Data Policy

This policy describes the information we process to support Dubme and its applications. You can find additional tools and information in the Profile screen in the Dubme app or by contacting us on hello@dubme.tv

I. What kinds of information do we collect?

To provide the Dubme Products, we must process information about you. The types of information we collect depend on how you use our Products. You can access and delete information we collect by visiting the Dubme app profile page or by contacting us at hello@dubme.tv

Things you and others do and provide


Device Information

As described below, we collect information from and about the computers, phones, connected TVs and other web-connected devices you use that integrate with our Products, and we combine this information across different devices you use. For example, we use information collected about your use of our Products on your phone to better personalize the content (including ads) or features you see when you use our Products on another device, such as your laptop or tablet, or to measure whether you took an action in response to an ad we showed you on your phone on a different device. 


Information we obtain from these devices includes: 


Information from partners

Advertisers, app developers, and publishers can send us information through Dubme tools and widgets they use, including our social plug-ins (such as the Like button), Login, our APIs and SDKs. These partners provide information about your activities off Dubme—including information about your device, websites you visit, purchases you make, the ads you see, and how you use their services—whether or not you have a Dubme account or are logged into Dubme. For example, a blogger could use our API to tell us what products you viewed, or a business could tell us about a purchase you made in its store. We also receive information about your online and offline actions and purchases from third-party data providers who have the rights to provide us with your information. 


Partners receive your data when you visit or use their services or through third parties they work with. We require each of these partners to have lawful rights to collect, use and share your data before providing any data to us. We will provide information about the types of partners we receive data from, once we have partnerships. 


All these data are stored on Amazon Web Services, and Google Cloud Platform in Germany, Ireland and USA.

Please, find more information and their policies of these platforms below:

https://aws.amazon.com/privacy/?nc1=f_pr

https://cloud.google.com/security/gdpr/

https://policies.google.com/privacy

And some information is collected for tracking and crash reporting purposes using Fabric services such as Crashlytics and Answers, as well as Google Services such as Google Analytics and Firebase Analytics. 

https://fabric.io/terms


Google analytics:

Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.

Google Analytics cookies are stored based on Art. 6 (1) (f) GDPR – DSGVO. The website operator has a legitimate interest in analyzing user behavior to optimize both its website and its advertising.

IP anonymization

We have activated the IP anonymization feature on this website. Your IP address will be shortened by Google within the European Union or other parties to the Agreement on the European Economic Area prior to transmission to the United States. Only in exceptional cases is the full IP address sent to a Google server in the US and shortened there. Google will use this information on behalf of the operator of this website to evaluate your use of the website, to compile reports on website activity, and to provide other services regarding website activity and Internet usage for the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with any other data held by Google.

Browser plugin

You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of this website. You can also prevent the data generated by cookies about your use of the website (incl. your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

Objecting to the collection of data

You can prevent the collection of your data by Google Analytics by writing us on support@dubme.tv

For more information about how Google Analytics handles user data, see Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=en.

 

MailChimp & Mailjet:

Dubme uses the services of MailChimp & Mailjet to send newsletters. MailChimp & Mailjet are referred as only Mailchimp below. 

 

MailChimp is a service which organizes and analyzes the distribution of newsletters. If you provide data (e.g. your email address) to subscribe to our newsletter, it will be stored on MailChimp servers in the USA.

MailChimp is certified under the EU-US Privacy Shield. The Privacy Shield is an agreement between the European Union (EU) and the US to ensure compliance with European privacy standards in the United States.

We use MailChimp to analyze our newsletter campaigns. When you open an email sent by MailChimp, a file included in the email (called a web beacon) connects to MailChimp’s servers in the United States. This allows us to determine if a newsletter message has been opened and which links you click on. In addition, technical information is collected (e.g. time of retrieval, IP address, browser type, and operating system). This information cannot be assigned to a specific recipient. It is used exclusively for the statistical analysis of our newsletter campaigns. The results of these analyses can be used to better tailor future newsletters to your interests.

If you do not want your usage of the newsletter to be analyzed by MailChimp, you will have to unsubscribe from the newsletter. For this purpose, we provide a link in every newsletter we send. You can also unsubscribe from the newsletter directly on the website.

Data processing is based on Art. 6 (1) (a) DSGVO. You may revoke your consent at any time by unsubscribing to the newsletter. The data processed before we receive your request may still be legally processed.

The data provided when registering for the newsletter will be used to distribute the newsletter until you cancel your subscription when said data will be deleted from our servers and those of MailChimp. Data we have stored for other purposes (e.g. email addresses for the members area) remains unaffected.

For details, see the MailChimp privacy policy at https://mailchimp.com/legal/terms/ and https://www.mailjet.com/privacy-policy/

Youtube

Dubme uses plugins from YouTube, which is operated by Google. The operator of the pages is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.

If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established. Here the YouTube server is informed about which of our pages you have visited.

If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account.

YouTube is used to help make our website appealing. This constitutes a justified interest pursuant to Art. 6 (1) (f) GDPR – DSGVO.

Further information about handling user data, can be found in the data protection declaration of YouTube under https://www.google.de/intl/de/policies/privacy.

Facebook

We offer the feature "Facebook Connect", which is offered by Facebook Inc., optionally for creating your customer account as well as for logging into our website and applications. You can also use Facebook Connect to recommend Dubme or our offers to your Facebook friends.

If you want to use this function, you will first be redirected to Facebook. There you will be asked to log in with your username and password. Of course we do not take note of your registration data/credentials. If you are already logged in to Facebook, this step will be skipped.


Afterwards Facebook informs you, which data are transmitted to us (public profile, friends list, Email address and current place of residence). You confirm this with the button "OK". With the transmitted data we create your customer account, whereby of course your friend list is not stored by us. For logging into Dubme via Facebook login, a Facebook generated unique token (a long string of letters and numbers) is also stored, which is exchanged with Facebook during the login process for secure authentication.


The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as your related rights and settings options for the protection of your privacy, please refer to the privacy policy at https://www.facebook.com/policy.php and the terms of use at https://www.facebook.com/legal/terms from Facebook.


In the context of usage-based online advertising, the product Custom Audiences of Facebook (Facebook Custom Audiences) is also used on the website or in the app. A Facebook cookie is set. Through Facebook Pixel we collect information about your activities on the website and behavioral files.

The cookies do not collect any personal information and can not be associated with such information.


For more information on the purpose and scope of the data collection and the further processing and use of the data, as well as the privacy settings, please refer to the privacy policy of Facebook. If you wish to opt out of using Facebook Custom Audiences, you can do so at https://www.facebook.com/ads/website_custom_audiences/.





























 

Provider

Type

Data transmission to third countries

3rd Country

Garanty gem. Art. 44ff DS-GVO

Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA;

Data Processor

yes

USA

EU-US Privacy Shield


Amazon Web Services, Inc.

Suite 1200

Seattle, WA 98144

United States

Data Processor

yes

USA

EU-US Privacy Shield

Mailchimp

Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA

Data Processor

yes

USA

EU-US Privacy Shield

Mailjet

13-13 bis, rue de l’Aubrac 75012 Paris, France

Data Processor

NO

-

-

YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA

Data Processor

yes

USA

EU-US Privacy Shield

Facebook Inc. 1601 WILLOW ROAD MENLO PARK, CA 94025, USA

Data Processor

yes

USA

EU-US Privacy Shield


See, more info about how is this information used in section-2.


II. How do we use this information?

 

We use the information we have (subject to choices you make) as described below and to provide and support the Dubme Products and related services described in the Dubme Terms. Here's how:

Provide, personalize and improve our Products.

We use the information we have to deliver our Products, including to personalize features and content (including your Video Feed, Look of the day videos, product lists and ads) and make suggestions for you (such as groups or events you may be interested in or topics you may want to follow) on and off our Products. To create personalized Products that are unique and relevant to you, we use your connections, preferences, interests and activities based on the data we collect and learn from you and others; how you use and interact with our Products; and the people, places, or things you're connected to and interested in on and off our Products. Learn more about how we use information about you to personalize your Dubme experience, including features, content and recommendations in Dubme Products; you can also learn more about how we choose the ads that you see.

Provide measurement, analytics, and other business services.

We use the information we have (including your activity off our Products, such as the websites you visit and ads you see) to help advertisers and other partners measure the effectiveness and distribution of their ads and services, and understand the types of people who use their services and how people interact with their websites, apps, and services. 

Promote safety, integrity and security.

We use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Products, and promote safety and security on and off of Dubme Products. For example, we use data we have to investigate suspicious activity or violations of our terms or policies, or to detect when someone needs help. 

Communicate with you.

We use the information we have to send you marketing communications, communicate with you about our Products, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

Research and innovate for social good.

We use the information we have to conduct and support research and innovation on topics of general social welfare, technological advancement, public interest, health and well-being. 


III. How is this information shared?

Your information is shared with others in the following ways: 


Sharing on Dubme Products

People and accounts you share and communicate with

Public information can be seen by anyone, on or off our Products, including if they don't have an account. This includes your Dubme username; any information you share with a public audience; information in your public profile on Dubme; and content you share, public Dubme account or any other public forum, such as Dubme Marketplace. You, other people using Dubme, and we can provide access to or send public information to anyone on or off our Products, including in other Dubme Company Products, in search results, or through tools and APIs. Public information can also be seen, accessed, reshared or downloaded through third-party services such as search engines, APIs, and offline media such as TV, and by apps, websites and other services that integrate with our Products. 


Content others share or reshare about you

People who can see your activity on our Products can choose to share it with others on and off our Products, including people and businesses outside the audience you shared with. For example, when you share a post or send a message to specific friends or accounts, they can download, screenshot, or reshare that content to others across or off our Products, in person. Also, when you comment on someone else's post or react to their content, your comment or reaction is visible to anyone who can see the other person's content, and that person can change the audience later. 


People can also use our Products to create and share content about you with the audience they choose. For example, people can share a photo of you in another photo, mention or tag you at in a post, or share information about you in their posts or messages. If you are uncomfortable with what others have shared about you on our Products, you can report the content by tapping on the more button and report or contact us directly on support@Dubme.tv

Apps, websites, and third-party integrations on or using our Products.

When you choose to use third-party apps, websites, or other services that use, or are integrated with, our Products, they can receive information about what you post or share. For example, when you play a video or use a Dubme Comment or Share button on a website, the developer or website can receive information about your activities in the widget/tool or receive a comment or link that you share from the website on Dubme. Also, when you download or use such third-party services, they can access your public profile on Dubme, and any information that you share with them. Apps and websites you use may receive your list of followers/following if you choose to share it with them. But apps and websites you use will not be able to receive any other information about any of your followers (although your followers may, of course, choose to share this information themselves). Information collected by these third-party services is subject to their own terms and policies, not this one. 

Devices and operating systems providing native versions of Dubme (i.e. where we have not developed our own first-party apps) will have access to all information you choose to share with them, including information your friends share with you, so they can provide our core functionality to you. 

New owner.

If the ownership or control of all or part of our Products or their assets changes, we may transfer your information to the new owner.


Sharing with Third-Party Partners

We work with third-party partners who help us provide and improve our Products or who use Dubme Tools to grow their businesses, which makes it possible to operate our companies and provide free services to people around the world. We don't sell any of your information to anyone, and we never will. We also impose strict restrictions on how our partners can use and disclose the data we provide. Here are the types of third parties we share information with:

Partners who use our analytics services.

We provide aggregated statistics and insights that help people and businesses understand how people are engaging with their posts, listings, Pages, videos and other content on and off the Dubme Products. For example, Page admins and Dubme business profiles receive information about the number of people or accounts who viewed, reacted to, or commented on their posts, as well as aggregate demographic and other information that helps them understand interactions with their Page or account.

Advertisers.

We provide advertisers with reports about the kinds of people seeing their ads and how their ads are performing, but we don't share information that personally identifies you (information such as your name or email address that by itself can be used to contact you or identifies who you are) unless you give us permission. For example, we provide general demographic and interest information to advertisers (for example, that an ad was seen by a woman between the ages of 25 and 34 who lives in Madrid and likes certain type of foundation) to help them better understand their audience. We also confirm which ads led you to make a purchase or take an action with an advertiser.

Measurement partners.

We share information about you with companies that aggregate it to provide analytics and measurement reports to our partners.

Partners offering goods and services in our Products.

When you subscribe to receive premium content, or buy something from a seller in our Products, the content creator or seller can receive your public information and other information you share with them, as well as the information needed to complete the transaction, including shipping and contact details.

Vendors and service providers.

We provide information and content to vendors and service providers who support our business, such as by providing technical infrastructure services, analyzing how our Products are used, providing customer service, facilitating payments or conducting surveys.

Researchers and academics.

We also provide information and content to research partners and academics to conduct research that advances scholarship and innovation that support our business or mission, and enhances discovery and innovation on topics of general social welfare, technological advancement, public interest, health and well-being.

Law enforcement or legal requests

We share information with law enforcement or in response to legal requests in the circumstances outlined below.


V. What is our legal basis for processing data?

We collect, use and share the data that we have in the ways described above: 


VI. How can you exercise your rights provided under the GDPR?

Under the General Data Protection Regulation, you have the right to access, rectify, port and erase your data. Learn more about these rights, and find out how you can exercise your rights. You also have the right to object to and restrict certain processing of your data. This includes: 


VII. Data retention, account deactivation and deletion

We store data until it is no longer necessary to provide our services and Dubme Products, or until your account is deleted - whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. The expiration date of your data for deletion when not used is 52 Months from its last accessed date.

When you delete your account, we delete things you have posted, such as your photos and status updates, and you won't be able to recover that information later. Information that others have shared about you isn't part of your account and won't be deleted. If you don't want to delete your account but want to temporarily stop using the Products, you can deactivate your account instead. To delete your account at any time, please contact us on support@dubme.tv

You are entitled to view, amend, or delete the personal information that we hold. Email your request to our data protection officer Fatih Girisken  (fatih@dubme.tv).

 

If you have any questions about how Dubme uses your personal data that are not answered here, or if you want to exercise your rights regarding your personal data, please contact us by any of the following means:

Send us an email to hello@dubme.tv

Send us a letter to Dubme GmbH, Panoramastr. 1, 10178 Berlin, Germany

Verantwortlicher für die Datenverarbeitung

Datenschutzbeauftragter des Verantwortlichen

Dubme GmbH

Panoramastr, 1, 10178 Berlin,Germany.

EMail:hello@dubme.tv

Dubme GmbH

Datenschutzbeauftragter

Panoramastr, 1, 10178 Berlin,Germany.

E-Mail: support@dubme.tv


Date of Last Revision: May 25, 2020