PRIVACY NOTICE FOR THE GLOMEX-PLAYER
This privacy notice informs users of the glomex player in the digital offers (e.g., in a website) and/or social media platforms of the publishers (together the “Digital Offers”) as well as on the glomex video platform “video.glomex.com” about the processing of personal data (“users data”). glomex GmbH (“glomex”) offers a wide range of free premium video content (“Video Content”) that can be embedded on Digital Offers or by glomex in its own video platform “video.glomex.com”.
The providing of free video content to users is only possible by displaying non-personalised or personalised advertising while using the glomex player. Based on pseudonymised data, glomex cooperates with advertising partners to display personalised advertising in the glomex player based on users’ interests and habits while surfing the internet with their consent. Without this consent, only non-personalised advertising is displayed. The glomex player is either embedded in Digital Offers or is available on the video platform “video.glomex.com”. If the glomex player is embedded in the Digital Offers, the corresponding data protection notices on the processing of personal data of the respective advertising partners must be observed.
The glomex player is offered by glomex GmbH, Dieselstraße 1, 85774 Unterföhring, Germany.
Users can contact the glomex data protection team at any time with data protection enquiries by sending a message to the postal address provided or by e-mail to firstname.lastname@example.org. glomex expressly points out that these enquiries are then not exclusively noted by the data protection officer. At the request of the users, confidential information can be forwarded to the data protection officer of glomex and answered by this data protection officer. In such cases, the words “Attn: Data Protection Officer” should be added to postal enquiries or, in the case of enquiries by e-mail, direct contact with the Data Protection Officer should be requested.
If the glomex player is embedded in Digital Offers, glomex and the respective publishers are jointly responsible for enabling data processing in the glomex player. The subsequent processing, storage, and transfer of users’ data by the advertising partners (see Sec. 3), is controlled by them and they are independently responsible for this processing. glomex has no control over these processing operations. Further information on the processing of personal data can be found in the data protection notices of the respective advertising partners. The contact details of these advertising partners are listed in Sec. 3 (Recipients of the data).
2) Data processing in connection with the glomex player
2.1 Categories of data processed, legal basis
The providing of the content in combination with advertising is basically realised by using the IP address, cookies, and comparable technologies (hereinafter also referred to as “identifiers”). Through the glomex player, glomex collects the following users’ data:
- current IP address of the end device (pseudonymised by deleting the last part of the IP address)
- information about the region or location (derived from the IP address)
- date and time of video playback in the glomex player
- technical information about the terminal device and operating system used (user agent data)
- users’ interactions with the glomex player and the advertising material and Video Content played therein (e.g., click on an advertising material)
- non-personal information about Video Content and the overall performance/popularity of advertising material
- Client Device ID and encrypted data about the manufacturer and the model of the used end device for the Digital Rights Management
2.2 Purposes of data processing for the glomex player
If users play Video Content in the glomex player, glomex provides this Video Content from their rights holders by means of an integration service and combines it with non-personalised or personalised advertising from different advertising partners. If users click on the advertisements played in the glomex player, for example, to access the advertised Digital Offer, then this is recorded by glomex.
Some of the Video Content from glomex is protected by a special system to safeguard existing copyrights. This prevents copyrighted Video Content from being modified or duplicated by unauthorized persons. Thereby, it ensures that the copyrighted Video Content can only be viewed as intended. For this purpose, the Video Content is encrypted and can only be decrypted again by authorized persons, the users, using a key provided for this purpose. This Digital Rights Management (DRM) is implemented for glomex by the provider Axinom GmbH, Kurgartenstraße 37, 90762 Fürth, Germany (“Axinom”). glomex has concluded a data processing agreement with this provider, which ensures processing only for the purpose of implementing Digital Rights Management.
glomex uses the user’s data mentioned in Sec. 2.1 for the following purposes:
- provision of its service,
- billing its customers, reviewing billings and measuring the efficiency of the advertising media (“billing”),
- fraud prevention,
- improving its own service (for example, in the context of A/B split testing),
- playing non-personalised advertising,
- copyright of Video Content through a Digital Rights Management.
The legal basis for this processing is the legitimate interest of glomex (Art. 6 para. 1 lit. f GDPR) in ensuring the secure operation of the glomex player, in enabling convenient use, in monetising the content and in protecting the copyright of the Video Content.
By loading identifiers of its advertising partners in the glomex player, glomex initiates the processing of users’ data by its advertising partners. glomex’s advertising partners (see Sec. 3) use identifiers for the following purposes:
- collecting, evaluating and analysing information about users’ activities within the glomex player and on Digital Offers (“usage analysis”),
- aggregating the collected pseudonymised users data to create usage profiles (“usage profiles”),
- playing targeted advertising in the glomex player that corresponds to the activities in the browser and the interests of the users (“personalised advertising”).
The legal basis for this processing is the consent of the users (Art. 6 para. 1 lit. a GDPR), which was given on the respective Digital Offers in which the glomex player is integrated. Without the users’ consent, the glomex player only displays non-personalised advertising.
3) Recipients of the data
glomex currently cooperates with the following advertising partners for the monetization of the video content it makes available:
- 1&1 Mail & Media GmbH, Elgendorfer Str. 57, 56410 Montabaur, Germany • Privacy Notice
- Amazon Europe Core S.à.r.l., 38 avenue John F. Kennedy, L-1855, Luxembourg • Privacy Notice
- Axel Springer SE, Axel Springer Str. 65, 10969 Berlin, Germany • Privacy Notice
- ATG Ad Tech Group GmbH, Friedensallee 38, 22765 Hamburg, Germany • Privacy Notice
- Burda Community Network GmbH, Arabellastr. 23, 81925 Munich, Germany • Privacy Notice
- BurdaForward GmbH, St.-Martin-Straße 66, 81541 Munich, Germany • Privacy Notice
- crossvertise GmbH, Königinstr. 59, 80539 Munich, Germany • Privacy Notice
- Goldbach Austria GmbH, Laimgrubengasse 14, 1060 Vienna, Austria • Privacy Notice
- Goldbach Germany GmbH, Feringastr. 12 B, 85774 Unterföhring, Germany • Privacy Notice
- Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland • Privacy Notice
- Netpoint Media GmbH, Rheinallee 60, 55283 Nierstein, Germany • Privacy Notice
- PULS 4 GmbH, Maria Jacobi Gasse 1, 1030 Vienna, Austria • Privacy Notice
- Phaistos Networks S.A., 76, 25th Martiou, 70400 Mires, Irakleio, Greece • Privacy Notice
- QUARTER MEDIA GmbH, Weidestraße 132, 22083 Hamburg, Germany • Privacy Notice
- Seeding Alliance GmbH, Ströer-Allee 1, 50999 Cologne, Germany • Privacy Notice
- SevenOne Media GmbH, Medienallee 4, 83774 Unterfoehring, Germany • Privacy Notice
- SevenOne Media (Schweiz) AG, Limmatstr. 275, 8005 Zurich, Switzerland • Privacy Notice
- ShowHeroes SE, Brunnenstr. 154, 10115 Berlin, Germany • Privacy Notice
- Smartstream TV GmbH, Dachauer Str. 15A, 80335 Munich, Germany • Privacy Notice
- Ströer Digital Media GmbH, Kehrwieder 8-9, 20457 Hamburg, Germany • Privacy Notice
- WebAds B.V., Keizersgracht 256, 1016 EV Amsterdam, Netherlands • Privacy Notice
- Welect GmbH, Duisburger Straße 19, 40477 Düsseldorf, Germany • Privacy Notice
- Virtual Minds GmbH, Ellen-Gottlieb-Straße 16, 79106 Freiburg im Breisgau, Germany • Privacy Notice
- The ADEX / Partnership with ProSiebenSat.1 Digital Data • Privacy Notice
glomex uses a service of ProSiebenSat.1 Digital Data GmbH, Medienallee 7, 85774 Unterföhring (“PSDD”) for advertising optimisation. glomex and PSDD are jointly responsible for enabling of data collection by PSDD in this context. PSDD uses The ADEX (“ADEX”) as a processor for this purpose.
ADEX offers technologies to optimally place and control advertising for users based on their individual interests and users’ behavior on Digital Offers and to make their percentage share of conversion, the path from the first advertisement to the final purchase, measurable (”user analysis”). These usage analyses are assigned to the users’ profiles based on identifiers.
The transmitted IP address of users’ devices is used to form household networks and then completely anonymised. In household networks, the devices connected to the internet, such as computers, telephones, and connected TVs, can be identified and the respective users’ data collected from Digital Offers can be combined across the various devices. With the information obtained, neither directly identifying data nor a specific location of the users can be determined. A direct personal identification of the users is therefore excluded.
If users no longer wish to receive behavior-based advertisements and would like to prevent the further collection of users’ data, the following opt-out link can be used: https://theadex.com/datenschutz-opt-out/. In this case, a technically necessary opt-out cookie will be set to comply with the users’ needs in the future. In addition, the use of the ADEX can also be prevented by not providing a consent for personalized advertising.
Users can find further information on the data processed by ADEX, the rights of users, and the disclosure of data by ADEX, in the ADEX privacy notice.
If glomex uses external service providers and transfers personal data to them, then they may only use the data to fulfil their task and in connection with specific instructions. The service providers are contractually bound to the data protection requirements, from the GDPR, the Federal Data Protection Act (BDSG) and the German Telecommunications and Telemedia Data Protection Act (TTDSG). In cases where data is processed in countries outside the European Union, suitable guarantees are in place to protect the users concerned (e.g., Standard Contractual Clauses).
4) Storage period
glomex stores billing-relevant users’ data (e.g., pseudonymised IP addresses and data on the user agent) for up to ten years for reasons of commercial and tax law.
Users of the glomex player can find information on the storage period of personal data at the advertising partners in the data protection notices of the respective advertising partners (see Sec. 3).
5) Users’ rights
The rights of the users of the glomex player are stipulated in the GDPR. These rights do not apply without restriction – in specific cases or in the specific use of users’ data, users are not entitled to the rights or exceptions exist (for example, in the case of data processing by glomex based on its legal obligations). In these cases, glomex informs the users in a written form.
Users may exercise the following rights at any time within the scope of their users’ data processed by glomex:
- right of access pursuant to Art. 15 GDPR (e.g., in the form of a copy).
- right to rectification pursuant to Art. 16 GDPR, if users consider the information held by glomex to be inaccurate.
- right to erasure (“right to be forgotten”) pursuant to Art. 17 GDPR, if one of the conditions set out therein applies.
- right to withdraw consent pursuant to Art. 7 para. 3 GDPR, insofar as the processing was based on consent.
- right to restriction of processing pursuant to Art. 18 GDPR, if one of the conditions set out therein applies.
- right of data portability pursuant to Art. 20 GDPR, if the processing was carried out by automated means and based on the user’s consent or for the performance of a contract.
- Right to object to processing pursuant to Art. 21 para. 1 GDPR, if the user provides grounds relating to his or her particular situation and glomex cannot demonstrate compelling legitimate grounds for the continued processing;
- Right to object to the processing of users data for direct marketing purposes pursuant to Art. 21 para. 2 GDPR, which can be exercised at any time.
If users intend to revoke their consent with regard to the setting of identifiers with the respective advertising partners of glomex, they shall refer to the instructions on how to change the cookie settings of the respective Digital Offers via which the users have accessed the glomex player. Non-personalised advertising does not constitute direct advertising due to the missing direct approaching of concrete users, which is therefore not relevant for a special right of objection according to Art. 21 para. 2 GDPR.
Pursuant to Art. 77 GDPR, users also have the right to lodge a complaint with any data protection supervisory authority. For example, the complaint may be lodged with a supervisory authority within the European Union in the Member State of the user’s habitual residence or place of work as well as the place of the alleged infringement. For glomex, the competent authority is the Bavarian State Office for Data Protection Supervision, post office box 606, 91511 Ansbach, Germany.
6) Changes to this privacy notice
As the glomex services evolve, changes to this privacy notice may become necessary. This website always contains the current version of the privacy notice.
Last amended: October 2022