1. What is this Data Protection Notice about?
The Playbrush GmbH and the Sunstar Group (also «we», «us») collects and processes personal data that concern you but also other individuals («third parties»). We use the word «data» here interchangeably with «personal data».
The «Sunstar Group» means the Playbrush GmbH, Obere Donaustraße 71/9-12, 1020 Vienna, Austria and its parent company, its subsidiaries and other Sunstar entities. A list of these can be found here.
In this Data Protection Notice, we describe how we process your data when you visit and search our customer sites https://eu.playbrush.com, https://playbrush.com, https://checkout.sunstargum.com, including our other websites or mobile apps https://play.google.com/store/apps/developer?id=Playbrush+LTD&hl=en_GB, https://apps.apple.com/gb/developer/playbrush-ltd/id959404938 (collectively «website»), obtain services or products from us, interact with us in relation to a contract, communicate with us or otherwise get in contact with us.
2. Who has access to Playbrush’s customer data and why?
For the other purposes set out in Section 4, we may disclose your personal data to other companies, to the following categories of recipients: Group affiliates (2.1), and e-commerce and service providers (2.2).
2.1. Intragroup data sharing
Playbrush GmbH in Austria is the primary recipient of your data and thus primarily responsible as a data controller for the processing under this Data Protection Notice. For specific business processes, Playbrush will share personal data with other Group companies as outlined in this section.
We reserve the right to inform you otherwise in a specific case, for example in additional Data Protection notices, on a form or in a contract, in case a deviation to the following data sharing set-up applies.
2.1.1. Playbrush and affiliates
A list of our Sunstar Group companies can be found here, where our parent company Sunstar lists all member affiliates. These group companies may use the data according to this Data Protection Notice for the same purposes as Playbrush GmbH uses it (see Section 4). We may also disclose health and related data to our group companies.
In the context of providing the APPs, Playbrush GmbH works closely with its subsidiary Playbrush Ltd. This also concerns the processing of your personal data. As part of the signup process in the app, your data is collected by the group companies. The app is developed and technically administered by Playbrush Ltd. as well as provided as a rights holder. In addition, after the signup you can conclude service contracts (subscriptions) and possible further purchase contracts (hardware) with Playbrush GmbH. The Playbrush companies operate a central database in which all customer data, i.e. the data from the APPs, as well as the purchase information are used for customer support, contract fulfillment as well as for product improvement, support and for own marketing purposes (e.g. newsletter). In most cases, this data is used by Playbrush GmbH as the central point of contact in providing customer support. The processing by Playbrush Ltd. is limited here to the provision of the technical infrastructure and the granting of license rights to the users of the APPs.
As part of their joint responsibility under data protection law, the group companies have agreed which of them will fulfill which obligations under the GDPR. This relates to the exercise of the rights of data subjects and the fulfillment of the information obligations under Articles 13 and 14 of the GDPR. This agreement is necessary because when using the APPs and Products, personal data is processed in different process sections and systems operated by our group companies. Even if there is joint responsibility, the group companies will fulfill the data protection obligations according to their respective responsibilities for the individual process steps.
As a contact and information point, affected parties can contact Playbrush GmbH (support@gumplaybrush.com) directly.
2.1.2. Playbrush as Joint Controller
In the following data sharing set-up Playbrush will share your data as a so-called Joint Controller (JC). Playbrush will act as JC when sharing your data with other affiliated recipients (cf. Table), ie. when Playbrush and its affiliates follow the same business interest and when both parties are using the same technological means when processing your data. For other cases Playbrush and its affiliates will act as sole or independent controllers, meaning that each entity processes your data for individually determined purposes and means. Below are given examples (cf. Table) illustrate, which data is shared with other affiliates in a JC-relationship.
Types of shared data cf. Nr. 3 | Recipients (Group affiliates) | Playbrush GmbH sharing as: Joint Controller (JC) | Purpose and legal basis (cf. Nr. 4-5) |
Joint Controller | |||
Newsletter and marketing campaign data;
Website and App analytics data | Sunstar Group entities
Playbrush Ltd. and Sunstar Group entities |
| Joint purpose of improving website, products, marketing and funnels to drive sales of all Sunstar products sold on the Sunstargum domain. Coordination of marketing campaigns. |
Customer survey | Sunstar Group entities Playbrush Ltd. (for App users)
|
| Surveys for product and service improvement
|
2.2. E-Commerce and sub-service providers
We work with service providers in Switzerland and abroad who process your data on our behalf or as joint controllers with us or who receive data about you from us as separate controllers (for example IT providers, shipping companies, advertising service providers, login service providers, banks, insurance companies, debt collection companies, credit information agencies, or address verification providers). This may include health data.
Key service provider for payments is:
Stripe payments Europe Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland (Purchases, Payment Processing Platform, Recurring Payments, Accounting). Stripe acts both as a Controller and Processor for Playbrush GmbH. For more details see https://stripe.com/de-ch/legal/dpa.
Contractual partners: This refers to our other contractual partners as data disclosure results from these contracts. For example, they receive registration data in relation to issued and redeemed vouchers, invitations, etc. If you work for one of these contractual partners, we may also disclose data about you to that partner in this regard. These recipients also include contractual partners with whom we cooperate or who carry out advertising for us and to whom we may therefore disclose data about you for analysis and marketing purposes (these may again be service recipients, but also sponsors and online advertising providers). We require these partners to send you, or display advertising based on your data only with your consent (for online advertising, see Section 12). Our online advertising partners are listed in Section 12. For other partners we will inform you of these in the context of the registration, vouchers or invitations.
2.3. Authorities and other recipients
· Authorities: We may disclose personal data to agencies, courts and other authorities in Switzerland and abroad if we are legally obliged or entitled to make such disclosures or if it appears necessary to protect our interests. This may include health data. These authorities act as controllers.
· Other persons: This means other cases where interactions with third parties follow from the purposes set out in Section 4.
All these categories of recipients may involve third parties, so that your data may also be disclosed to them. We can restrict the processing by certain third parties (for example IT providers), but not by others (for example authorities, banks, etc.).
3. What data do we process?
We process various categories of data about you. The main categories of data are the following:
· Technical data: When you use our website or other online offerings, we collect the IP address of your terminal device and other technical data to ensure the functionality and security of these offerings. This data includes logs with records of the use of our systems as well as data related to the use of our brushes. We generally keep technical data for 6 months. To ensure the functionality of these offerings, we may also assign an individual code to you or your terminal device (for example as a cookie, see Section 12). Technical data as such does not permit us to draw conclusions about your identity. However, technical data may be linked with other categories of data (and potentially with your person) in relation to user accounts, registrations, access controls or the performance of a contract.
· Registration data: Certain offerings, for example competitions, and services (such as login areas of our website, newsletters, etc.) can only be used with a user account or registration, which can happen directly with us or through our third-partyservice providers. In this regard you must provide us with certain data, and we collect data about the use of the offering or service. If you redeem a voucher issued by the Playbrush or Sunstar group with us, we may require certain data from you at the time of redemption. If we issue a voucher to you for one of our contractual partners, we may share or receive some of your registration data from the relevant contractual partner (see Section 7). Registration data may be required in relation to access control to certain facilities. We generally keep registration data for 12 months from the date the use of the service ceases or the user account is closed.
· Communication data: When you are in contact with us via the contact form, by e-mail, telephone or chat, or by letter or other means of communication, we collect the data exchanged between you and us, including your contact details and the metadata of the communication. If we record or listen in on telephone conversations or video conferences, for example for training and quality assurance purposes, we will tell you specifically. Such recordings may only be made and used in accordance with our internal policies. You will be informed when such recordings take place, for example by an indication during the video conference in question. If you do not want to be recorded, please notify us or leave the (video) conference. If you simply do not want your image to be recorded, please turn off your camera. If we must determine your identity, for example in relation to a request for information, a request for press access, etc., we collect data to identify you (for example a copy of an ID document). We generally keep this data for 12 months from the last exchange between us. This period may be longer where required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. E-mails in mailboxes and written correspondence are generally kept for at least 10 years if they relate to an order, warranty or otherwise may influence the financial position of Playbrush. Recordings of (video) conferences we will usually keep for 12 months. Chats are generally stored for 1 year.
· Master data: With master data we mean the basic data that we need, in addition to contract data (see below), for the performance of our contractual and other business relationships or for marketing and promotional purposes, such as name and contact details, and information about, for example, your role and function, your bank details, your date of birth, customer history, powers of attorney, signature authorizations and declarations of consent. We process your master data if you are a customer or other business contact or work for one (for example as a contact person of the business partner), or because we wish to address you for our own purposes or for the purposes of a contractual partner (for example as part of marketing and advertising, with invitations to events, with vouchers, with newsletters, etc.). We receive master data from you (for example when you make a purchase or as part of a registration), from parties you work for, or from third parties such as contractual partners, associations and address brokers, and from public sources such as public registers or the internet (websites, social media, etc.). We may also process brushing behavior data and information about third parties as part of master data. We may also collect master data from our shareholders and investors. We generally keep master data for 10 years from the last exchange between us or from the end of the contract. This period may be longer if required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. For contact information used only for marketing and advertising, the retention period is usually much shorter, usually no more than 2 years from the last contact.
· Contract data: This means data that is collected in relation to the conclusion or performance of a contract, for example information about the contracts and the services provided or to be provided, as well as data from the period leading up to the conclusion of a contract, information required or used for performing a contract, and information about feedback (for example complaints, feedback about satisfaction, etc.). This may include health data and information about third parties (family members using brushes). We generally collect this data from you, from contractual partners and from third parties involved in the performance of the contract, but also from third-party sources (for example credit information providers) and from public sources. We generally keep this data for 10 years from the last contract activity or from the end of the contract. This period may be longer where necessary for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons.
· Behavioral and preference data: Depending on our relationship with you, we try to get to know you better and to tailor our products, services and offers to you. For this purpose, we collect and process data about your behavior and preferences. We do so by evaluating information about your behavior in our domain, and we may also supplement this information with third-party information, including from public sources. Based on this data, we can for example determine the likelihood that you will use certain services or behave in a certain way. The data processed for this purpose is already known to us (for example where and when you use our services), or we collect it by recording your behavior (for example how you navigate our website). We anonymize or delete this data when it is no longer relevant for the purposes pursued, which may be – depending on the nature of the data – between 2 weeks and 24 months (for product and service preferences). This period may be longer where necessary for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. We describe how tracking works on our website in Section 12.
· Other data: We also collect data from you in other situations. For example, data that may relate to you (such as files, evidence, etc.) is processed in relation to administrative or judicial proceedings. We may also collect data for health protection (for example as part of health protection concepts). We may obtain or create photos, videos and sound recordings in which you may be identifiable (for example at events, with security cameras, etc.). We may also collect data about who enters certain buildings, and when or who has access rights (including in relation to access controls, based on registration data or lists of visitors, etc.), who participates in events or campaigns (for example competitions) and who uses our infrastructure and systems and when. Moreover, we collect and process data about our shareholders and other investors, in addition to master data, including information for registers, in relation to the exercise of their rights and events (for example general meetings). The retention period for this data depends on the processing purpose and is limited to what is necessary. This ranges from a few days for many security cameras, to a few weeks for contact tracing and visitor data, which is usually kept for 3 months, to several years or more for reports about events with images.
Much of the data set out in this Section 3 is provided to us by you (through forms, when you communicate with us, in relation to contracts, when you use the website, etc.). You are not obliged or required to disclose data to us except in certain cases, for example within the framework of binding health protection concepts (legal obligations). If you wish to enter contracts with us or use our services, you must also provide us with certain data, in particular master data, contract data and registration data, as part of your contractual obligation under the relevant contract. When using our website, the processing of technical data cannot be avoided. If you wish to gain access to certain systems or buildings, you must also provide us with registration data. However, in the case of behavioral and preference data, you generally have the option of objecting or not giving consent.
As far as it is not unlawful, we also collect data from public sources or receive data from other companies within our group, from public authorities and from other third parties (such as credit agencies, address brokers, associations, contractual partners, internet analytics services, etc.).
4. For what purposes do we process your data?
We process your data for the purposes explained below. Further information is set out in Sections 12 for online services. These purposes and their objectives represent interests of us and potentially of third parties. You can find further information on the legal basis of our processing in Section 5.
We process your data for purposes related to communication with you, in relation to responding to inquiries and the exercise of your rights (Section 10) and to enable us to contact you in case of queries. For this purpose, we use communication data and master data, and registration data in relation to offers and services that you use. We keep this data to document our communication with you, for training purposes, for quality assurance and for follow-up inquiries.
We process data for the conclusion, administration and performance of contractual relationships. This includes the processing of brushing data for the purpose of in-app notifications based on toothbrushing performance (frequency, duration, accuracy), users receive reminders within the respective Playbrush mobile app to use their Playbrush or download more games (contract fulfillment and consent), the Storage of brushing data on toothbrushing performance and aggregation of this data from multiple Playbrush Mobile Applications of a respective user in order to make it accessible to the respective user (or in the case of minors, to his/her legal representative) on the Playbrush Dashboard web application and to display it graphically.
Through the application, parents can view their children's collected data on the GUM Playbrush platform, assign it to user profiles and compare it. In doing so, the data is displayed graphically and feedback on toothbrushing performance is provided. Playbrush profiles in the Playbrush Dashboard are always assigned to the profiles of the respective children (only using the selected alias name). The data is only made available to the respective user (or in the case of minors, to their legal representative) and not to third parties. The cleaning data is always stored with a game profile in one of the respective Playbrush mobile applications in connection with the hardware identification number of the Playbrush device, so that it can be clearly assigned (contract fulfillment and consent).
We process data for marketing purposes and relationship management, for example to send our customers and other contractual partners personalized advertising for products and services from us and from third parties (for example from advertising partners). This may happen in the form of newsletters and other regular contacts (electronically, by e-mail or by telephone), through other channels for which we have contact information from you, but also as part of marketing campaigns and may also include free services. You can object to such communications at any time or refuse or withdraw consent to be contacted for marketing purposes. With your consent, we can target our online advertising on the internet more specifically to you. Finally, we also wish to enable our contractual partners to contact our customers and other contractual partners for marketing purposes.
We further process your data for market research, to improve our services and operations, for product development and to provide technical support for users (contract fulfillment). This includes the analysis of the collected brushing data to develop personalized performance improvement advice for the respective user, which is provided to the user within the respective Playbrush mobile application or within the Playbrush Dashboard application (contract fulfillment and consent), the analysis of collected brushing data in terms of toothbrushing performance by aggregating it with other users' data to explore toothbrushing behaviors and opportunities for improvement in general contract fulfillment and consent)
We may also process your data for security, access control purposes and fraud prevention and detection (legitimate interest in the security and integrity of the systems).
We process personal data to comply with laws, directives and recommendations from authorities and internal regulations («Compliance»).
We also process data for the purposes of our risk management and as part of our corporate governance, including business organization and development.
We may process your data for further purposes, as part of our internal processes and administration or for quality assurance purposes and training. These further purposes may include Storage for the purpose of comparing the toothbrushing performance data collected by the Playbrush mobile applications with other users' data by graphically displaying it under the respective selected alias name.
5. On what basis do we process your data?
Where we ask for your consent for certain processing activities (for example for the processing of sensitive personal data, for marketing mailings and for advertising management and behavior analysis on the website), we will inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future by providing us with written notice (by mail) or, unless otherwise noted or agreed, by sending an e-mail to us or selecting the appropriate setting in our apps and cookies management. For withdrawing consent for online tracking, see Section 10. Where you have a user account, you may also withdraw consent or contact us also through the relevant website or other service, as applicable. Once we have received notification of withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.
Where we do not ask for consent for processing, the processing of your personal data relies on the requirement of the processing for initiating or performing a contract with you (or the entity you represent) or on our or a third-party legitimate interest in the particular processing, in particular in pursuing the purposes and objectives set out in Section 4 and in implementing related measures. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognized as a legal basis by applicable data protection law. This also includes the marketing of our products and services, the interest in better understanding our markets and in managing and further developing our company, including its operations, safely and efficiently.
Where we receive sensitive personal data (for example health data, data about political opinions, religious or philosophical beliefs, and biometric data for identification purposes), we may process your data on other legal basis, for example, in the event of a dispute, as required in relation to a potential litigation or for the enforcement or defense of legal claims. In some cases, other legal basis may apply, which we will communicate to you separately as necessary.
6. What applies in the case of profiling and automated individual decisions?
We may automatically evaluate personal aspects relating to you («profiling») based on your data (Section 3) for the purposes set out in Section 4, where we wish to determine preference data, but also to detect misuse and security risks, to perform statistical analysis or for operational planning. We may also create profiles for these purposes.
We pay attention to the proportionality and reliability of the results and take measures against misuse of these profiles or profiling. Where these can produce legal effects concerning you or similarly significantly affect you, we generally ensure human review.
In certain situations, it may be necessary for the efficiency and consistency of decision-making processes that we automate discretionary decisions that produce legal effects concerning you or similarly significantly affect you («automated individual decisions»). In these cases, we will inform you accordingly and take the measures required by applicable law.
7. Is your personal data disclosed abroad?
We disclose data to other parties during our business operation. These are not all located in Austria. Your data may therefore be processed both in Europe, the UK, the USA and in some cases, in any country in the world.
If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the revised European Commission’s standard contractual clauses, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exception. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing.
8. How long do we process your data?
We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in documentation and keeping evidence require it or storage is a technical requirement. You will find further information on the respective storage and processing periods for the individual data categories in Section 3, and for cookies in Section 11. If there are no contrary legal or contractual obligations, we will delete or anonymize your data once the storage or processing period has expired as part of our usual processes.
9. How do we protect your data?
We take appropriate security measures to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.
10. What are your rights?
Applicable data protection laws grant you the right to object to the processing of your data in some circumstances, for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing.
To help you control the processing of your personal data, you have the following rights in relation to our data processing, depending on the applicable data protection law:
– The right to request information from us as to whether and what data we process from you.
– The right to have us correct data if it is inaccurate.
– The right to request erasure of data.
– The right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller.
– The right to withdraw consent, where our processing is based on your consent.
– The right to receive, upon request, further information that is helpful for the exercise of these rights.
– The right to express your point of view in case of automated individual decisions (Section 6) and to request that the decision be reviewed by a human.
If you wish to exercise the above-mentioned rights in relation to us (or with one of our group companies), please contact us in writing, at our premises or, unless otherwise specified or agreed, by e-mail; you will find our contact details in Section 13. For us to be able to prevent misuse, we need to identify you.
You also have these rights in relation to other parties that cooperate with us as separate controllers – please contact them directly if you wish to exercise your rights in relation to their processing. You will find information on our key partners and service providers in Section 2 and additional information in Section 12.
Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.
If you do not agree with the way we handle your rights or with our data protection practices, please let us (Section 2) know. If you are in the EEA, the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country. You can find a list of authorities in the EEA here: EDPB Overview EU-Member States. You can reach the UK supervisory authority here: Contact UK DPA.
11. Do we use online tracking and online advertising techniques?
We use various techniques on our website that allow us, and third parties engaged by us, to recognize you during your use of our website, and possibly to track you through several visits. This Section informs you about this.
In essence, we wish to distinguish access by you (through your system) from access by other users, so that we can ensure the functionality of the website and carry out analysis and personalization. We do not intend to determine your identity, even if that is possible where we or third parties engaged by us can identify you by combination with registration data. However, even without registration data, the technologies we use are designed in such a way that you are recognized as an individual visitor each time you access the website, for example by our server (or third-party servers) that assign a specific identification number to you or your browser (so-called «cookie»).
We use these technologies on our website and may allow certain third parties to do so as well. However, depending on the purpose of these technologies, we may ask for consent before they are used. You can access your current settings here. You can also set your browser to block or deceive certain types of cookies or alternative technologies, or to delete existing cookies. You can also add software to your browser that blocks certain third-party tracking. You can find more information on the help pages of your browser (usually with the keyword «Data Protection») or on the websites of the third parties set out below.
We distinguish the following categories of «cookies» (including other technologies such as fingerprinting):
– Necessary cookies: Some cookies are necessary for the functioning of the website or for certain features. For example, they ensure that you can move between pages without losing information that was entered in a form. They also ensure that you stay logged in. These cookies exist temporarily only («session cookies»). If you block them, the website may not work properly. Other cookies are necessary for the server to store options or information (which you have entered) beyond a session (i.e. a visit to the website) if you use this function (for example language settings, consents, automatic login functionality, etc.). These cookies have an expiration date of up to 24 months.
– Performance cookies: To optimize our website and related offers and to better adapt them to the needs of the users, we use cookies to record and analyze the use of our website, potentially beyond one session. We use third-party analytics services for this purpose. We have listed them below. Before we use such cookies, we ask for your consent. You can withdraw consent at any time through the cookie settings here. Performance cookies also have an expiration date of up to 24 months. Details can be found on the websites of the third-party providers.
– Marketing Cookies: We and our advertising partners have an interest in targeting advertising as precisely as possible, i.e. only showing it to those we wish to address. We have listed our advertising partners below. For this purpose, we and our advertising partners – if you consent – use cookies that can record the content that has been accessed or the contracts that have been concluded. This allows us and our advertising partners to display advertisements that we think will interest you on our website, but also on other websites that display advertisements from us or our advertising partners. These cookies have an expiration period of a few days to 12 months, depending on the circumstances. If you consent to the use of these cookies, you will be shown related advertisements. If you do not agree with them, you will not see less advertisements, but simply any other advertisement.
In addition to marketing cookies, we use other technologies to control online advertising on other websites and thereby reduce advertising wastage.
We currently use offers from the following service providers and advertising partners (where they use data from you, or cookies set on your computer for advertising purposes).
12. What data do we process on our social network pages?
We may operate pages and other online presences («fan pages», «channels», «profiles», etc.) on social networks and other platforms operated by third parties and collect the data about you described in Section 3 and below. We receive this data from you and from the platforms when you interact with us through our online presence (for example when you communicate with us, comment on our content or visit our online presence). At the same time, the platforms analyze your use of our online presences and combine this data with other data they have about you (for example about your behavior and preferences). They also process this data for their own purposes, for marketing and market research purposes (for example to personalize advertising) and to manage their platforms (for example what content they show you) and, to that end, they act as separate controllers.
We process this data for the purposes set out in Section 4, for communication, for marketing purposes (including advertising on these platforms, including Section 11) and for market research. You will find information about the applicable legal basis in Section 5. We may disseminate content published by you (for example comments on an announcement), for example as part of our advertising on the platform or elsewhere. We or the operators of the platforms may also delete or restrict content from or about you in accordance with their terms of use (for example inappropriate comments).
For further information on the processing of the platform operators, please refer to the Data Protection information of the relevant platforms. There you can also find out about the countries where they process your data, your rights of access and erasure of data and other data subjects' rights and how you can exercise them or obtain further information. We currently use the following platforms:
– Facebook: On Facebook we operate the page https://www.facebook.com/gumkinder/. The controller for the operation of the platform for users from Europe is Facebook Ireland Ltd., Dublin, Ireland. Their Data Protection notice is available at www.facebook.com/policy. Some of your data will be transferred to the United States. You can object to advertising here: www.facebook.com/settings?tab=ads. Regarding the data collected and processed when visiting our site for «page insights», we are joint controllers with Facebook Ireland Ltd., Dublin, Ireland. As part of page insights, statistics are created about the actions visitors perform on our site (comment on posts, share content, etc.). This is explained at www.facebook.com/legal/terms/information_about_page_insights_data. It helps us understand how our page is used and how to improve it. We receive only anonymous, aggregated data. We have agreed our data protection responsibilities according to the information on www.facebook.com/legal/terms/page_controller_addendum.
– Instagram: Here we operate the page: https://www.instagram.com/teamplaybrush/. The entity responsible for operating the platform for users from Europe is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland. Their privacy policy is available at https://privacycenter.instagram.com/policy/. Some of your data will be transferred to the USA. We are jointly responsible with Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland, for the data that is collected and processed when you visit our site for the creation of "Instagram Insights". As part of Page Insights, statistics are compiled about what visitors do on our site (comment on posts, forward content, etc.). We have regulated our responsibilities regarding data protection in accordance with the information at www.facebook.com/legal/terms/page_controller_addendum.
– LinkedIn: Here we operate the page: https://www.linkedin.com/company/playbrush /. The entity responsible for operating the platform for users from Europe is LinkedIn Ireland Unlimited Company, Ireland. We are jointly responsible with Wilton Place, Dublin 2, Ireland, for the data collected and processed when visiting our site for the creation of "Page Insights". As part of Page Insights, statistics are compiled about what visitors do on our site (comment on posts, forward content, etc.). This is described at https://legal.linkedin.com/pages-joint-controller-addendum. It helps us to understand how our site is used and how we can improve it. We only receive anonymous, aggregated data.
– YouTube platform: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter "YouTube") In connection with the operation of our YouTube and Google (https://www.youtube.com/@gumkinder), we use the dashboard overview from Google (the provider of the services), with which Google provides us with statistical data on the use of our YouTube page. This data is anonymous to us, which means that the personal data of individual users or visitors is not visible to us. You can find out what data Google uses for usage analysis in connection with our YouTube page and what information Google provides on data processing in connection with the implemented functions here: https://policies.google.com/privacy?gl=CH&hl=de#infocollect For the YouTube platform, you can manage your selection here: https://support.google.com/youtube/answer/2531367?hl=de. You can find YouTube's privacy policy here: https://support.google.com/youtube/topic/2803240?hl=de&ref_topic=6151248.
13. Data Protection contacts
Data Controller
Playbrush GmbH, Obere Donaustraße 71/9-12, 1020 Vienna, Austria
Data Protection Officer contact
Our Data Protection Officer can be contacted directly at:
Can we update this Data Protection Notice?
This Data Protection Notice is not part of a contract with you. We may update this Data Protection Notice at any time. The version published on this website is the current version.
Last updated: 01.09.2024