Last update: 25 March 2019
- through our Twitter account located at twitter.com/unitedinternet and
Collectively, we refer to the Websites and the Apps, as the “Services”.
United Internet AG processes your Personal Data in compliance with the EU General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG), the German Stock Corporation Act (AktG) and all other relevant legal provisions.
"Personal Information” is information that identifies you as an individual or pertains to an identifiable natural person, e.g.,
- Email address
- Telephone number
- Postal address (including billing and shipping addresses)
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
- Through the Services
- We collect Personal Information through the Services, for example, when you sign up for a newsletter
- From Other Sources
- We receive your Personal Information from other sources, for example from publically available databases
Use of Personal Information
We and our service providers use Personal Information for legitimate business purposes including:
- Providing the functionality of the Services and fulfilling your requests.
- To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, or compliments.
- To send administrative information to you, such as changes to our terms, conditions and policies.
- Providing you with investor newsletters, press releases and/or other information materials and facilitating social sharing
- To send you investor newsletters, press releases, or other mails, with information about our corporation, our services, new products and other news about our company.
- To facilitate social sharing functionality that you choose to use.
- Analysis of Personal Information for business reporting.
- To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
- To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
- Aggregating and/or anonymizing Personal Information.
- We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.
- Accomplishing our business purposes.
- For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
- For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
- For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests;
We will engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest. The legal basis for processing is established by Art. 6 (1) sentence 1 lit. a), lit. c) and/or lit. f) GDPR.
Disclosure of Personal Information
We disclose Personal Information:
- You can consult the list and location of our affiliates in our annual report which you can download here.
- To our third party service providers, to facilitate services they provide to us.
- These can include providers of services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, services related to our shareholder meetings and other services.
- By using the Services, you may elect to disclose Personal Information
- On message boards, chat, profile pages, blogs and other services to which you are able to post information and content. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
- To comply with applicable law and regulations.
- This can include laws outside your country of residence.
- To cooperate with public and government authorities.
- To respond to a request or to provide information we believe is important
- These can include authorities outside your country of residence.
- • To cooperate with law enforcement.
- For example, when we respond to law enforcement requests and orders or provide information we believe is important.
- For other legal reasons.
- To enforce our terms and conditions; and
- To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
- In connection with a sale or business transaction.
- We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
When using the website purely for information, meaning if you do not register yourself or provide us with other information, we only collect Personal Data which your browser sends to our server. If you would like to look at our website for this reason, we collect the following data which we require for technical reasons to be able to display our website to you and to guarantee stability and security (legal basis established in Art. 6 (1) sentence 1 lit. f) GDPR):
- Name of the file accessed,
- Date and time of access,
- Data volume transferred,
- Report on successful access,
- Description of the web browser type,
- Referrer URL (previously visited page),
- Host name of accessing computer (IP address).
These data are not combined with other data sources, most particularly not with your contact data or other data you share in the context of using the website or our shareholder portal.
In addition to the above-mentioned data, when you use our website, both "session cookies" in your web browser and "permanent cookies" may be stored on your computer. Cookies are small text files which are transferred to the computer when a web page is accessed and which send us certain information. Basically there are two types of cookies; Cookies that are only generated when an Internet page is accessed and which are deleted again when the browser is closed (known as session cookies) and cookies which are stored on the user’s computer when a web page is accessed (known as permanent cookies). These cookies can be used for various purposes such as the user-friendly presentation of the offering.
You can prevent a cookie from being installed by changing the settings on your Internet browser so that it does not permit text files of this kind to be stored on your computer. In addition, you can delete cookies stored on your computer at any time.
"Other Information" is any information that does not reveal your specific identity or does not directly relate to an identifiable individual
- Browser and device information
- App usage data
- Information collected through pixel tags and other technologies
- Demographic information and other information provided by you that does not reveal your specific identity
- Information that has been aggregated in a manner such that it no longer reveals your specific identity
If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
- Through your browser or device:
- Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
- Using Pixel tags and similar technology
- Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:
- Receiving electronic communications from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by contacting us as at firstname.lastname@example.org.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
Data subject rigths
Under the legal provisions you have the right to obtain information on the processed Personal Data concerning you from the aforementioned contact address (Art. 15 GDPR) and to apply for the rectification (Art. 16 GDPR) or erasure (Art. 17 GDPR) of your Personal Data or a restriction on processing (Art. 18 GDPR).
Please indicate clearly in your enquiry which Personal Information you would like to have changed or whether you would like your Personal Information to be removed from our database. With your protection in mind, we are only able to respond to enquiries in connection with Personal Information which is linked to the specific email address which you use to send us your enquiry. In the event, we may initially have to verify your identity before we can begin to process your enquiry. We will try to respond to your enquiry as soon as reasonably practicable.
Moreover, you have the option of consulting the competent supervisory authority.
Right to object (Art. 21 GDPR): If we process your data for the purpose of safeguarding your legitimate interests (Art. 6 (1) sentence 1 lit. f), you can object to this processing on grounds arising from your special situation. Please send your objection to the aforementioned contact address.
Right to withdraw consent (Art. 7 (3) GDPR): If we process your Personal Data on the basis of your consent (Art. 6 (1) sentence 1 lit. a) GDPR), you can withdraw this consent at any time. Please send your request for withdrawal to the aforementioned contact address.
Right to data portability (Art. 20 GDPR): If we process your Personal Data based on your consent (Art. 6 (1) sentence 1 lit. a) GDPR), you have the right to receive your Personal Data in a structured, customary and machine-readable format.
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). Die Zeitspanne, über die wir eine laufenden Vertragsbeziehung zu Ihnen haben und die Dienste für Sie bereitstellen (solange Sie beispielsweise ein Konto bei uns haben oder die Dienste weiter nutzen);
THIRD PARTY SERVICES
The service providers we work with process your Personal Data exclusively in accordance with our instructions and only to the extent that this is necessary for carrying out the contracted service. All employees of United Internet AG and the employees of mandated service providers who have access to your Personal Data and/or process them are under obligation to treat these data confidentially.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.
JURISDICTION AND CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.
ADDITIONAL INFORMATION REGARDING THE EEA:
If we pass on Personal Data to service providers outside the European Economic Area (EEA), the relaying of data only takes place if the non-EU country has had a suitable level of data protection confirmed by the EU Commission or if other suitable data protection guarantees are in place (e.g., binding data protection rules within the company or an agreement making use of the EU Commission’s standard contractual clauses).
You are welcome to request detailed information on this as well as on the data protection level of service providers in non-EU countries from the aforementioned contact address.
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
United Internet AG
Elgendorfer Straße 57
If you have comments on or inquiries about the processing of Personal Data, please contact United Internet AG’s Data Protection Officer at:
United Internet AG
The Data Protection Officer
Elgendorfer Straße 57