Table of Contents:
- Definitions and basic information on data processing
- Fundamentals of data processing and data security
- Processing of Personal Data
- Promotional Agreement
- Information delivery via electronic channels and personalisation
- Server log data
- Google Analytics and User ID
- Google Remarketing & Retargeting Services
- Individualisation / Customisation of content
- Use of Facebook Social plugins
- Facebook Remarketing, App Analytics and Audience Network
- Other remarketing tools
- Rights of Users
- Offerer (hereinafter referred to as “provider”, “we” or “us”) of the on-line service can be contacted here: Eleven Internet Services LLP. 2nd & 3rd Floor, Basil Moneta, 80 Feet Main Rd, Koramangala 4th Block, Bengaluru 560095, India
- The term “user” includes all customers and visitors of our sites/ social media channels/ pages/ products. The terms used, such as “users” are to be understood gender neutral.
Definitions and basic information on data processing
- Personal data – Data protection is about the protection of personal data. Personal data is defined as any information relating to a natural person who can be identified, directly or indirectly, by reference to an identifier. These include, for example, the name, the email address or web pages visited by the respective person.
- Pseudonymous data – Pseudonymous data does not directly disclose a data subject’s identity, but it may still identify an individual by way of association with additional information. It is usually statistical data. For example, pages / websites visited by a user and their respective duration of stay. In such cases, unlike personal data, the true identities of the visitors are not determinable, since these data are stored only in pseudonymous user profiles (Eg: “user profile 12923” instead of “user profile Alex Dickens”).
- Web beacons – Web beacons (also known as pixel tags) are small code strings that provide a method of delivering a graphic image on a web page for the purpose of transmitting information, such as the IP address of the computer that is hosting the page on which the web beacon appears, has downloaded; the Internet address (URL) of the page where the Web Beacon appears, the time of the display of the page containing the web beacon, the types of browsers that have retrieved the web beacon and the ID number of a cookie on the computer that was previously placed there by that server.
- IP address – The IP address is assigned to an Internet connection when dialling into the Internet by the Internet provider (dynamic IP address). The subscriber can only be identified with the help of the provider, who only publishes the data on the basis of court orders. According to the privacy advocates, this possibility of establishing a personal reference suffices (so-called “absolute personal reference”). It is also possible that the IP addresses, example for larger companies, remain unchanged (statistical IP address). The provider may store the IP address to safeguard against cyber attacks and / or to identify the visitor.
Fundamentals of data processing and data security
- We only process personal data of users in compliance with the relevant data protection regulations in accordance with the requirements of data minimization and data avoidance. This means that the data of the users are processed only if a legal permission exists, in particular if the data for the performance of our contractual achievements as well as online services are required, or prescribed by law or in the presence of a consent.
- We take organizational, contractual and technical security measures in accordance with the state of the art to ensure that the provisions of the data protection laws are adhered to and in order to protect the data processed by us against accidental or intentional manipulation, loss, destruction or access by unauthorized persons.
Processing of personal data
- When contacting us (via contact form or e-mail or any other method), the details of the user are stored in order to process the request as well as in the event of need for follow up.
- By using electronic channels such as email and / or notifications and / or push notifications, you agree to receive messages from us with informative and / or promotional offers such as in the following areas but not limited to: test drives, cars, free vouchers, discount offers , Travel items, sweepstakes, product samples, newsletters, loans, finance, insurance, investment, mobile communications, free tickets, online games, travel, applications, mobile games and applications, videos, quizzes, personality tests, social media offers, news, entertainment, dating, fashion, cosmetics, editorial content, deals, smartphones, toolbars, browser add-ons, software, gifts, newspapers, magazines, computer games, skill games, special offers, SIM cards, power, gas, energy, telecommunications, mail order, product samples, games, surveys, market research, loans, photo products and the likes.
- This advertising consent is valid within and other countries where the users have consented and / or also where explicit consent is provided for by law.
- Benefit to users: As part of our policy, we strive to provide best and exclusive service / benefits / offers suiting your needs and requirements as we identify.
- Cancellation: You can of course unsubscribe from this service at any time.
Information delivery via electronic channels and personalisation
- Emails and other electronic notifications (hereinafter collectively referred to as “newsletters”) with promotional information about us and our services will be sent only with the express consent of the users or if permitted by law.
- We may obtain the consent to shipping with a consent dialog within our online service and confirm with an e-mail (so-called double-opt-in).
- Non-promotional information includes news in the context of the contractual relationship with the users. This includes the sending of information as far as these belong to but not limited to the services of the service provider, technical information, changes in the services of the provider, prices or contractual provisions, the payment process, inquiries or any other such similar messages.
- The users can unsubscribe from these emails at any time.
- As part of the registration, the provider saves the login and the confirmation time and the IP address of the user. The provider is legally obliged to log the applications in order to prove a proper registration.
- In order to adapt our newsletters to the interests of the users and to avoid content that is irrelevant for the users, as well as to adjust the transmission frequency (eg: to send fewer newsletters when the interest of the users is lower), we measure whether the Newsletters are opened (this with the help of a web beacon, a small graphic in the newsletter content) and which links are clicked (this with the help of a link redirection over our servers). We do not intend to use this information for other purposes and the users can unsubscribe from such newsletters as and when they choose to.
Server log data
- We collect data about access to servers on which our online service is executed (so-called server log files). The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
- We use the log data without assignment to the person of the user or other profiling according to the legal provisions only for statistical evaluations for the purpose of operation, security and optimization of our servers.
Google Analytics and UserID
- We also use the Analytics function UserID to track interaction data. This user ID is additionally anonymised and encrypted and is not related to other data except the pseudonymous use.
- Google will use this information on our behalf to evaluate the use of our online offerings by users, to compile reports on the activities within this online offerings and to provide us with further services related to the use of this online offerings and the internet usage. In this case, pseudonymous user profiles of the processed data may be created.
- We only use Google Analytics with activated IP anonymization. This means that the IP address of the users will be shortened by Google in respective regions. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.
- We use Google Analytics for remarketing, Google Display Network impressions reports, DoubleClick Campaign Manager integration, Google Demos demographics reports, and interests. You can disable Google Analytics for display advertising and customise the ads on the Google Display Network by visiting the ad settings at this link: https://www.google.com/settings/ads .
- The IP address submitted by the user’s browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to their use of the online offer as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout.
- For more information about Google’s use of data, hiring and opt-out options, please visit Google’s websites: https://www.google.com/policies/terms/ (“Google’s use of your data when you use websites or our partners’ apps “), http://www.google.com/policies/technologies/ads ( “Use of data for promotional purposes” ), https://support.google.com/ads/answer/2662856?hl=en ( “Managing information provided by Google to show you ads” ) and http://www.google.com/ads/preferences ( “Determine which ads Google shows you” ).
Google Remarketing & Retargeting Services
- We use the Google LLC’s Marketing and Remarketing Services (“Google Marketing Services”), headquartered at 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, (“Google”).
- Google Marketing Services allows us to better target advertisements for and on our website so that we only present ads to users that potentially match their interests. For example, if a user sees advertisements for products he’s been interested in on other websites, this is called “remarketing”. For these purposes, when Google and our other websites that have Google Marketing Services are active, Google immediately codes Google, and so-called remarketing tags (invisible graphics or code, etc.) are added to the website as “Web Beacons”) incorporated into the website. With their help, the user is given an individual cookie, i.e., a small file is saved (instead of cookies, comparable technologies can also be used). The cookies can be set by different domains, including but not limited to google.com, doubleclick.net, invitemedia.com, admeld.com or googlesyndication.com. This file records user’s interests based on the content consumed and other relevant information as mentioned here. The IP address captured of the users with Google Analytics reporting could be shortened within the same region and / or in exceptional cases completely transferred to a Google server in the USA and shortened there. The IP address will not be merged with data of the user within other offers from Google. This information above may also be associated with such information from other sources. If the user then visits other websites, they can be displayed according to his interests with the ads tailored to him.
- The data of the users are pseudonym processed in the context of the Google marketing services. For example, Google does not store and process users’ names or e-mail addresses, but processes the relevant data in a cookie-related manner within pseudonymous user profiles. That is, from the perspective of Google, the ads are not managed and displayed to a specifically identified person, but to the cookie owner, regardless of who that cookie owner is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected about users by “DoubleClick” is transmitted to Google and stored on but may not be limited to Google’s servers in the United States.
- Among the Google marketing services we use is the online advertising program “Google AdWords”. In the case of Google AdWords, each advertiser receives a different “conversion cookie”. Cookies can not be tracked through AdWords advertisers’ websites. The information collected through the cookie is used to generate conversion statistics for AdWords advertisers who have opted for conversion tracking. Advertisers will see the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, they do not receive information that personally identifies users.
- We also use Google Optimization Services to test the usability and effectiveness of our websites, for example through A / B testing, where users are presented with different versions of web pages.
- Other Google marketing services we use include Campaign Manager and Google Tag Manager, which can add more Google analytics and marketing services to our site (eg: AdWords, DoubleClick, or Google Analytics).
- If you wish to opt-out of Google Marketing Services, you may take advantage of Google’s recruitment and opt-out options: http://www.google.com/ads/preferences .
Individualisation / Customisation of content
- The data used includes in particular those that we receive in the context of the registration of users (eg: gender, name or country), as well as data that we receive about their use of our online offerings (eg: which parts of our site does a user uses the most, recommends, favours or shares with other users, etc)
Use of Facebook social plugins
- Within this service are social plugins (“plugins”) of the social network Facebook, which are from Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are located in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland (“Facebook”). The plugins are usually recognizable by one of the Facebook logos (eg “f” on a blue tile or a “thumbs up” sign). You can find the complete list of all plugins at https://developers.facebook.com/docs/plugins/ .
- When a user calls a web page of this service that contains such a plugin, his browser establishes a direct connection to the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s browser and integrated into the website by the browser. The provider therefore has no influence on the amount of data that Facebook collects with the help of this plugin and therefore informs users according to their level of knowledge. By integrating the plugins, Facebook receives the information that a user has called up the corresponding page of the service. If the user is logged in to Facebook, Facebook can assign the visit to his Facebook account. When a user interacts with the plugins, for example, pressing the Like button or commenting, the corresponding information is transmitted from your browser directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will find out and save their IP address.
- You may opt out of Facebook social plug-ins and use your data for promotional purposes. To do this you can go to the page set up by Facebook and follow the instructions on the usage-based advertising settings: https://www.facebook.com/settings?tab=ads. The settings are also platform-independent and so they are adopted for all devices.
Facebook Remarketing, App Analytics and Audience Network
- Within our online offer are advertising content of the Facebook Audience Network as well as so-called “Facebook pixels” and “App Analytics” functions (collectively referred to as “Facebook Remarketing Features”) of the social network Facebook, which is the Facebook Inc , 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are located in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland (“Facebook”), used. With the help of the Facebook Remarketing functions, Facebook is able to designate the visitors of our offer as a target group for the presentation of advertisements, so-called “Facebook Ads”. Accordingly, we use these Facebook Remarketing features to display the Facebook Ads we submit only to Facebook users who have also shown an interest in our website, as well as those Facebook users who might be interested in similar features (so-called “Lookalike Audiences”). In other words, with the help of the Facebook Remarketing features, we want to make sure that our Facebook Ads are in line with the potential interest of users and are not annoying. Using the Facebook Remarketing/ retargeting features, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing if users have been redirected to our site after clicking on a Facebook ad.
- The Facebook Remarketing functions are integrated into our sites or those of members of Facebook’s Audience Network directly through Facebook and can save a so-called cookie on your device, i.e., a small file (alternatively, especially with “App”). Analytics’ features, including device-related identifiers). If you then log in to Facebook or visit Facebook in the logged-in state, the visit and use of our offer is noted in your profile. Here, user profiles can arise.
- The data collected about you is anonymous to us, and so are inconclusive to get the identity of the users. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible. The processing of the data by Facebook is part of Facebook’s data usage policy: https://www.facebook.com/policy.php .
- You may object to the collection through Facebook remarketing features and use of your data for promotional purposes. To do this you can go to the page set up by Facebook and follow the instructions on the usage-based advertising settings: https://www.facebook.com/settings?tab=ads or the contradiction on the pagehttp://www.aboutads.info / choices or the EU side http://www.youronlinechoices.com explain. Do note that the settings are platform-independent and are adopted for all devices.
Other Remarketing tools
- Within our online offerings, we use third party analytics, remarketing / retargeting and advertising technologies to increase the efficiency of the marketing practices used and their relevance to users, and to market advertising space in our offerings. Third-party vendors may use so-called pixel tags (invisible graphics, also known as “web beacons”) for these purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of our online offerings. Here, user profiles can arise. The pseudonymous information may also be stored in cookies on the user’s device and, among other things but not limited to technical information about the browser and operating system, referring web pages.
- Below we provide information on the individual third-party providers, their privacy statements and the possibility of their data collection to contradict (so-called “opt-out”), on:
Rights of users
- Users have the right to correct inaccurate data, revoke consent, regulatory complaint, blocking and deletion of their personal data.
- The data stored with us is deleted as soon as it is are no longer necessary for its purpose and the deletion does not conflict with any statutory storage requirements.