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Privacy Notice

Starcom Germany GmbH (“we,” “us,” or “our”). This Privacy Notice sets out how we collect, use, share, and protect any information we collect through this website (“Website”). This Privacy Notice also explains the measures we take to safeguard your information and describes how you may contact us regarding our privacy practices.

Introduction
Any data collected through this Website, including personal data (as defined under applicable data protection laws, referred to as “Personal Data”), will only be used for the purposes set out in this Privacy Notice. Notwithstanding, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. When data is collected on this Website, Starcom Germany GmbH is acting as a data controller.

Please read this Privacy Notice thoroughly. If you disagree with the way personal information will be used, please do not use www.starcomgermany.com.

We may include links to other websites, including social media platforms. This Privacy Notice only covers this Website and does not apply to the data practices of other websites. We encourage you to read the privacy notices available on other websites you visit.

I. What Personal Data do we collect and process through the Website?
The following describes the categories of Personal Data we collect.

Contact Information and Internet or other electronic network activity information (Technical data), Identifiers
Firstname, last name, e-mail address, telephone number only if you transmit suchdata to us.
Browsinghistory; search history; online interests, such as information about categoriesof consumer interests derived from online usage; and information on aconsumer's interaction with a website, application, or advertisement. Online identifiers; IP address; mobile adidentifiers.

General Geolocation data
Non-precise locationinformation from your device or IP address.

Education information
Informationrelated to education, such as degrees earned, schools attended, grades. Onlywhen you transmit.

Your verbatimcommunications to us or shared on the public areas of our site
Informationthat you directly send us by using the comment functionality on this Website asfar as we do provide those services on the webpage.

Inferences
Informationdrawn from any of theinformation identified in this section to create an attribute about yourpreferences, characteristics, or behaviour.

II.      Categories of the sources of Personal Data
We may collect:We may collect the Personal Data outlined above fromthe following categories of sources:

Directly from you, for example, when you send us your questions orcomments using the query form or make use of your privacy rights.

From publicly availablesources, data brokers, partners (e.g., that offer co-brandedservices, sell or distribute our products, or engage in joint marketingactivities), advertising networks, internet service providers, data analyticsproviders, operating systems and social networks.

Indirectly from you by using automatedtechnologies, such as cookies, pixels, third party tags, scripts, log files andother means to automatically collect information about the use of our WebsiteFurther information about our use of cookies can be found in section XIV ofthis Privacy Notice.

III.      Purpose of data collection and legal basis
The following table providesinformation about our purposes andlegal basis for collecting your Personal Data:

To read and respond to your queries to us, sent using our online query form.
Depending on your request, we will rely on our legitimate interest orthe performance of pre-contractual measures to respond to individuals’ queries.

When you contact us through the data access request form.
We rely on our legal obligation to provide you a process to exerciseyour rights.

To contact you where you have indicated you wish to receive news from us.
For visitors from the European Union, we rely on your consent, where youindicate that you want to receive marketing material from us.

Operating our website, for example, operating, analyzing,improving, and securing our website.
For visitors from the European Union, we rely on your consent to obtainyour Personal Data through cookies.

Marketing services, for example:
Assisting in targeting and optimizing of direct  mail and email campaigns, display, mobile and social media marketing.

Measuring the effectiveness of online or offline  ad campaigns by determining which messages are most likely to be seen or  opened by which types of clients and potential clients, or which types of ads  are most likely to lead to purchases.

Analyzing  and optimizing our (or our service providers’) proprietary databases or  helping us identify and mitigate potential fraud.

Providing “verification”  or data “hygiene” services, which is how companies update and/or “clean”  their databases by either verifying or removing or correcting old, incorrect  or outdated information.

For visitors from the European Union, we rely on your consent to useyour Personal Data for marketing services.

Online targeting, for example:
Creating or helping tocreate defined audience segments based on common demographics and/or shared(actual or inferred) interests or preferences. When we do this, we work with adata partner that “matches” our or other information through de-identificationtechniques (such as through coded data “hashing”) with online cookies and otheridentifiers, in order to target and measure ad campaigns online across variousdisplay, mobile and other media channels.

Creating “identity” graphs, to help across various channels, such as connectingidentities based on common personal, device-based, or network-based identifiers.

For visitors from the European Union, we rely on your consent to useyour Personal Data for online targeting.

Other internal purposes, such as: internal research, internal operations, auditing,detecting security incidents, debugging, short-term and transient use, qualitycontrol, and legal compliance.
Our legitimate interest to support our internaloperations and conduct research.

Legal purposes, such as: (a) comply with legal process or a regulatory investigation(e.g. regulatory authorities’ investigation, subpoena, or court order); (b)enforce our Terms of Service, this Privacy Notice, or other contracts with you,including investigation of potential violations thereof; (c) respond to claimsthat any content violates the rights of other parties; and/or (d) protect therights, property or personal safety of us, our platform, our customers, ouragents and affiliates, its users and/or the public. Such disclosure may be fora business purpose.

We rely on our legal obligation or the performance of contract tosupport such legal purposes.

We may aggregate, de-identify and/or anonymize any information collected so thatsuch information can no longer be linked to you or your device (“Aggregate/De-IdentifiedInformation”). We may use Aggregate/De-Identified Information for anypurpose, including without limitation for research and marketing purposes, andmay also share such data with any other party, including advertisers,promotional partners, and sponsors, in our discretion, unless otherwiseprohibited by applicable law.

Our legitimate interest to support our internaloperations.

We use analytics services, such as Google Analytics, to help us understand how users’access and use the Website.

For visitors from the European Union, we rely on your consent to useyour Personal Data for analytic services.

IV.              Interest-basedAdvertising.
We work with agencies, advertisers, ad networks, and other technology services toplace ads about our products and services on other websites and services. Forexample, we place ads through Google and Facebook that you may view on theirplatforms as well as on other websites. 

V.               With whom do we Share Personal Data
We may disclose your Personal Data collected and processedthrough this Website for various purposes related to our business. Thedisclosure may be to our clients, partners, or vendors.  

VI.              With whom do we disclose Personal Data for a BusinessPurpose?
We may disclose yourPersonal Data or Sensitive Personal Data to our service providers that assistus with our business purposes. Our service providers are to only process yourPersonal Data in accordance with our instructions.  

VII.             Automated Decision Making and Profiling
When processing your PersonalData, we do not use processes that involve automated decision making orprofiling. 

VIII.            How long do we keep your information?
We keep Personal Data for as long as is necessary for the purposesdescribed in this Privacy Notice, complying with legal and regulatoryobligations, protecting our or other’s interests, and as otherwise permitted orrequired by law. When Personal Data is no longer necessary for or compatiblewith these purposes, it is removed from our systems in accordance with ourinternal retention policies. The criteria used to determine our retentionperiods include:

The length of time we have an ongoing relationship with you and provide the Websiteor our services to you;

Whetherour processing of the Personal Data is consistent with what an average consumerwould expect when the Personal Data was collected;

Whether the Personal Data is processed for any other disclosed purpose(s) compatiblewith what is reasonably expected by the average consumer;

Whether the Personal Data is relevant and useful to the provision of our services andour further processing is permitted by law;

Whether the Personal Data has been de-identified, anonymized, and/or aggregated; and

Whether there is a legal obligation to which we are subject.

XI.                 Your rights and choices regarding your Personal Data
Please use this LINK if you want to make use of any of your belowmentioned legal rights.

1. Where you areresident of the EU
Subject to certain exceptions and the jurisdiction in whichyou live, if you are a resident of the EU, the GDPR provides you with specificrights regarding your Personal Data. This subsection describes your rights andexplains how to exercise those rights regarding Personal Data that we holdabout you.  These rights include:

1.1. The right of access:
You can access all Personal Data we hold about you,know the origin of this Personal Data and obtain a copy in an understandableformat.You may also use your right to access yourPersonal Data to control the exactness of the data and have them rectified ordeleted. You have no justification to provide to exercise your right to access;

1.2. The right to rectification:
In order to avoidthat inaccurate or incomplete Personal Data relating to you is process orshared, you can ask us to rectify them;

1.3. The right to erasure:
You may requestthe erasure or deletion of the Personal Data we hold on you. This is not anabsolute right since we may have to keep your Personal Data for legal orlegitimate reasons. You may, for example, exercise your right to deletion inthe following cases:(a) if you have withdrawn your consent to theprocessing (see below);(b) if you legitimately objected to theprocessing of your data (see below);(c) when data is not or is no longer necessaryfor the purposes for which it was initially collected or processed;(d) the data is processed unlawfully (e.g.,publishing hacked data);

1.4. The right to object to the processing of your Personal Data:
We process yourPersonal Data based on our legitimate interest (to determine to whichprocessing this applies, please refer to Section II of this Privacy Notice),you may at any time object to the processing of your Personal Data for reasonsrelating to your personal situation. We may nevertheless, on a case-by-casebasis, reject such a request by pointing out the legitimate and imperiousreasons justifying the processing of this data which prevail on your interests,rights and freedoms, or when this data is necessary to establish, exercise ordefend a right before a Court.

1.5. The right to restrict processing:
The right to limitthe processing completes your otherrights. This right means that thedata processing relating to you and that we are performing is limited, so thatwe may keep this data, but we cannot use it or process it in any other manner.This right applies in specific circumstances, i.e.:
(a) if you challenge the exactness of yourPersonal Data. The processing is then limited for a period of time so that theagency may verify the exactness of the Personal Data;
(b) if the processing is unlawful and you objectto the erasure of your Personal Data and request instead that its use belimited;
(c) if we do not need the Personal Data for thepurposes mentioned above in Section I anymore, but you still need it toestablish, exercise or defend rights before a Court; and
(d) in the cases where you objected to theprocessing which is based on the legitimate interests of the agency, you mayask to limit the processing for the time necessary for us to verify if we canaccept your objection request (i.e., the time necessary to verify whether thelegitimate reasons of the agency prevail over yours).

1.6. The Right to object to data processing for directmarketing purpose
You mayunsubscribe or object, at any time and without any justification, to thereception of direct marketing communications. Simply either (i) click on thelink in the footer of the communications you receive from us; or (ii) use thehyperlink above; or (iii) send us an email at the emailaddress set out in the “Further Information” section below with the wordunsubscribe in the subject field of the email.

1.7. The right to data portability:
(a) You may request to retrieve the Personal Data you provided us with, in a structured,commonly used, and machine-readable format, for personal use or to share themwith a third party of your choice.
(b) This right only applies to Personal Data you provided us with, directly orindirectly, and which was processed through automated means, if this processingis based on your consent or the performance of a contract. Please check thelist of our Personal Data processing activities’ legal grounds (in Section IIof this Privacy Notice) to know whether our processing is based on theperformance of a contract or on consent.

1.8. The right to withdraw your consent to the processing of your PersonalData at any time:
(a) You may read Section II of this PrivacyNotice in order to identify the purposes for which the processing of yourPersonal Data is based on your consent.
(b) If you are unsatisfied with the way weprocess your Personal Data or if your request has been rejected, you may alsolodge a formal complaint with your local competent data protection authority.
(c) Personal Data will be stored in accordancewith our applicable data retention requirements and corporate policies. Theretention period for Personal Data varies depending on the type of PersonalData and the purposes of processing it.
(d) We will respond without undue delay and inany event within one month from the data we receive your request. Thistimeframe can be extended by two months to take the complexity of the request,or the number of requests received into account. In this case, we will informyou within one month from receiving your request, specifying the reasons forextending the response timeframe.

2. Your general rightsregarding
datacollection

2.1.
Do Not Track:

Your browser settings may allow you to automatically transmit a “Do Not Track”signal to online services you visit. Note, however, there is no industryconsensus as to what site and app operators should do with regard to thesesignals. Accordingly, unless and until the law is interpreted to require us todo so, we do not monitor or take action with respect to “Do Not Track” signals.For more information on “Do Not Track,” visit https://www.allaboutdnt.com.

2.2. Analytics:
We may use our owntechnology or third-party technology to track and analyze usage information toprovide enhanced interactions and more relevant communications, and to trackthe performance of our advertisements.

On ourwebsite, we use the analytics tracking tool called Google Analytics (G4) fromthe US-based company Google Inc. For Europe, the company responsible for allGoogle services is Google Ireland Limited (Gordon House, Barrow Street Dublin4, Ireland). Google Analytics collects data regarding your actions on ourwebsite. For example, if you click on a link, this action will be saved as acookie and sent to Google Analytics. By using the reports that we obtain fromGoogle Analytics, we are able to better adapt our website and services to yourneeds. Below, you will find more details regarding the tracking tool andinformation about what data is stored and how you can prevent this.

Using browser add-ons to deactivateGoogle Analytics-JavaScript (ga.js, analytics.js, dc.js) prevents GoogleAnalytics from using your data. You can download and install the browser add-onfrom: https://tools.google.com/dlpage/gaoptout?hl=de. Please make sure thatwhen using this add-on only Google Analytics data collection has beendeactivated.

On our website, we have implemented IP Anonymization from GoogleAnalytics (G4). This function has been developed by Google so that this websitecan comply with the applicable data protection provisions and recommendationsissued by the local data protection authorities in the event that theseauthorities prohibit the storing of full IP addresses. IP anonymization ormasking is a default setting and cannot be set to visible or “unmasked”.Therefore, IP addresses are neither recorded nor stored. You can find out moreinformation regarding IP anonymization here: https://marketingplatform.google.com/about/analytics/.

2.3.
Interest-Based Advertising:
The companies we work with to provide you with targeted ads are requiredby us to give you the choice to opt out of receiving targeted ads. Most ofthese companies are participants of the Digital Advertising Alliance (“DAA”)and/or the Network Advertising Initiative (“NAI”). To learn more about thetargeted ads provided by these companies, and how to opt out of receivingcertain targeted ads from them, please visit: (i) for website targeted ads fromDAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longerdeliver certain targeted ads to you, butdoes not mean you will no longer receive any targeted content and/or ads (e.g.,in connection with the participants’ other customers or from other technologyservices).

Please note that if you opt out using any of these methods, the opt outwill only apply to the specific browser or device from which you opt out. Weare not responsible for the effectiveness of, or compliance with,any opt out options or programs, or the accuracy of any other entities’statements regarding their opt out options or programs.


X.              Data Security
We use a variety of methods, suchas firewalls, intrusion detection software and manual security procedures, designedto secure your data against loss or damage and to help protect the accuracy andsecurity of information and to prevent unauthorizedaccess or improper use. Nevertheless, transmission via the internet is notcompletely secure and we cannot guarantee the security of information aboutyou. If you think that the www.starcomgermany.de or any Personal Data is not secure or that there hasbeen unauthorized access to the www.starcomgermany.de or your Personal Data, please contact privacyofficer@publicisgroupe.com orlocal DPO yusuf.tuncay-eberl@publicisresources.com immediately.  

XI.             DataTransfers
Due to the international nature of our business, yourPersonal Data may be transferred outside the European Union.

If you are an EU resident, your Personal Data may betransferred to the US or any country which is not considered to have the samelevel of data protection as in the EU. While in those jurisdictions, yourPersonal Data may be accessible to regulatory authorities in accordance withthe laws of those jurisdictions. However, we ensure all data transfers from theEU comply with applicable legal requirements by executing standard contractualclauses. Should you wish to know more about how your Personal Data is protectedor wish to request a copy of the contractual protections please contact privacyofficer@publicisgroupe.com or local DPO yusuf.tuncay-eberl@publicisresources.com 

XII.            Use of cookies , other tracking technology, social media and socialmedia plug-ins
Cookies are small pieces of text or code sent to yourdevice when you visit the Website. Cookies are used to optimize the viewingexperience, count visitors to a webpage, troubleshoot any problems, keepwebsites secure, and better serve content. The following cookies are used onthe Website:

‍Strictly Necessary cookies are required toprovide the basic functions of the website and cannot be turned off.  They are essential for accessing certainfeatures of the website and could include signing in, adding items to a cart,or e-billing.

Performance cookies are used to identifythe pages used and to measure and track the performance of our website. Thishelps us to analyze web page traffic data and improve our website to fit yourneeds. We only use the information for statistical analysis purposes

Functional cookies are used to provideservices you request. These cookies can remember your preferences to boost theuser experience on a website.

Targeting cookies may be set by us or byour advertising partners. They may be used to build a profile of your interestsand show you relevant advertisements on this website or others. They do notstore personal information but are based on uniquely identifying your browser.If you do not allow these cookies, you will experience less relevantadvertising

Overall, cookies help us provide youwith a better Website, by enabling us to monitor which pages you find usefuland which you do not. You can choose to accept or decline cookies. Most web browsers automatically acceptcookies, but you can usually modify your browser setting to decline cookies ifyou prefer. This may prevent you from taking full advantage of the Website.
For more information about the cookies dropped on your device,please review the Cookie Notice. 

XIII.           Use of socialmedia and social mediaplug-ins
Starcom Germany GmbH
has a fan page or a company page on Twitter, Facebook, Instagram, YouTube and LinkedIn that you can useor visit. Starcom Germany GmbHacts as ajoint data controller with the social media platform for the collection of yourpersonal data when you visit our company page on the social media platform. We will collect PersonalData about you in order to understand our followers better and understand thepublic response to our products and services. Any information you provide to uswhen you engage with our content (such as through our brand page or viaFacebook Messenger) is treated in accordance with this Privacy Notice. Also, ifyou publicly reference us or our Website on social media (such as by using ahashtag associated with us in a tweet or post), we may use your reference on orin connection with our Website.

You can readmore regarding our joint controllership with the platforms at the following links:

LinkedIn: https://legal.linkedin.com/pages-joint-controller-addendum

Instagram: https://www.facebook.com/legal/controller_addendum

We may providesocial media plug-ins on the Website to allow you to easily share content fromour Website through social media, and in doing so, we may receive your PersonalData from the social media platform that you have authorized to share with us.When you share content using these buttons, a new page will pop up from therelevant social media platform. If you’re already logged into your account onthat social media platform, then you will probably be automatically logged intothis pop-up page, so that you don’t have to log in again. If, however, you arenot logged in (or if you are not registered with the social media platform),the page will ask you for your information. Starcom Germany GmbH is joint data controllers with thesocial media platforms for the collection of your personal data that iscollected by the platforms when you visit our website.

We have no control over how social mediaplatforms use your Personal Data and they may independently collect informationabout you when you leave our Website.
 The informationcollected and stored by those parties remains subject totheir own policies and practices, including what information they share withus, your rights and choices on their services and devices, and whether theystore information in the U.S. or elsewhere. We encourage you to read the privacy notices on the various social media platformsyou use.

Findout more about how these social media platforms use your Personal Data:
·      Instagram
·      LinkedIn 

XIV.                Financial Incentive
We do not offer any financial incentives related to our collection ofyour Personal Data. 

XV.                 Notification of changes
Any changes to this Privacy Noticewill be promptly communicated on this page and you should check back to seewhether there are any changes.Continued use of the Website after a change in the Privacy Notice indicatesyour acknowledgement and acceptance of the use of Personal Data in accordancewith the amended Privacy Notice. 

XVI.                Further Information
If you consider that we are notcomplying with this Privacy Notice, if you have any questions in relation tothis Privacy Notice, or have questions about your rights and choices, pleasecontact privacyofficer@publicisgroupe.com or local DPO yusuf.tuncay-eberl@publicisresources.com. Data subjects in Europe may also lodge a formal complaint with theircompetent data protection authority. If you have any questions about our data practices or you wish to exercise your rights or know about the contractual protections in place, please contact the Publicis Chief Data PrivacyOfficer at privacyofficer@publicisgroupe.com or local DPO yusuf.tuncay-eberl@publicisresources.com.

Updated: November 10, 2023