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DATA PRIVACY POLICIES

Last update: Sept 29, 2023
For privacy inquiries, please write to privacy[at]1plusx.com


1PLUSX DATA PRIVACY POLICIES

In the following policy, we would like to provide information about how we
handle your personal data in accordance with Art. 13 of the General Data
Protection Regulation (GDPR).

1. Controller

The controller for the data collection and processing described below is 

1plusx GmbH

Eichenstrasse 2

8808 Pfäffikon

Switzerland

Email: privacy@1plusx.com

 

2. Representative in the EU

According to GDPR Article 27, data subjects who are in the EU can also contact
our representative in the EU, Arthur Cox LLP, FAO Company Compliance and
Governance, Ten Earlsfort Terrace, Dublin, D02 T380, Ireland; Email:
privacy@triplelift.com

 

3. Data processing for our website’s operations

In the following, we would like to inform you about how we handle your personal
data when you visit our website.

 

3.1 Usage data

When you visit our webpage, usage data is temporarily processed on our web
server to technically enable you to call up our web pages. 

This data record consists of

 * the name and address of the requested content
 * the date and time of the request
 * the amount of data transferred
 * the access status (content transferred, content not found)
 * the description of the web browser and operating system used
 * the referral link, which indicates the page from which you came to ours
 * the IP address of the requesting computer, which is shortened so that a
   personal reference can no longer be established.

We process your usage data in accordance with Art. 6 (1) p. 1 lit. f GDPR in our
legitimate interest to be able to provide you with a functional website.

Subsequently, the data records are anonymized by shortening your IP address to
evaluate them for statistical purposes and improve the quality of our websites
and to store them in a log.

 

3.2 Cookiebot Consent Banner

On our websites, we use the consent banner “Cookiebot” of the provider Cybot
A/S, Havnegade 39, 1058 Copenhagen, Denmark, within the scope of a commissioned
processing relationship according to Art 28 GDPR. The data processing by
Cookiebot is carried out on the basis of Art. 6 para. 1 p. 1 lit. f GDPR for the
purpose of and in our legitimate interest to be able to use cookies and similar
technologies on our websites in a data protection compliant manner and to enable
you to easily withdraw your consent.

If you provide consent via our Consent Banner, Cybot processes the following
data:

 * Your IP address
 * the date and time of consent
 * the user agent of the end user’s browser
 * the URL from which the consent was sent
 * a pseudonymous, random and encrypted key (key)
 * Your consent status, which serves as proof of your consent.

Your data is logged on Cybot’s servers. Your IP address is shortened by removing
the last three digits so that a personal reference can no longer be established.
Your key and consent status are also stored in the cookie “CookieConsent” in the
browser of your end device for a period of 12 months. In this way, our website
is able to check your consent status for all subsequent and future page views
and to activate or deactivate them in accordance with your decision to use
cookies and other technologies when you return to the page. The verification is
done by matching the key and consent status from the “CookieConsent” cookie with
the values provided to Cybot when you gave your consent to ensure that the
status of your original consent has not changed.

For more information about Cybot’s handling of personal data, please visit
https://www.cookiebot.com/de/privacy-policy/.

 

3.3 Cookie policy of 1plusX.com

Below you will find our guidelines and explanations on the use of cookies and
similar techniques on our websites. The content is automatically displayed as a
script via our Consent Banner System (CookieBot). For proper display and
function, your browser settings must allow for the loading of scripts.  Our
Consent Banner can also be retrieved at any given time via the link Privacy
settings in our footer at the bottom of the page.

--------------------------------------------------------------------------------



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it to the domain group in the Cookiebot Manager to authorize the domain.



3.4 Google Tag Manager

On our website, we integrate the “Google Tag Manager” of Google LLC, 1600
Amphitheatre Parkway, Mountain View, California 94043, USA.

In the European Union (EU) and the European Economic Area (EEA), Google Tag
Manager is offered as a service by Google Ireland Limited Gordon House, Barrow
Street, Dublin 4, Ireland.

Google Tag Manager is a tag management system (TMS) that allows us to integrate
and manage additional website content in JavaScript or HTML code. 

In particular, so-called tags can be integrated and managed on our website. Tags
are small code fragments or markings (web beacons, tracking pixels or similar
markings) that allow services to distinguish or identify users for website
analysis or user tracking purposes. 

The analysis of website visits or user tracking is not carried out by the Google
Tag Manager, but by the services used for these purposes, such as Google
Analytics or other third-party solutions. Rather, the Google Tag Manager merely
serves to integrate and manage the tags necessary for analysis or tracking into
our website. Since the Google Tag Manager is provided by Google and is reloaded
from its servers when the page is called up, the usage data technically required
for calling up the page is also transmitted. Google also receives your IP
address, which is technically required to retrieve the content. 

The data processing is based on Art. 6 para. 1 p. 1 lit. f GDPR. The purpose and
our legitimate interest are to efficiently manage our website content. Data
processing may also take place outside the EU or EEA in third countries. There
is a risk that authorities in third countries may access the data for security
and monitoring purposes without you being informed or having legal recourse. We,
therefore, take measures in accordance with Art. 44 et seq. GDPR to ensure an
adequate level of data protection despite these risks. In principle, we have no
influence on further data processing by the third-party provider.

Further information on the handling of personal data by Google can be found at
https://policies.google.com/privacy?hl=de.

 

3.5 Website analytics and tracking

3.5.1 Google Analytics

We use the web analytics service “Google Analytics” of Google LLC, 1600
Amphitheatre Parkway, Mountain View, California 94043, USA, for the
demand-oriented design of our website. In the European Union (EU) and the
European Economic Area (EEA), Google Analytics is offered as a service by Google
Ireland Limited Gordon House, Barrow Street, Dublin 4, Ireland, which supports
us as a processor according to Art. 28 GDPR. Google Analytics creates usage
profiles based on pseudonyms and usage data. In the process, user interactions
such as button clicks, scroll depth, and the use of filtering and search
functions are also recorded. For this purpose, permanent cookies are stored on
your terminal device and read by us. In this way, we are able to recognize
returning visitors and count them as such. Collected data is stored by us in
Google Analytics for a period of 26 months. Data processing is based on your
consent pursuant to Art. 6 para. 1 p. 1 lit. a GDPR, provided you have given
your consent via our Consent banner. Your consent is voluntary and can be
withdrawn at any time with effect for the future pursuant to Art. 7 (3) GDPR.
You can withdraw your consent at any time by clicking on “Change your consent”
or via the link, “Privacy settings”.

In this context, the processing of your data may also take place in countries
outside the European Union (EU) and the European Economic Area (EEA) in third
countries without an adequate level of data protection, in particular in the
USA. If your data is transferred to third countries, there is a risk that
authorities there may access your data for security and monitoring purposes
without you being informed or being able to appeal. We transfer your data to
third countries on the basis of your consent pursuant to Art. 49 (1) p. 1 lit. a
GDPR. In principle, we have no influence on further data processing by the
third-party provider.

For more information on the handling of personal data by Google, please visit
https://policies.google.com/privacy?hl=de.

 

3.5.2 Google Ads Conversion Tracking

On our websites, we integrate the “Google Ads Conversion Tracking” of Google
LLC, 1600 Amphitheatre Parkway, Mountain View, California 94043, USA. In the
European Union (EU) and the European Economic Area (EEA), Google Ads conversion
tracking is offered as a service by Google Ireland Limited Gordon House, Barrow
Street, Dublin 4, Ireland. If an ad placed by us via Google Ads is displayed to
you on other websites or if you click on it, these other websites store a Google
Ads conversion tracking cookie with a pseudonym assigned to us in your terminal
device on the basis of your consent given there. If you subsequently visit our
websites within the storage period of this cookie, this cookie will be read by
Google ad conversion tracking on our website. In this way, Google can determine
that you were shown an advertisement placed by us or that you clicked on it and
subsequently visited our websites as well as, if applicable, how you
subsequently used our websites. 

The conversion of an advertisement into action by the website visitor is
referred to as a conversion. From this information, Google Ads creates
statistics for us, from which we can see how many users have responded to our
advertisements and in what way. Based on these statistics, we can optimize the
effectiveness of our advertising and control our advertising strategy. Data
processing is based on your consent pursuant to Art. 6 para. 1 p. 1 lit. a GDPR,
provided you have given your consent via our Consent banner. Your consent is
voluntary and can be withdrawn at any time with effect for the future pursuant
to Art. 7 (3) GDPR. You can withdraw your consent at any time by clicking on
“Change your consent” or via the link, “Privacy settings”.

In this context, the processing of your data may also take place in countries
outside the European Union (EU) and the European Economic Area (EEA) in third
countries without an adequate level of data protection, in particular in the
USA. If your data is transferred to third countries, there is a risk that
authorities there may access your data for security and monitoring purposes
without you being informed or being able to appeal. We transfer your data to
third countries on the basis of your consent pursuant to Art. 49 (1) p. 1 lit. a
GDPR. In principle, we have no influence on further data processing by the
third-party provider.

For more information on the handling of personal data by Google, please visit
https://policies.google.com/privacy?hl=de.

 

3.5.3 Crazy Egg

We use the UX tool Crazy Egg on our website (Crazy Egg, Inc., 6220 E. Ridgeview
Lane, La Mirada, CA, 90638, USA. Crazy Egg). The tool uses cookies to help to
analyze anonymous user clicking behavior and navigation. This information
generated by the cookie about your use of the 1plusX website is transferred to
Crazy Egg’s servers in the USA and stored there. If you don’t wish to be
tracked, you can stop Crazy Egg from collecting cookie data related to your
website usage (IP address included) and terminate processing of data by Crazy
Egg, you can opt-out here:

http://www.crazyegg.com/opt-ou…

In-depth information about  data collection and processing  by Crazy Egg can be
found here:

http://www.crazyegg.com/privac…

 

3.5.4 LinkedIn Insight Tag

We use the LinkedIn Insight Tag, a piece of java script code to track
conversions, retarget website visitors, and analyze additional user interaction
with our LinkedIn posts and advertising. The LinkedIn Insight Tag enables the
collection of metadata such as IP address information, timestamp, and events
such as page views. All data is encrypted. The LinkedIn browser cookie is stored
in a visitor’s browser until they delete the cookie or the cookie expires
(there’s a rolling six-month expiration from the last time the visitor’s browser
loaded the Insight Tag). You can opt-out of cookies on your LinkedIn settings
page. Visit their Cookie Policy for more information.

The data processing is based on your consent pursuant to Art. 6 para. 1 p. 1
lit. a GDPR, provided that you have given your consent via our Consent Banner.
Your consent is voluntary and can be withdrawn at any time with effect for the
future pursuant to Art. 7 (3) GDPR. You can withdraw your consent at any time by
clicking on “Change your consent” or via the link, “Privacy settings”.

Data processing may also take place outside the EU or EEA in third countries.
There is a risk that authorities in third countries may access the data for
security and monitoring purposes without you being informed or having legal
recourse. We transfer your data to third countries on the basis of your consent
pursuant to Art. 49 (1) p. 1 lit. a GDPR. In principle, we have no influence on
further data processing by the third-party provider.

For more information on the handling of personal data by Hotjar, please visit
https://de.linkedin.com/legal/cookie-policy.

 

3.6 Google ReCaptcha

To protect our web forms from automated requests, we use so-called Captchas.
Within the captcha function, you may be asked to solve tasks or click on
checkboxes. The user input in this context and, if necessary, the mouse
movements are used to estimate whether the input comes from a human being or an
automated program. The Captcha embedding is based on Art. 6 para. 1 p. 1 lit. f
GDPR and in the interest of protection against spam and abuse.

If you do not wish this data processing, please refrain from using our web
forms.

 

3.7 ‘Contact Us’ form

You have the possibility to contact us via our contact form. To use our contact
form, we need the data provided in the contact form from you. These are email
address, subject and the message or request itself.

We use this data on the basis of Art. 6 para. 1 p. 1 lit. f GDPR to be able to
answer your inquiry as promptly and accurately as possible. Your data will only
be processed to answer your inquiry. We will delete your data if it is no longer
required and there are no legal retention obligations to the contrary. With
regard to processing pursuant to Art. 6 (1) p. 1 lit. f GDPR, you have the right
to object at any time. For this purpose, please contact the e-mail address
stated in the imprint.

You may also subscribe to the 1plusX newsletter and other marketing
communications by registering your email and opt-in found in the footer of each
page on our website. Please refer to section 3.10 in this privacy policy.

 

3.8 Content downloads

Content downloads: when you download content off our content hub or other parts
of our site, we store the data you submit through the form. This data is only
used to deliver the requested content, and to keep a record that we have been in
touch with you. 

You may also subscribe to the 1plusX newsletter and other marketing
communications by registering your email and opt-in found in the footer of each
page on our website. Please refer to section 3.10 in this privacy policy.

 

3.9 ‘Book a demo’ form

You have the option to contact us by clicking on “Book a Demo”. 

To be able to contact you as an interested party and potential customer with a
view to initiate further contact, we collect and process the data to be entered
in the input mask. These are your first and last name, your email address, your
company, country as well as telephone number and your request itself. The legal
basis is the necessity to carry out pre-contractual measures according to Art. 6
para. 1 p. 1 lit. b) GDPR or the legitimate interest according to Art. 6 para. 1
p. 1 lit. f) GDPR to contact you for an interest in concluding a contract with
the company for which you have requested us. Your data will only be processed to
respond to your inquiry. We delete your data if they are no longer required and
there are no legal retention obligations to the contrary. With regard to
processing pursuant to Art. 6 (1) p. 1 lit. f GDPR, you have the right to object
at any time. For this purpose, please contact the email address stated in the
imprint. 

You may also subscribe to the 1plusX newsletter and other marketing
communications by registering your email and opt-in found in the footer of each
page on our website. Please refer to section 3.10 in this privacy policy.

 

3.10 Marketing communications

On each page of our website, we offer you the opportunity to subscribe to 1plusX
marketing communications, such as our newsletter. As part of the registration
process, we process your email address to inform you by email about our
products, services, events and promotions.

In addition, as part of our newsletter or marketing communications tracking, we
process data at the time you opened the respective email as well as on your
other interactions with the content, e.g. clicks on further links or the
percentage at which you read the email. We process this data to check the
effectiveness of our marketing communication and to optimize our relevant
content. The legal basis for data processing is your consent pursuant to Art. 6
(1) p. 1 lit. a GDPR. Your consent is voluntary and can be withdrawn at any time
with effect for the future pursuant to Art. 7 (3) GDPR.

If you no longer wish to receive 1plusX communications, you can unsubscribe at
any time by using the unsubscribe link that you will find in every newsletter or
marketing communication we send you.

You can also declare your wish to cancel all 1plusX marketing communications by
sending an to privacy@1plusx.com.

In the context of our marketing communications, we transmit your data to
Hubspot, Inc., 25 First Street, Cambridge, MA 02141 USA , which is a strictly
instruction-bound and accordingly contractually obligated service provider
vis-à-vis us, within the scope of order processing pursuant to Art. 28 GDPR.
Further information on the handling of personal data can be found at
https://legal.hubspot.com/privacy-policy. Data processing may also take place
outside the EU or EEA in third countries. There is a risk that authorities in
third countries may access the data for security and monitoring purposes without
you being informed or being able to appeal. We therefore take measures in
accordance with Art. 44 et seq. GDPR to ensure an adequate level of data
protection despite these risks.

 

3.11 Social Plugins

We enable you to use social plugins for Twitter, Facebook and LinkedIn. For
reasons of data protection, however, we only integrate the social plugins we use
in deactivated form. When you call up our websites, no data is therefore
transmitted to social media services. However, you have the option of activating
and using the social plugins integrated into our websites. For this purpose, we
use a solution that results in all data and functions required to display the
social plugin being provided by our web server in a first step. Only when you
decide to activate the respective social plugin and click on the corresponding
preview image or icon, a connection to the servers of the operator of the
respective social media service is established by your browser in a second step.

When you activate a plugin, the social media service receives in particular your
IP address and, among other things, knowledge about your visit to our websites.
This occurs regardless of whether you have an account with the respective social
media service. If you are logged in, the data can be directly assigned to your
social media profile. Overall, we have no influence on whether and to what
extent the respective social media service processes personal data after
activation. However, it is likely that the social media service will create
usage profiles from your data and use them for the purpose of personalized
advertising. In addition, your data will be used to inform other users of the
social media service about your activities on our websites.  The embedding is
based on your consent pursuant to Art. 6 para. 1 p. 1 lit. a GDPR, provided that
you have given your consent by clicking on the preview image. Please note that
the embedding of many social plugins leads to your data being processed outside
the EU or EEA. In some countries, there is a risk that authorities may access
the data for security and monitoring purposes without you being informed or
being able to appeal. If we use providers in unsafe third countries and you
consent, the transfer to an unsafe third country will be based on Art. 49 (1)
lit. a GDPR. 

If you no longer wish your personal data to be processed by the activated social
plugins, you can prevent future processing by no longer clicking on the preview
image or icon of the respective social plugin.

 

3.12 Job applications via our website

When you click on one of the job advertisements on our website, you will be
taken to the page of one or more of the vendors we use to manage our recruitment
related activities, which could include, for example, communicating with you and
responding to your requests, updating you on the status of your application,
informing you about new vacancies, setting up and conducting interviews and
tests for applicants, backgrounds checks processing and similar services related
to processing your job application. When we collect or receive information from
a third-party, such as from a job recruiting site, your provision of and our
access to information will be governed by those parties’ own policies and
applicable laws.

If you are located outside of the United States, your personal data may be
transferred to the United States once you submit it through one of these sites.
The transfer to the United States will be subject to appropriate additional
safeguards under contractual agreements.

Your personal data will be retained for as long as reasonably necessary to
evaluate your application for employment and related administration, in
accordance with applicable laws or regulatory requirements.

 

4. Further data processing activities

In the following, we would like to inform you about other data processing
activities in which we may process your personal data.

 

4.1 General processing of business contact data

If you are in contact with us or have a contractual relationship with us, for
example as a supplier, customer, interested party or business partner, we may
process your data in our programs, such as our CRM systems, to the extent
necessary for the respective purpose. We process and store this data there for
as long as necessary or as long as statutory retention obligations may exist.
The legal basis is our legitimate interest in a practicable implementation and
maintenance of our business relationships in accordance with Art. 6 para. 1 p. 1
lit. f) GDPR.

 

4.2 Data processing for the assertion, exercise or defense of legal claims

In addition, we process your data in individual cases for the purpose and in the
interest of asserting, exercising and defending legal claims, provided that your
data is relevant to a legal dispute. The legal basis for the processing of your
data is Art. 6 para. 1 p. 1 lit. f GDPR. If necessary, your data will be
transmitted in individual cases to the required extent to investigating
authorities, lawyers, experts, courts or bailiffs.

 

4.3 Data processing for the documentation of data protection compliance

Insofar as you provide us with a declaration of consent on our websites, we
process your personal data in order to be able to prove that you have consented
to the data processing in question as part of the accountability obligation
incumbent upon us under Article 5 (2) GDPR. Insofar as you exercise your data
subject rights under the GDPR towards us, we also process your personal data in
order to be able to prove within the scope of the accountability obligation
pursuant to Art. 5 (2) GDPR that we have complied with the GDPR when processing
your request. In addition, it may happen that we forward your personal data in
connection with an inquiry to our company data protection officer, who advises
us on all data protection issues and supports us in particular in processing
inquiries from data subjects in connection with the assertion of the rights
mentioned below. In each case, the processing is carried out on the basis of
Art. 6 para. 1 p. 1. lit. c GDPR.

 

4.4 Data processing for the fulfillment of other legal obligations

Finally, we process personal data if this is necessary for the fulfillment of a
legal obligation. The legal basis for the processing of your data in these cases
is Art. 6 para. 1 p. 1 lit. c GDPR in conjunction with the respective legal norm
that imposes such an obligation on us. If necessary, your data will be
transmitted in individual cases to the required extent to auditors, financial or
investigative authorities, lawyers, experts or courts.

 

4.5 Data transfer to independent third parties in the event of company
restructuring

For the purpose of and in the interest of preparing and carrying out the sale of
individual legal assets of our company or individual parts of our company for
the purpose of making a profit, we transfer personal customer data to
acquirers. The legal basis for this is Art. 6 para. 1 p. 1 lit. f GDPR.

 

5. Recipients or categories of recipients of personal data

The recipients of your data as well as data transfers to third countries have
already been indicated separately in some cases in the data processing described
above. Furthermore, we may transfer your data to service providers who support
us, for example, in the operation of our websites or communication tools used,
for example, as hosting or cloud services providers, if the legal data
protection requirements are met. For example, if the data protection
requirements are met, we transmit personal data to authorities, such as billing
data, if applicable, to tax authorities. If contracts under data protection law
are required for the transfers, we have concluded corresponding contracts with
the service providers. Insofar as data processing may also take place outside
the EU or EEA in third countries, there is a risk that authorities in third
countries may access the data for security and monitoring purposes without you
being informed or having the right to appeal. We therefore take measures in
accordance with Art. 44 et seq. GDPR to ensure an adequate level of data
protection despite these risks, for example by concluding standard contractual
clauses with our service providers in conjunction with further technical
measures.

 

6. Storage period of data

Unless a specific storage period is specified separately for the data processing
described above, we process your data as long as this is necessary to achieve
the stated purposes or a separately granted declaration of consent to longer
storage is available. We then delete your data from all our operational systems.
We proceed in the same way if, in the case of processing based on the consent
granted to us pursuant to Art. 6 (1) sentence 1 lit. a GDPR, you exercise your
right of revocation pursuant to Art. 7 (3) GDPR or, in the case of processing
based on legitimate interests pursuant to Art. 6 (1) sentence 1 lit. f GDPR, you
exercise your right of objection pursuant to Art. 21 GDPR and the conditions
stated therein are met.

In particular, insofar as in the event of your objection there are demonstrably
compelling grounds for further processing by us that outweigh your interests,
rights and freedoms as a data subject, this would continue to be permissible.
The same applies if the processing serves the assertion, exercise or defense of
legal claims by us. Insofar as the fulfillment of a legal retention obligation
imposed on us precludes deletion, we transfer the data concerned to archives and
restrict further processing for the duration of the retention period. In this
case, final deletion will only take place after the retention period has
expired.

 

7. Voluntariness of the provision of your data

The provision of your personal data is neither legally nor contractually
required. However, in certain cases, it is necessary for you to be able to use
the services offered on our websites. Failure to provide personal data may
result in our websites being restricted in their functions or in you not being
able to use the services offered.

 

8. Your rights

When processing your personal data, the GDPR grants you certain rights as a data
subject:

 

8.1 Right of access by the data subject (Art. 15 GDPR)

You have the right to obtain confirmation as to whether personal data concerning
you is being processed; if this is the case, you have a right to be informed of
this personal data and to receive the information specified in Art. 15 GDPR.

 

8.2 Right to rectification (Art. 16 GDPR)

You have the right to rectification of inaccurate personal data concerning you
and, taking into account the purposes of the processing, the right to have
incomplete personal data completed, including by means of providing a
supplementary statement without delay.

 

8.3 Right to erasure (Art. 17 GDPR)

You have the right to obtain the erasure of personal data concerning you without
undue delay if one of the reasons listed in Art. 17 GDPR applies.

 

8.4 Right to restriction of processing (Art. 18 GDPR)

You have the right to request the restriction of processing if one of the
conditions listed in Art. 18 GDPR is met, e.g. if you have objected to the
processing, for the duration of our examination.

 

8.5 Right to data portability (Art. 20 GDPR)

In certain cases, which are listed in detail in Art. 20 GDPR, you have the right
to receive the personal data concerning you in a structured, commonly used and
machine-readable format, or to request that this data be transferred to a third
party.

 

8.6 Right to object (Art. 21 GDPR)

If data is collected on the basis of Art. 6 (1) 1 f GDPR (data processing for
the purpose of our legitimate interests) or on the basis of Art. 6 (1) 1 e GDPR
(data processing for the purpose of protecting public interests or in the
exercise of official authority), you have the right to object to the processing
at any time for reasons arising from your particular situation. We will then no
longer process the personal data unless there are compelling legitimate grounds
for the processing which override your interests, rights and freedoms or if data
is still needed for the establishment, exercise or defence of legal claims.

 

8.7 Right to withdraw consent (Art. 7 GDPR)

If the processing of data is based on your consent, you are entitled to withdraw
your consent to the use of your personal data at any time in accordance with
Art. 7 (3) GDPR. Please note that the withdrawal is only effective for the
future. Processing that took place before the withdrawal is not affected. 

 

8.8 Right of complaint to a supervisory authority (Art. 77 GDPR)

According to Art. 77 GDPR, you have the right to lodge a complaint with a
supervisory authority if you believe that the processing of your data violates
data protection regulations. This right may be asserted in particular with a
supervisory authority in the Member State of your habitual residence, your place
of work or the place of the suspected infringement. 

 

9. Contact details of the data protection officer

Our company data protection officer will be happy to provide you with
information or suggestions on the subject of data protection. Please contact us
at: privacy@1plusx.com. 

 

10. Amendment of this data protection declaration

This data protection declaration was last updated on 14.12.2021.

 


1PLUSX'S PRIVACY POLICY
DATA MANAGEMENT PLATFORM

1plusX collects and processes data as a data processor on behalf of our
customers. Data collection is used among other things, to deliver relevant
advertising or content, to improve the user experience and to enhance analytical
skills for our customers.

Our customers have privacy policies in place which explain the usage, the data
security and your choices as a user regarding your data. If you have a cookie
from us set in your browser, it means it has been set from us as a data
processor to enable our service to our customers, the data controllers. All your
user rights can be executed directly on the privacy policies of our customers.

Partners of 1plusX

While 1plusX actively communicates high data protection standards to its
partners through contractual agreements and other measures, the partners
themselves are responsible for compliance and therefore 1plusX cannot be held
liable for any violation of the 1plusX data protection guidelines by one of the
partners used by 1plusX.

1plusX works together with the following partners for the playout of
advertising:

 * Adform
 * Adition Technologies
 * Contact Impact
 * DreamLab
 * Facebook
 * Google Ad Manager
 * Google Display & Video 360
 * Improve Digital
 * Madvertise
 * MediaMath
 * MailChimp
 * One by AOL
 * Rubicon Project
 * Smart Ad Server
 * Xandr
 * YieldLab

When working with these partners, some data is also transmitted to their ad
servers, some of which may be located in countries outside the European Union.
This is pseudonymised cookie information (cookie ID or device ID) and the
assignment to relevant advertising segments. In this respect, it is ensured that
an appropriate level of data protection exists in each case.


OPT-IN AND OPT-OUT



1plusX adheres to the Europe-wide principles of the EDAA, the Online Behavioral
Advertising Framework. 1plusX is also an official vendor of the IAB Transparency
and Consent Framework, as listed here.

You can perform a cross-customer opt-in and a cross-customer opt-out, via the
“Your Ad Choices” management by our partner Your Online Choices. To opt-out or
opt-in, click https://www.youronlinechoices.com/uk/your-ad-choices

Additional Requests related to the 1plusX Data Management Platform

For additional requests related to the data collection and data processing of
1plusX’s Data Management Platform please send an email to  privacy@1plusx.com.
According to GDPR Article 27, data subjects who are in the EU can also contact
our representative in the EU, Mr. Marco Dohmen, 1plusX GmbH c/o WorkRepublic,
Neuer Wall 71, 20354 Hamburg, Germany; E-Mail: marco.dohmen@1plusx.com


1PLUSX AND CCPA

Description of consumer’s rights

If you are a California resident, California law, including the California
Consumer Privacy Act (“CCPA”) and California Civil Code section 1798.83,
provides you with additional rights regarding our collection and use of your
personal information.

Right to Know

You can request a summary of the personal information 1plusX has collected about
you in the last 12 months.

You can find the respective form to submit your request on our Privacy Policy
page on the customer’s websites where we have placed our cookie.

Alternatively, you can request this information by sending an email to
privacy@1plusx.com, after which you will receive a web link to activate the data
access request.

Right of Deletion

You can request Data Deletion by selecting the respective option on our Privacy
Policy page on the customer’s websites where we have placed our cookie.

Right to non-discrimination

1plusx does not discriminate against any consumer and allows consumers to freely
exercise their CCPA rights.

Right to opt-out

You are able to opt-out of the sale of personal information we have collected.
By selecting the respective call to action “Do not sell my personal information”
on our Privacy Policy page on the customer’s websites where we have placed our
cookie.

The result of opting out from the sale of your personal information will be to
stop tracking your behavior and interactions whatsoever. In addition, you will
not be part of any segment and no personalization shall take place.

How to submit a request

California Law permits residents of California to request specific details on
how their data is shared with third-party companies or affiliates for direct
marketing or other business-related purposes.

If you are a California resident and you need to submit such a request, send an
email to privacy@1plusx.com with the subject “California Privacy Rights”.

Additionally, due to the nature of 1plusX’s business, in the properties of our
customers, we provide you specific web forms that allow Californian Residents to
exercise their rights. More specifically, we provide clear call to actions to:

 * Request Deletion
 * Opt-out from Sale
 * Request Data Access


LIST OF PI CATEGORIES COLLECTED OR SHARED BY THE BUSINESS IN THE LAST 12 MONTHS

1plusX collects and processes data on behalf of our Customers as a Service
Provider. According to CCPA, Personal Information is defined as the information
which can potentially identify, relate to, describe, reference, is reasonably
capable of being associated with, or could reasonably be linked, directly or
indirectly, with a particular consumer or device.

1plusX upon Customer’s request shall collect the following categories of
information (according to the categories mentioned in CCPA §1798.140). These are
the categories of information that have been collected in the past 12 months.

 * Identifiers (refers mainly to online identifiers, IP addresses, encrypted
   email addresses)
 * Internet or other electronic network activity information
 * Geolocation Data
 * Inferences

It must be highlighted that 1plusX uses industry-standard encryption and
security measures designed to protect any personal data from re-identification.

The sources of the collected data may be the following:

 * Customer’s web/mobile properties where the user’s activities are observed and
   recorded either via cookie, an SDK or a Data Layer
 * Online/ Offline Databases or Data Marketplaces
 * Ad Networks (including SSPs, DSPs, Ad Servers)

1plusX shares only anonymized information with Service Providers and Third
Parties only to the extent that is required to fulfill the service. 1plusX does
not share any information among customers with respect to user privacy, thus the
data for each customer is siloed and cannot be exposed or transferred.

More specifically, the online identifiers (e.g. hashed cookie ID, hashed emails)
will be shared with Advertising Networks, Data Management Platforms, and Data
Analytics Providers. This information is often accompanied by Internet/
Electronic network activity information, Geolocation Data, and Inferences. At
1plusX we make sure that by providing this information the other party will be
unable to re-identify a specific individual or household. The information that
we share with 3rd parties cannot be linked to a specific individual or household
due to the hashing functions that we apply on the identifiers (e.g. cookie,
login ID, email address).

The collection of the information allows 1plusX to move towards its business
goal. In that context, the main purposes for collecting the previously mentioned
categories are:

 * Internet-based marketing
 * Data Analysis & Behavioural reporting
 * Other operational purposes

   



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