Mitgo Privacy Policy

This Privacy Policy provides information on how Mitgo Service  GmbH Heinz-Nixdorf-Straße 6, 74172 Neckarsulm, Germany (hereinafter “Mitgo” or “we/us/our”) concerns your personal and non-personal data if you visit our website, www.mitgo.com

1.  Controller and Data Protection Officer

The data controller per the definition under GDPR is:

Mitgo Service GmbH ,

Data Protection Officer

Should you have any questions about our data protection measures, the processing of your data, or the protection of your rights as a data subject, you can contact our Data Protection Officer and us: data-support@mitgo.com

2. Definitions

2.1 Personal data

“Personal data” means any information relating to an identified or identifiable natural person. An identifiable natural person 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.

2.2 Technical data

“Technical data” means any information that cannot be related to your identity, e.g., information on browser types, operating systems, domain names, access dates and times, referring website addresses, online transactions, and browsing and search activity.

2.3 Processing

“Processing” means any operation or set of operations performed on data such as the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of said data.

 3. Collecting and processing personal data

The scope of how we collect and process your personal and non-personal data or other information depends on the way you interact with us or our technologies and services:

·       As a visitor of www.mitgo.com

·       As a registered users of the Mitgo ID Service

·       As a job applicant to Mitgo

With this Privacy Policy, we want to inform you of which information we receive and use at every stage.

We use personal data only to administer and provide our technologies and services. We store personal and any other kind of data strictly in compliance with applicable data protection and privacy legislation and our contractual duties and will prevent unauthorized access to data to the best of our abilities.

3.1.   for visitor of www.mitgo.com

If you visit the Mitgo website, we log the following data to facilitate the use of our website and to ensure its security and the stability of our web servers:

·        The IP address of the requesting device

·        The date and time of your visit

·        The data specifications of your browser and operating system 

·        The website you were referred from to our website (a so-called Referrer URL). 

This information is stored in a log file until it is automatically deleted.

cookies

When you visit Mitgo websites, information may be stored on your device in the form of cookies.

A cookie is a small text file sent from a web server to your browser and stored on your device. When you revisit our website, the cookie information is transferred to our web server again. For example, we may recognize you and consider your settings when displaying the website. Cookies can be categorized as first-party cookies (deployed by Mitgo) and third-party cookies (deployed by third parties).We use cookies to improve and optimize the usability of our website. Cookies do not cause damage to your device or contain viruses, trojans, or other malicious software. The cookie stores data linked to the respective device used. This does not mean, however, that we store personal data about you or are aware of your identity.

Visiting and surfing our website is possible without cookies. Most browsers accept cookies automatically. You may alter the security settings of your web browser to stop your device from receiving and storing cookies, to allow cookies to be received and stored from selected websites only, or to be notified before accepting cookies. Please note, however, that these settings may negatively affect the usability and user experience of websites and other online services. You may delete cookies stored in your browser at any time. Information stored in cookies will be removed from your device.

 We further categorize cookies as follows:

Type	Description
Category 1: Technically (essential) necessary cookies	These cookies are technically necessary to ensure the website landing page functions properly. We cannot provide for the website landing page to function without deploying such cookies.
Category 2: Functional cookies	These cookies serve to create the most pleasant surfing experience possible on our website landing page with a maximum of individual usage conformity. It includes enabling login across sessions, high surfing speed through search suggestions, or storing individual page settings, such as language or text size, etc.
Category 3: Performance cookies	These cookies optimize our website and lead to a continuously improved surfing experience (e.g., by evaluating the use of website landing page features offered, reporting display errors, etc.).
Category 4: Social media and advertising cookies	Some of these cookies allow you to connect to your social media account and share content. Others help to customize advertising by adapting to your interests.

Cookie categories 2 to 4 may be deployed in the context of web tracking. In such a case, the cookie helps analyze web traffic. They may be combined with information about your activities on our website and processed in pseudonymous usage profiles. This helps us analyze web traffic information and improve our website to adapt it to users’ needs. We only use this information for statistical analysis. In addition to cookie-based web tracking, there is non-cookie-based web tracking that uses other means, such as your individual device settings, to recognize you when revisiting our website.

The legal basis for deploying category 1 cookies is our legitimate interest in providing our website under Art. 6(1)(f) of GDPR. The legal basis for deploying category 2 to 4 cookies and web tracking is your consent under. When you visit our website for the first time or revisit it, we will (i) inform you about the use of category 2 to 4 cookies and web tracking and (ii) ask for your consent. To request your consent, we display a relevant banner.

In addition, some web analytics providers are members of industry associations whose websites allow the use of web tracking to be prevented centrally. Please find below the reference to the websites of these associations for expressing your choices regarding web tracking and processing data in pseudonymous profiles.

·        European Interactive Digital Advertising Alliance (EDAA): http://www.youronlinechoices.com/de/praferenzmanagement/

·        Digital Advertising Alliance (DAA): www.aboutads.info/choices/

·        Network Advertising Initiative (NAI): http://www.networkadvertising.org/choices/

If you don’t consent to the deployment of cookies or delete cookies from your device, this may affect your ability to use the website or individual functionalities.

You can also manage many companies’ cookies used for online advertising via the consumer choice tools created under self-regulation programs in many countries, such as the US-based Your Ad Choices page or the EU-based Your Online Choices.

Personal data in the “request” or “contact details” form.

Personal data in the “request”  form

For the purposes of receiving feedback for request of Partnerships/Co-Investors/Co-Founders

We may collect data about you that may include:

-Name
-Email address
-Linkedin
– any additional data that you might put in a request form.
You provide this data to us by using the “request” form or by the email you send.

For the purpose of receiving feedback or any questions you may have, we may collect data about you that may include:

– Email address
– Name
– any additional data that you might put in an email or comment. You provide this data to us by using the “Contact us” form or by the email you send.

3.2.   for registered users of the Mitgo ID Service

Mitgo ID is a service that helps you manage your all-in-one Mitgo account.
The Mitgo account stores the following:
Your personal information:  full name, email, phone number, date of birth, country of residence;
Information about linked social media accounts and services;
Security settings;
Session history and data;
Other information;
The Mitgo ID account allows you to access all Mitgo products and services: Admitad, TakeAds, Earnings Wallet, and others.
When you change information or settings in your Mitgo ID account, these changes apply automatically to all your accounts for Mitgo products and
The processing of personal data is necessary for the performance of a contract.
We do not collect or use any personal data other than the data that you voluntarily provide.

Cookies
In addition to the cookies specified in the section for visitors, we use strictly necessary cookies on MitgoID account pages for the website to function properly.





Analyzing tools
We use Google Analytics and Microsoft Clarity on our website for the purposes of the adequate design and continuous optimization of our website, as well as reporting on website usage.

3.3.   If you’re applying for a job with Mitgo

As part of the recruitment process, Mitgo (hereafter, “we” or “Mitgo”) may collect and process personal data relating to job applicants.
We have a legitimate interest in processing personal data during the recruitment process and in keeping records of the process. The personal data may be disclosed to employees and agents of Mitgo in connection with the processing of your CV and for other purposes, including the comparison of the information provided in the CV with the requirements of vacant positions at Mitgo. The personal data provided may be processed outside the European Union and may be disclosed by Mitgo to any entity within Mitgo, as well as to external parties and authorities as permitted and/or required by applicable law and regulations.

3.4. Process

In Short: We process your information to provide, improve, and administer our Site and Mitgo ID Service, communicate with you, for security and fraud prevention, and comply with the law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with us, including:

• To study data you provided to us in order to evaluate potential collaboration opportunities, as well as enable such collaboration (for example, to draft contracts, non-disclosure agreements and other documents of similar nature that establish a legally binding relationship between you and us).
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have.
• To request feedback. We may process your information when necessary to request feedback and to contact you.
• To protect our service. We may process your information as part of our efforts to keep our service safe and secure, including fraud monitoring and prevention.
• To evaluate and improve our service, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and evaluate and improve our service, products, marketing, and your experience.
• To identify usage trends. We may process information about how you use our service to better understand how it is being used so we can improve it.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional materials that are most relevant to you.
• To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.
• Your consent, if you have given us such consent

 4. Newsletters

With the following information, we will inform you of the contents of our newsletter and the procedure for the registration and dissemination of newsletters, and the evaluation of statistics thereof, as well as your right to object to the procedure. By subscribing to our newsletter, you agree to the receipt of the newsletter and the procedures described.

We send out newsletters, emails, and other electronic notifications with promotional information (hereinafter “Newsletter”) subject to the recipient’s consent or legal permission.

Registering for our newsletter is handled through a so-called double opt-in procedure, which means you will receive an email after you register, in which you will be asked to confirm your registration once again. Registrations for the newsletter are recorded to prove adherence to the precise registration process according to legal requirements. This includes storing the time of logon and confirmation. Furthermore, changes to the data stored by Mindbox, a third-party service, are also recorded.

The newsletters can be sent by Mitgo or Mindbox.

Mindbox is a newsletter platform of the Dutch company Mindbox.Cloud B.V. (a Dutch private limited company) located at Strawinskylaan 613, 1077XX Amsterdam, The Netherlands.

The email addresses of our newsletter recipients and further data described in the context of this information are stored on Mitgo’s and Mindbox’s respective servers. Mindbox uses this information to send out and evaluate the newsletters on our behalf. In addition, Mindbox can use this data to optimize or improve its services, e.g., for the technical optimization of the dissemination and the presentation of the newsletter or for economic purposes to determine from which countries the recipients come. However, Mindbox does not use the data of our newsletter recipients to contact them independently or transfer data to third parties except in cases prescribed by Mindbox’s Privacy Policy (https://mindbox.cloud/documents/privacy-policy/).

To register for the newsletter, we only need your email address. Any other voluntarily provided information about you is only used to personalize the newsletter. You can change the personal data you share with us at any time.

There are cases when we direct newsletter recipients to Mindbox’s websites. For instance, our newsletters contain a link with which newsletter recipients can access newsletters online (for example, in case of problems displaying the newsletter in the email program).

You may terminate the receipt of our newsletter at any time, which means you revoke your consent to receive it. By doing so, your consent to the dissemination of the newsletter via Mindbox and statistical analysis thereof expires at the same time. Unfortunately, it is not possible to cancel the dissemination of the newsletter via Mindbox or the statistical evaluation thereof through other means. You may withdraw your consent to receive our newsletter at any time by changing the notification settings in your account. In addition, you can find a link to unsubscribe from our newsletter at the bottom of each newsletter.

5. Legal Basis

The processing of your personal data relies on the following legal bases:

• Your consent, if you have given us such consentThe initiation or execution of a contract with you The fulfillment of legal obligations The implementation of our legitimate interests
• 6. Data protection and transmission to third parties

Mitgo takes all technical and organizational security measures required to protect your personal data from loss, unauthorized disclosure, or other forms of misuse. Data is stored in a safe environment that is not open to public access. Your personal data may be encrypted before transmission in certain cases (e.g., processing your login data). This means that communication between your device and our servers will include recognized encryption measures if your browser supports doing so.

Our staff has been trained in privacy matters and responsibly handling personal data and information to which they gain access.

Please be aware that should you contact us via email, the confidentiality of the information therein may not be ensured. Third persons may have access to the contents of emails.

For Mitgo to execute its business processes in a convenient and optimal manner, it may be necessary for certain data to be processed by trusted third parties and reliable partners. These third parties may:

• Send emails
• Manage communications (e.g., newsletters, security notifications, chat, etc.)
• Host websites
• Conduct other related activities

on behalf of Mitgo. However, Mitgo only shares data that is needed to serve the specific purpose for which the third parties are engaged. Mitgo ensures that these third parties are under similar obligations to maintain privacy and confidentiality as Mitgo’s own employees and that they will handle your information in the way and to the extent Mitgo is permitted to. Mitgo does not allow any third party to use your information for any purposes for which the information was not collected.

Mitgo will only disclose your personally identifiable information (PII) outside the country you live in if it is necessary for the intended purpose of processing. However, as a member of the worldwide Mitgo group of companies, each local Mitgo entity may maintain or perform data processing operations in countries outside the European Economic Area (EEA) or in countries without an adequate level of data protection if doing so is required for the fulfillment of our obligations or the underlying contract with you. Furthermore, subcontractors of Mitgo, which Mitgo engages to act on its behalf concerning the processing of your PII, may be domiciled in such areas.

To secure the transfer and processing of PII, Mitgo has implemented and requested the required technical and organizational measures and has entered into the appropriate contractual frameworks with Mitgo Group companies and subcontractors, which ensure that the data recipient has implemented an adequate level of data privacy in its organization. This includes the signing of Data Processing Agreements and standard contractual clauses issued by the EU Commission. These precautions ensuring that your information will be treated securely, confidentially, and under the applicable data protection laws.

If Mitgo is acquired by or merges with a third party, we reserve the right, in either of these circumstances, to transfer or assign the information we have collected from you as part of such a merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your information is treated, transferred, or used.

6.1. Transmission to Mitgo  brands.

6.1.1. For  registered users of the Mitgo ID Service: 
The data is shared with the brands of Mitgo if users are registered with the brand and the brand is integrated with Mitgo ID.
List of brands:

Admitad https://www.admitad.com/privacy/
Takeads https://takeads.com/privacy/
ConvertSocial https://convertsocial.net/privacy/

Purpose: providing Mitgo ID service for users.
 
6.1.2.  Transmission to  job applicant:
The data is shared with the brands under Mitgo when a user applies for a job listed in the brand’s vacancy.
List of brands:
https://mitgo.com/brands

7. Transfer to Third Countries

We only transfer personal data to third countries where we can ensure the careful handling of personal data by employing contractual agreements or other suitable guarantees, such as certifications or proven compliance with international security standards.

8. User Rights

You have the following rights concerning our processing of your personal data:

·        The right to access

·        The right to rectification

·        The right to erasure

·        The right to restrict processing

·        The right to data portability

·        The right to object (on grounds related to your particular situation) if your personal data is processed based on our legitimate interest 

·        The right to withdraw your consent at any time in the event of any consent-based processing of your personal data without affecting the lawfulness of processing said data based on consent before your withdrawal

·        The right to lodge a complaint with a supervisory authority.

You may exercise your legal rights by contacting us via email at data-support@mitgo.com.

If you are registered as a publisher or an advertiser on our website, you may access your account and correct or delete some of your data by yourself.

While observing applicable privacy legislation, we will erase your data without any action required by you if retention of your data is no longer necessary for the purpose pursued or retention is no longer allowed for any legal reason. We may restrict processing instead of erasing your data where it is legally not allowed to erase (e.g., legal obligations to maintain your personal data).

9. Amendments

We may modify this Privacy Policy and our data security provisions at any time, particularly if new laws and/or regulations need to be adopted or if we regard amendments as reasonable.

10. Questions/Contacts

For all questions and requests related to the security of your personal data:
data-support@mitgo.com