Data privacy

Data protection provision of SevenVentures GmbH


Data protection provisions


As of:  29 April 2022



The following data protection provisions apply to the website [www.sevencommerceandventures.com] ("Online Offer").

We participate in the "IAB Europe Transparency & Consent Framework" and adhere to its specifications and guidelines. We enable you to manage your consents and objections in our Consent Management Plattform with the identification number 318 ("CMP").


1. Who are we (Responsible person)

The person responsible in the sense of data protection law is [SevenVentures GmbH, Medienallee 4, 85774 Unterfoehring, dataprotection@sevenventures.com], hereinafter "we" or "us".

Exceptions are explained in this data protection provisions.


2. Contact details of our data protection officer

If you have any questions about this data protection provisions or generally about the processing of your data within the scope of this online offer, please contact our data protection officer:

Simply use the information in the contact section.


3. What do we process your personal data for and on what legal basis

Personal data is any information relating to an identified or identifiable natural person. When we process personal data, this means that we collect, store, use, transmit to others or delete it.

We process your personal data for the following purposes and on the basis of the legal bases mentioned. In the event that the data processing is based on the legal basis of Legitimate Interest, we will also explain our legitimate interest that we pursue with the processing.


General purposes of processing

1. Providing this online offer. This includes in particular enabling the use of the online offer; provision of a contact option and response to inquiries sent via it;

Legal basis of the processing and statement of legitimate interest: Contract fulfillment


2. Consent and opt-out management in accordance with data protection law

Legal basis of the processing and statement of legitimate interest: Fulfillment of a legal obligation


3. Conducting sweepstakes in accordance with the respective sweepstakes terms and conditions.

Legal basis of the processing and statement of legitimate interest: Contract fulfillment


4. Information Security: Investigate incidents and ensure system security, including detection and   tracking of unauthorized access and attempted access to our web servers.

Legal basis of the processing and statement of legitimate interest: Fulfillment of our legal   obligations to comply with data security as well as legitimate interest (in the elimination of malfunctions, ensuring system security and the detection   and tracking of unauthorized access attempts or accesses


5. Compliance with statutory retention obligations and other legal obligations (e.g. in connection with   company audits).

Legal basis of the processing and statement of legitimate interest: Fulfillment of our legal obligations, in particular with regard to the retention of certain   information and in connection with company audits; legitimate interest (in creating the conditions for compliance with legal obligations).


6. Preservation and defense of our rights.

Legal basis: legitimate interest (in asserting and defending our rights)


7. Disposal of all or part of the business.

Legal basis: Legitimate interest (in transferring customer data to the acquirer in connection with a sale of our   business operations; as a rule, this presupposes that the customers have   consented to a transfer of contract or have not objected to a transfer after   being given sufficient information).


Please note your right to object to the processing of data for the purpose of direct marketing or for personal reasons (see sections Your right to object to direct marketing and Your right to object on personal grounds).


Purposes of processing in connection with Cookies

Processes based on cookies are integrated into this online offering. We participate in the IAB Europe Transparency & Consent Framework and adhere to its specifications and guidelines. Below you will find information on the purposes for which we or our partners use cookies. You can learn more about this in our CMP.


1. Selecting simple ads. Ads can be shown to you based on the content you're viewing, the app you're using, and your approximate location or device type.

Legal basis: Legitimate interest (in displaying   ads that are as interesting as possible for our users and accordingly offer   them added value) or consent (in accordance with the stated legal basis in   our CMP.


2. Create a personalized ad profile. A profile can be created about you and your interests to show you personalized ads that are relevant to you.

Legal basis: Consent


3. Select personalized ads. Personalized ads can be displayed to you based on a profile created about you.

Legal basis: Consent


4. Create a personalized content profile. A profile can be created about you and your interests to show you personalized content that is relevant to you.

Legal basis: Consent


5. Select personalized content. Personalized content can be displayed to you based on a profile created about you.

Legal basis: Consent


6. Measure ad performance. The performance and effectiveness of ads you see or interact with can be  measured.

Legal basis: Legitimate interest (in the efficient playout and billing of advertisements) or consent (in accordance with the stated legal basis in our CMP.


7. Measure content performance.  The performance and effectiveness of content you see or interact with can be  measured.

Legal basis: Legitimate interest (in displaying content that is as interesting as possible for our users and accordingly offers them added value) or consent (in accordance with the stated legal basis in our CMP)


8. Use market research to gain insights about target audiences. Market research can be used to learn more   about the audiences that use services or applications and view ads.

Legal basis: Legitimate interest (in better understanding target groups and optimizing our own offering) or consent (in accordance with the stated legal bases in our CMP).


9. Develop and improve products. Your data may be used to improve existing systems and software and to develop new products.

Legal basis: legitimate interest (in the development and improvement of our offer)


10. Ensure security, prevent fraud, and troubleshoot. Your data may be used to identify and prevent fraudulent activity and to ensure that systems and processes are functioning properly and securely.

Legal basis: Legitimate interest (in   ensuring security, preventing fraud and eliminating errors).


11. Provide ads or content technically. Your device may receive and send information necessary for you   to view and use content and ads.

Legal basis: Contract fulfillment (provision of content) or legitimate interest (in the provision of advertisements).


12. Select personalized content. Merge with offline data sources. Data from offline data sources may be merged with data from your online activities in order to use them for one or more   processing purposes or specific processing purposes.\n* Data from your online  activities may be merged with offline data in order to use them for one or more processing purposes or specific processing purposes on a complementary basis.

Legal basis: Consent


13. Link different devices. To use for one or more processing purposes, it is possible to determine whether different devices belong to you or your household.

Legal basis: Consent


14. Receive and use automatically sent device properties for identification. Your device can be distinguished   from other devices based on information it sends automatically, such as IP   address or browser type.

Legal basis: Consent


15. Use Precise Location Data. Your accurate location data can be used for one or more processing purposes. This means that your location can be determined precisely to within a few meters.

Legal basis: Consent


16. Actively query device properties for identification. Your device can be recognized via a query of   its specific characteristics.

Legal basis: Consent


4. Who gets your personal data and why

Disclosure of data to third parties

We will only pass on your personal data to third parties if this is necessary for the fulfillment of the contract, if we or the third party have a legitimate interest in passing on the data, if we have your consent to do so or if this is necessary for the fulfillment of a legal obligation.

We may disclose personal data to a third party in particular if

  • if we are obliged to do so by law or by enforceable official or court order in an individual case;

  • in connection with legal disputes (vis-à-vis courts or our lawyers) or audits (vis-à-vis auditors);

  • in connection with possible criminal acts to the competent investigative authorities;

  • in the event of sale of the business (to the acquirer).

If data may be transferred to other third parties on a regular basis, this will be explained in this data protection notice. In the case of transfer on the basis of consent, the explanation can also be provided when consent is obtained.


Passing on data to service providers

We reserve the right to use service providers for the collection and processing of data. Service providers receive from us only the personal data that they need for their specific activities. For example, your e-mail address may be passed on to a service provider so that it can deliver a newsletter that you have ordered. Service providers may also be commissioned to provide server capacity. Service providers are usually integrated as so-called order processors, who may only process personal data of the users of this online offer according to our instructions.

Insofar as service providers are not already named in this data protection information, these are the following categories of service providers:

  • IT service provider (technical support), United Kingdom

  • IT service provider (hosting), Israel

  • IT service provider (content management), Germany

5. When do we share data with countries that are not part of the European Economic Area

We also disclose personal data to third parties or processors located in non-EEA countries. In this case, we ensure before the transfer that either an adequate level of data protection exists at the recipient (e.g. based on an adequacy decision of the EU Commission for the respective country pursuant to Art. 45 GDPR or the agreement of so-called EU standard contractual clauses of the European Commission with the recipient pursuant to Art. 46 GDPR) or an explicit consent of our users is available.

These are third parties or processors in the following countries: United Kingdom and Israel.

You can obtain from us an overview of the recipients in third countries and a copy of the specifically agreed arrangements for ensuring the appropriate level of data protection. Please use the information in the Contact section for this Purpose.


6. How long do we store your data

We store your data for as long as this is necessary to provide our online offer and the associated services or we have a legitimate interest in the continued storage. In all other cases, we delete your personal data with the exception of data that we must retain in order to comply with legal (e.g. tax or commercial) retention periods (e.g. invoices).

We block data that is subject to a retention period until the period expires.

Specifically, the following retention periods apply to the personal data processed as part of this online service. Log-files:

Contact form: 30 days

Contact details SevenVentures Pitch Day: up to 90 days.

Information on the storage period of cookies and app identifiers can also be found in the CMP.


7. Are you obliged to provide us with personal data

In principle, you are not obliged to provide us with your personal data. However, the use of certain services of this online offer may require the provision of personal data, e.g. registration or participation in a competition. If this is the case, we will point this out to you. Mandatory data is regularly marked with an *. If you do not wish to provide us with the required data, you will unfortunately not be able to use the corresponding services.


Log-files

Every time you use an online service, certain information is automatically transmitted by your terminal device and stored by us to determine malfunctions and for security reasons (e.g. to clarify attempted attacks) and then deleted. Log files whose further storage is necessary for evidentiary purposes are exempt from deletion until the final clarification of the respective incident and may be passed on to investigating authorities in individual cases. In den Log-Dateien werden insbesondere folgende Informationen gespeichert:

  • IP address (Internet Protocol address) of the terminal device from which the online service is accessed;

  • Internet address of the website from which the online offer was accessed (so-called origin or referrer URL);

  • Name of the service provider through which the online offer is accessed;

  • Name of the retrieved files or information;

  • Date and time and duration of the retrieval;

  • Volume of data transferred;

  • Operating system and information about the terminal device used; and

  • http status code (e.g. "request successful" or "requested file not found").

Log files are also used for analysis purposes.


8. Cookies

Information on cookies used in this online offering can be found in our Consent Management Platform (also referred to as CMP). If personal data is processed in connection with processes based on these technologies, you will also find more detailed information on the purposes pursued there. Information on how you can object to such processing can also be found in the relevant notes.

If you use our online services as a registered user in a logged-in state, we will adopt your privacy settings that are stored in your user profile. This data originates from your CMP settings prior to your first login to one of our services and is updated each time the privacy settings are changed in the respective CMP in the logged-in state. Please note that an update in further services only takes place after reloading the respective online offer, e.g. opening the app.


9. Your rights (rights of the data subject)

How can you enforce your rights

Please use the information in the Contact section to assert your rights. In doing so, please ensure that we are able to clearly identify you.

Alternatively, you can also use the settings options in your user account to correct the data you provided during registration or for your advertising objection. In addition, you can use the "Unsubscribe" link at the end of the respective e-mail for this purpose.

You can adjust your settings regarding cookies and/or advertising identifiers and the data processing based on them at any time in our CMP.


Your rights of access and rectification

You can request that we confirm whether we process personal data relating to you and you have a right of access with regard to your data processed by us. If your data is incorrect or incomplete, you may request that your data be corrected or completed. If we have disclosed your data to third parties, we will inform them of the rectification to the extent required by law.


Your right to deletion

You may, if the legal requirements are met, demand that we delete your personal data without delay. This is particularly the case if

  • Your personal data is no longer required for the purposes for which it was collected;

  • the legal basis for the processing was exclusively your consent and you have revoked it;

  • you have objected to the processing for advertising purposes ("advertising objection");

  • you have objected to processing based on the legal basis of Legitimate Interest on personal grounds and we cannot demonstrate that there are overriding legitimate grounds for processing;

  • your personal data have been processed unlawfully; or

  • Your personal data must be deleted to comply with legal requirements.

If we have passed on your data to third parties, we will inform them of the deletion, insofar as this is required by law.

Please note that your right to delete data is subject to restrictions. For example, we do not have to or are not allowed to delete data that we still have to retain due to legal retention periods. Data that we need to assert, exercise or defend legal claims are also excluded from your right of deletion.

Your right to restrict processing

You may, if the legal requirements are met, request us to restrict processing. This is particularly the case if

  • the accuracy of your personal data is disputed by you, and then until we have had the opportunity to verify the accuracy;

  • the processing is not lawful and you request restriction of use instead of erasure (see the previous section for this);

  • we no longer need your data for the purposes of processing, but you need it to assert, exercise or defend your legal claims;

  • you have objected on personal grounds, and then until it is determined whether your interests are overridden.

If there is a right to restrict processing, we mark the data concerned to ensure that it is only processed within the narrow limits that apply to such restricted data (namely, in particular, for the defense of legal claims or with your consent).


Your right to data portability

You have the right to receive personal data that you have given us for the fulfillment of a contract or on the basis of consent in a transferable format. In this case, you may also request that we transfer this data directly to a third party, insofar as this is technically feasible.


Your right to revoke consent

If you have given us consent to process your data, you can revoke this at any time in our CMP with effect for the future. The legality of the processing of your data until the revocation remains unaffected.


Your right to object to direct marketing

You can also object to the processing of your personal data for advertising purposes ("advertising revocation) at any time. Please take into account that for organizational reasons there may be an   overlap between your revocation and the use of your data in the context of an   already running campaign.


Your right to object on personal reasons

You have the right to object to data processing by   us for reasons arising from your particular situation, insofar as this is   based on the legal basis of legitimate interest. We will then stop processing   your data unless we can prove - in accordance with the legal requirements -   compelling reasons for further processing that are worthy of protection and   which outweigh your rights.

Your right to complain to a supervisory authority

You have the right to file a complaint with a data protection authority. In particular, you can contact the data protection authority that is responsible for your place of residence or your federal state or that is responsible for the place where the violation of data protection law has occurred. Alternatively, you can also contact the data protection authority responsible for us.


10. Contact

For information and suggestions on the subject of data protection, we or our data protection officer are at your disposal at the e-mail address dataprotection@sevenventures.com.

If you would like to contact us, you can reach us as follows:

[SevenVentures GmbH, Medienallee 4, 85774 Unterföhring]


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