1. ACCESSING AND USING THE WEBSITE
1. Access data (Log files)
With each call of this Website our servers automatically store general access data about this process in server log files.
These data include:
- the called Website
- the IP address of the requesting system
- the type of browser and version used
- the operating system used
We do not aggregate such data with other data sources. The temporary storage of the IP address in logfiles is necessary for technical reasons and to ensure the security of our system, in particular relating to the recognition of misuse. These purposes also constitute our legitimate interest according to Art. 6 Para. 1 lit. f GDPR. We only retain such data for as long as it is necessary for the stated purposes. IP addresses will be deleted or masked after 14 days at the latest.
2. Other data that we may collect
In addition, we collect and process information about your use of this Website and interaction with its content and services.
The information collected may include:
- Java on / off
- Cookies on / off
- IP-address in a shortened form (last three digits of the IP address are deleted)
- Referrer-URL (i.e. the previously visited site)
- Operating system
- Date and time of the visit
- Your browsing activity (such as scroll positions, clicks and mouse movements)
- Time and duration of page interactions
- Search queries made
- Clicks on banners and links
- Other information about how you interacted with this Website
We may use and disclose such information for the following purposes:
- to provide, customize, measure and improve this Website, its content and functionalities
This includes our use of the data to provide, manage and improve the technical and functional aspects of the Website, to design the Website more user-friendly as well as to optimise the selection of its contents and functionalities. This also includes internal business purposes such as troubleshooting, data analysis, testing and research.
- to process and record your redemption of promotional offers
As we finance ourselves through commissions to provide our service free of charge to you, we may use information about your visit to our website, i.e. your click on of promotional offers for reporting purposes in order to bill and collect our commission from business partners.
- to provide you with personalised content
- for Advertising and (Re-)Targeting purposes
We consider these purposes as in our legitimate interest within the meaning of Art. 6 Para. 1 lit. f) GDPR. Our users expect us to provide offers to them, which reflect their current interests.
We retain this information as long as necessary and relevant for the aforementioned purposes or until you make legitimate use of your right to object to our use of such information. Pseudonymous user profiles are stored for a maximum of 24 months.
2 SPECIAL FUNCTIONS OF THE WEBSITE
2.1 Registration on our Website
You might have the possibility to register on our Website for a customer account by entering personal data into the registration mask. If you take this opportunity you may be asked to enter the following personal data:
- email address
- password (encrypted)
In addition your IP address and the date and time of registration will also be automatically stored on our servers. The collection of this data is necessary in order to understand the (possible) misuse of an email address at a later date, and it therefore serves us to prove that our process is in line with legal requirements.
We process your data exclusively for the purpose of granting you access to your customer account.
We store the data collected during the registration process for the duration of the registration. Registered persons are able to change the personal data specified during the registration at any time in their customer account, or to have them completely deleted from our data stock. If you exercise this right we will delete the customer account and the personal data stored therein without delay. You can also exercise the right at any time by sending your request by email.
2.2 Contacting us
We collect your personal data that you voluntarily disclose to us when you contact us via e-mail or through a contact form provided on the Website for general or specific queries.
The contact form may ask for the following personal data to be entered:
- email address
- message text
- further details for specific queries or reports, if applicable
In addition your IP address and the date and time of contact will also be automatically stored on our servers. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address at a later date, and it therefore serves us to prove that our process is in line with legal requirements.
Your request/enquiry will be transmitted and handled by one of our employees who is responsible for handling the topics addressed in your request/enquiry. Your data will only be used to handle your request/enquiry, e.g., to provide you with the service information you asked for, and will not be used for any other purpose, unless expressly permitted or required by applicable law.
We retain the personal data you provide to us when contacting us for the duration of the respective conversation with you, but no longer than for 6 months after the conversation is closed, unless applicable laws require longer retention periods in individual cases. The conversation will be considered as closed if the circumstances indicate that all relevant facts have been clarified or if you instruct us to delete your data. All personal data which were stored in the context of your conversation with us will be deleted immediately in this case.
2.3 Online Surveys
From time to time we may conduct online surveys by a questionnaire provided via this Website. Participation in these surveys is completely voluntary and you may choose whether or not to participate and therefore disclose information to us. When participating in a survey we may ask you to provide your name, email address, age and/or location. Surveys will be analysed by one of our employees who is responsible for the evaluation of surveys. We use the information submitted via the surveys solely for research and measurement purposes, including the measurement of the effectiveness and optimisation of our content and promotional activities.
We use the technical infrastructure and software solution of third parties for the creation, implementation and evaluation of such surveys. Currently we use the following third party services:
- Google Forms which is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).
- TYPEFORM S.L., Carrer Bac de Roda 163, 08018 Barcelona, Spain.
When participating in a survey, the IP address of the user, information on the time and duration of the survey as well as the information provided in the survey form by the user are transferred to these service providers. Our service providers will process the information provided via the surveys as our data processor only on our behalf and in accordance with our instructions. Our service provider in particular transfer the survey results into an exportable and structured form.
We only retain personal data for as long as it is necessary for the respective survey. Personal data will then be made anonymous or will be deleted.
This website may offer you the possibility to register for free WhatsApp-alerts. If you make use of this service we will send current vouchers, discount codes and/or similar offers directly to your smartphone.
In order to subscribe to the WhatsApp-alert you must click on the button featuring the WhatsApp logo, save the phone number that appears as a contact on your mobile phone and send a message via WhatsApp saying “START”. You will now start receiving messages from us.
In order to be able to offer the WhatsApp-alert we use a service, provided by the MessengerPeople GmbH, Otto-Lindenmeyerstraße 28, 86153 Augsburg. MessengerPeople provides the technical infrastructure for our WhatsApp-alerts. In order to do this MessengerPeople will collect and store your phone number, the given username and the type of device upon subscription. We only have access to your username and any messages sent by you to us.
2.5 DISQUS-commenting function
This Website may use the comment system of Disqus, Inc., 301 Howard Street, Suite 300, San Francisco, CA 94105, USA (“DISQUS”).
Disqus offers an online public comment sharing platform where users may log in and create profiles to participate in conversations with peers. By registering with DISQUS you can comment on any website that offers this function. Disqus offers various ways of registering: You can either register directly with your own DISQUS account or through your existing accounts on Facebook, Twitter, or Google Plus. If you register via one of these social media networks, the respective provider may collect and process information relating to your use of the comment system. More detailed information can be found in the data privacy policies of the respective networks. DISQUS also allows you to use the commenting function as a “guest” without registration. However, some functions may not be available in that case.
If you log in using your DISQUS log-in data, a connection will be made to the DISQUS server and DISQUS will be informed that you are visiting this website and using the comment function. This information may be associated with your DISQUS account and DISQUS may use such information to deliver targeted content and advertising to you.
We receive the following information from DISQUS when you make a comment: the content of your comment, your name, your email address, your password (encrypted), and the IP address assigned to you by your provider at the time you make the comment. We require the comment text in order to be able to publish this. We exclusively use such information in order to be able to get in contact with you regarding any queries relating to your comments or in order to avoid abuse. Under certain circumstances, it may legally be required to delete comments or exclude them from publication (e.g. insulting comments). Otherwise, the comments shall remain on this Website until the commented content is deleted by its author.
3 NEWSLETTER SUBSCRIPTION
You are free to subscribe to our newsletter. Our newsletter informs you regularly about the most recent vouchers, discount codes, or other online saving opportunities for various product categories such as fashion, travel, and/or electronics in connection with deals published on the websites of Global Savings Group (Top5Coupons.com). You will receive these emails from us and the Local Group Company, which is responsible for handling your customer relationship on a local level. Your email address will only be passed to third parties if you have given your express consent to do so in order to receive newsletters about certain products or services of these third parties.
5.1 Data collection with the registration and Double-opt in
When subscribing to our newsletter we will ask you to enter your email address in the registration mask. Further details such as last name, first name, and/or sex may be entered optionally in some cases. We will use such data solely to provide you with our newsletter.
When you subscribe to our newsletter, your IP address and the date and time of the registration will also be automatically stored on our servers. The collection of this data is necessary in order to understand the (possible) misuse of the email address of a user at a later date, and it, therefore, serves us to prove that our registration process is in line with legal requirements.
After you have submitted your newsletter request, we will send a confirmation email to the given email address. This confirmation email contains a link that you need to click on to confirm your subscription. This so-called double-opt-in-procedure helps us to ensure that the email-account holder has actually authorized the receipt of our newsletter.
3.2 Use of newsletter service providers
We use technical service providers which help us managing the newsletter subscriptions and providing related marketing services (“Newsletter Service Providers”). This includes service providers which may have their registered seat and servers in a state outside of the European Union e.g. in the USA. However, we exclusively work with companies that offer an appropriate data protection level in line with the stipulations of the GDPR.
Currently, we work with the following Newsletter Service Providers:
- “MailChimp”, a service of Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA.
- “ExactTarget”, a service of salesforce.com, Inc, The Landmark @ One Market, Suite 300, San Francisco, California 94105, USA.
Our Newsletter Service Provider will process your email addresses and other personal data as described in section 5.3 as our data processor only on our behalf and in accordance with our instructions to help us evaluate the usage of our newsletter, to personalize your newsletter communications, to compile reports on newsletter activity and to provide other statistical and analytical services relating to the usage of our newsletter. Our Newsletter Service Providers are in no way authorized to use the data of our newsletter subscribers in order to contact them themselves or to forward the data to third parties.
We will track and evaluate your usage of our newsletters, such as email-opens and email-clicks, by means of a tracking technology made available by the Newsletter Service Provider. For this purpose the HTML-emails sent with our newsletter may contain web beacons (also called pixel tags, tracking pixel, or GIFs), automatically embedded by our Newsletter Service Providers. A web beacon is a small graphic that contains unique identifiers that allow an analysis of the success or failure of our Newsletter campaigns. Our Service Provider records each subscriber's email address, IP address, date, and time associated with each open and clicks in order to provide us with aggregated reports about how an email campaign performed and what actions subscribers took.
As part of your registration, we may ask for your consent to tailor the content of our newsletter to your personal interests. This is done by evaluating the data about your interactions with our newsletter and your use of this Website. That means that the pseudonymous Usage Data, we collected about you in the past and we will collect in the future will be attributed to your email address. This single record helps us to understand your needs and preferences even better so that we can adjust the contents of the newsletter optimally to your personal interests and provide you with relevant content. We only combine your data as described and provide you with personalized content, if we have your express consent to do so.
3.4 Retention period and right to object
If you merely would like to opt-out of the newsletter tracking you may configure your email program in a way that emails are presented in text form instead of HTML format. This way the web beacons will not be able to work. You can also configure your browser settings in a way that no cookies are stored on your computer. Web beacons typically only work in conjunction with cookies. However, in these cases, the newsletter will not be displayed to you in full and you may not be able to use all functions.
4. SWEEPSTAKES, CONTESTS etc
From time to time you may have the opportunity to participate in sweepstakes, contests, raffles, or similar promotional activities (“Promotional Activities”) through this Website. We typically ask you for certain personal data in order for you to participate in such Promotional Activities, such as your name, surname, age, address, phone number, social media account, consumer behavior, and/or email address. We collect this information solely to administer the respective Promotional Activity (e.g. to verify your eligibility, to determine the winner and to present the award, and/or to publish the winner´s name on this Website) unless you have given your explicit consent to use such data for specified other purposes. All Promotional Activities conducted via this Website are subject to the terms and conditions of each individual Promotional Activity. Such terms and conditions may provide additional information related to the processing of your personal data. Unless expressly otherwise specified, personal data collected by us in respect of Promotional Activities will not be stored any longer than is required to fulfill the purpose of the respective Promotional Activity.
5 INFORMATION FROM BUSINESS PARTNERS
5.1 Information in relation to our commission
As we finance ourselves through commissions, we may receive information from our business partners (e.g. merchants) about your online purchases, which you may place on websites of third parties (e.g. online-shops) after a visit to this Website. Such information is transmitted to us automatically with the help of tracking cookies. We never receive information that can directly identify you but merely commission related information such as the value of your purchase and date and time of the transaction. We also work with several so-called affiliate networks (“Affiliate Networks”), which connect us with merchants and take over the technical and billing process. In these cases, we receive the respective information from such Affiliate Networks. We solely use this information for billing purposes.
5.2 Personalized Coupons
Under certain circumstances, our business partners offer you the possibility to redeem vouchers for goods or services offered on their website. If you have created a shopping basket but have not checked-out yet, and subsequently call this Website, some business partners may share information regarding your open shopping basket (for the example purchase value and product category). For this purpose, we and our respective business partners use a technology (DoubleClick for Publishers) provided by Google Inc. This technology enables us to tailor and display vouchers on this website based on the content of your shopping basket. This form of advertising is carried out completely automatically and does not allow us to draw any conclusions about your identity.