Updated on 23rd May 2018
The Jaduda GmbH is a subsidiary of the Goldbach Group AG. The companies of the Goldbach Group market and convey advertising in private electronical media focussing on TV, radio, digital out of home, online as well as search engine and mobile marketing. The Goldbach Group is located in Küsnacht in Switzerland and is active in the DACH (Germany, Austria, Switzerland) region.
In the scope of this company group, we (the Jaduda GmbH) operate the DSP (Demand Side Platform) Splicky which supports advertisers and agencies in purchase and the placement of advertising spaces on the market with focus on mobile and digital out of home by connecting agencies with the publishers. Our mobile DSP enables advertisers to prepare targeted and effective mobile advertising campaigns in real time with complete transparency, and enables agencies to manage the targeted and effective mobile advertising campaigns of their customers in real time with complete transparency.
In order to support the agencies in reaching an appropriate target audience and to minimise the display of uninteresting or inappropriate advertising, we record and process data in the scope of our work processes. This includes both data of the actual display of the commercials or banners as also data of cooperation partners.
This data protection declaration is to give the users and consumers of the advertising materials clear and comprehensive information such as how Jaduda handles this data, which data is stored and how the use of data can be objected to.
Data protection is important for us
We believe that the safe and respectful handling of data is fundamental for the success of our company and the viability of the advertising industry. Jaduda is via the Goldbach Group corporate partner of the iab-Europe, the trade association of the European digital and interactive marketing industry («IAB»). Jaduda thus follows the European principles for the voluntary self-regulation of the digital advertising industry for usage based online advertising. In this connection, Jaduda was independently tested by ePrivacy GmbH, certified and distinguished with the seal of quality EDAA Trust Seal.
Information on the Online Behavioral Advertising Framework of the EDAA can be found under: www.edaa.eu
Information about our data and data sources
As operator of a Demand Side Platform (DSP), we are also participators in real time marketing apart from booking fixed times and locations. In so doing, information about available advertising spaces in mobile phone apps, on websites, in mobile games or similar is exchanged between the publishers, the SSP’s (Supply Side Platform) and our DSP. We receive information which the user of a smartphone, browser or also the operator of a digital out of home display has released to us. This can be data independent of persons as e.g. the used app, the resolution of the screen, the sex or the location of the device, but it can also concern personal data such as name and address, the IP address or the ID of the smartphone (IDFA/IFA).
Due to this data, the suitable advertising materials are selected from our active campaigns and offered for delivery in a bidding process (analogue to a stock exchange between publisher and agency). Here the focus is always on the idea to only deliver such advertising materials which are in conformity with a potential purchase interest of the user to generate a positive advertising success.
In order to adjust our products even better to the desired target groups, we use additional person independent data of partners outside the Goldbach Group. Here it concerns generally accessible data such as weather, events (e.g. sport events) or general information about target groups in certain public places. This data is linked in real time due to person independent information such as time, location or language setting of the smartphone to the advertising enquiry.
The allocation ensues by way of the directly transmitted information in real time and not due to user profiles.
With individual marketing campaigns, we offer multilevel contacts as strengthening of the advertising message. For this, the identifiers of mobile devices are stored which have received an advertisement from us for a limited time period. Within this strengthening campaign, the devices are again addressed targettedly at a later time period. Aim of this retargeting is to achieve a strengthening of the advertising message within a marketing campaign. The stored identifiers are not used to build up user profiles or to identify a person, and expire after the termination of the respective marketing activity. If the user of a mobile device has objected to the use of his personal device data, we do not use his device data for an identification in retargeting.
As on most desktop websites we also use “cookies” in the mobile terminal device. A cookie consists of data sent by a website and stored in the web browser of a customer or consumer while he or she is just calling up a website – in this case any website with advertising material we delivered. If the customer or consumer later calls up the same website again, the data stored in the cookie can be called up again from the website to recognise the user.
Here our sole interest is on identifying a chain of action by the user and not in the identification of the person. In processing the information for this reason, also solely the number of such chains of action is revealed (clicks, buys).
In using the technologies with cookies and beacons, it is possible for us to optimise the display of advertising campaigns so that an allocation to interested customers is improved. We can also make our services available in the deactivation of cookies. If you decide that you don’t want any cookies, you can still see the advertisements which we place with publishers or advertising marketplaces. If you however decide against cookies, you may see the same advertisements again and again. This also contains advertising which little interests you or which is not relevant for you.
We want our customers and consumers to see and use the things which interest them and that you use our services how you like. Cookies cannot directly personally identify you in any way and they do not cause any damage to your system or your files.
Newsletter & social media
Jaduda operates own sites on the social media platform Facebook with competitions and product information for advertising purposes. For this an interested Facebook user is sent a newsletter. To be able to receive the newsletter also personal information such as the email address and the name are to be given. It is sent solely to people who have agreed to the reception of the newsletter in an opt in. The sending can be objected to any time via an unsubscribe link in the newsletter.
A linking with personal data from the newsletter sending and other data sources does not occur.
Storage and exchange of data within the Goldbach Group
As an independent company located in Germany, the Jaduda GmbH is also a part of the Swiss Goldbach Group. Our IT systems and data in many departments are also centrally managed, stored and archived within the group of companies. As a company certified by IAB and EDAA, the Goldbach Group is here bound as entire group with its companies in Switzerland, Austria and Germany to the strict European data protection guidelines.
Data which occurs in the scope of our work processes is stored with Jaduda up to 7 days in our data centre in Germany, the USA and Singapore. Device IDs for retargeting (as described above) are kept campaign related within a campaign period. This can be a period of a few days up to several weeks.
Data which is stored long term for the reporting of a marketing campaign is anonymised and consolidated in target groups, so that tracing back to individual persons is not possible any more. This is e.g. the quantity of spots of a campaign which was displayed in a certain app. In this consolidated view, there is no personal information any more such as smartphone ID or IP address.
Within the Goldbach Group, the Jaduda GmbH transmits prepared data of advertising enquiries to an in-house data management platform (DMP). This DMP is technically operated by Lotame, which also is subject to the strictest data protection principles and is certified according to IAB and EDAA. (see: https://www.lotame.com/about-lotame/privacy/)
The recording of data in the DMP is solely for the purpose of identifying person independent interest groups, which better enables the display of advertising with positive advertising success without tracing individual persons. This is e.g. the identification of a certain age group at a certain moment at a certain place. By way of this information, a negative advertising experience can be reduced without neglecting the personal rights of individual persons due to this. In no case is the data used to create user profiles with categories as for example your ethnic origin, your political opinion or your religious or philosophical convictions, your union activity, your health or sex life or to sell or pass on to third parties.
For the optimisation of our products solely consolidated, grouped result data is used.
Within the processing of our data, the use of personal data is helpful but not absolutely essential. Thus e.g. with the aid of a smartphone ID, information about jointly used apps is made to ascertain the possible interest of an anonymous person in this app. Here the person himself is not of interest but solely the joint use of various apps.
Objection to the use of personal data
The use of personal data in the display of the advertising materials can be objected to at any time. With each advertising material displayed by Jaduda which technically enables an opt out, a link to this data protection declaration and the respective opt out form is delivered. With the opt out process, the ID of the smartphone (IDFA with iPhone devices or IFA with Android) as well as the IP address are deposited in a data security list insofar as these were transmitted to us with the opt out. After the opt out, all future enquiries and processing steps of these IDs are executed in such a manner as if there had been no transmission of the ID to us. Further, advertising materials are delivered to enquiries insofar as they correspond to the person independent target group.
After an opt out, the personal information is removed or anonymised from the record before the transmission to the internal DMP.
Users can deactivate the reception of cookies with a click on Jaduda under preference management here: www.youronlinechoices.eu
In this deactivation process, your computer will ask for an ID tag for the “deactivation cookie” which prevents anonymous data from being connected with your computer, and thus prevents us from using this data to send targeted advertising or other contents to your web browser. Please observe that this deactivation process deletes the cookie ID which is allocated to your computer but not the cookie itself – the cookie has to remain on your computer so that we can recognise the deactivation of the user. For users of several computers or browsers, this means that they have to deactivate the reception of cookies on each computer or each browser. Also if users change the computer or delete cookies from their computer they have to repeat the deactivation process.
Protection of the data through the user
All current mobile terminal devices give the user the possibility to decide himself which personal data can be transmitted. Thus each user has the possibility in the installation of an app to release the transmission e.g. of GPS data or not. In addition, it is possible to basically deactivate the transmission of the smartphone ID in the device or to give it anew. In these cases the data is not transmitted and cannot be considered or locked.
Joint use of data outside the Goldbach Group
Jaduda can publish anonymous, aggregated or summarised information about target groups and campaign success chances as part of our business and marketing activities or make it available in other ways. This enables us to advise customers and future customers optimally about the use of our services and about whether you should use our services.
It can also occur that we disclose user or consumer data to: protect the legal rights of Jaduda or its staff, authorised agents and contractors, offer protection and security to visitors to our platform, protect from fraud or to comply with the law or court orders.
If Jaduda sells or transfers its business, a part of it or assets, or involves itself otherwise in a merging or transfer of companies, or participates in an asset purchase, insolvency or other transaction, we could transfer user or consumer information to a third party as part of this transaction.
International transfer of data (outside Goldbach Group)
Data which is collected by Jaduda in the scope of its own business processes can be stored or processed in the United States or other countries in which Jaduda’s partners, subsidiaries or authorised agents are located.
Insofar as in the opt out of the use of personal data was not objected to, this also concerns personal data. Here we consider that our partners are certified according to the privacy shield or via contracts (binding corporate rules) to agree to the European data protection guidelines. Jaduda does not pass personal data on to companies which do not comply with this.
Jaduda transfers data to the following companies for the accumulation of additional information in visibility (visibility of advertisements), fraud detection (fraud detection in the display), target groups (e.g. location information) to the following international partner companies during the delivery process:
Our partners within the EU:
- Lotame (UK)
- AdSquare (GER)
- Adjust (GER)
- Integral Ad Science GmbH (GER)
- Ad (GER)
Our partners outside the EU who are subject to the EU Privacy Shield: (see: www.privacyshield.gov/list )
Our partners outside the EU with data protection agreement:
We use so-called web fonts from Google LLC., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA („Google“) for displaying fonts.
Google is certified for the „Privacy Shield“ (https://www.privacyshield.gov/), which is to ensure compliance with the data protection level in the EU.
When you visit a page, your browser loads the required web fonts into your browser to display texts and fonts correctly. To do this, your browser connects to Google, which tells Google that our web pages have been accessed through your IP address.
The use of Google Fonts is in the interest of a consistent and attractive presentation of our websites. If your browser does not support Google Fonts or Web Fonts, your device will use a default font.
The legal basis for the processing of personal data when using Google Fonts is Article 6 (1) lit. f DSGVO (legitimate interest).
We follow generally accepted industrial standards for protection from unauthorised access, destruction or publishing of data. This includes carrying out the necessary technical, electronical and administrative activities to protect the data security as well as the access to and the use of data. All data stored on our servers is handled confidentially and not made generally accessible to the public. Our servers are protected with Firewalls and are in safe data protection facilities to further increase the security. Please observe however that despite suitable efforts to protect the data on our servers no transmission method via internet is guaranteed safe. Even though we endeavour to always protect your data, we cannot guarantee its absolute safety and are not liable for any security breach through outstanding third parties.
Changes to this data protection declaration
We reserve the right to carry out changes to this data protection declaration by publishing an updated version on this site. The date on which the current data protection declaration was published is always at the top of this site. All changes to this data protection declaration are carried out in in accordance with applicable law.
If you take up contact with us, we store this correspondence if necessary including your email address. This solely applies to your correspondence with us – we do not store any email addresses of users as part of our advertising activity online.
If you think that we have violated official principles contact us under email@example.com. If this should not solve your problem, follow the IAB complaints procedure under: www.youronlinechoices.com/uk/make-a-complaint.
Questions and comments
Please send questions and comments regarding this data protection declaration to firstname.lastname@example.org or via post to: Jaduda GmbH, Körtestrasse 10, 10967 Berlin
External data protection officer:
represented by Prof. Dr. Christoph Bauer
Große Bleichen 21, 20354 Hamburg