PRIVACY POLICY

This Privacy Policy only applies to the following website: “www.global-savings-group.com”. Other websites connected directly or indirectly with this Website, do not fall within the scope of this Privacy Policy.

1 DATA PROTECTION AT ONE GLANCE

This section gives you a brief overview about the collection, processing and use of your personal data and the use of cookies when you visit and/or interact with this Website, its content and services. The details of our practices and your rights in that regard are explored in greater detail throughout this privacy policy.

In order to provide this website to you, we collect, process and use the following data.

  • Access data: With regard to each of your visits to this website, our web-servers record technical information which your browser automatically transmits. This includes the internet protocol (IP) address used to connect your computer or mobile device to the internet, the browser type and version you use, the operating system and date and time of your access. [More Details]
  • Personal data you provide to us: We collect information about you that you actively provide to us by using special functions of this website, such as our contact forms. These data includes your email address as well as other details which are necessary for the provision and use of the respective services.
  • Usage Data: In addition we actively collect further information about your visit to this website and your usage of its services and content. That information includes the full uniform resource locators (URL) clickstream to, through and from this website (including date and time), visited sub-pages, information you searched for, response times, length of visits to certain pages, email openings and which banners or links on the website or in an email were clicked on. We use such data for a variety of purposes. For example we use this information to better understand your needs and preferences so that we can improve this website and its functions and to provide you with more relevant and interest-based contents. [More Details]
  • Cookies and similar tracking technologies: We automatically collect such usage data with the help of cookies and similar technologies. We may store unique identifiers in such cookies that can be used to identify your browser on subsequent visits to this website. [More Details]
  • Third-Party technologies: We also allow selected third parties to use cookies or similar technologies on this website. These third parties include analytics, advertising networks and other service providers that assist us in providing, evaluating, and improving this website and our services and to provide targeted advertising based on your browsing activities and interests. [More Details]
  • Social media networks: We may use plug-ins from social media networks on this website that allow you to share content with these networks. If you use these features, these networks may use their own cookies to collect data about you.
  • Disclosure to third parties: We may disclose some of your information to business partners in connection with the redemption of promotional offers published on this Website, to affiliated companies who provide joint content and services (such as newsletter and customer support) or to service providers who perform certain services on our behalf, but only to the extent necessary to perform the respective services. Some of the service providers may be located in a country outside Switzerland and the EU/EEA. However, we exclusively work with companies that offer an appropriate data protection level. [More Details]

2 WHO WE ARE AND WHAT WE DO

Operator of this Website is CupoNation GmbH, Radlkoferstraße 2, 81373 Munich, Germany (“CupoNation”, “we”, “us”), a company of Global Savings Group GmbH, Radlkoferstraße 2, 81373 Munich, Germany (“Global Savings Group”). Within Global Savings Group, CupoNation is responsible for the overall strategy, restructuring, product development, marketing strategy and quality assurance for the entire group. In this function, CupoNation also decides about the purposes and means of the processing of personal data that is collected in connection with the websites of Global Savings Group. Therefore, CupoNation is the controller of such data.

We collect and process your personal data in accordance with applicable data protection laws, in particular with the General Data Protection Regulation, Regulation (EU) 2016/679 (“GDPR”). Insofar as we obtain your consent for the processing of your personal data (e.g. when subscribing to our newsletter), Art. 6(1) lit.a GDPR and Art. 6(1) lit. c GDP serves as the legal basis therefor. Regarding any other processing activities as described in this privacy policy, the processing is based on Art. 6(1) lit. f.1 GDPR, according to which the processing of personal data is permitted, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of our users which require protection of personal data.

3 ACCESSING AND USING THE WEBSITE

3.1 Access data (Log files)

With each call of this Website our servers automatically store general access data about this process in server logfiles.

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.

3.2 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.

For this purpose we use cookies and similar technologies which contain a unique identifier, consisting of a string which enables websites to recognize devices used to access a website on each subsequent visit throughout its lifetime. These identifiers do not allow us to draw any conclusions as to your identity. For more information about the specific types of cookies and similar technologies served through this website, their purposes and your options to manage them, please refer to our cookie policy.

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 customize, measure and improve this Website and our services

This includes our use of the data to 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 usage of promotional offers for reporting purposes in order to bill and collect our commission from business partners.

to provide you with personalised content

We also use this information to tailor our content and promotional offers we may display on this Website or send to you to your interests. For this purpose, we create pseudonymised usage profiles. These usage profiles help us to better understand your needs and preferences so that we can provide you with individual and interest-based contents and promotional offers. Pseudonymous usage profiles do not allow us to draw any conclusions as to your identity and we do not combine such profiles with data that directly identifies you (e.g. email address), unless you have explicitly allowed us to do so (e.g. as part of your newsletter subscription as explained in section 5 of this privacy policy).

for Advertising and (Re-)Targeting purposes
We or more specifically the advertising partners referred to in section 5 of this privacy policy also use this information in order to deliver targeted advertising on this Website or on websites of third parties which is based on your prior visit to this Website.

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.
You have the right to object at any time to the display of personalised advertising by our advertising partners via the opt-out links provided under section  5 of this privacy policy. In addition, you can prevent the storage of the cookies used for such purposes by adjusting the cookie settings in your browser software. For more information, please see our Cookie Policy.

4 COOKIES

When you first visit this website, we will inform you about the use of cookies and similar technologies served through this website and ask for your consent to the use of such cookies. The wording of the Cookie Consent declaration can be viewed at the bottom of this Privacy Policy. You can also change your cookie preferences at any time with effect for the future.

The specific types of cookies served through this website, their purposes and your options to manage them are described in further detail in our cookie policy.

5 USE OF THIRD PARTY TOOLS

We allow certain third parties to use cookies or similar technologies on this website. These third parties include analytics, advertising networks and other service providers that assist us in providing, evaluating, and improving this Website and our services and to provide targeted advertising based on your browsing activities and interests.

These third parties may use cookies or similar technologies and collect data about your use of this Website and your interaction with its content and functions, including the total number of visitors to this Website, the websites our visitors have come from, the pages you visit, date, time and duration of your visit, frequency, clicked banners/links as well as information about type of device, browser version, language settings and geographic location (including country, city, region). They may also collect online-identifiers (e.g. User-ID) and/or IP-addresses. We do not have access to these cookies or to any personal identifiable data collected with these cookies that allow us to identify single users. We may, however, use information arising from the cookies provided by these third parties. All data collected is made available to us only anonymously and in statistical form. We do not have access to any data that allows us to identify you.

Some of the service providers are based in a country outside the EU/EEA. However, we exclusively work with companies that offer an appropriate data protection level in line with the stipulations of the GDPR. For more information please see section 6.

Below we will give you an overview and description of third-party provider technologies we may use for this Website.

5.1 Web analytics tools

We have implemented all analytic tools with activated IP anonymisation, so that the last three digits of the IP address are deleted directly after the data collection and only a portion of your IP address may be used and stored on the servers of the respective service providers.

Google Analytics is a web analytics service provided by Google Inc., Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) who reports on user interactions on this website.

The information collected by Google Analytics (including the anonymized IP address) will be transmitted to and stored by Google on servers in the United States. According to Google only in exceptional cases the full IP address may be transmitted directly to a Google server in the USA and encrypted there. Any user-identifiers (e.g. Cookie-ID) stored by Google Analytics will automatically be deleted from Googles´ servers after 14 months.

For further information please refer to Googles Analytics security and privacy principles: https://support.google.com/analytics/answer/6004245?hl=de.

Opt-Out: You can prevent the processing of your data by Google Analytcs by installing the Google Analytics opt-out browser add-on available under https://tools.google.com/dlpage/gaoptout?hl=de. The browser add-on is available for most modern browsers.

Greenhouse is a recruiting system provided by Greenhouse Software, Inc. 110 Fifth Avenue, 3rd Floor New York, NY 10011, USA (“Greenhouse”).

For the purposes of managing and evaluating your application, we will ask you to disclose to us certain data. When you apply to an open position using our ATS, with the exception of the mandatory fields marked with asterisks, you decide yourself which data you are willing to enter and share with us. Depending on the specific position, we may asked you for the following personal data to be submitted:

  • First Name
  • Last Name
  • Email
  • Phone number (optional)
  • Current place of residence (city & country)
  • Curriculum Vitae (CV)
  • Cover Letter
  • Relevant Certifications
  • Desired annual salary
  • Earliest start/ Notice period
  • URL of your LinkedIn profile (optional)
  • URL of your own website (optional)
  • Information on how you became aware of the position (optional)
  • Skype ID (optional)

When you submit your application, your data will be automatically shared via Greenhouse with the GSG Company specified in the job posting for which you are applying.

For further information please refer to our Privacy Statement Regarding Job Applications at https://www.global-savings-group.com/privacy-statement-job-applications/

For further information regarding Greenhouse and GDPR, please refer to Greenhouse’s GDPR conformity at https://www.greenhouse.io/gdpr

6 DISCLOSURE OF YOUR PERSONAL DATA

We only disclose your personal data to third parties, if this is necessary for the purpose of providing this Website and services, we are obligated or entitled hereto by contract or law or you have granted your explicit consent.

6.1 Service providers

We also work with technical service providers, who may have access to your personal data, but only to the extent necessary to perform their respective services. For instance we engage technical service providers to manage our Newsletter. These service providers may not disclose your personal data to third parties or use these for any other purposes than instructed.

We use Amazon Web Services (“AWS”) for hosting this website. AWS is a service of Amazon Web Service Inc, P.O. Box 81226 Seattle, WA 98108-1226, USA (“Amazon”). The data is stored exclusively in a German data center (Frankfurt am Main), which is certified according to ISO 27001, 27017 and 2018 as well as PCI DSS Level 1. All data stored by us on Amazons system is under our sole control and is automatically encrypted. Amazon is not allowed to access or use our data for any purpose whatsoever. For more information on AWS and data protection, please visit https://aws.amazon.com/de/compliance/eu-data-protection/ and https://aws.amazon.com/de/privacy/.

6.2 Data transfer outside of the EU

Some of these service providers are based in a country outside the EU/EEA. However, we exclusively work with companies that offer an appropriate data protection level in line with the stipulations of the GDPR. We also have appropriate agreements in place to ensure that the service providers will take all necessary measures to protect your personal data in accordance with applicable requirements.

The data transmission to service providers in the USA is carried out on the basis of the so-called “EU-US Privacy Shield” or on so-called “standard contractual clauses” of the EU-Commission. The EU-US Privacy-Shield is an agreement between the European Union and the USA that guarantees the compliance with European data protection standards in the USA. The standard contract clauses of the EU-Commission concerns a contract, in which the service provider is obligated to protect personal data, in line with the contractual regulations to process these at our order and in particular not to forward these to third parties. A free copy of the standard contract clauses will be provided to you upon request. For this purpose please contact us and send a stamped envelope for a reply to the address stated under Section 7.

7 YOUR RIGHTS

In respect to our processing of personal data related to you, you are entitled to the following rights free of charge.

7.1 Right to withdraw consent pursuant to art. 7 GDPR

If you have given us your consent to process your data but change your mind later, you have the right to withdraw your consent at any time by sending an email or written letter to our contact address as stated below. We will stop processing your data accordingly.

7.2 Right of access pursuant to Art. 15 GDPR

You have the right to obtain confirmation from us as to whether or not any personal data concerning your person is being processed by us and, if this is the case, you shall have the right to access your information pursuant to Art. 15 GDPR. However, with regard to pseudonymised usage profiles created by us ,we are not able to allocate these to individual persons. Accordingly, we cannot provide any information relating to these data, unless you provide us with information, which enables us to allocate such data to your person. We will point this out to you in case of an inquiry.

7. 3 Right to rectification pursuant to Art. 16

You have the right to request us to rectify any inaccurate or incomplete personal data we hold about you.

7.4 Right to erasure pursuant to Art. 17 GDPR

You have the right to obtain the erasure of your personal data we hold about you if we do not have a legal reason to continue to process and hold it.

7.5 Right to restrict processing pursuant to Art. 18 GDPR

You have the right to ask us to restrict how we process your data subject to Art. 18 GDPR. In this case, we will be permitted to store the data but not further process it.

7.6 Right to data portability pursuant to Art. 20 GDPR

You are entitled to receive personal data that you have provided to us with your consent in a structured, commonly used and machine-readable format or – if technically feasible – to demand that we transfer those data to a third party.

7.7 Right to object to data processing pursuant to Art. 21 GDPR

Under the requirements of Art. 21 GDPR you have the right to object to the processing of your personal data at any time on grounds relating to your particular situation (e.g. a possible risk to life or health). The aforementioned general right to object applies to all processing purposes described in this privacy policy, which are based on the legal basis of legitimate interest. In the event you make legitimate use of such right, we will no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing, which override your interests, rights, and freedoms or for the establishment, exercise or defense of legal claims.

As far as your personal data is processed for direct marketing purposes you may object to this at any time without giving reasons. In order to object to the display of personalised advertising by our advertising partners, please use the opt-out links provided under clause 5 of this privacy policy. In addition, you can prevent the storage of the cookies used for such purposes by adjusting the cookie settings in your browser software. For more information, please see our Cookie Policy.

7.8 Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with the competent supervisory authority if you feel that the processing of your data is carried out by us by breaching applicable law. You can reach out to the supervisory authority which is responsible at your place of residence or to the supervisory authority responsible for us.

The supervisory authority that is responsible for us is:

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Promenade 27
91522 Ansbach
Phone: +49 (0) 981 53 1300
Fax: +49 (0) 981 53 98 1300
Email: poststelle@lda.bayern.de

8 CONTACT DATA AND PROTECTION OFFICER

If you have questions relating to this privacy statement, if you wish to exercise any of your rights or if you have any other concerns regarding the processing of your personal data by us, please contact us by email at datenschutz@cuponation.com and provide the details of the request that you are making, for example by specifying personal data you want access to. You can also contact us under the following contact details:

CupoNation GmbH
Data protection
Radlkoferstraße 2
81373 Munich
Germany
Phone: +49 (0) 89 96058699

You can also contact our group commissioner for data protection Mr. Michael Mayer at these contact details.

9 CHANGES TO THIS PRIVACY POLICY

We may change this privacy policy at any time with effect for the future. The then current version of this policy will be made available on the Website. While we do not intend to make changes to this policy very often, please always check our most current policy. The most recent version date is located at the bottom of this policy.

ANNEX: CONSENT DECLARATIONS

In connection with your use of this Website you may have given one or more of the following consent declarations:

When accessing this Website (“Cookie Consent”)

We use first-party and third-party cookies for several reasons. Click on Cookie Settings button to find a detailed overview of the different types of cookies used on this website and our the reasons for using them

LAST UPDATED, MAY 22, 2018