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plista Privacy Policy

This Privacy Policy describes how plista collects and uses data from web sites, applications and other digital properties (we refer to all of these below as “Sites”) in connection with its products and services as well as from its corporate web sites (www.plista.com, planet.plista.com and blog.plista.com; collectively, the “plista web sites”) and how individuals can manage choices and exercise rights related to certain data collected or used in our products and services and on the plista web sites.

Who are we?

plista GmbH, with registered office address at Torstrasse 33-35, D-10119 Berlin (Tel.: +49 (0) 30 4737537-0; Fax: +49 (0) 30 484984411; Email: privacy@www.plista.com) is a global platform for data-driven native advertising. Other than when acting at the direction of a client or other third party, plista (“we”, “us” or “our”) is a data controller responsible for your personal data when you interact with our Services or visit the plista web sites. If you have any questions or comments regarding this Privacy Policy, please contact our Data Protection Officer, by email to privacy@www.plista.com or in writing to plista, Data Protection Officer, Torstrasse 33-35, D-10119 Berlin, Germany, Attn: Privacy.

What are our Services?

plista does not provide services directly to consumers. Instead, we provide our business clients with services focused on customized recommendations of content and ads to users of Sites within the plista-network, i. e. those web sites, apps and other digital properties on which plista products are used (“Services”). This is done by plista recommending users certain content or ads based on an analysis of certain user information collected or accessed across Sites, such as (i) content based on their interests, (ii) content based on the interests of similar users, and (iii) content that they have previously viewed on Sites outside the plista-network and location information (“User Information”). We call this type of advertising “Interest-Based Advertising”.

What information is collected and utilized by plista?

plista Services are designed to collect and/or utilize information regarding individuals’ browsing, usage and interactions when they view and interact with Sites and with advertisements where our Services are utilized. We also collect information that identifies browsers and devices with which we have interacted previously. Such information includes the following categories of data:

Technical Identifiers

These can be used to identify your browser, mobile advertising environment, and/or device, and typically include: + Cookie IDs + Mobile advertising IDs (e.g., IDFAs and Google Advertising IDs)

Additional Technical Information

+ Internet protocol address (“IP address”) and data derived from an IP address, such as non-precise geolocation data that indicates the country, region, city, and/or postal code of a device + Type of Internet browser, browser language, and operating system + Connection type (wired or Wi-Fi), network to which the device is connected, and mobile carrier (if available) + Latitude/longitude of a mobile device. For purposes of this Privacy Policy, “mobile device” includes smartphones and tablet computers.

Online Activity Information

plista Services collect information on your online browsing activity to determine what types of activities, services and products you and other users may be interested in and how you and other users interact with certain content and ads. This information includes: + Information relating to the Sites and pages viewed (i.e., in order to ascertain interests) + Site/page you came from before, and visited after, viewing an advertisement + Date and time of online activity + Frequency and duration of visits to a Site + Interaction with an advertisement, article, content, such as clicks and conversions

User Information received from third parties

We also receive User Information from other companies, including our affiliates, clients, partners and carefully selected service providers, that is collected outside the Services and is provided to us for use in our Services to improve our recommendations. For example, if a Site user was previously surfing on a Site outside of the plista-network where technologies of a plista partner are integrated, the relevant partner may also have set a cookie on the user´s device, which contains a randomly assigned identifier (“Partner ID”) and which can be recognized and used by plista. In order to recommend content to the user of Sites in the plista-network which he/she has previously viewed on Sites outside the plista-network, plista can recognize the user on the basis of the Partner ID and exchange the plista cookie ID with the respective partner, so that the user can be displayed the previously viewed content correctly. When we receive User Information from third parties, such information is provided to us via a service provider in conjunction with a cookie ID, advertising ID, or similar user ID that identifies a customer or consumer to the client or service provider, but we do not receive any names, addresses, phone numbers, email addresses or similar data that would enable identification of a particular individual connected with these IDs.

Information collected on the plista web sites

On the plista web sites, plista collects, via cookies, web beacons and similar technologies as described above information about our visitors and how they use the plista web sites, including browser type, the web site they were visiting before they visited the plista web sites, time of day, their IP address, their mobile advertising IDs and similar device identifiers (“Usage Data”). We use Usage Data for a variety of purposes, including to improve the plista web sites and Services. plista receives information that enables identification of a particular individual, such as names and personal contact information, through the plista web sites only when you choose to submit this information to us (for example, through a contact form, request to receive a newsletter or email marketing or as part of your submission of a job application). Our service providers and we will use information collected through the plista web sites to provide features and services, to process your job application or other request, to contact you with information, for internal business purposes, for customer service purposes and as otherwise described in this Privacy Policy.

How do we collect information?

We collect information and receive information on behalf of our clients about users through the use of cookies, advertising IDs, pixels, and other technologies when a user visits the Sites on which plista provides Services or when a user visits the plista web sites. Here are some explanations of these terms:

Cookie

is a small alphanumeric text file that is stored in a browser by a web site or by a third-party ad server or other third party which allows that web site or third party to recognize that browser and remember User Information and other information.

Advertising ID

is an alphanumeric identifier made available by a platform or operating system (such as Apple iOS or Google Android) that allows application developers and third parties to recognize a particular device in an application environment. It is associated with User Information and other information and, together with such associated information, is used in the performance of our Services, and in particular Interest-Based Advertising activities.

Pixel

is a line of code that is used by a Site or third party to assign online activities to a device or browser, or more specifically to the applicable cookie or advertising ID. The use of a pixel allows us to record, for example, that a device or browser has visited a particular Site or page.

In browser environments, plista installs cookies in the user´s browser, including a Targeting Cookie that contains a randomly assigned identifier (cookie ID). In mobile app environments, the relevant app provider shares the user´s advertising ID with plista. Subsequently, plista collects the user’s User Information across Sites within the plista-network. The data collected does not include names, mailing addresses, phone numbers, email addresses or similar personal data. Each time a user visits a Site within the plista-network, plista analyzes the User Information associated with the user’s ID (either cookie ID or advertising ID) and provides individual recommendations of content and ads based on the user’s interests or on the interests of similar Site visitors.

Cookies used for the plista Services

The following chart provides information about our cookies used for rendering Services, which are set in the browsers of Site users, all of which are “persistent” cookies (meaning they are stored until they expire or are deleted/removed by a user):

plista Targeting Cookie (“Pookie”)

Functionality: With this cookie, we assign the user a random identifier (cookie ID) and collect User Information based on the user’s web browsing behavior and activities, which is used in the performance of our Services, and in particular Interest-Based Advertising activities. Retention Period: 1 year

plista Opt-Out Cookie (“Ploptout”)

Functionality: This cookie informs us that a visitor to a plista Site used the opt-out function in order to no longer receive Interest-Based Advertising from plista. Retention Period: 30 years

plista Retargeting Cookie (“rt11”)

Functionality: This cookie records the IDs of the user’s retargeting campaigns communicated to us by our partners / service providers. Retention Period: 60 days

plista User Matching Cookie (“um”)

Functionality: This cookie lists the third party IDs of the user communicated to us by our demand side platform (“DSP”) partners / service providers. Retention Period: 30 days

plista Article Impressions Cookie (“arv”)

Functionality: This cookie informs us of the articles previously visited by the user and helps us to optimize article recommendations. Retention Period: 3 days

plista Recommendation Clicks Cookie (“rec”)

Functionality: This cookie informs us of the recommendations the user has previously clicked on and helps us to optimize ad recommendations. Retention Period: 3 days

plista Recommendation Impressions Cookie (“red”)

Functionality: This cookie informs us of the recommendations previously displayed to the user. Retention Period: 3 days

plista Frequency Capping Cookie (“frc”)

Functionality: This cookie helps us to ensure that only a limited number of ad impressions is shown to the user in a given timeframe. Retention Period: 3 days

plista Impression Rotation Cookie (“imp”)

Functionality: This cookie helps us to ensure that the user is shown the broadest possible variety of ads and article recommendations. Retention Period: 3 days

plista Click Rotation Cookie (“cls”)

Functionality: This cookie helps us to ensure that the user is no longer shown advertisements he has already clicked. Retention Period: 3 days

Cookies used for the plista web sites

The following chart provides information on the cookies used on the plista web sites:

plista Session Cookie (“PHPSESSID“)

Functionality: This session cookie allows the browser of a visitor to the plista web sites to be recognized as an active visitor and the navigation on the plista web sites is always assigned to this browser, so that the visitor does not have to start anew at every step. Retention Period: Automatic deletion when closing the browser

plista Opt-Out Cookie (“Ploptout”)

Functionality: This cookie informs us that a visitor to the plista web sites used the opt-out function in order to no longer receive Interest-Based Advertising from plista. Retention Period: 30 years

plista Cookie-Info Cookie (“cookie_notice-accepted”)

Functionality: This cookie informs us that a visitor to the plista web sites has been shown the information on the use of cookies by plista (so-called cookie banner) and that the visitor has subsequently clicked on the “ok” button. Retention Period: 2 months

plista Planet Cookies (“user-email”, “user-token_pl” und “user_token_pl”)

Functionality: These session cookies are only set in browsers of users of the plista web site planet.plista.com and make its use more comfortable for these users by storing the respective login data. Retention Period: Automatic deletion when closing the browser

Google Cookies (i. e. “_ga”, “_gat UA”, “__utma”, “__utmz“)

Functionality: These cookies from our service provider, Google, allow us to use Google Analytics and Google Tag Manager to collect information about how our visitors use the plista web sites. The information generated by the cookies about your use of the plista web sites is usually transmitted to a Google server in the USA and stored there. As “IP anonymization” is activated for the plista web sites, your IP address will be truncated by Google within EU or EEA Member States, and only in exceptional cases will the full IP address be transmitted to a Google server in the US and be truncated there. According to Google’s terms, the IP address transmitted by your browser in the context of Google Analytics will not be merged with other data of Google. You can prevent transmission of the data generated by the cookies and relating to your usage of the plista web sites (incl. your IP address) to Google as well as the processing of these data by Google by downloading and installing the browser plug-in available at the following link:

For information on the data use and retention practices of Google and its affiliates and subsidiaries, please see Google’s privacy policy currently located at www.google.com/privacy.html. Retention Period: 10 minutes (_gat und _gat UTA) , Up to 3 years (_ga)

Linkpulse Cookie (“_lp4_u“)

Functionality: This cookie of our service provider, Linkpulse, allows us to collect information about how our visitors use the plista web sites. Retention Period: Automatic deletion when closing the browser For Linkpulse´s privacy policy, please visit:

Stripe Cookies (i. e. “__stripe_mid“ und “__stripe_sid“)

Functionality: These session cookies of our service provider, Stripe, are only set if a user of the plista web site planet.plista.com choses Stripe as a payment service provider. Retention Period: Automatic deletion when closing the browser For Stripe´s privacy policy, please visit:

Vimeo Cookies (i. e. “player”, “vuid”, “_utmt_player“)

Functionality: These cookies from our service provider Vimeo are necessary to provide visitors of our website with additional functions, including video. Retention Period: From automatic deletion when closing the browser up to 2 years For Vimeo

How do we use this information?

plista processes the User Information it collects and receives for the purposes of providing the following Services to clients, as well as for administrative, security and compliance purposes. Specifically, we carry out the following activities:

Ad/ Content Selection, Delivery, Reporting

In order to provide our Services, we analyze the User Information collected and received over a period of time across different Sites and/or access or store information on devices (via cookie IDs and advertising IDs, as applicable) for the purpose of delivering advertising and content to Site users. We may also integrate (and use for the same purpose) User Information obtained from third parties.

Measurement

We process User Information to deliver ads and content and to measure the delivery of such ads and content, to learn about what factors make advertising successful or unsuccessful and generate reports to understand and improve Service usage and advertising effectiveness.

Storage and Access of Information

In order to provide our Services, we store and recognize our Cookies on users’ browsers and receive and recognize advertising IDs associated with users’ mobile device platforms/operating systems. We use the information collected and received for the above purposes through typical methodologies used in Interest-Based Advertising, such as cookie matching where we share User Information associated with the cookie IDs we have assigned with select third parties and service providers in order to display certain types of ads and content.

Whom do we share data with?

plista shares data with third-party service providers that perform services and functions on our behalf and/or on behalf of our clients, such as companies that are involved in the delivery of Interest-Based Advertising – including demand-side platforms, advertising networks, advertising exchanges, and ad servers; as well as service providers that help us administer the plista web sites and provide marketing assistance. If we reasonably believe we are obliged by law or legal process to disclose information to a third party (including law enforcement), then we will do so. In addition, we may disclose information to a third party (including an auditor or other service provider) in order to investigate, prevent, or take action regarding suspected or actual prohibited activities and/or in order to review, evaluate, or address the integrity or security of our Services or the plista web sites.

Memberships

We are a member of the European Interactive Digital Advertising Alliance (EDAA). In connection with such membership, we adhere to the IAB Europe EU Framework for Online Behavioural Advertising, and we support deployment of the Advertising Option icons (AdChoices). Advertisements that are provided by organizations that participate in these frameworks display the icon shown below when technologically feasible. Clicking on such icon provides you with information about Interest-Based Advertising.

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We are also participating in the IAB Europe’s Transparency & Consent Framework as a “global vendor”.

Opt-Out/Right to Withdraw Consent

You may opt out of plista Interest-Based Advertising through several mechanisms. You may choose not to receive customized third-party ads or content via plista Targeting Cookies on the browser you are using by clicking below, in which case the plista Targeting Cookie will be replaced with an “Opt-out” Cookie and the Interest-Based Advertising data previously collected or received in association with the replaced plista Targeting Cookie will not be used for Interest-Based Advertising on any other device or browser that we have reasonably linked to the browser where the information was collected. To opt out of data collection via cookies from plista please click here:

Our Opt-out Cookies are programmed to expire thirty years after they are initially issued. If you buy a new device, upgrade or change web browsers or delete this opt-out cookie, you will need to perform the opt-out process again. In order for the opt-out process to work, your browser must be set to accept third-party cookies. In browser environments, you may also refuse or remove cookies from both plista and other service providers, via the following methods: + Adjusting your browser settings to refuse or remove cookies, which would result in the cessation of Interest-Based Advertising via cookies from plista and from other providers. However, by doing so, you may not be able to use certain features on certain web sites or take full advantage of all web site offerings and Interest-Based Advertising. You may refuse or remove cookies by following the directions provided in your browser settings. Further information about cookies is available at

+ Adjusting the cookie settings at the level of the web site owner where you granted us consent to our cookie usage; cookie settings options may vary by web site owner. + Opting out of Interest-Based Advertising via our targeting cookies, as well as the targeting cookies of other service providers, at the following web site: www.youronlinechoices.com (by clicking the “Your ad choices” link after selecting the appropriate country)

In mobile app environments, you may opt out of Interest-Based Advertising from just plista or from both plista and other service providers, via the following method: + Selecting “Limit Ad Tracking” via your device settings, which will result in the elimination of Interest-Based Advertising via the applicable advertising ID from plista and from other providers.

Children’s Privacy

plista’s Services and the plista web sites are not directed at children (as defined by applicable law) or at Sites primarily directed to children. plista does not knowingly collect information from children (determined in accordance with the age requirement for the applicable country). If you believe a child has provided us with personal data and would like to have the information removed, please contact us at privacy@www.plista.com.

Transfer of Data in the Event of Acquisition

In the event that another company acquires all or substantially all of our assets or all or substantially all of the assets of our business through a consolidation, merger, asset purchase, corporate reorganization, or other transaction, we reserve the right to transfer all information that is in our possession or under our control to the acquiring party.

Information Security and Global Data Transfers

We follow generally accepted online advertising industry standards to protect against unauthorized access to, unlawful processing of, unauthorized retention of, and unauthorized disclosure of data. These standards include undertaking necessary physical, electronic, and management activities required to protect data integrity, access, and use. Please keep in mind, however, that despite these efforts to protect data on our servers, no method of transmission over the Internet is guaranteed to be secure. plista Services are used globally and therefore we may transfer data to countries around the world, including countries outside your country or continent. We will, where necessary, put in place appropriate safeguards to ensure such data is protected. When we transfer personal data from the EU or the European Economic Area (EEA) to an affiliate outside the EU or EEA, we enter into standard (“model”) contractual clauses, or substantially equivalent terms and conditions, with the recipient in order to ensure an appropriate level of data protection. When we transfer personal data from the EU or EEA to an unaffiliated entity (such as a service provider performing services on our behalf) outside the EU or EEA, we either enter into standard (“model”) contractual clauses, or substantially equivalent terms and conditions, or ensure that such transfer is pursuant to another valid mechanism, such as the service provider being certified under the EU-U.S. Privacy Shield Framework.

Data Retention

We generally maintain the information we collect through our Services in non-aggregated form for a period of not more than 12 months. This data includes Sites visited, content viewed, ad interactions, IP addresses, browser type and language settings. We maintain this information for such 12-month period to enable our clients to perform year-over-year analyses. We maintain information we collect through our Services in an aggregated or anonymized form for a period longer than 12 months.

EU / EEA Users

Legal bases for processing information

We collect, use, share, and/or transfer personal data of EU and EEA citizens and residents when we have a lawful basis for doing so, which typically entails user consent, our legitimate interests (including our interests in providing and/or facilitating our Services and the plista web sites, unless those interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data), other legal rights, or a combination of such bases. To the extent we rely on your consent, which may be provided either directly to us or via a third party (such as a “consent management provider”) to use your information in certain ways, we will process your personal data within the scope of that consent. If you are a citizen or resident of the EU or EEA, you have the right to object to any of this processing. If you want to object, please click here.

Rights of EU / EEA users

EU / EEA citizens and residents have a number of rights with regard to their personal data, including the right to access their information. For such EU / EEA users, in many cases where we process personal data, they may also have a right to restrict or limit the ways in which we use that personal data. In certain circumstances – for example, where we process your personal data for direct marketing purposes or pursuant to our legitimate business interests – you also have the right to object to the processing of your personal data by us, and you can also request that we delete your personal data. You also have a right to obtain a copy of your personal data in an easily accessible format, and in certain circumstances, you may also request us to transfer personal data about you to third parties. To the extent feasible, we will carry out these requests and we may ask you to verify your identity before doing so. With respect to the personal data you provide to us on the plista web sites, you have the right to receive a copy of the personal data stored by plista and, if necessary, to correct, block or delete them. You also have the right to withdraw your given consent regarding the use of your personal data in connection with our newsletter or email marketing. You may withdraw by canceling your subscription or unsubscribing at any time. With respect to our Services, because we do not retain and store any names, addresses, phone numbers, email addresses or similar data that would enable identification of a particular individual in association with a cookie ID or advertising ID, we are unable technically to offer the ability for you to change elements of the personal data about you. If you believe any of the personal data elements about you is inaccurate, please note that you have the right to withdraw your consent to our processing of your personal data at any time. If you have questions about any of these rights or wish to exercise these rights, please contact us at privacy@www.plista.com. You should also contact us at that email alias if your personal data or preferences change, if you do not want us to send you the information you previously requested, or if you have any queries about how we use your personal data. Without limiting any other rights you may have, you also have the right to lodge a complaint against us with a supervisory authority in the EU Member State where you are based. Click here to find your local supervisory authority:

Changes to our Privacy Policy

Please note that because of the changing nature of privacy laws and regulations, digital technologies, and our business, we may modify this Privacy Policy from time to time. Please review this Privacy Policy periodically to become aware of any changes that may have occurred. If you continue to visit the plista web sites or engage with plista Services after any change in this Privacy Policy, we will take this as an indication that you have accepted the updated terms.