lease_token

This cookie stores a randomly generated token that contains no personal data. The token enables time-limited access to website content after users have viewed an advertisement. The storage duration is a maximum of two days, and the domain is *.welect.de. Processing is carried out with consent in accordance with Art. 25 para. 1 TTDSG or without consent in accordance with Art. 25 para. 2 TTDSG, as the cookie is deemed technically necessary. If you have questions regarding this, particularly about technical necessity, we are happy to assist.

Ad Fraud Prevention

To prevent ad fraud, we use the FouAnalytics – Fraud Detection Analysis tool, provided by H.O.T. AG. This tool analyzes technical data such as browser information, operating systems, and user behavior to distinguish between human users and bots. Processing is based on our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR. All personal data, such as IP addresses, is anonymized at an early stage. Data is deleted after a maximum of 24 months.

For detailed information on FouAnalytics' data protection practices, please refer to their privacy policy.

Additionally, we use the verification provider IAS (Integral Ad Science). IAS provides us with IP addresses valid for seven days, after which they are deleted. These IP addresses represent invalid, fraudulent addresses, ensuring that no ads are displayed to them. Furthermore, we integrate a fraud tracking pixel from IAS during ad delivery. This pixel is used solely to monitor fraudulent or suspicious traffic. Processing is based on our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR. For more information, please refer to the IAS Privacy Policy.

No Sharing or Selling of Personal Data

We do not share or sell personal data to third parties. Data without personal identifiers is used solely with your consent for internal market research purposes and to improve our services.

Integrated Third-Party Providers

When integrating third-party providers (e.g., within PUR subscription models where multiple providers are connected at the request of the publisher or website administrator), data collection and processing are carried out independently by these providers. Please refer to their respective privacy policies and contact details.

Welect SSP

The Sell Side Platform (SSP) is our technology for digital service operators, helping publishers and online platforms manage, optimize, and sell their advertising inventories. This enables our business partners/customers to offer their digital advertising spaces to various DSPs (Demand-Side Platforms) in real-time auctions by providing the necessary technology for this process. Through the platform, publishers and marketers can manage ad inventory sales and access related analytics.

Our business partners act independently when processing personal data related to their activities.