Data Privacy

Privacy Policy for the CAMOONI network 

1. Scope

We take the protection of personal data extremely seriously. This Privacy Policy explains which of your personal data we process – and for what purpose – when using our online platform.

This Privacy Policy applies to all content on the CAMOONI network (hereafter referred to as CAMOONI), including newsletters and prize draws for which you register on CAMOONI.

We, Camooni GmbH, Heimhuder Strasse 63, 20148 Hamburg, Germany are responsible for providing such content (hereafter referred to as Controller).

The EU General Data Protection Regulation (hereafter referred to as GDPR) and the member state provisions to implement the GDPR, in Germany the German Data Protection Act (BDSG), form the legal basis for this Privacy Policy.

2. Definitions

Personal data

‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing

‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. 


3. Types of personal data

Access data

Access data constitutes data regarding each access to the server on which our website is hosted. Access data includes the IP address of the device accessing the server, the data and time of the request, the difference in time zone from Greenwich Mean Time (GMT), the content of the request (specific page), the access status/HTTP status code, the amount of data transmitted in each case, the requesting website, the browser, operating system and interface, as well as the language and version of the browser software.

Cookies

In addition to access data, your access device also saves cookies when you use our website. Cookies are small text files that are saved in and assigned to your browser via which certain information is served where the cookies is set (by us or third-party providers).

This website uses the following cookie types, including a description of their scope and functionality:

Transient cookies are automatically deleted from your access device when you close your browser. This includes, in particular, session cookies that save a so-called session ID which enables various browser requests to be assigned to a single session. This enables the browser session to be recognised when you return to our website. Session cookies are deleted if you log out of the platform or close your browser.

Persistent cookies are automatically deleted from your access device after a specified period of time that depends on the cookie in question.

Message data, content and member communication

If you registered as a CAMOONI member and manage your account or manage someone else’s account as a Business Manager or Coop Manager, if you use the contact form on our website, or if you take part in a prize draw, we will process the personal data you supply via the respective form or upload to the network (first name, last name, date of birth, e-mail address, postal address, profile image). We also process the username, password and content that CAMOONI members post or link to on CAMOONI, as well as any accompanying information such as likes, followers, sed cards, images, videos and audio clips. We also process personal data you share, disclose or otherwise supply to us by communicating via the platform (e.g. if you submit a complaint).

Furthermore, we process personal data in the context of press inquiries via the contact options provided for this purpose on CAMOONI.

Payment data

This includes your basic details (name and username) as well as data used to purchase credit (amount, price, date, credit, contractual details). Debit and credit card details used to purchase credit on CAMOONI is processed directly by our payment providers – PayPal GmbH and BS Payone GmbH (see Section 7 for further details).


4. Purposes of processing 

Access data

In order to operate the network, to prevent fraud and abuse, our hosting provider collects access data on our behalf. The legal basis for processing this data is Article 6(1) sentence 1 f GDPR. Please refer to Section 8 for further details on IP address processing by third-party providers.

Cookies

Cookies serve to improve the usability of websites for users (e.g. by saving login details). They can also be used to collect website usage statistics which we can analyse to improve our offerings. 
In terms of the use of cookies by third-party providers, please refer to section 8. Article 6(1) sentence f GDPR constitute the legal basis for the use of cookies.

Users can control the use of cookies. Most browsers provide an option to limit or fully deactivate the storage of cookies. However, you will experience some degree of limitation in terms of features and usability if you opt out of using cookies on CAMOONI.

Message data, content and member communication

We process message data, content and member communication for the purposes of contractual fulfilment and to operate our network (legal basis: Article 6(1) sentences a, b and f GDPR).

Payment data

We process payment data to render our contractual services as well as the subsequent accounting (legal basis: Article 6(1) sentences a and f) and billing (legal basis: Article 6(1) sentences a and b) of said services.


5. CAMOONI messaging system and e-mails sent to members

We will use our internal messaging system to let you know about CAMOONI news in relation to direct promotions as well as the security and optimisation of our network (legal basis: Article 6(1) sentences a and f GDPR). To this end, we use the Mandrill services provided by The Rocket Science Group LLC d/b/a MailChimp, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA. This means that your personal data (e-mail address and IP address) are sent to a server in the USA. Further details about the use of data in connection with this service is available here: https://mailchimp.com/legal/privacy/. Rocket Science has pledged to comply with the Privacy Shield framework between the EU and the US Department of Commerce that covers the collection, use and storage of personal data from EU Member States. Further details are provided here: https://mailchimp.com/legal/privacy/.

If you booked a showcase on CAMOONI, we will e-mail you to let you know when it is due to expire to give you an opportunity to renew it. You may also receive e-mails providing you with details about special offers on showcases like the ones you already booked. If and to the extent required for security reasons, we’ll also e-mail you about security updates surrounding the CAMOONI platform (legal basis: Article 6(1) sentences a and f GDPR). If you do not wish to receive e-mails with expiration reminders and offers, you can object to the receipt at any time by e-mail to support@camooni.com without incurring other costs than the transmission costs according to the basic rates.


6. Prize draws 


If you register for one of our prize draws, we will use your personal data to carry out and conduct the prize draw. Should you be a prize draw winner, your data may be passed on to the companies involved in the prize draw. This means that it may be necessary to pass your data on to companies that conduct a prize draw on our behalf. We generally also reserve the right to publish the names of winners on CAMOONI.  
Prize draw winners may be notified via the Intranet, e-mail or by post. If you provided a phone number during registration, we reserve the right to notify you of prize draw wins by phone. The legal basis for this is Article 6(1) sentences a and f GDPR).


7. Categories of personal data recipients

Hosting provider/e-mail provider

The data specified in Section 3 is saved on our hosting provider’s servers on our behalf. Our hosting provider is only granted access to the extent required on a technical level. If you communicate with us via e-mail, your e-mails and any personal data provided therein will be saved on the servers of our e-mail provider, Google G-Suite. As a result, any such data as specific in Section 3 that you provide to us in e-mails may be sent to the USA. To this end, we refer to Google’s data security policy available here: https://gsuite.google.com/intl/en/faq/security/. The legal basis for this is Article 6(1) sentences a and f GDPR. We require the aforementioned services to operate and optimise our network.

IT service provider

Our IT service provider is also granted access to the data specified in Section 3 for the purpose of system maintenance and optimisation. The IT service provider does not perform any further processing, and it has no access to member correspondence unless absolutely required for technical reasons (legal basis: Article 6(1) sentences a and f GDPR).

Payment providers

Payment data is forwarded to the payment providers (PayPal GmbH, BS Payone GmbH) for the purpose of processing payments (legal basis: Article 6(1) sentences a and b GDPR). Please refer to the payment providers’ respective privacy policy for provisions regarding their processing of payment data:

PayPal GmbH: https://www.paypal.com/uk/webapps/mpp/ua/privacy-prev

BS Payone GmbH: https://www.payone.com/en/privacy/

PR agency

 

Personal data sent to us in press inquiries will possibly be transmitted to our PR agency for the purpose of responding to requests (Article 6(1) sentence 1 f DSGVO.

Auditors, tax consultants, debt collection agencies, lawyers

We also supply payment data to the auditors and tax consultants we commission to handle our accounting processes, and – where necessary – to debt collection agencies to collect outstanding debts, and to lawyers as and when required for legal reasons (legal basis: Article 6(1) sentences a and f GDPR).

Integration of third-party services and content

Please refer to Sections 5 and 8 for further information about the integration of third-party services and content on our website and the corresponding data transfers.

A transfer to other third parties otherwise will occur only in the following cases:

- if necessary for the assertion, exercise or defense of legal claims and there is no reason to believe that you have a predominant legitimate interest in failure to disclose your data (legal basis is Article 6(1) sentence 1 f GDPR);

- We are required by law to disclose in connection with government inquiries, court orders or legal proceedings.


8. Integration of third-party services and content

CAMOONI provides a range of services from other companies to improve our offering for you (legal basis: Article 6(1) sentences a and f GDPR). In order to do so, the providers of such content (hereafter referred to as Third-party Providers) require the user’s IP address as they are unable to send content to the respective user’s browser if they do not have the IP address. Hence, the IP address is required to serve such content. We strive to only use content from Third-party Providers that use your IP address solely for the purpose of serving content. However, we do not have any influence over Third-party Providers who also use your IP address, e.g. for statistical or other purposes. To this end, please refer to the respective Third-party Provider’s Privacy Policy provided below. We offer the following services from Third-party Providers:

Facebook

Creating a CAMCUT (video blogshot)

If a CAMOONI user enters a link (URL) to a Facebook video in the user interface with the aim of creating a blogshot, or if a user clicks on ‘play’ to watch a CAMCUT linked to a Facebook video, the user’s IP address will be sent to Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (hereafter referred to as Facebook).

Share button

Users can use the ‘share’ button to share a blogshot on Facebook. We do not have any influence over the scope of data that Facebook collects with this plugin, and therefore provide users with information based on our level of knowledge which is such that only the user’s IP address is sent to Facebook, and only for the purpose of displaying the button.

Facebook Data Policy

The purpose and extent to which Facebook collects, processes and uses user data, and the user’s corresponding privacy rights and settings are provided in Facebook’s Data Policy: https://www.facebook.com/about/privacy/ Here you get to know more.

Facebook members who do not want Facebook to collect their personal data when using CAMOONI and who do not want Facebook to link said data to their saved member data must log out of Facebook before visiting CAMOONI. It is also possible to block Facebook Social Plugins by way of browser add-ons.

Facebook has pledged to comply with the Privacy Shield framework between the EU and the US Department of Commerce that covers the collection, use and storage of personal data from EU Member States. Further details are provided here: https://www.privacyshield.gov/.

Google

Google Analytics

CAMOONI uses Google Analytics, a web analysis service provided by Google Inc. (‘Google’). Google Analytics uses so-called cookies, i.e. text files saved on your computer which can be used to analyse your use of the CAMOONI platform. Your CAMOONI usage information saved by the cookie is generally sent to and saved by a Google server in the US. However, if IP anonymisation is used on this website, Google will shorten your IP address before sending it to a server in the US if you are located in one of the Member States of the European Union or other States party to the Agreement on the European Economic Area. Your IP address will only be sent to a Google server in the US before being shortened there in exceptional circumstances. Google will use this information to evaluate your use of the CAMOONI platform, to generate reports on website activity, and to provide additional services in connection with your website use and overall Internet use. The IP address sent to Google Analytics from your browser will not be collated with any other Google data. You can block cookies from being saved by activating the corresponding setting in your browser software. However, we would like to point out that you may not be able to use all of CAMOONI’s features in full if you choose to block cookies. If you would like to prevent Google from setting a cookie to collect your website usage data and IP address, and from subsequently processing said data, you can download and install the following browser add-on: http://tools.google.com/dlpage/gaoptout

We would like to point out that the Google Analytics code snippet gat._anonymizeIp(); was added to this webpage to ensure anonymised collection of IP addresses (known as IP masking).

Further information about the terms of use and privacy are available here: https://support.google.com/analytics/answer/6004245?hl=en

Google has pledged to comply with the Privacy Shield framework between the EU and the US Department of Commerce that covers the collection, use and storage of personal data from EU Member States. Further details are provided here: https://www.privacyshield.gov/.

Share button for Google Plus (Google+)

Users can use the ‘share’ button to share a blogshot on Google Plus. We do not have any influence over the scope of data that Google collects with this plugin, and therefore provide users with information based on our level of knowledge which is such that only the user’s IP address is sent to Google, and only for the purpose of displaying the button.

YouTube

When clicking on CAMCUTS inked to YouTube, the user’s IP address will be sent to YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. Further information about user data usage is provided in the Google Privacy Policy: https://www.google.de/intl/en/policies/privacy/

Google has pledged to comply with the Privacy Shield framework between the EU and the US Department of Commerce that covers the collection, use and storage of personal data from EU Member States. Further details are provided here: https://www.privacyshield.gov/.

Pinterest

Individual blogshots can be ‘pinned’ on Pinterest, which is operated by Pinterest Inc., 808 Brannan Street, San Francisco, CA 94103-490, USA. When clicking on the Pinterest logo, log data is sent to Pinterest servers located in the US. This log data may contain your IP address, the address of websites you visited that also use Pinterest features, information about your browser and browser settings, the date and time of the request, your Pinterest usage behaviour, and cookies.

For further details about the type of information Pinterest collects, uses and processes, and to learn about your corresponding rights and privacy options, please refer to the Pinterest privacy policy: https://policy.pinterest.com/en/privacy-policy


9. Data provision

When registering and purchasing credit on CAMOONI, personal data must be provided in order to conclude an agreement. You are not otherwise obliged to provide any personal data when visiting CAMOONI; however, your PC’s IP address will be automatically collected when visiting CAMOONI. Please refer to Sections 4 and 8 of this Privacy Policy for information regarding the use of cookies.


10. Duration of processing

Access data and cookies

For security reasons, access data is saved on an ongoing basis (e.g. to clarify instances of fraud and misuse).

We have no influence over the duration of processing if Third-party Providers process IP addresses and use cookies to process usage data. Sections 5 and 8 provide a series of links to the privacy policies of third-party providers which inform you of their respective duration of processing.

Account and purchasing data

Personal data we process for contractual purposes are saved in line with the retention periods prescribed under fiscal and trade law or other statutory retention periods (the retention periods are between 2 to 10 years). If we send or disclose your personal data to third parties in order to render services, fulfil contractual duties and for billing purposes (Sections 5 and 7), we have no influence of the duration of processing by these companies.

Content and member communication

We continue to publicise posted content on CAMOONI beyond the term of your membership unless we are legally obliged to remove said content from the CAMOONI platform. CAMOONI shall not use said content for any other purposes following termination of membership. We also save any member communication via the network beyond the membership term as deletion of individual communication would involve an unreasonable amount of time and effort.

E-mails to members

E-mails will only be sent to members for the purposes set out in Section 5 unless separate consent has been granted to send such e-mails beyond the contractual term.

Prize draws

Data collecting in connection with a prize draw will be deleted once the prize draw has been completed in full unless there are statutory retention periods requiring sustained storage of said data. This may include, for example, fiscal provisions applicable as a result of winning prizes. Prize draw data will be deleted once any statutory retention periods expire unless you provided your consent for us to retain it beyond said retention periods.

Other data submitted

We will save any data you submit via our web forms or by other means, such as by e-mail, for as long as required to process your request unless said data is subject to prolonged retention periods under fiscal and trade law or other statutory retention periods (the retention periods are between 2 to 10 years) or unless you provided your consent to retain said data for longer.


11. Right of objection

You have the right to object to the collection of personal data processed in line with Section 6(1) sentence f GDPR at any time if you find yourself in a certain situation that justifies such an objection. However, your personal data will continue to be processed if there are legitimate grounds for continuing to process the data that outweigh your interests, rights and liberties, or if processing serves to assert or defend legal claims. If we process your personal data for direct advertising purposes, you have the right to object to your personal data being processed for such promotional purposes at any time without the need to state a reason (Article 21 GDPR).


12. Other data subject rights

You are entitled to withdraw the consent you granted. We would like to advise you that withdrawal does not have any effect on the lawfulness of your consent to process data until such time as you withdraw your consent (i.e. your withdrawal does not apply retrospectively).

Within the scope of the GDPR you have the right to request, free of charge, the personal data we have stored about you (Article 15 GDPR).

The GDPR also gives you a right to rectification (Article 16 GDPR), a right to erasure (Article 17 GDPR), a right to restriction of processing (Article 18 GDPR) and a right to data portability (Article 20 GDPR) of your personal data.

You also have the right to lodge a complaint with the supervisory authority responsible for CAMOONI in justified cases (Article 77 GDPR).

You can assert your rights arising from the GDPR by e-mail or in writing. The provider’s contact details are provided below.


13. Contact details

Controller: Camooni GmbH, Heimhuder Strasse 63, 20148 Hamburg, Germany 

Responsible data protection authority: Freie und Hansestadt Hamburg, Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit (Free and Hanseatic City of Hamburg, Hamburg Commissioner for Data Protection and Freedom of Information), Klosterwall 6 (Block C), 20095 Hamburg, Germany, Phone: +49 40 428 54 4040, Fax: +49 40 428 54 4000, e-mail: mailbox@datenschutz.hamburg.de

Last updated: May 2018

Use of cookies We use our own and third-party cookies to continually optimise your experience on our website. By continuing to use our website you agree to the use of cookies. Further information about cookies is provided in our Privacy Policy.